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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:

Instructional activities do not include:

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:

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 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.

Approved: ACUE (11-5-15)
Revised: Editorial (7/1/21)