Federal Regulations for Online Attendance
Question 16: If an institution monitors whether its online students log into classes, is this an institution that is required to take attendance?
Answer 16: No. The monitoring of whether online students log into classes does not by itself result in an institution being an institution that is required to take attendance for Title IV, HEA program purposes. If, however, the monitoring of student activity is tracking academic engagement, then the institution would be an institution that is required to take attendance for Title IV, HEA program purposes.
Academically related activities include but are not limited to:
• physically attending a class where there is an opportunity for direct interaction between the instructor and students;
• submitting an academic assignment;
• taking an exam, completing an interactive tutorial, or participating in computer-assisted instruction;
• attending a study group that is assigned by the school;
• participating in an online discussion about academic matters; and
• initiating contact with a faculty member to ask a question about the academic subject studied in the course.
Academically related activities do not include activities where a student may be present but not academically engaged, such as:
• living in institutional housing;
• participating in the school’s meal plan;
• logging into an online class without active participation; or
• participating in academic counseling or advisement.
Participation in academic counseling and advising are no longer considered to be academic attendance or attendance at an academically related activity.
Documenting attendance when students are enrolled in distance education courses
In a distance education context, documenting that a student has logged into an online class is not sufficient, by itself, to demonstrate academic attendance by the student. A school must demonstrate that a student participated in class or was otherwise engaged in an academically related activity, such as by contributing to an online discussion or initiating contact with a faculty member to ask a course-related question. Examples of acceptable evidence of academic attendance and attendance at an academically-related activity in a distance education program include:
• student submission of an academic assignment,
• student submission of an exam,
• documented student participation in an interactive tutorial or computer-assisted instruction,
• a posting by the student showing the student’s participation in an online study group that is assigned by the institution,
• a posting by the student in a discussion forum showing the student’s participation in an online discussion about academic
• matters, and
• an e-mail from the student or other documentation showing that the student initiated contact with a faculty member to ask a question about the academic subject studied in the course.