plan; (iii) Logging into an online class or tutorial without any further participation; or (iv) Participating in academic counseling or advisement" (34 CFR 600.2 "Distance education")16
The Department of Education specifies that “academic attendance” for financial aid purposes relates to the definition of “academic engagement” and entails institutional documentation of attendance policies which govern when the institution determines that a student has withdrawn:
“(7)(i) “Academic attendance” and “attendance at an academically-related activity” must include academic engagement as defined under 34 CFR 600.2. (ii) A determination of “academic attendance” or “attendance at an academically-related activity” must be made by the institution; a student’s certification of attendance that is not supported by institutional documentation is not acceptable” (34 CFR 668.22(l)(7)).17
The Department of Education provides guidance on how to track the date of withdrawal for financial aid purposes at institutions that do not require attendance. This is relevant in online education for instructors tracking periods of inactivity, which could involve a student's withdrawal from the institution:
“(3) The “date of the institution’s determination that the student withdrew” for an institution that is not required to take attendance is— (i) For a student who provides notification to the institution of his or her withdrawal, the student’s withdrawal date as determined under paragraph (c) of this section or the date of notification of withdrawal, whichever is later; (ii) For a student who did not provide notification of his or her withdrawal to the institution, the date that the institution becomes aware that the student ceased attendance; (iii) For a student who does not return from an approved leave of absence, the earlier of the date of the end of the leave of absence or the date the student notifies the institution that he or she will not be returning to the institution; or (iv) For a student whose rescission is negated under paragraph (c)(2)(i)(B) of this section, the date the institution becomes aware that the student did not, or will not, complete the payment period or period of enrollment. (v) For a student who takes a leave of absence that is not approved in accordance with paragraph (d) of this section, the date that the student begins the leave of absence” (34 CFR 668.22(I)(3)).18
The Department of Education clarifies that an institution must be able to document whether a student has attended the institution during a period in which the student receives financial aid:
"(c) For purposes of this section, the Secretary considers that a student has not begun attendance in a payment period or period of enrollment if the institution is unable to document"
16 https://www.ecfr.gov/current/title-34/part-600#p-600.2(Academic%20engagement)
17 https://www.ecfr.gov/current/title-34/part-668/section-668.22#p-668.22(l)(7)
18 https://www.ecfr.gov/current/title-34/part-668/section-668.22#p-668.22(l)(3)