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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:
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Written ArrangementsStudy Abroad/Exchange/Internships Presented by Betsy Mayotte and Cara Piperni ANZFAA Melbourne, Vic. October, 2014
Schema • The What • The How • Resources
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”.
practices The How • 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
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