Institutional Eligibility Nautochia Webb U.S. Department of Education Training & Information Services Division

2 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

3 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

4 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

5 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 clock hours, 70% completion rate and 70% placement rate in related job fields; in existence for one year eligible for Direct Loans only

6 6 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

7 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

8 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

9 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

10 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 (b)(16), (c) Apply to Participate

11 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

12 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 four- year programs must apply for waiver through electronic application prior to exceeding limits Apply to Participate

13 Eligible Institution Additional Eligibility Requirements 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 Applies to Periods Prior to 7/1/2012:

14 Eligible Institution Additional Eligibility Requirements Bankruptcy –School is not eligible if the school or an affiliate of school files for bankruptcy Apply to Participate

15 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

16 General Participation Requirements Voter registration HEA 487(a)(23) and (d) Constitution Day (September 17 th ) FR dated May 24, 2005 and May 31, 2005 Availability of GED program (b)(13) Drug-Free Workplace and drug abuse prevention program (c) Apply to Participate

17 General Participation Requirements Civil Rights and Privacy requirements 99.31(a)(13) and (14) Notify ED of contracts with servicers (e) Incentive compensation (b)(22) Apply to Participate

18 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) Apply to Participate

19 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

20 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 Apply to Participate

21 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

22 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 Apply to Participate

23 ) Reporting Changes Apply and Wait for Approval (34 CFR ) 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 Apply to Participate

24 ) Reporting Changes Apply and Wait for Approval (34 CFR ) 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 ( clock hour) programs Apply to Participate

25 ) Reporting Changes Apply and Wait for Approval (34 CFR ) 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

26 Reporting Changes Report and “Go” (34 CFR ) 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 § Apply to Participate

27 ) Reporting Changes Report and “Go” (34 CFR ) 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

28 Reporting Changes Report and “Go” (34 CFR ) 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

29 Reporting Changes Report and “Go” (34 CFR ) 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

30 Reporting Changes Changes to GE Program - effective July 2012 Reporting not required for 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 (c) and approval still required based on regulations prior to July 1, 2011 and PPA agreement

31 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

32 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 Maintain well-organized and documented files Involve all major offices (admissions, registrar, placement, business, student affairs) Reconcile regularly Attend training regularly Apply to Participate

33 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

34 Program Integrity Institutional Self-Assessment Use FSA Assessments –Link from underhttp://ifap.ed.gov “Tools for Schools” –Ask for technical assistance from your School Participation Team Apply to Participate

QUESTIONS?

CONTACT INFORMATION: Nautochia Webb Customer Service: FSA is committed to providing the best possible customer service. Help us, help you! Please provide any feedback on this training at: Feedback on Training can also be shared with: Annmarie Weisman, Eastern Region Supervisor CONTACT INFORMATION: Nautochia Webb Customer Service: FSA is committed to providing the best possible customer service. Help us, help you! Please provide any feedback on this training at: Feedback on Training can also be shared with: Annmarie Weisman, Eastern Region Supervisor