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1.7.1.5 Admissions Standards

With a few exceptions, eligible institutions may admit as regular students only persons who have high school diplomas or recognized equivalents.280 A recognized equivalent of a high school diploma is either a GED or a state certificate.281

In 2010, the Department adopted rules that require schools to develop and follow procedures to evaluate the validity of a student’s high school diploma.282 In order to meet the administrative capability standard to participate in the federal aid programs, schools are required to develop and follow procedures to evaluate the validity of a student’s high school completion if the school or the Department has reason to believe that the high school diploma is not valid or was not obtained from an entity that provides secondary school education.283 In July 2019, the Department provided clarification regarding the role of institutions in checking the validity of a student’s high school completion, as is required under the regulations.284 The clarification noted that:

“If an institution establishes and follows a process to evaluate the validity of a student’s high school completion that includes (1) receiving documentation from the secondary school that confirms the validity of the student’s diploma, and (2) 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, then the institution is in compliance with 34 CFR 668.16(p).”

Although institutions may satisfy the requirements of the regulation by establishing and following a process that meets this description, they may also satisfy the requirements in other ways that do not meet this description. 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.” Thus, the Department has made clear that a process that meets the two-part description above satisfies this requirement, and that other approaches used by institutions are still valid to the extent that they comply with the language of 34 C.F.R. § 668.16(p).

Beginning in 2011–2012, the Department added questions to the FAFSA form that ask first-year undergraduates for the name of the high school the student graduated from and the state where the school is located. There is a drop-down list of both public and private high schools, which is derived from National Center for Education Statistics data.285 Schools should review any diploma that that they have reason to believe is not valid.286

There continue to be problems with the use of diploma mills.287 For more on this problem—and on false certification regulations that provide for federal student loan discharges in instances in which schools certified non-high-school graduates as eligible for aid based on either high school graduation status falsified by the school or high school diplomas falsified by the school or a third party to which the school referred the borrower—see §§ 10.4.2.5, 13.3.2.6, infra.

The Department issued guidance for cases in which schools discovered that students who are already enrolled did not in fact have valid high school diplomas. The Department advised schools in these cases to contact the “School Participation Team” and have information available about the circumstances under which the school initially accepted the student’s high school diploma status and the types and amounts of assistance received.288

Schools’ use of ability-to-benefit tests as an alternative eligibility measure to high school diplomas is discussed in § 1.6.1, supra.

Footnotes

  • 280 {273} 20 U.S.C. §§ 1001(a), 1002.

  • 281 {274} 34 C.F.R. § 600.2.

  • 282 {275} 75 Fed. Reg. 66,832 (Oct. 29, 2010).

  • 283 {276} 34 C.F.R. § 668.16(p).

  • 284 U.S. Dep’t of Educ., Electronic Announcement, Checking the Validity of a Student’s High School Completion (July 23, 2019), available at https://ifap.ed.gov.

    The Department stated that it recognized that this safe harbor provision will not apply to students who completed high school at a secondary school not required to be recognized by the relevant department or agency in the state where the school is located, and it encouraged institutions “to consider alternative processes for checking the validity of high school completion for such students.”

  • 285 {277} 75 Fed. Reg. 34,806 (June 18, 2010).

  • 286 {278} 34 C.F.R. § 668.16(p).

  • 287 {279} See § 13.3.2.6, infra.

  • 288 {282} U.S. Dep’t of Educ., Dear Colleague Letter, GEN-12-03, Title IV Student Financial Assistance Disbursed to Students Without a Valid High School Diploma (Feb. 9, 2012).