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Department clarifies process for checking on high school completion
July 29, 2019
Financial aid professionals checking on the validity of a high school diploma have some authority to go beyond the process outlined in regulations.
In a July 23 Electronic Announcement, the Department of Education clarified that a process that includes the two steps outlined in the regulations satisfies the requirement of checking the validity of high school completion but other approaches are valid, as long as they comply with the language in the regulation.
According to the Department, an institution is in compliance with 34 CFR 668.16(p) if it establishes and follows a process to evaluate the validity of a student's high school completion that includes:
- receiving documentation from the secondary school that confirms the validity of the student's diploma, and
- confirming with or receiving documentation from the relevant department or agency in the state in which the secondary school is located that the secondary school is recognized as a provider of secondary school education.
The Department goes on to say that financial aid professionals may also satisfy the requirements of the regulation in ways that do not meet the description above. In order to satisfy 34 CFR 668.16(p) an institution need only "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."
However, the Department cautions that nothing in the Electronic Announcement "shall be construed as providing a safe harbor for an institution or an individual involved in this process against claims of fraud or prosecution for criminal activity."