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
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