Academic Administrative Policies and Procedures Manual

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 Academic Attendance or Attendance at an 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 academic attendance or attendance at an academically-related activity.  The student's attendance must include "academic engagement" as defined below.
According Title IV Federal Student Aid regulation 34 CFR 600.2, "academic engagement" is active participation by a student in an instructional activity related to the student's course of study  that may be recorded in a grade book to, document a student's last date of attendance and includes but is not limited to:

• Attending a synchronous class, lecture, recitation, or field or laboratory activity, physically or online, where there is an opportunity for interaction between the instructor and students
• Submitting an academic assignment
• Taking an assessment or an exam
• Participating in an interactive tutorial, webinar, or other interactive computer-assisted instruction
• Participating in an assigned study group, group project, or online discussion
• Interacting with an instructor about academic matters

Instructional activities do not include:

• Living in institutional housing
• Participating in the institution's meal plan
• Logging into an online class or tutorial without any further participation
• Participating in academic counseling or advisement.

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 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.

Retention Period:

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.