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U.S. Department of Education

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- Program Integrity Q&A

Questions on this topic are divided into the following categories:
                - **Recognized Equivalent of a High School Diploma**
                - **Checking the Validity of a High School Diploma**
                - **Documenting High School Completion Status**
                - **Foreign High School Diploma**

In addition to the Q&As listed below, please see the following resources for guidance related to High School Diploma:
                - Program       Integrity Issues; Proposed Rule (Page 34823)
                - Program       Integrity Issues; Final Rule (Pages 66887 – 66892 and 66951)
                - Dear       Colleague Letter GEN-12-01
                - Dear       Colleague Letter GEN-12-03
                - Dear       Colleague Letter GEN-12-09
                - Dear       Colleague Letter GEN-14-06
                - Checking  the Validity of a Student’s High School Completion

**Recognized Equivalent of a High School Diploma (RED)**

RED-Q1.  The regulations at 34 CFR 600.2 include the definition of a “recognized equivalent of a high school diploma.” One of those equivalents is “an academic transcript of a student who has successfully completed at least a two-year program that is acceptable for full credit toward a bachelor’s degree.” Does this mean that any coursework that is at least two years or more is an acceptable equivalent of a high school diploma?

RED-A1.  No. To be a “recognized equivalent of a high school diploma,” the two years of coursework must be acceptable for full credit toward a bachelor’s degree. The following are considered the equivalent of completing a "two-year program," regardless of the time it takes a student to complete the coursework (e.g., on an accelerated schedule):
                - Successful completion of an associate’s degree program;
                - Successful completion of at least 60 semester or trimester credit hours or 72 quarter credit hours that does not result in the awarding of an associate’s degree, but that is acceptable for full credit toward a bachelor’s degree at any institution; or
                - Enrollment in a bachelor’s degree program where at least 60 semester or trimester credit hours or 72 quarter credit hours have been successfully completed, including credit hours transferred into the bachelor’s degree program.  [Guidance issued 1/24/2014;  revised 7/7/2015 ]

RED-Q2. How can an institution verify whether an online GED program is valid?

RED-A2. The regulatory provision that allows a GED certificate to be considered the “equivalent of a high school diploma” requires obtaining the certificate.  The requirement is not satisfied by completing a “GED program.”  For Title IV purposes, there is no concept of a valid GED program, online or not.  The student must take and pass the GED test in person at a designated GED Testing Center.  Once the student has completed all sections of the GED test and passed by satisfactorily meeting minimum scores, the State will issue a certificate of high school equivalency.

The student may also be issued an official GED transcript by the test publisher or the jurisdiction where the test was taken which will provide the test scores for each academic content area of the GED test.  Institutions often use the GED transcript to make academic placement determinations.  The GED transcript meets the definition of a recognized equivalent of a high school diploma if, in addition to the content scores, the official GED transcript indicates that the student passed the GED test. [Guidance issued 1/24/2014]

RED-Q3.  Please advise if a certificate of high school completion is sufficient for a student to be eligible for Title IV funding.

RED-A3.  No.  Generally a certificate of high school completion (as opposed to a high school diploma) is issued to students who have completed high school coursework, but who have not met all the academic high school graduation requirements, including passing any required examinations.

We rely on a State's determination as to what constitutes a high school diploma including whether a certificate of high school completion is equivalent to a high school diploma in that State.  Therefore, institutions should check with the State in which the certificate of high school completion was awarded to see if that State considers the certificate of high school completion to be a high school diploma or its equivalent. [Guidance issued 1/24/2014]

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**Checking the Validity of a High School Diploma (CVD)**

CVD-Q1.  Do high schools have to be accredited for their graduates to be eligible for Title IV aid?

CVD-A1.  For Title IV student aid purposes, there is no requirement that a high school be accredited.  In determining whether a student’s high school diploma is valid, the Federal Student Aid Handbook suggests that institutions check with the appropriate state agency in the State in which the high school is located to determine if a diploma issued from that school is recognized by that State as a high school diploma.  [Guidance issued 1/24/2014]

CVD-Q2.  How can an institution determine whether a student’s high school diploma is valid for purposes of establishing Title IV eligibility?

CVD-A2.  Final regulations published on October 29, 2010, require postsecondary institutions to develop and apply procedures to evaluate the validity of a student’s high school diploma if the institution or the Department has reason to believe that the diploma is not valid or was not obtained from an entity that provides secondary school education (34 CFR §668.16(p)).

Because we rely on a State's determination as to what constitutes a high school diploma in that State, we encourage institutions to check with the relevant department or agency in the State in which the high school is located to determine if a diploma from the high school (which does not have to be accredited) is recognized by that State (see Volume 1 of the Federal Student Aid Handbook).  Another resource within the State that an institution may want to consult with is the State attorney General’s office.  For example, one State attorney General’s office has taken enforcement actions against entities that issue diplomas or other certificates of completion of secondary education without providing a legitimate secondary school education.

Another publication that may be helpful to institutions is the  “State Regulation of Private and Home Schools” which provides a brief  description for each state’s legal requirements that apply to K–12 private  schools in the United States. See  https://www2.ed.gov/about/inits/ed/non-public-education/regulation-map/index.html.  [Guidance issued 2/23/2016]

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**Documenting High School Completion Status (DHC)**

DHC-Q1.  Can an institution provide Title IV aid to a student who completes his or her high school requirements early, but the high school does not formally issue the high school diploma until a later time (e.g., at the end of the school year)?

DHC-A1.  Yes, if the institution obtains a signed statement from an official of the high school or school district indicating that the student has completed all of the required coursework and has successfully passed any required proficiency examinations for the high school diploma.  The statement must include the date when the actual high school diploma will be issued. [Guidance issued 1/24/2014]

DHC-Q2.  Can a student who does not have a high school diploma, or its recognized equivalent, or who has not completed a secondary school education in a homeschool setting, be admitted as a regular student to a postsecondary educational institution?

DHC-A2.  Yes, only if the student is beyond the age of compulsory school attendance in the State in which the institution is physically located, or is dually or concurrently enrolled in the institution and a secondary school. However the student must have a high school diploma or its recognized equivalent, or have completed a secondary school education in a homeschool setting in order to be eligible to receive Title IV aid.  Note one exception: students may qualify for Title IV aid under one of the ATB alternatives, either because the student is “grandfathered,” as described in Dear Colleague Letter GEN-12-09, or because the student is enrolled in an eligible career pathway program as described inDear Colleague Letter GEN-16-09 [Guidance issued 1/24/2014; **revised 6/7/2016**]

DHC-Q3.  Can an institution rely on a student’s self-certification on the FAFSA that he or she obtained a high school diploma or must the institution verify the student’s high school completion status?

DHC-A3.  An institution may rely on a student’s self-certification on the FAFSA that he or she obtained a high school diploma. However, if the institution has reason to believe that the high school diploma is not valid or was not obtained from an entity that provides secondary school education or if the student was placed in a Verification Tracking Group that requires verification of high school completion status, the institution must follow its procedures, as required under the regulations at 34 CFR 668.16(p), to evaluate the validity of the student's high school completion. [Guidance issued 1/24/2014; **revised 2/21/2014**] 

DHC-Q4.  When an institution relies on a student’s self-certification on the FAFSA that he or she obtained a high school diploma, but later determines that the student did not obtain the diploma, is the institution or the student responsible for returning all Title IV aid disbursed to the student?

DHC-A4.  Generally the student is liable and responsible for returning all Title IV funds disbursed to or on behalf of the student.   However, if the institution knew or should have known that the student did not have a high school diploma, the institution would be liable and must return all Title IV funds disbursed to the student.  This could happen, for example, if contrary to what the student provided on the FAFSA, the institution’s admissions office has a high school transcript that does not show that the student both completed high school and was awarded a high school diploma. [Guidance issued 1/24/2014]

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**Foreign High School Diploma (FHD)**

FHD-Q1.  Is a high school diploma from a foreign country recognized as a valid diploma?

FHD-A1.  Yes, if the institution determines whether the foreign secondary school credentials are evidence of completing the equivalent of a secondary education in the United States.  Institutions that do not have the expertise to make that determination themselves may use a foreign diploma evaluation service. [Guidance issued 1/24/2014]

FHD-Q2.  What documentation may an institution accept to verify high school completion status for an applicant who indicates that he or she cannot obtain documentation of his or her completion of a secondary school education in a foreign country?

FHD-A2.  In most cases, applicants who completed their secondary school education in a foreign country will be able to obtain a copy of their foreign high school diploma or transcript.  Applicants may also document their high school completion status by obtaining a copy of a “secondary school leaving certificate” (or a similar document) from the Ministry of Education in the country where they completed secondary school.  For assistance in obtaining documentation of their secondary school education completion, applicants may contact the foreign high school, the Ministry of Education or that country’s consulate in the United States.  There may be rare cases where it is impossible for a refugee, an asylee, or a victim of human trafficking to obtain documentation of his or her completion of a secondary school education in a foreign country.  Therefore, in these rare cases, applicants must submit to the institution:
                - Proof of their attempt to obtain documentation of their completion of a secondary school education in a foreign country, i.e., a copy of an e-mail or letter, including proof of mailing;
                - A signed and dated statement that indicates that the applicant completed his or her secondary school education in a foreign country, the name and address of the foreign high school where the applicant completed the secondary school education and the date when the foreign high school diploma was awarded.
                - A copy of the entry status documentation that identifies the applicant’s current or prior status as a refugee, an asylee, or as a victim of human trafficking and who entered the United States after the age of 15.   [Guidance issued 1/24/2014;  revised 12/15/2015 ]

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Program Integrity Q&A

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