TASFAA Annual Conference 2010 Galveston, Texas

So What? The Higher Education Act of 1965, as amended, requires an institution of higher education participating in the Federal student aid programs to admit as regular students: Only persons who have obtained a high school diploma or its recognized equivalent (or are beyond the age of compulsory school attendance).

In order to be eligible to receive Title IV aid, a student must: 1. Have a high school diploma or its recognized equivalent, or 2. Completed secondary school in a home school setting, or 3. Pass an independently administered examination approved by the Secretary, or 4. Successfully complete 6 credits at own expense

There is a regulatory definition of the “recognized equivalent of a high school diploma,” HOWEVER, the term “high school diploma” is not defined in regulations.

A student may self-certify on the FAFSA that he has received a high school diploma or GED or that he has completed secondary school through homeschooling as defined by state law.

If a student indicates that he has a diploma or GED, the postsecondary institution isn’t required to ask for a copy.

Basically, if a student does not have a high school diploma or GED and has not completed secondary school through home schooling, the student will have to pass an Ability-to-Benefit test to qualify for student aid.

If the institution requires a HS Diploma or GED for admission, the institution must rely on that copy of the diploma or GED and not on the student’s certification alone.

Confirming the authenticity of a student’s high school experience has become more difficult in part due to the proliferation of high school diploma mills.

Institutions that have concerns about the validity of a diploma from a particular school often check with the department of education for the state in which the school is located.

If the state department or agency has jurisdiction over the high school, it can confirm whether a diploma from the school (which does not have to be accredited) is recognized by the state.

Not all states have a means of recognizing even all the legitimate high schools operating in their state, particularly private high schools.

Who Cares? ( at least the GAO) The Government Accountability Office, in an August 2009 report found a “growing problem” and recommended to ED that the Department have a clearer, official policy about high school diploma mills.

For Whom The Problem Exists? Primarily, but not exclusively public Two Year Community Colleges and private For Profit Institutions who do not require a copy of the HSD or GED document for admissions to the school. 1.Consistency of information provides “cover” 2.Inconsistent information uncovers the problem 3.Conflicting information must be resolved 4.There in “lies” the problem 5.Collecting documentation and verifying it’s legitimacy

CASE STUDY The student completed the FAFSA in August of 2008 and answered the “do you have a HSD or GED” yes, which is the same answer they provided on the college’s admissions application. The public Two Year Institution does not require submission of that document for admission so none was collected. Self reported on both applications. No confirmation required. No problem. File awarded Pell and the student took out a loan.

The same student completed the 2009/10 FAFSA in March of 2009; but, this time the answer to the same question was no. This caused conflicting information which prompted a “request for documentation” letter requiring the student to submit a copy of the HSD/GED before the file could be awarded for 2009/10.

Life After The Final Regs Are Published Team 1 reached consensus on this issue but because consensus was NOT reach on all issues ED may present different language. If they follow through with what was agreed to it will look like this:

Beginning with the award year, a student completing the Free Application for Federal Student Aid (FAFSA) will be required to list the name of the secondary school or entity that provides a secondary school program of study and the state that awarded his or her high school diploma.

If the secondary school or entity the student provides does not match the list of secondary schools maintained by the Department or if the student does not provide the name of the secondary school or entity or the state that issued the diploma, ED may flag the student's FAFSA for further review by the institution to determine if the student has a valid high school diploma before the student can receive any Title IV aid.

The Department will provide guidance, most likely in the FSA Handbook, to help schools evaluate the validity of a high school diploma for purposes of awarding Title IV aid.

The proposed regulatory language consists only of an addition to the standards of administrative capability, whereby a school must "develop and follow procedures to evaluate the validity of a student's high school completion if the institution or the Secretary has reason to believe that the high school diploma is not valid or was not obtained from an entity that provides secondary school education."

What is Ability to Benefit (ATB)? Students must possess: High school Diploma, GED Recognized equivalent OR, Pass Independently administered U. S. Department of Education approved test of basic math and English skills,

How ATB testing works ED overseeing test publishers Test publishers certify and monitor test administrators to ensure: Independence Proper administration Independent Test Administrators (ITA): Proctor tests Submit answer sheets directly to Test Publisher

Current Regulations: Test publishers submit analysis to ED to identify test irregularities once every three years no follow up required

GAO Findings: Lack of monitoring of ATB testing by ED Test Publishers School Officials Oversight Needed

GAO Study – 2 Recommendations Improve monitoring of Ability To Benefit tests Revise regulations to strengthen controls

NPRM – 6 credit hours/225 clock hours ( (e)) Add “satisfactory completion of 6 credit hours” (HEA provision) Students may not receive aid for this coursework, and Students may not receive aid retroactively Coursework must be in an eligible program 6 quarter/semester or 225 clock hours

NPRM: States and Test Publishers ( – ) Must have process to follow up on test irregularities Take corrective action Report decertified test administrators

NPRM: Independent Test Administrator ( ) Add definition to regulations No current or prior financial or ownership interest Not a current or former employee Not a current or former member of the board of directors Not a current or former student

NPRM: Agreements – Test Publisher and State ( ) In response to the GAO report: Rigorous certification and decertification Test score analysis every 18 months Notify ED, ITA and the school Decertification of ITA Notify Schools/Students – improper test Notify ED -- compromised tests

NPRM: Institutional Accountability ( ) Schools are liable: Test not independently administered School or employee compromised test Cannot document test score

Special Thanks Rich Heath Anne Arundel Community College Elaine Neely Kaplan University

QUESTIONS?