Administrators who oversee online education say a federal plan to require colleges to take attendance in virtual courses would impose significant time demands on faculty members and increase cost burdens on institutions.
The U.S. Education Department proposed the change as part of a larger package of federal policies designed to protect students and hold institutions accountable for the financial aid dollars they receive. The rules emerged in July, from a negotiated rule-making session the agency held last year.
Taking attendance would not be as simple as students logging into the learning management system or stating “here” at the beginning of each class session. Every 14 days, students would be expected to turn in an assignment or interact with a professor or fellow students during lectures and course discussions, although the department has yet to define exactly what mechanism or standard it would require colleges to use to align with the new policy.
A department spokesperson told Inside Higher Ed, “The office does not usually comment on notices of proposed rule making beyond the text of the official proposals.”
Potential Financial Burden
The goal, according to the department’s proposal, is to avoid having students drop out of online courses while the institution continues to collect federal Title IV financial aid funds.
“A school that is not required to take attendance may use as a withdrawal date either the last date of a student’s academically related activity that it has on record or the midpoint of the payment period,” the proposed regulation states. “This can lead to institutions failing to report an accurate date, or using the date that allows the institution to keep the most money.”
Carolyn Fast, director of higher education and senior fellow at the Century Foundation, served on the negotiating committee for the rule making that developed the proposed regulations. She believes taking attendance is a “completely reasonable” thing to ask.
“A concern is if a school isn’t taking attendance—how do they know when a student withdraws?” she said. “I think it’s just a common-sense thing. If you’re calculating it based on a date and don’t know when they’re attending, how could it be accurate?”
David Baime, senior vice president for government relations at the American Association of Community Colleges, said he asked the Education Department for data showcasing how widespread an issue the lack of attendance taking is. He said the department did not respond.
“Despite what the department has said, it can ultimately be quite complicated and difficult and furthermore costly for institutions to provide documentation that the department appears to be requiring as a result of the attendance requirement for online courses,” he said.
The department acknowledges this will be costly for higher education institutions in the beginning. According to the proposed regulations, it would cost a total of $7,552,669 across 1,866 institutions to implement the attendance-taking measures, based on the salary of education administrators, who earn $49.33 per hour. This would be a one-time cost, according to the department. The 1,866 is half of the 3,732 institutions that offer at least one distance education course, according to 2022 Integrated Postsecondary Education Data System data; the department assumes that roughly half of those already have attendance-taking measures in place and that it would take the remaining half of institutions roughly 10 minutes a day to capture attendance data for their records.
Baime believes the department “wildly underestimated” the costs and time involved for the process.
For Caleb Simmons, executive director of online education at the University of Arizona, the concern is less about finances and more about placing a burden on faculty already shouldering many changes.
“We’d be able to figure it out on the financial side and even the workload side, although it would be a pain point,” said Simmons, who oversees Arizona Online. “But there has to be an acknowledgment of the additional workload that’s placed on faculty—in addition to teaching obligations, being there for students, research. It’s an ever-growing amount of work with no additional compensation.”
Differing Online and In-Person Standards
Baime and Simmons both said implementing the requirement would be difficult; Baime called it “inconceivable” and Simmons, brainstorming, said Arizona would potentially have to create some tool in its learning management software, since “we could not ask every individual faculty [member] to send us a report.”
Jordan DiMaggio, vice president of policy and digital strategy at UPCEA, the online and professional education association, said the proposal was another reminder that online and in-person courses play by a different set of standards.
“There’re questions on whether the department is truly focused on protecting students’ outcomes and taxpayer dollars,” he said in a previous interview with Inside Higher Ed regarding the proposed regulations. “Or do they kind of reveal an antiquated bias against online education that’s framed by some suspicion and distrust of the field as a whole?”
Several industry experts pointed out that if a student does not attend class in person for two weeks, there is not an assumption they dropped out of class.
Simmons pointed out online courses often serve a population that needs more flexibility from a rigid schedule. He cited a current student of his in Bangladesh who has had to miss several classes in a row due to ongoing tensions in his country and a loss of power.
“That is a one-off anecdote, but this is not unusual for online learners; they’re firmly enmeshed in life, and this perhaps makes it less accessible because it’s less flexible,” he said, adding he is not necessarily against ensuring online entities provide a high-quality, rigorous program. “They’re on the right path for what they’re trying to regulate. The problem, from my perspective, is it’s too wide of a brush.”
Emmanual Guillory, senior director of government relations at the American Council on Education, echoed Simmons’s concerns.
“They’re trying to support their families in whatever ways, and they don’t have the luxury to have a carved-out time every week to go sit in the classroom with their peers and learn,” he said in a previous interview with Inside Higher Ed. “What you’re doing is you are limiting the ability of these students to access postsecondary education by using student aid funding, and this could have a huge impact on low-income students.”
The proposed regulations were posted in the final week of July and are open for public comments until Aug. 23. If they are finalized before Nov. 1, they will be implemented no earlier than July 2026.