Tips for Complying with the High School Diploma Requirements

Are you sometimes confused by requirements governing institutional responsibilities for checking the validity of a student’s high school diploma and when you may use the ability-to-benefit alternatives? During the NASFAA conference, the Department of Education (ED) provided some tips for complying with these requirements.

Section 668.16(p) of the administrative capability regulations requires all schools to develop and follow procedures to evaluate the validity of a student’s high school diploma if the school or ED has reason to believe the student’s diploma is not valid or was not provided by an entity that provides secondary school education (i.e., a diploma mill). This requirement applies even if the school does not require a high school diploma for admission. 

High school completion will be a verification item, but not until the 2013–14 award year and then only for certain students. ED pointed out that it expects to select only a small number of applications for this verification item. Although ED will not describe the criteria to be used in selecting those applicants, selection will be based on information in ED systems that identify individuals that seem to be risky or suspect. Since there are no comments on 2012–13 ISIRs related to high school completion standards, the need to check a student’s claim to have a valid high school diploma during 2012–13 would be triggered by the school. 

What might cause a school to have reason to believe there may be a problem with the validity of a student’s high school diploma? When working with students from the high school in the past, the school’s financial aid, admissions, registrar, or other institutional office may have identified issues with or concerns about the high school. The school also might have conflicting information about the student, such as whether the student received a high school diploma or the name of the high school awarding the student’s diploma. Remember, the administrative capability regulations require the financial aid office to be informed if any institutional office has any information that has a bearing on a student’s Title IV eligibility. 

Schools also need to keep in mind that inclusion or exclusion of a high school on the drop-down box used to populate FAFSA on the Web should not be used as an indicator of whether the high school is a “good” or “bad” school. Inclusion on the list only means the high school completed, as applicable, the National Center for Educational Statistics (NCES) public or private high school survey used in compiling the drop-down list. A high school may have chosen not to complete the NCES survey for valid reasons. Although some postsecondary schools have shared information with ED about certain high schools with which they have had problems, ED does not maintain a list of “bad” high schools.

When trying to determine whether a high school is a diploma mill, ED suggests looking at whether the high school charges a fee for a diploma but provides little or no educational instruction for the diploma.  ED also suggests the checking the following resources for obtaining information about a particular high school:

  • The State Department of Education in the state in which the high school is located (i.e., the state’s standards for high school completion; these standards vary from state to state);
  • Companies that evaluate transcripts from foreign high school; 
  • Certain membership organizations (e.g., the National Collegiate Athletic Association, National Association for College Admissions Counseling, the College Board, etc.) that have rules for how they validate the validity of high schools (membership in the organization may be required to obtain the information);
  • Other institutions of higher education; and
  • Certain occupations (e.g., state trooper) for which a high school diploma is required for employment in the state.  

If a student does not have a high school diploma or its equivalent, GEN 12-09 provides guidance about when a school may use the ATB alternative and includes a grandfathering test. Should a student be qualified to use any of these alternatives, the school must document that fact as well as the specific alternative used to establish the student’s Title IV eligibility.

ED will continue to maintain a list of approved ATB tests and passing scores. Schools should note that the 10/29/10 final program integrity regulations imposed higher and stricter standards for ATB test publishers. ED does not know how many ATB test publishers will continue to be approved under the new standards, nor of any publisher that has chosen to no longer be an approved ATB test publisher.


Publication Date: 8/13/2012

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