A school, which is not required to take attendance, processes official withdrawals on a daily basis. Can they review records after the term ends for what may be an unofficial withdrawal—any grades of “F”, “W”, or “I”—to determine with faculty if the student did begin attendance?
What if a school is unable to determine whether or not a student started attendance in any class, can the school assume attendance ceased at 50 percent and complete the return of Title IV funds calculation accordingly?
The answer to the first question is yes. Please see the following from page 5-22 of the 2015-16 FSA Handbook: "For a student who withdraws, without providing notification, from a school that is not required to take attendance, the school must determine the withdrawal date no later than 30 days after the end of the earlier of (1) the payment period or the period of enrollment (as applicable), (2) the academic year, or (3) the student’s educational program."
However, the answer to the second question is no. Please see the following from page 4-62 of the 2015-16 FSA Handbook which states that "A student is considered not to have begun attendance if a school is unable to document the student’s attendance in any class."
Publication Date: 5/27/2016