Written ArrangementsStudy Abroad/Exchange/Internships

Presented byBetsy Mayotte

and

Cara Piperni

ANZFAAMelbourne, Vic.October, 2014

Schema

• The What

• The How

• Resources

The Why

THE WHAT

Definitions

• Home School:– The school where the student is enrolled

in a degree or certificate program

• Host School:– The school where the student is taking

part of her degree/certificate requirements through a contractual or consortium arrangement with the home school

Definitions• Written arrangement– Assumption is that home school found

host school’s academics equal to it’s own– Home school must accept credit of host

school• Unless grade not acceptable to home school

– Can be indefinite unless written for particular student or group or terms change

– International schools cannot have WA with US school for Title IV purposes

Definitions

• Written arrangement

– Does not include affiliations for international nursing, veterinary and medical schools

Definitions

• Written arrangement–Must provide enrolled and prospective

students:• Description of written arrangement• Defined portion of program not being

provided by home school• Name and location of host school• Method of delivery of that part of program• Estimated additional costs students may

incur

Consortium Agreement

• Written agreement between two or more eligible schools where host school offers part of the credits needed for the home to school to grant the degree or certificate

Contractual Arrangement

• Agreement between an eligible and an ineligible school. International schools may not participate in contractual arrangements for Title IV purposes

“Stair-casing”

• Articulation agreements between schools where student take first credential at school A, which is then applied to school B as preliminary credits needed for a second credential.

• Allowed between eligible foreign schools other than US schools.

Enrollment Reporting

Reporting is the responsibility of the “Home School”

• The Home School is the school where the student is enrolled for the purpose of obtaining a degree or certificate.

• Enrollment status must include the coursework taken at the “host school”.

THE HOW

practices• Independent Study Away• Bilateral Exchange Agreements• Internships

Independent Study Away

• Incoming = we might sign– McGill host to student registered at another school– Consortium agreement with the least risk involved

• We insist any funding is awarded by home school so not part of our USDL awarding process

• Out of scope of our compliance audit and cohort default rate

• We confirm only our Title IV eligibility, student cost and enrolment status, and agree not to disburse any funding

– Only for individual student/situation, never a blanket consortium agreement.

Independent Study Away• Outgoing = we never sign

– McGill student who will pay fees at host institution and return with credits towards their degree

– We never sign consortium agreements nor give USDL because of:• Reliance on host school for our disbursing compliance• Host school Title IV eligibility could change; can never

verify program of study eligibility nor method of teaching (distance ed)

• High frequency enrolment reporting to NSLDS• Not listed in our transcript to track course load• Timeliness of critical information doesn’t meet FSA

deadlines• SAP! While grades not included, does impact

quantitative component (% credits earned vs. attempted)

Bilateral Exchange Agreements

• Falls under FSA manual definition of ‘study-abroad program’

• Partnership with selective schools of equivalent prestige

• McGill student registered and pays tuition to McGill

• We’ve never disbursed USDL if student going back to U.S. for exchange

• The subject of DoE scrutiny during re-certification process

• DoE asked for a copy of every bi-lateral exchange agreement

• We also provided– Our evaluation criteria for evaluating potential

exchange partnerships– Overview of clauses we insist upon

• Were verbally told that we cannot draw down Title IV funds for that exchange term if with an ineligible school

• DoE admitted published list of eligible schools is not updated and is a constant moving target

Bilateral Exchange Agreements

Bilateral Exchange Agreements• Going forward– Reviewing list of exchange partner schools once

per year for Title IV eligibility, and publishing as such

– Adding clause to agreement template, putting onus on partner institution to announce any changes in Title IV status

– Negotiated with Registrar to have exchange locations identified for all US students, as not indicated on transcript

– Updating website, student communications– Preparing statement for US students to use/sign

to lodge complaint with their representative re: diminished opportunity for Americans with normal means.

Internships

• Our required internships were scrutinized during re-certification process

• Internships subject to written arrangements for related program to remain eligible. Exception:– If subject to oversight by an accreditor or

government entity for the program, AND– If students are monitored by qualified

institutional personnel

• McGill was successful in being recognized for this exception

THANK YOU!

QUESTIONS?