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- Program Integrity Q&A -

Questions on this topic are divided into the following categories:
                - **Credit Hour**
                - **Accrediting Agencies**
                - **Role of States**

In addition to the following Q&As, please see the following resources for guidance related to the definition of a Credit Hour:
                - Preamble to the final regulations ( https://www.govinfo.gov/content/pkg/FR-2010-10-29/pdf/2010-26531.pdf ) – published 10/29/2010
                - GEN-11-06 ( http://ifap.ed.gov/dpcletters/GEN1106.html ) – published 3/18/2011

**Credit Hour (CH)**

CH-Q1: Must an institution use the Federal definition of a credit hour as a starting point for making academic judgments about the credits associated with courses and programs if the institution is to continue to be eligible for Federal funding such as student aid?

CH-A1: No. As discussed in the preamble of the final regulations (see 75 FR 66845, available at https://www.govinfo.gov/content/pkg/FR-2010-10-29/pdf/2010-26531.pdf), nothing in the regulations prevents an institution from defining a credit hour using other metrics or measures of student progress and learning outcomes for academic and other non-Federal purposes, so long as it is also awarding Federal student aid using the credit hour definition in the regulations. An institution may have courses measured in Federal credit hours and also in institutional credit hours. Use of the Federal credit hour definition is only required for Federal program purposes, for example, determining enrollment status in order to determine Federal student aid eligibility for a student. However, we believe the definition is flexible enough to meet institutional needs as well as Federal needs. [Guidance issued 3/18/2011]

CH-Q2: Can an institution comply using a measure of student progress and learning outcomes other than a credit hour?

CH-A2: Yes. An institution may use other measures to the extent the institution determines reasonable equivalencies to a credit hour of student work. For example, the Department continues to provide for the utilization of direct assessment of student learning under 34CFR 668.10 in lieu of credit hours in a Department-approved direct assessment program, as long as an institution establishes a methodology to reasonably equate the direct assessment to credit hours. [Guidance issued 3/18/2011]

CH-Q3: Does the definition of a credit hour mean that all 3-credit courses will have to meet for 3 hours per week or the equivalent of 37.5 clock hours for a semester hour?

CH-A3: No. The credit-hour definition does not dictate particular amounts of classroom time versus out-of-class student work. Further note that the definition provides that a credit hour may be for an equivalent amount of work over a different amount of time. There is no requirement that a 3-semester hour course meet 3 hours per week during a semester or a 3-quarter-hour course meet 3 hours per week during a quarter. The requirement is that the institution determine that there is an amount of student work for a credit hour that reasonably approximates not less than one hour of class and two hours of out-of-class student work per week over a semester for a semester hour or a quarter for a quarter hour. For example, an institution with a semester-based calendar has a graduate seminar for which it awards 3 semester hours. The class meets only one hour per week over a 15-week semester with the students expected to perform a substantial amount of outside research that is the equivalent of 8 or more hours of student work each week of the semester. For purposes of the Federal definition, the institution would be able to award up to 3 semester hours for the course. With regard to the need to have the equivalent of 37.5 hours, the 37.5-hour requirement relates to undergraduate programs subject to the clock-to-credit-hour conversion requirements in §668.8(k) and (l). These requirements are not relevant to degree programs of at least two academic years and graduate programs, and would not apply to certain nondegree undergraduate programs. Further, similar to the definition of a credit hour in §600.2, §668.8(l)(2) provides institutions with the flexibility to take into account out-of-class student work in determining the credit hours that may be used for Federal purposes. [Guidance issued 3/18/2011]

CH-Q4: How would an institution apply the definition of a credit hour if the institution offers asynchronous online courses that are not also offered in a classroom setting?

CH-A4: There is no "seat time" requirement implicit in the definition of a credit hour. An institution that is offering asynchronous online courses would need to determine the amount of student work expected in each online course in order to achieve the course objectives, and to assign a credit hour based on at least an equivalent amount of work as represented in the definition of credit hour. [Guidance issued 3/18/2011]

CH-Q5: What is the relationship of a defined credit hour to a “week of instructional time” as defined under §668.3(b)(2) and used in determining the weeks of instructional time for purposes of an educational program and student eligibility?

CH-A5: In general, a week of instructional time is any seven-day period in which at least one day of regularly scheduled instruction or examination occurs; instructional time does not include vacation time, homework, or periods of counseling or orientation. Thus, in any seven-day period, a student is expected to be academically engaged through, for example, classroom attendance, examinations, practica, laboratory work, internships, and supervised studio work. In the case of distance education and correspondence education, academic engagement would include, but not be limited to, submitting an academic assignment; taking an exam, an interactive tutorial, or computer-assisted instruction; attending a study group that was assigned by the institution; contributing to an academic online discussion; and initiating contact with a faculty member to ask a question about the academic subject studied in the course. Merely logging into the electronic classroom does not constitute academic engagement.

Even though a student’s homework, research, or other unsupervised student work is not considered in determining the weeks of instructional time in an educational program, such student work would be considered in determining the number of credits to be awarded for a student’s coursework. (Note: we believe that financial aid administrators are familiar with these and other title IV student financial aid concepts. Academic personnel are encouraged to consult with their financial aid staff to gain a better understanding of how credit hours factor into the administration of title IV funds.)  [Guidance issued 3/18/2011]

CH-Q6: Must an institution have a single policy and procedures related to the credit hour that applies to all disciplines, degree levels, teaching/learning formats, and delivery modes?

CH-A6: No. We recognize that complex institutions with multiple degree levels may not have rigidly uniform policies and procedures related to the credit hour across a variety of disciplines, degree levels, teaching/learning formats, and delivery modes. However, institutions must have policies and procedures that ensure sufficient consistency to gain the confidence of accrediting agencies through peer review that their assignment of credit hours conforms to commonly accepted practice in higher education. [Guidance issued 3/18/2011]

CH-Q7: Can you provide an example of an institution using different credits for title IV purposes and for academic purposes?

CH-A7: Institution A uses the term "credit hour" in describing a course, but awards credits for that course solely on the basis of classroom time without any expectation of student work outside of the classroom. For example, the institution awards 3 credit hours for a course that meets 3 hours per week over a semester. For Federal purposes, the course is a one credit hour course. [Guidance issued 3/18/2011]

CH-Q8: If an institution measures student progress in courses or in units, rather than in credits, is the institution required to change its practices and offer 3-credit courses?

CH-A8: No. The institution may continue its current practice of measuring progress in courses or in units. However, the institution must award Federal student aid using the credit hour definition in the regulations. [Guidance issued 3/18/2011]

CH-Q9.  The revised regulations streamlining the clock to credit hour conversion will go into effect on July 1, 2016.  For affected institutions that wish to transition back to credit hours, what if the payment period doesn’t end at the end of a term?  When can an institution transition to credit hours?

CH-A9.  An institution may transition to credit hours from clock hours at three different times:
                - Institutions can teach the remainder of the current program to currently enrolled students as a clock hour program;
                - New students (enrolled after 7/1/16) may be enrolled under the new regulations;
                - An institution may choose to switch from clock hours to credit hours at the end of a payment period (as long as the payment period ends after 7/1/16).   New

CH-Q10.  When can an institution update its Eligibility and Certification Approval Report (ECAR) to reflect the new status of the program?

CH-A10.  An institution can update its ECAR starting July 1, 2016, after the revised regulations take effect.  New

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**Accrediting agencies (A)** (also refer to Enclosure B in Dear Colleague Letter GEN-11-06)

A-Q1: What is the role of accrediting agencies in reviewing an institution’s implementation of the clock-to-credit-hour conversion formula under §668.8 (l)?

A-A1: An accrediting agency is responsible, as part of its analysis of an institution under §602.24(f), for ensuring that the institution is complying with the requirements in §668.8(l)(2) when determining the amount of student work outside of class used to convert the clock hours for the educational activities in a program, and that the conversion results are compliant with the definition of a credit hour in §600.2. [Guidance issued 3/18/2011]

A-Q2: An institution restructures a 720-clock-hour undergraduate program that has no out-of-class student work and is subject to the clock-to-credit-hour conversion. Under current regulations, the program is considered a 24-semester-hour program for title IV student financial assistance purposes. The institution is restructuring the program to increase the clock hours in the program to 900 clock hours in order to continue to support the 24 semester hours previously awarded and to provide eligibility under the October 29 regulations for Federal student assistance at the previous level. What is the responsibility of the accrediting agency?

A-A2: The conversion of the 900 clock hours to 24 semester hours is appropriate under the conversion standard of 37.5 clock hours per semester hour under §668.8(l)(1) of the October 29 regulations. However, the accrediting agency must review this restructuring as a substantive change because the addition of these clock hours constitutes a substantial increase in the number of clock hours awarded for successful completion of the program. Similarly, accrediting agencies are responsible for ensuring that the credit hours determined by an institution making a conversion based on out-of-class student work under §668.8(l)(2) conform to the definition of a credit hour in §600.2. [Guidance issued 3/18/2011]

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**Role of States (RS)**

RS-Q1: Do the regulations add a requirement that, to authorize an institution, a State must review and evaluate the institution’s policies and procedures for the assignment of credit hours, and the institution’s application of its policies and procedures in assigning credit hours to its programs and courses?

RS-A1: No. The regulations do not regulate States, and they do not require that a State review and evaluate every institution’s assignment of credit hours. Only for those public postsecondary vocational institutions in New York, Pennsylvania, Oklahoma, and Puerto Rico that participate in the Federal student assistance programs based on State approval in lieu of accreditation by a nationally recognized accrediting agency, will the recognized State agency be required to perform such an assessment of those institutions’ assignment of credit hours. (See 34 CFR 603.24(c) of the October 29 regulations.) [Guidance issued 3/18/2011]

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Program Integrity Q&A

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