BeautyLink - Volume 8, Issue 4 - 26
Is It Legit?
aid eligibility requirement is
that, generally, the applicant must be a high school
graduate or have the recognized equivalent of a
high school diploma. Much could be said regarding
the distinction between a high school graduate and
"recognized equivalents." Here, we will focus on the
legitimacy of a high school diploma.
A FEDERAL STUDENT
AND THEN THERE'S
Documentation of Completion
Of note, in most cases, the U.S. Department of
Education (ED) does not require an institution to verify
that a student is a high school graduate.1 Generally, a
student may self-certify his or her high school completion status when completing the Free Application for
Federal Student Aid (FAFSA).2 Yet, it is important to
understand that this allowance to self-certify does not
negate a State's, an institution's or accrediting agency's
own requirement that a student submit a valid high
school diploma or equivalent during the admissions
process. Students who apply for Federal Student Aid
are selected by ED, or their school, to have their application data verified through the "verification" process.
Then, they are assigned to one of several "Verification
Tracking Groups," such as V4 or V5. Students who are
in Verification Tracking Groups V4 or V5 are required
to provide documentation of high school completion.
An ongoing concern are so-called diploma mills.
The Higher Education Opportunity Act defines a
diploma mill as an unaccredited entity that provides
a degree, certificate, diploma, or other credential to
an individual with the intent that they may use it to
indicate to the general public that he/she has completed an educational program, for little to no cost,
in a short period of time.3 While the law was written
with college diploma mills in mind, ED expanded that
understanding to include high school diploma mills.4
Naturally, a fake diploma does no one any good.
Schools must have a method to validate questionable
claims of high school completion. In fact, regulations
require that Title IV-eligible schools have procedures
to evaluate the legitimacy or validity of a student's
high school completion status [34 CFR 668.16(p).]
There are several points a school must keep in mind
and steps it may take to comply with requirements to
This material is presented for informational and
educational purposes only and should not be considered to be giving legal advice.
1 NOTE: All URLs listed were accessed on 08/26/2016.
3 Higher Education Opportunity Act of 2008
Program Integrity Questions and Answers - High School Diploma.
2 Program Integrity Questions and Answers - Documenting High
School Completion Status
evaluate the validity of students' high school completion status.
1. Know the regulatory requirements applicable
to high school completion status (referenced
above), and guidance in the Federal Student
Aid Handbook related to high school diplomas,
as well as the stipulations of the relevant department or agency within your State.
2. If your school policy requires a valid copy of
a student's high school diploma (or recognized
equivalent), ensure you have a copy for every student. Again, there must be documentation of high
school completion for students in Verification
Tracking Groups V4 and V5.
3. Affirm that all high school transcripts and diplomas are final versions with an actual graduation date.
4. Develop policies and procedures related to questionable high school diplomas and a student's
completion status. Disseminate the policies to
all staff and students.
5. Consider developing a high school completion
status review committee to resolve questions
about diploma and completion status validity.
Retain minutes of these meetings.5
6. Most, but not all, legitimate high schools are
accredited. If the school is regionally accredited, it is almost 100% certain to be legitimate
due to the requirements for being regionally
7. Maintain an ongoing review of news and
government websites (e.g., Federal Trade
Commission, ED, State Attorney General's Office)
for information related to lawsuits against potential diploma mills.
8. Develop a list of invalid high schools and diploma
mills for use when processing applications.
9. Review the criteria that the National Association
for College Admission Counseling (NACAC) utilizes or recommends.
Appropriate steps taken in implementing effective policies and processes will ensure a school has
determined if an applicant's high school completion
status and diploma is "legit."
4 Regaining Eligibility: Questions and Answers
5 NASFAA 2016 Annual Conference - "Validating High School
Credentials and the Increased Existence of Diploma Mills."
https://www.nasfaa.org/handouts (membership required)
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