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The regulation has been on the books for awhile: If a student qualifies to graduate, except in exceptional circumstances, he or she is * and should either graduate or acquire other types of funding. But how can schools identify these students? Reviewing those who applied to graduate can be a huge task, let alone reviewing all the students who did not apply for graduation to see if they should have. So, for the most part, the regulation has remained unenforced due to its impracticality.

“Until now, schools haven’t been able to systematically identify student who met graduation requirements,” said Joel Wenger, Associate Director of Financial Aid at Purdue University. “Most schools have had to do that work manually, so at a large school, where you have 7000 students graduating, when do you have time? It’s next to impossible.”

However, the revolution in student data management has led to the the emergence of industry-standard software that enables institutions to track students’ readiness-to-graduate much more accurately and efficiently, and the Department of Education is likely to start paying more attention to schools’ compliance with this regulation.

“There are a lot of reasons students would choose not to graduate, and some are legitimate,” said Lesa Beals, Senior Associate Registrar at Purdue. Students may not seek graduation for reasons such as:

• Wanting to study abroad.

• Wanting to add a minor.

• No job lined up.

• Not wanting to return to their home country because of circumstances.

• Wanting to retake classes to raise G.P.A. for graduate school applications.

Some situations warrant an exception, but often these cases can’t be justified to an auditor.

“It’s a question of what is the institution comfortable with signing off on to extend time to degree? What does the federal government allow?” Beals said. “We’re trying to identify as many of those reasons as we can to help advise and guide the academic community that interacts on the front line with students, to give best recommendations, and to help people understand it’s not just financial aid implications or four-year graduation rate, but, in some cases, Immigration and Homeland Security issues.”

Beals and Wegner will discuss this issue in depth, covering the steps Purdue is taking to ensure federal compliance and institutional integrity, at the ̽��¥ Annual Meeting in Orlando.

* To wit: “To be eligible for Title IV funds, a student must be a regular student as defined in 34 CFR 668.32. A regular student is defined as a student ‘enrolled or accepted for enrollment at an institution for the purpose of obtaining a degree, certificate, or other recognized credential offered by that institution.’

“It is understood that students are not eligible to receive federal Title IV assistance for credit hours or coursework which does not count towards the completion of that student’s degree program requirements.”