Determining Semester Participation

LionPATH grading screen showing participation options

Under federal regulations, students who do not complete the entire semester may not earn the full amount of their aid for the semester, and the University must return any unearned federal student aid funds to the federal government. Regulations require us to document the last date of attendance at (or participation in) an "academically-related activity" for students with failing grades in order to determine the amount of aid to return. Previously, last date of attendance was only captured for "F" grades; however, the University now requires last date of attendance for "NG" and "DF" grades as well. According to federal regulations, "academically related activities" that may be recorded in a gradebook and which document a student's last date of attendance include but are not limited to:

  • Physically attending a class that enables direct interaction between instructor and students
  • Submitting an academic assignment
  • Taking an exam, an interactive tutorial, or computer-assisted instruction
  • Attending an assigned study group
  • Participating in an online discussion about academic matters
  • Initiating contact with a faculty member to ask questions about the course subject matter

Note: In the case of online courses, academically related activity must include substantive interaction and participation in the course, not simply signing in to the course.

When assigning grades, the Faculty Center Grade Roster in LionPATH provides the options of "Participated Entire Semester," "Participated Partial Semester," or "Never Attended" for "F," "DF," or "NG" grades (see screenshot below). If "Participated Partial Semester" is selected, the last date of attendance is required. For details on entering grades, you can review the online tutorial titled “Entering and Importing Grades Using the Grade Roster.”

The documentation used to determine the last date of attendance for a student must be retained for five years after course completion (see GURU General Retention Schedule – formerly Appendix 18) and be available for auditors to review upon request. This often includes gradebook content, whether in paper or electronic form. The US Department of Education has indicated that gradebooks are adequate documentation of a student's last date of attendance so long as:

  • the gradebooks record and identify activities that are academically related,
  • the gradebooks are maintained in a timely and consistent manner, and
  • the information in the gradebooks is not changed without recording the change.

It is important to note, for last date of attendance and federal financial aid purposes, gradebook entries must include a clear description of each activity as well as the date of the assignment submission, the taking of an exam, participation in an online discussion about academic matters, etc. In addition, gradebooks must be maintained under a consistent and timely practice so that the integrity of the documentation supporting the determination of a student's last date of attendance cannot be brought into question.

The impact of non-compliance is significant as it puts at risk Penn State's participation in federal financial aid funding, potentially adversely impacting a vast majority of our students who rely on financial aid. Almost 75 percent of Penn State students rely on some type of financial aid. Our most recent data states that the University received more than $706 million in federal financial aid funding alone. Your cooperation in maintaining adequate gradebook documentation ensures that Penn State remains in compliance with the applicable regulations and that this vital funding source for our students is continued.

Questions about this regulatory requirement may be directed to Anna Griswold, executive director for Student Aid, Questions about the grade reporting functionality when assigning a grade of "F," "DF" or "NG" may be directed to Robert Kubat, university registrar, at