Colleagues,
I write today to ask for your support in addressing concerns that have arisen in recent months with the Department of Education (ED) relating to financial aid. ED regularly audits institutions to ensure compliance with policies relating to the administration of financial aid. PSU participated in this year’s audit by providing materials to ED through meetings and responses to ED inquiries. This process was ably led by Amanda Bierbruaer, Associate Vice President of Enrollment Management and Student Finances, along with the expertise of Elijah Herr, Director of Financial Aid and Scholarships, and Cindy Baccar, Associate Vice Provost and Registrar. The audit identified several areas for PSU improvement, among them several issues relating to how financial aid is awarded for study abroad programs.
One of the most significant findings of the audit relates to the expectation from ED that institutions be able to verify the attendance of students receiving financial aid, in other words, that students receiving federal financial aid are indeed attending classes. Because PSU does not have a consistent and uniform policy for verifying student attendance in study abroad or other classes, we have been found to be non-compliant in this area. It is important for all of us to realize that failure to remain in compliance risks PSU’s authorization to administer financial aid. With the significant numbers of PSU students who rely on financial aid to support their education, you can understand that this is a serious and urgent matter that requires all of our attention.
To remain in compliance and, therefore, eligible to disburse financial aid to students, PSU is required to have both a policy and a mechanism in place by which we can document that students have initiated attendance in each course for which they are registered and receive financial aid. If a student does not initiate attendance in each class, PSU must recalculate the student’s eligibility and, if necessary, return some or all of their financial aid.
To fulfill expectations regarding attendance, we must be able to document a student’s attendance in at least one class meeting for which they are registered in the first two weeks of class. As you can imagine, there are multiple ways in which attendance can be affirmed. For in-person classes, this can be achieved through calling a roll, having students turn in required assignments, sign-in sheets, or other mechanisms, as instructors choose. For online classes, attendance can be verified through a student's participation in quizzes, assignments, etc.
Because of the importance and urgency of this process, PSU must respond to the ED audit by June 26th and have a plan in place by the fall of 2023. This means having both a policy and a mechanism for implementation by the beginning of fall term. While our plan is iterable as we learn more and revise our practices, we must have a plan in place for fall term 2023 and begin implementing that plan.
Because this is a matter that requires collaboration between the faculty and administration, we have begun meeting with a number of stakeholder partners, including the Education Policy Committee of the Faculty Senate, the AAUP, PSUFA, and GEU. With the guidance of the Faculty Senate Presiding Officer and Presiding Officer-Elect and affirmation of the Senate, a working group has been formed to work over the summer on developing a plan for the initiation of attendance and implementation of that plan. That working group will include members from the Educational Policy Committee (EPC), as well as administrative officers from Financial Aid, the Registrar’s Office, and the Office of Information Technology (OIT). Because of the urgency of this matter and our desire to have faculty engagement going forward, our response to the audit will have two phases.
Phase one will be the plan developed by the working group over the summer, for which implementation will begin in the fall. This plan will be shared with ED as part of our formal response to the audit in the next month.
Phase two will be a longer-term plan that will explore multiple options for affirming attendance, including a scan of best practices at other institutions, technology solutions, etc. This phase of the plan will begin in the fall and will be developed in partnership with stakeholders during the 2023-24 academic year.
Part of the task of the working group will be to articulate guidelines for faculty so that there is clarity of expectation for how to implement an attendance policy this fall. The working group will also identify tools that can be used to support faculty in accomplishing this task. These guidelines will be shared with faculty before the start of fall term.
I know from experience that PSU faculty can respond quickly and effectively to urgent matters relating to support for our students and compliance with external bodies. Indeed, when I first arrived at PSU, we had been deemed out of compliance by NWCCU relating to our assessments of learning as ongoing components of continuous improvement. The response from faculty was overwhelming, to the point that PSU was praised specifically in our last accreditation report for “the widespread evidence of program assessment.” I know that we can meet this challenge as well. I thank you all, in advance, for your support of this effort.
Best,
Susan Jeffords
Provost and Vice President for Academic Affairs
