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We recently transitioned from Blackboard to Desire2Learn (D2L).  An adverse result of our transition has been a compliance issue with financial aid regulations for verifying last date of attendance with a meaningful educational activity.  We (IT) have been working with our Financial Aid Office and with D2L with poor results.


Basically, D2L can generate a date and time that the student last logged into the system, it cannot determine which course and whether the student completed an academic related activity.  We are also unable to determine whether students have engaged in all of their classes as required.  Since this is the only data that we can retrieve from the system we will use this information, however, this is considered insufficient and a compliance issue.


Has anyone faced this issue and do you have a solution for Financial Aid?   I’m working with our Provost to find a solution.




Regulations require the institution that does not take attendance to determine the last date of attendance at an academically related activity as a student’s withdrawal date for R2T4 purposes.

Reference: 34 CFR 668.22(c)(1)(i) and (ii); FSA HB April, 2012 Volume 5 pg. 52


Participation in academic counseling and advising are no longer considered to be academic attendance or attendance at an academically related activity.

Reference: 34 CFR 668.22(c)(3); FSA HB April, 2012 Volume 5 pg. 59



- Mac -


Keith W. McIntosh, MBA
Vice Chancellor for Information Technology

and Chief Information Officer (CIO)

Information Technology
Pima County Community College District


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