Higher Learning Commission

Policy Title: Practices for Verification of Student Identity

Number: FDCR.A.10.050

An institution offering distance education or correspondence education, as specified in the federal definitions reproduced herein solely for reference, shall have processes through which the institution establishes that the student who registers in the distance education or correspondence education courses or programs is the same student who participates in and completes and receives the academic credit.

Distance education/course means education that uses one or more of the {following} technologies (i) to deliver instruction to students who are separated from the instructor: and (ii) to support regular and substantive interaction between the students and the instructor, synchronously or asynchronously. The technologies used may include: (i) the internet; (ii) one way and two way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber optics, satellite, or wireless communications devices; (iii) audioconferencing; or (iv) videocassettes, DVDs, and CD-Roms, if the videocassettes, DVDs or CDRoms are used in conjunction with any of the technologies listed in clauses (i) through (iii).

Correspondence education/course means: (1) Education provided through one or more courses by an institution under which the institution provides instructional materials, by mail or electronic transmission, including examinations on the materials, to students who are separated from the instructor. (2) Interaction between the instructor and the student is not regular and substantive, and is primarily initiated by the student. (3) Correspondence courses are typically self-paced. (4) Correspondence education is not distance education. 34CFR 602.3 (11/1/2010)

Institutional Practices. In verifying the identify of students who participate in class or coursework the institution may make use of a variety of methods at the option of the institution, including but not limited to: (1) secure login and pass code; (2) proctored examinations; and (3) new or other technologies and practices that are effective in verifying the identity of students. Such methods must have reasonable and appropriate safeguards to protect student privacy. Institutions must notify students at the time of registration or enrollment of any projected additional student charges associated with the verification of student identity such as separate fees charged by proctoring services, etc.

Commission Review. The Commission will review an institution’s student identity verification protocols when an institution requests permission to add programs in distance delivery as well as during a comprehensive evaluation. The Commission will also require that institutions submit information about student identity verification protocols on the Commission’s Institutional Update.

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Policy History

Last Revised: June 2012
First Adopted: February 2009
Revision History: Adopted February 2009, revised February 2010, revised and renumbered June 2012
Notes: Former policy number: 4.0(d)

Policy Number Key

Section FDCR: Policies Required by Federal Regulation

Chapter A: Federal Compliance

Part 10: General

Related Procedures


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