Pop Quiz - Is This School Considered an Attendance-Taking Institution?

Question:

A school uses course room attendance such as discussion posts, assignments, and quizzes to validate participation in distance education courses up until its census date. The school is not required to take attendance by any outside agency or other entity. Given that the school can technically gather attendance data after the census period, does this mean the school is required to take attendance through the entire payment period?

Answer:

No, this does not mean you are required to take attendance through the entire payment period. However, see the following from 668.22(b)(3)(iii) [emphasis added]:

" (b) Withdrawal date for a student who withdraws from an institution that is required to take attendance.
(3)(i) An institution is required to take attendance if—
(A) An outside entity (such as the institution's accrediting agency or a State agency) has a requirement that the institution take attendance;
(B) The institution itself has a requirement that its instructors take attendance; or
(C) The institution or an outside entity has a requirement that can only be met by taking attendance or a comparable process, including, but not limited to, requiring that students in a program demonstrate attendance in the classes of that program, or a portion of that program.
(ii) If, in accordance with paragraph (b)(3)(i) of this section, an institution is required to take attendance or requires that attendance be taken for only some students, the institution must use its attendance records to determine a withdrawal date in accordance with paragraph (b)(1) of this section for those students.
(iii)(A) If, in accordance with paragraph (b)(3)(i) of this section, an institution is required to take attendance, or requires that attendance be taken, for a limited period, the institution must use its attendance records to determine a withdrawal date in accordance with paragraph (b)(3)(i) of this section for that limited period.
(B) A student in attendance the last time attendance is required to be taken during the limited period identified in paragraph (b)(3)(iii)(A) of this section who subsequently stops attending during the payment period will be treated as a student for whom the institution was not required to take attendance."

 

Publication Date: 4/22/2016


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