This message was shared with all faculty on June 22, 2023. 

Dear Colleagues, 
​Under Title IV (“Student Assistance”) of the Higher Education Act of 1965, institutions of higher education are required to verify that students receiving financial aid have begun Initial Course Participation (ICP). ICP refers to the student’s attendance in class during the term for which they are receiving financial aid.

Over the winter, I charged a working group led by Vice Provost Steve Weber with colleagues from across the Office of the Provost, Financial Aid, Faculty Senate, Academic Information Systems and the Office of the University Registrar with creating a process to bring Drexel into compliance with this financial aid regulation. This new process requires that instructors verify whether each enrolled student has begun attendance in a course.

Affected Courses

As a pilot for this new process, only instructors of quarter courses in the summer term of Academic Year 2022-2023 will be asked to verify students’ attendance. Beginning with Academic Year 2023-2024, student attendance (ICP) verification will be required for every billable and credit-bearing course for which there is a possibility of one or more students receiving federal financial aid, including both graduate and undergraduate courses and quarter and semester courses. Instructors will receive reminders of this process when they are deemed to be teaching a course that requires ICP verification.

Key Dates and Process

The following bullets outline the ICP process during the upcoming summer quarter.

  • Instructors are strongly encouraged to include language in their syllabi regarding ICP (view the proposed syllabus statement).
  • In the first course meeting after the add/drop deadline (July 2, 2023), instructors should take attendance and record all attending students in the ICP column, which will appear in Drexel Learn course shells.
  • In subsequent class meetings, instructors should record the attendance of students who have not attended any previous classes until the end of Week 3 (July 16, 2023). After this time, students whose attendance has not been recorded will be considered not to have begun Initial Course Participation.
  • The Offices of Financial Aid and the University Registrar will follow up with students who receive financial aid and do not have verified ICP. No further action is needed on the part of the faculty member.

In courses with non-gradable sections such as recitations and labs, attendance may alternatively be taken in the non-gradable sections. In online, asynchronous courses where taking attendance is not possible, ICP can be verified through students’ completion of an activity. For more information, please visit the ICP FAQ page on the Office of the Provost’s website.

We understand that ICP verification and follow up requires extra effort on the part of instructors and administrative staff. This is a collaborative effort, and we appreciate everyone’s contributions to ensuring Drexel’s compliance with this federal regulation.


Paul E. Jensen
Executive Vice President
Nina Henderson Provost