Written Arrangements
Study Abroad/Exchange/Internships
Presented by
Betsy Mayotte
and
Cara Piperni
ANZFAA
Melbourne, 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 recertification process
Bilateral Exchange Agreements
• 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
THANK YOU!
QUESTIONS?