Transcript Document

Institutional Eligibility
Nautochia Webb
U.S. Department of Education
Training & Information Services Division
Eligible Institution
Eligibility 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 Programs
Institution 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
Apply to Participate
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Eligible Programs
Proprietary 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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Eligible Programs
Proprietary 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:
– 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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Eligible Programs
Proprietary Institution of Higher Education and
Postsecondary Vocational Institution
• 34 CFR 668.8(d)
• Provides program leading to a
baccalaureate degree in liberal arts
– Must be a program offered since 1/1/2009
– Must have accreditation since 10/1/2007 or
earlier
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Eligible Institution
Admissions 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 Institution
Eligibility 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
Apply to Participate
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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
Apply to Participate
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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 years
– For 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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Apply to Participate
Eligible Institution
Additional 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
Apply to Participate
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Eligible Institution
Additional Eligibility Requirements
• 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 fouryear programs
• must apply for waiver through electronic
application prior to exceeding limits
Apply to Participate
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Eligible Institution
Additional Eligibility Requirements
Applies to Periods Prior to 7/1/2012:
• 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
Apply to Participate
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Eligible Institution
Additional Eligibility Requirements
• Bankruptcy
– School is not eligible if the school or an
affiliate of school files for bankruptcy
Apply to Participate
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Eligible Institution
Additional Eligibility Requirements
• 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
Apply to Participate
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General Participation Requirements
• Voter registration
HEA 487(a)(23) and 668.14(d)
• Constitution Day (September 17th)
FR dated May 24, 2005 and May 31, 2005
• Availability of GED program
668.14(b)(13)
• Drug-Free Workplace and drug abuse
prevention program
668.14(c)
Apply to Participate
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General Participation Requirements
• Civil Rights and Privacy requirements
99.31(a)(13) and (14)
• Notify ED of contracts with servicers
668.25(e)
• Incentive compensation
668.14(b)(22)
Apply to Participate
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General Participation Requirements
• 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
Apply to Participate
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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
Apply to Participate
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Financial Responsibility
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
Apply to Participate
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Financial Statements
• Submit 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
Apply to Participate
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Administrative Capability
34 CFR 668.16
• 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
Apply to Participate
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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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Apply to Participate
Reporting Changes
Apply and Wait for Approval
(34 CFR 600.20)
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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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Apply to Participate
Reporting Changes
Apply and Wait for Approval
(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
Apply to Participate
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Reporting Changes
Report 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
Apply to Participate
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Reporting Changes
Report and “Go” (34 CFR 600.21)
• 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
Apply to Participate
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Reporting Changes
Report and “Go” (34 CFR 600.21)
• 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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Reporting Changes
Report and “Go” (34 CFR 600.21)
• 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 Changes
Changes 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 Integrity
Why is it Important?
• Department of Education and schools
have a fiduciary responsibility to
taxpayers
• Strong controls help ensure continued
public trust and continued funding
Apply to Participate
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Program Integrity
How Does Your School Contribute?
• Establish strong
controls
• Have written policies
and procedures
• Implement policies and
procedures
• Review prior audits or
program review reports
Apply to Participate
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• Maintain well-organized
and documented files
• Involve all major offices
(admissions, registrar,
placement, business,
student affairs)
• Reconcile regularly
• Attend training regularly
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
Apply to Participate
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Program Integrity
Institutional Self-Assessment
• Use FSA Assessments
– Link from http://ifap.ed.gov under
“Tools for Schools”
– Ask for technical assistance from your
School Participation Team
Apply to Participate
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QUESTIONS?
CONTACT INFORMATION:
Nautochia Webb 646-428-3758
[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]