Presented by:
Jamie Morley, Ph.D.
Spring Zutes
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Satisfactory Progress
ATB
Equivalent to HS Diploma
Verification of High School Graduation
90/10
Definition of Credit Hour and course retakes
Department of Education Approval for New Programs
Gainful Employment Disclosure Requirements
Title IV Consumerism Requirements
Top Audit, Program Review and Accreditation findings
A butterfly means that there is material or a form available at
www.educationconsultingsolutions.com for free download.
Earn one eyeball by asking a question or sharing an ah-ha moment!
Satisfactory Academic Progress (SAP)
New rules governing SAP are much more friendly to our students, but the
requirements of policy development and the consistent application of the
policy are more rigorous.
1. Financial Aid Warning is the original “probation” and is only available to schools
who measure progress by payment period.
2. Financial Aid Probation requires the student to file an appeal on the basis of
injury or illness, the death of a relative, or other special circumstances. The
policy must describe the information the student must submit to support the
appeal, including why the student failed to make satisfactory academic progress, and
what may have changed in the student’s situation that will allow the student to
demonstrate SAP at the next evaluation.
3. Allowance for an Individual Academic Plan provides the opportunity for a
student to continue in a probationary status up through program completion.
Ability-To-Benefit (ATB) test
Effective with the 2012-2013 award year, new students who do not have a high
school diploma, or an equivalent such as a GED, and who did not complete
secondary school in a homeschool setting are not eligible for Title IV funds. Such
students can no longer become eligible by passing an approved “ability-to-benefit”
test or by satisfactorily completing at least six credit hours or 225 clock hours of
college work that is applicable to a degree or certificate offered by the student’s
postsecondary institution.
However, students who were enrolled in an eligible educational program of study
before July 1, 2012 may continue to be considered Title IV eligible under either the
ATB test or credit hour standards.
Equivalents to a high school diploma (600.2)
The Department recognizes several equivalents to a high school diploma:
• A GED;
• A certificate demonstrating that the student has passed a state-authorized
examination (for example, the California High School Proficiency Exam) that
the state recognizes as the equivalent of a high school diploma;
• An academic transcript of a student who has successfully completed at
least a two-year program that is acceptable for full credit toward a
bachelor’s degree; or
• For a student who enrolls in a program that leads at least to an
associate’s degree or its equivalent, before completing high school, a
transcript indicating the student has excelled in high school. The student
must no longer be enrolled in high school and must satisfy your school’s
written policy for admitting such students.
Verification of High School Graduation
The Chicken and the Egg: Attestation and Validation
Final regulations published on October 29, 2010 (75 FR 66832), require institutions to
develop and apply procedures to evaluate the validity of a student’s high school
diploma if the institution or the Department has reason to believe that the diploma
is not valid or was not obtained from an entity that provides secondary school
education (34 CFR 668.16(p)).
When would an institution have reason to believe that there is an issue with the
student’s high school diploma?
ED tells you
The financial aid office knows there is a problem
Another office at the institution, such as admissions, has identified an
issue
Sample policy
Verification of High School Graduation
A student may self-certify on the FAFSA that he has received a
high school diploma or GED or that he has completed secondary
school through homeschooling as defined by state law. If a
student indicates that he has a diploma or GED, your school isn’t
required to ask for a copy (except as noted below), but if your
school requires a diploma for admission, then you must rely on
that copy of the diploma or GED and not on the student’s
certification alone.
90/10….and talk of 85/15
Two consecutive years and you are branded ineligible!
What are some options?
• Purchase a non eligible title IV Schools so that their revenue can be added to
yours.
• Partnering with extern sites – you pay them to accept your students and they
contribute to the students tuition expense.
• Partner with Employers for tuition assistance in continuing education
opportunities.
• Offer short programs or seminars to increase non title IV revenue.
• Hold your deposits of Title IV towards the end of the year knowing at minimum
you will be violating cash management regulations.
• Scholarships….we haven’t heard of any that are school based that pass the test.
Definition of Credit Hour
Credit hour (600.2): Except as provided in 34 CFR 668.8(k) and (l), a credit hour is
an amount of work represented in intended learning outcomes and verified by
evidence of student achievement that is an institutionally established
equivalency that reasonably approximates not less than—
(1) One hour of classroom or direct faculty instruction and a minimum of
two hours of out of class student work each week for approximately
fifteen weeks for one semester or trimester hour of credit, or ten to
twelve weeks for one quarter hour of credit, or the equivalent amount of
work over a different amount of time; or
(2) At least an equivalent amount of work as required in paragraph (1) of
this definition for other academic activities as established by the
institution including laboratory work, internships, practical, studio work,
and other academic work leading to the award of credit hours.
Gainful Employment Regulations
On June 30, 2012, a U.S. District Court vacated most of the gainful employment regulations
Court’s decision was based on ED’s rationale for setting the Repayment Rate failure
threshold. Because of the interrelationship of the gainful employment requirements, the
Court vacated most of the gainful employment regulations – GE Metrics, GE Reporting,
Adding New GE Programs. Court left in place GE Disclosure requirements.
ED Statement in Response to Decision:
"The court upheld our authority to regulate career college programs while urging a clearer
rationale for standards around repayment rates. We are reviewing our legal and policy
options to move forward in a way that best protects students and taxpayers while advancing
our national goal of helping more Americans get the skills they need to compete in the
global economy."
Title IV Consumerism Requirements
Why recreate the wheel! USDOE did a great job creating templates for each of the
following requirements:
Institutional and Financial Assistance Information for Students
Drug & Alcohol Prevention
Student Right-to-Know Act
Clery/Campus Security Act
FERPA
Safeguarding Customer Information
Misrepresentation
Loan Disclosures
And ECS created a checklist to keep you on track:
Title IV Consumer Information Checklist
BEWARE: The number of Program Reviews being conducted are
on the rise
Message: Be Proactive!
When we asked a Program Review Specialist with the Department of
Education what we should communicate to schools, the answer was:
“Ensure the processes and procedures are in place for problem
resolution. Failure to resolve student issues at the school level is
an express invitation for a program review.”
Top Financial Aid Program Review Findings
Identified at the July 2012 DE Conference
1. R2T4 calculation errors
2. Verification violations
3. Entrance/Exit counseling deficiencies
4. Crime awareness requirements not met
5. Student credit balance deficiencies
6. Satisfactory Academic Progress policy not adequately developed/monitored
7. R2T4 funds made late
8. Pell Grant overpayments/ underpayments
9. Account records inadequate/not reconciled
10. Inaccurate recordkeeping
11. Lack of administrative capability
12. Information in student files missing/ inconsistent
Findings on Both Audit and Program Review Lists
July 2012
1. R2T4 calculation errors
2. R2T4 funds made late
3. Pell Grant overpayment/underpayment
4. Verification violations
5. Student credit balance deficiencies
6. Entrance/Exit counseling deficiencies
Retaking Courses
The new regulations related to retaking coursework only apply to
the definition of full-time for undergraduate students
You may include any repetition of the program in a student's
enrollment status for a term as long as the student has never
passed the course. If the student passes the course, you may
include one repetition after passing the course. Any second or
subsequent repetition of the passed course may not be included
in the student's enrollment status for purposes of the title IV, HEA,
programs.
Thank you for your time!
QUESTIONS-?