N-6: LAST DATE OF ACADEMICALLY-RELATED ACTIVITY
When a faculty member assigns a failing grade to a student, the University is required to document certain information about the failing grade. This is a requirement under Title IV, Federal Student Aid regulation 34 CFR 668.22(a). A student earns federal student aid through attendance. The percentage of aid earned is based on the percentage of the semester the student completes. If a student does not complete the entire semester (i.e. stops participating), the University may be required to return a portion of the student's aid to the federal government.
Documentation of Student’s Last Date of Academically-Related Activity:
When assigning a failing grade in the student system grade reporting function, faculty are required to indicate whether the student participated for the entire semester, participated for a partial semester, or never participated. When indicating that a student completed only a ‘partial semester,’ faculty must provide the last recorded date of the student’s participation in an academically-related activity.
According to federal regulations, "academically-related activities" that may be recorded in a grade book and which document a student’s last date of attendance include but are not limited to:
- Physically attending a class that enables direct interaction between instructor and students
- Submitting an academic assignment
- Taking an exam, an interactive tutorial, or computer-assisted instruction
- Attending an assigned study group
- Participating in an online discussion about academic matters
- Initiating contact with a faculty member to ask questions about the course subject matter.
In addition, for online courses, academically-related activity must include substantive, constructive and meaningful feedback and interaction on discussion boards in the online classroom. Substantive interaction and participation in the course does not include simply signing in to the course. Substantive interaction includes written responses such as:
- an in-depth exploration of a specific idea, which can include but is not limited to a specific theme, topic, key words, relevant phrases, a hypothesis, constructive criticism, etc.
- a personal opinion or self-reflection that directly relates to the course content and is communicated in a thoughtful, meaningful way
- a request for clarification, further information, a recommendation, and/or further explores or expands on a previous comment thread
Written responses/posts such as “ditto” or “I agree” do not meet the substantive interaction requirement.
Retention of Documentation:
Faculty must retain documentation that supports the date they report as a student’s last academically-related activity. That documentation must be readily available for review if requested for an audit or program review by the Federal Department of Education. This documentation often includes the syllabus and gradebook content, whether in paper or electronic form. The U. S. Department of Education has indicated that gradebooks are adequate documentation of a student's last date of attendance so long as:
- the gradebooks record and identify specific activities that are academically related
- the date of submission of each activity is recorded or aligns with the course syllabus
- the gradebooks are maintained in a timely and consistent manner, and
- the information in the gradebooks is not changed without documentation of the reason for the change (documentation must also be retained)
The Administrative Council on Undergraduate Education (ACUE) does not specify the method for retaining gradebook documentation. Since University policy already requires retention, faculty/departments/colleges should have established mechanisms in place. However, to better facilitate the collection, storage and retrieval of this documentation, faculty are strongly encouraged to use the grade reporting and other course management functions in the University’s designated LMS. Faculty who exit the University must submit their gradebook documentation to their academic unit for retention.
Gradebook retention currently is specified through policy AD35, “University Archives and Records Management” and the associated GENERAL RETENTION SCHEDULE (Formerly APPENDIX 18), which states that the retention period is five years after course completion as required under Federal Student Aid regulations.
Approved: ACUE (11-5-15)