Finding 22688 (2022-004)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2022
Accepted
2023-03-30
Audit: 21940
Organization: Marymount University (VA)

AI Summary

  • Core Issue: The school lacks a clear written policy requiring instructors to document the last date of attendance for students who fail to attend classes, leading to potential misclassification of unofficial withdrawals.
  • Impacted Requirements: Title IV regulations mandate that schools must determine if a student has unofficially withdrawn based on attendance records, especially for those who fail all courses.
  • Recommended Follow-Up: Develop and implement a formal policy that requires instructors to consistently document last dates of attendance to ensure compliance with Title IV requirements and avoid potential refunds.

Finding Text

Criteria: A school must have a procedure for determining whether a Title IV aid recipient who began attendance during a period completed the period or should be treated as a withdrawal. If a student who began attendance and has not officially withdrawn fails to earn a passing grade in at least one course offered over an entire period, the school must assume, for Title IV purposes, that the student has unofficially withdrawn, unless the institution can document that the student completed the period. In the absence of evidence of a last day of attendance, a school must consider a student who failed to earn a passing grade in all classes to be an unofficial withdrawal. Condition: Based on professional judgement, we selected six students who received all failing grades for testing and all students had documentation of last date of attendance at an academically related activity. Three of the six student?s documented last date of attendance at an academically related activity was before the 60% point of the payment period, for which a refund would possibly be required if the student did not attend any class through the end of the period. Cause: The University has a grading policy that includes an F, failure to meet standards, and FA, failure primarily due to poor or non-attendance. Instructors enter a last date of attendance if the student failed to attend class; however, there is no written policy to rely which instructors are required to enter a last date of attendance.

Corrective Action Plan

Marymount University followed the University grading policy when determining whether or not a student received an earned F grade in all of his/her courses. (See below for policy information). Marymount University?s grading policy states that an F grade is assigned for students who fail to meet course objectives; such an F grade is by definition an earned F and not an unearned F as the student has completed the course but failed to meet standards. Marymount University instructors assign FA (Failure to Attend) grades for students who disappear, walk away, or otherwise fail to complete a course. For FA grades, last dates of attendance are assigned by instructors in the majority of cases. In the case of the students cited in the finding, Marymount followed its own grading policy when determining whether or not the failing grade received by the student was an earned F (completing the course but failing to meet course objectives) or an FA grade (failure to attend and did not complete the course). F grades would not result in Return to Title IV Funds calculations since they were considered earned. FA grades would result in Return to Title IV Funds calculations because they were considered unearned failing grades. Marymount University is not an attendance-taking institution according to Title IV standards, and individual instructors have control over their own attendance policies. Last dates of attendance as reported by these instructors are used in Return to Title IV Funds calculations; if a last date of attendance cannot be determined, the 50% point is used. Marymount University has the policy in place. However, Marymount University will review the language of the policy and revise the language to remove any ambiguities in the future. Marymount University Attendance Policy https://marymount.smartcatalogiq.com/en/2021-2022/catalog/marymount-university-catalog-2021-22/academic-information-and-policies/undergraduate-academic-information-and-policies/attendance/ Undergraduate Grading Policy https://marymount.smartcatalogiq.com/2021-2022/catalog/marymount-university-catalog-2021-22/academic-information-and-policies/undergraduate-academic-information-and-policies/evaluation-of-students/undergraduate-grading-policies/ Graduate Grading Policy https://marymount.smartcatalogiq.com/2021-2022/catalog/marymount-university-catalog-2021-22/academic-information-and-policies/graduate-academic-information-and-policies/evaluation-of-students/graduate-grading-policies/

Categories

Student Financial Aid

Other Findings in this Audit

  • 22687 2022-003
    Significant Deficiency Repeat
  • 22689 2022-005
    Significant Deficiency Repeat
  • 599129 2022-003
    Significant Deficiency Repeat
  • 599130 2022-004
    Significant Deficiency Repeat
  • 599131 2022-005
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Loan Program $33.12M
84.425 Education Stabilization Fund $3.62M
84.063 Federal Pell Grant Program $2.48M
84.033 Federal Work Study Program $196,664
84.007 Federal Supplemental Educational Opportunity Grant Program $139,253
47.076 Grants to Reduce Domestic Violence, Dating Violence, Sexual Assualt and Stalking on Campus $70,650