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High School diploma Mills Abuses of Ability to Benefit tests. TASFAA Annual Conference 2010 Galveston, Texas. So What?. The Higher Education Act of 1965, as amended, requires an institution of higher education participating in the Federal student aid programs to admit as regular students:

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high school diploma mills abuses of ability to benefit tests

High School diploma MillsAbuses of Ability to Benefit tests

TASFAA Annual Conference

2010

Galveston, Texas

slide2

So What?

The Higher Education Act of 1965, as amended, requires an institution of higher education participating in the Federal student aid programs to admit as regular students:

Only persons who have obtained a high school diploma or its recognized equivalent (or are beyond the age of compulsory school attendance).

slide3

In order to be eligible to receive Title IV aid, a student must:

1. Have a high school diploma or its recognized equivalent, or

2. Completed secondary school in a home school setting, or

3. Pass an independently administered examination approved by the Secretary, or

4. Successfully complete 6 credits at own expense

slide4

There is a regulatory definition of the “recognized equivalent of a high school diploma,”

HOWEVER,

the term “high school diploma” is not defined in regulations.

slide5

A student may self-certify on the FAFSA that he has received a high school diploma or GED or that he has completed secondary school through homeschooling as defined by state law.

slide6

If a student indicates that he has a diploma or GED, the postsecondary institution isn’t required to ask for a copy.

slide7

Basically, if a student does not have a high school diploma or GED and has not completed secondary school through home schooling, the student will have to pass an Ability-to-Benefit test to qualify for student aid.

slide8

If the institution requires a HS Diploma or GED for admission, the institution must rely on that copy of the diploma or GED and not on the student’s certification alone.

slide9

Confirming the authenticity of a student’s high school experience has become more difficult in part due to the proliferation of high school diploma mills.

slide10

Institutions that have concerns about the validity of a diploma from a particular school often check with the department of education for the state in which the school is located.

slide11

If the state department or agency has jurisdiction over the high school, it can confirm whether a diploma from the school (which does not have to be accredited) is recognized by the state.

slide12

Not all states have a means of recognizing even all the legitimate high schools operating in their state, particularly private high schools.

slide13

Who Cares?

( at least the GAO)

The Government Accountability Office, in an August 2009 report found a “growing problem” and recommended to ED that the Department have a clearer, official policy about high school diploma mills.

slide14

For Whom The Problem Exists?

  • Primarily, but not exclusively public Two Year Community Colleges and private For Profit Institutions who do not require a copy of the HSD or GED document for admissions to the school.
  • Consistency of information provides “cover”
  • Inconsistent information uncovers the problem
  • Conflicting information must be resolved
  • There in “lies” the problem
  • Collecting documentation and verifying it’s legitimacy
slide15

CASE STUDY The student completed the 2008-09 FAFSA in August of 2008 and answered the “do you have a HSD or GED” yes, which is the same answer they provided on the college’s admissions application. The public Two Year Institution does not require submission of that document for admission so none was collected. Self reported on both applications. No confirmation required. No problem. File awarded Pell and the student took out a loan.

slide16

The same student completed the 2009/10 FAFSA in March of 2009; but, this time the answer to the same question was no. This caused conflicting information which prompted a “request for documentation” letter requiring the student to submit a copy of the HSD/GED before the file could be awarded for 2009/10.

slide17

Problems, we have problems, lots and lots of problems.Student submitted copy of the HSD from an “on line” out of state company. A review of the company's web site revealed that while the document said, “High School Diploma,” they were actually a GED prep operation, not a HS degree program. The student paid hundreds, was issued the document but never sat for the GED.

slide18

Life After The Final Regs Are PublishedTeam 1 reached consensus on this issue but because consensus was NOT reach on all issues ED may present different language. If they follow through with what was agreed to it will look like this:

slide19

Beginning with the 2011-12 award year, a student completing the Free Application for Federal Student Aid (FAFSA) will be required to list the name of the secondary school or entity that provides a secondary school program of study and the state that awarded his or her high school diploma.

slide20

If the secondary school or entity the student provides does not match the list of secondary schools maintained by the Department or if the student does not provide the name of the secondary school or entity or the state that issued the diploma, ED may flag the student's FAFSA for further review by the institution to determine if the student has a valid high school diploma before the student can receive any Title IV aid.

slide21

The Department will provide guidance, most likely in the FSA Handbook, to help schools evaluate the validity of a high school diploma for purposes of awarding Title IV aid.

slide22

The proposed regulatory language consists only of an addition to the standards of administrative capability, whereby a school must "develop and follow procedures to evaluate the validity of a student's high school completion if the institution or the Secretary has reason to believe that the high school diploma is not valid or was not obtained from an entity that provides secondary school education."

what is ability to benefit atb
What is Ability to Benefit (ATB)?
  • Students must possess:
    • High school Diploma,
    • GED
    • Recognized equivalent

OR, Pass

    • Independently administered
    • U. S. Department of Education approved
      • test of basic math and English skills,
how atb testing works
How ATB testing works
  • ED overseeing test publishers
  • Test publishers certify and monitor test administrators to ensure:
    • Independence
    • Proper administration
  • Independent Test Administrators (ITA):
      • Proctor tests
      • Submit answer sheets directly to Test Publisher
current regulations
Current Regulations:
  • Test publishers submit analysis to ED
    • to identify test irregularities
    • once every three years
    • no follow up required
gao findings
GAO Findings:
  • Lack of monitoring of ATB testing by
    • ED
    • Test Publishers
    • School Officials
  • Oversight Needed
gao study 2 recommendations
GAO Study – 2 Recommendations
  • Improve monitoring of Ability To Benefit tests
  • Revise regulations to strengthen controls
nprm 6 credit hours 225 clock hours 668 32 e
NPRM – 6 credit hours/225 clock hours (668.32 (e))
  • Add “satisfactory completion of 6 credit hours” (HEA provision)
    • Students may not receive aid for this coursework, and
    • Students may not receive aid retroactively
    • Coursework must be in an eligible program
    • 6 quarter/semester or 225 clock hours
nprm states and test publishers 668 141 668 156
NPRM: States and Test Publishers (668.141 – 668.156)
  • Must have process to follow up on test irregularities
  • Take corrective action
  • Report decertified test administrators
nprm independent test administrator 668 142
NPRM: Independent Test Administrator (668.142)
  • Add definition to regulations
    • No current or prior financial or ownership interest
    • Not a current or former employee
    • Not a current or former member of the board of directors
    • Not a current or former student
nprm agreements test publisher and state 668 150
NPRM: Agreements – Test Publisher and State (668.150)

In response to the GAO report:

  • Rigorous certification and decertification
  • Test score analysis every 18 months
  • Notify ED, ITA and the school
    • Decertification of ITA
  • Notify Schools/Students – improper test
  • Notify ED -- compromised tests
nprm institutional accountability 668 154
NPRM: Institutional Accountability (668.154)
  • Schools are liable:
    • Test not independently administered
    • School or employee compromised test
    • Cannot document test score
special thanks
Special Thanks

Rich Heath

Anne Arundel Community College

Elaine Neely

Kaplan University