institutional eligibility nautochia webb u.s. department of education training & information...

Institutional Eligibility

Nautochia WebbU.S. Department of Education

Training & Information Services Division

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Eligible InstitutionEligibility Requirements

• Authorized by the state (34 CFR 600.9)• Accredited by accrediting agency

recognized by the Department of Education (ED, or sometimes referred to as the Department)

• Offers at least one eligible program

Apply to Participate

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Eligible ProgramsInstitution of Higher Education

• 34 CFR 668.8(c)• Associate, bachelor’s, graduate or

professional degree, or• At least a 2-year program acceptable for full

credit toward a bachelor’s degree, or• At least a 1-year training program that leads

to a degree or certificate (or other educational credential) and prepares students for gainful employment in a recognized occupation


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Eligible ProgramsProprietary Institution of Higher Education and

Postsecondary Vocational Institution

• 34 CFR 668.8(d)• Programs must provide training that prepares

student for gainful employment in a recognized occupation and contain a minimum of:– 15 weeks instruction and 600 clock hours,16

semester/trimester hours, or 24 quarter hours– 10 weeks of instruction and 300 clock hours, 8

semester/trimester hours, or 12 quarter hours• Graduate or professional program or • admit only students with equivalent of an associate degree

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• 34 CFR 668.8(d)• Programs must provide training that prepares

student for gainful employment in a recognized occupation and contain a minimum of:– 10 weeks instruction and 300-599 clock hours,

• 70% completion rate and 70% placement rate in related job fields;

• in existence for one year • eligible for Direct Loans only

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34 CFR 668.8(d)Provides program leading to a baccalaureate degree in liberal arts

Must be a program offered since 1/1/2009Must have accreditation since 10/1/2007 or earlier

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Eligible InstitutionAdmissions Standards

• Admits as regular students persons who have high school diplomas or GED– May also accept students who completed secondary

school education in a home-school setting treated as a home school or private school by state law

– If home-schooled, and under age of compulsory attendance, ED considers student above age if the state in which institution is located does not consider student truant

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Eligible InstitutionEligibility Requirements

“The Two-Year Rule”

Proprietary or postsecondary vocational schools must have been authorized and provided an eligible program for at least 2 years prior to the date of application

During initial periods of participation, these schools cannot receive approval of additional programs that would expand the scope of eligibility


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Eligible Institution Additional Eligibility Requirements

“The 90/10 Rule”

• Applicable to proprietary schools only• May derive no more than 90% of its

revenues from the Title IV HEA programs• 10% of revenue must come from non-

Title IV funding: tuition, fees, other institutional charges, school activities necessary for students enrolled in those programs


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Eligible Institution Additional Eligibility Requirements

“The 90/10 Rule”

Consequences of failure to meet 90/10 include:For 1 fiscal year - provisional certification for 2 yearsFor 2 fiscal years - loss of eligibility for at least 2 fiscal years

34 CFR 668.14(b)(16), 668.28(c)


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Eligible InstitutionAdditional Eligibility Requirements

• Correspondence Course Limitation and Correspondence Student Limitation (or the “Two 50% Rules”)– Not eligible if more than 50% of courses

are taught through correspondence or– Not eligible if 50% or more of regular

students are enrolled in correspondence courses


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• Incarcerated Student Limitation– Not eligible if more than 25% of regular

students are incarcerated– Requirement may be waived for public or

nonprofit school providing two-year or four-year programs• must apply for waiver through electronic

application prior to exceeding limits


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• Ability-to-benefit Limitation– Not eligible if more than 50% of regular

enrolled students had neither a high school diploma nor equivalent, unless school provides a four-year bachelor’s degree or two-year associate degree program


Applies to Periods Prior to 7/1/2012:

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• Bankruptcy– School is not eligible if the school or an

affiliate of school files for bankruptcy


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• Crimes involving FSA Program Funds– School is not eligible if the school, its owner, or its

chief executive officer:• Has pled guilty to, has pled nolo contendere to, or is

found guilty of a crime involving the acquisition, use, or expenditure of FSA Program funds; or

• Has been judicially determined to have committed fraud involving FSA Program funds


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General Participation Requirements

• Voter registrationHEA 487(a)(23) and 668.14(d)

• Constitution Day (September 17th)FR dated May 24, 2005 and May 31, 2005

• Availability of GED program668.14(b)(13)

• Drug-Free Workplace and drug abuse prevention program668.14(c)


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• Civil Rights and Privacy requirements99.31(a)(13) and (14)

• Notify ED of contracts with servicers668.25(e)

• Incentive compensation668.14(b)(22)


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• Consumer Information – Annual individual notice to students

containing list of consumer information and how to obtain it (includes Campus Security, Equity in Athletic Disclosure, Family Educational Rights and Privacy, Student Right to Know and general information about school)

http://www.ifap.ed.gov/qahome/qaassessments/consumerinformation.html


http://www.ifap.ed.gov/qahome/qaassessments/consumerinformation.html

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Fundamentals of Federal Student Aid Administration Training

• Required when institution wishes to participate in Title IV for the first time– Must be completed within one year (before

or after) of approval to participate in Title IV Programs

• Required when there is a change of ownership

• Institution may request waiver• Not required when participating institution

wishes to participate in additional Title IV programs


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ED reviews financial statements and systems and determines school’s ability to – Properly administer the FSA programs– Meet all of its financial obligations– Provide the services described in official

publications

Financial Responsibility


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Financial StatementsSubmit with application, audited financial statements prepared in accordance with

Generally Accepted Accounting Principles (GAAP)Generally Accepted Government Auditing Standards (GAGAS)

Thereafter, must submit annual financial statements and compliance audits


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Administrative Capability

• Outlines school’s ability to administer the Title IV Programs in accordance with the Law and Regulations

• Section K of application • Reviewed by ED through program reviews

and annual compliance audits

34 CFR 668.16


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Reporting Changes Apply and Wait for Approval

(34 CFR 600.20)• Increase level of program offering (e.g.,

adding graduate degree programs when previously offered only baccalaureate programs)

• Change in educational programs outside the scope of current approval (§600.10)

• Add a branch campus• Change in institutional structure


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(34 CFR 600.20)

• Change in accrediting agency• Change in state authorizing agency• Change in ownership or type of ownership• Request for additional Title IV program• Addition of short-term (300-599 clock hour)

programs


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(34 CFR 600.20)• Addition of a location, if the school

– Is provisionally certified; – Is on the cash monitoring or reimbursement system of

payment; – Has acquired assets of another school that provided

educational programs at that location and participated in Title IV during that year;

– Would be subject to loss of eligibility under cohort default rules if it adds that location; or

– Department previously prohibited the school from disbursing Title IV funds without prior approval


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Reporting ChangesReport and “Go” (34 CFR 600.21)

• All schools must report the following information within 10 calendar days of the change– Change to school’s name or additional location

name– Address change for principal location or any

additional locations– Additional location unless required to apply

under §600.20


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• All schools must report the following information within 10 calendar days of the change– Change in measurement of program (e.g., clock hours

to credit hours or from semester hours to quarter hours)

– Decrease in level of program offering (e.g., drops graduate programs)

– Person’s ability to substantially affect actions of school if person did not previously have this ability


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• All schools must report the following information within 10 calendar days of the change– Change in financial aid administrator– Closure of branch campus or additional

location– Governance of a public institution

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• Additional reporting by school owned by publicly traded corporations:– Report any change in person’s ability to

substantially affect the actions of the institution if that person did not previously have this ability

– Must report when it notifies accrediting agency but no later than 10 days after institution learns of change

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Reporting ChangesChanges to GE Program - effective July 2012• Reporting not required for 2011-2012 award year

34 CFR 668.6(a)-repayment rate & debt-to-income metric

eliminated-submission of corrections to previously reported information is voluntary-web-page disclosures are still required per 668.6(b)

• 90-day notice not required to offer new GE programs. 34 CFR 668.10(c) and 668.20-approval still required based on regulations prior to July 1, 2011 and PPA agreement

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Program IntegrityWhy is it Important?

• Department of Education and schools have a fiduciary responsibility to taxpayers

• Strong controls help ensure continued public trust and continued funding


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Program IntegrityHow Does Your School Contribute?

• Establish strong controls

• Have written policies and procedures

• Implement policies and procedures

• Review prior audits or program review reports

• Maintain well-organized and documented files

• Involve all major offices (admissions, registrar, placement, business, student affairs)

• Reconcile regularly• Attend training regularly


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Program Integrity

• School Participation Teams review school information and determine compliance or need for program review– Annual financial statements and

compliance audits– Other databases – Guaranty Agency program reviews– Student complaints


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Program IntegrityInstitutional Self-Assessment

• Use FSA Assessments– Link from http://ifap.ed.gov under “Tools for Schools”– Ask for technical assistance from your

School Participation Team


http://ifap.ed.gov/

http://ifap.ed.gov/

QUESTIONS?

CONTACT INFORMATION:

Nautochia Webb [email protected]

Customer Service: FSA is committed to providing the best possible customer service. Help us, help you! Please

provide any feedback on this training at:http://s.zoomerang.com/s/Nautochia_Webb_Workshop

Feedback on Training can also be shared with:Annmarie Weisman, Eastern Region Supervisor

[email protected]

mailto:[email protected]

http://s.zoomerang.com/s/Nautochia_Webb_Workshop

http://s.zoomerang.com/s/Nautochia_Webb_Workshop

mailto:[email protected]

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