Program Integrity’s Greatest Hits

1. Program Integrity’sGreatest Hits Presenters: Mary Heid and Matt McCreary

2. Final Rules • Published October 29, 2010 • Most provisions effective July 1, 2011

3. #9 – High School Diploma#8 – incentive compensation#7 – Written Agreements#6 – Verification/IRS Datamatch#5 – Title IV Disbursement#4 – Ability to Benefit#3– Credit hours/clock hours#2 – Repeated Coursework#1 – Return to title IV

4. High School Diploma • Must develop and follow procedures to evaluatevalidity • 2011-12 newquestion on FAFSA §668.16(p)

5. High School Diploma • Documentation to validate • Student-certification is NOT sufficient

6. #9 – High School Diploma#8 – incentive compensation#7 – Written Agreements#6 – Verification/IRS Datamatch#5 – Title IV Disbursement#4 – Ability to Benefit#3– Credit hours/clock hours#2 – Repeated Coursework#1 – Return to title IV

7. Incentive Compensation Safe Harbors Removed

8. Definitions Commission, bonus, or other incentive payment Securing enrollments or the award of financial aid Enrollment Entity/person engaged in recruitment, admission or financial aid awards Incentive Compensation §668.14 (b)(22)

9. Incentive Compensation • Two-part test • Is payment a commission, bonus, or other incentive payment given to a person or entity for services rendered? (2) Is the commission, bonus, or other incentive payment based in any part, directly or indirectly upon success of securing enrollments or awarding financial aid? DCL GEN-11-05

10. Incentive Compensation If YES to both questions, payment is prohibited DCL GEN 11-05

11. #9 – High School Diploma#8 – incentive compensation#7 – Written Agreements#6 – Verification/IRS Datamatch#5 – Title IV Disbursement#4 – Ability to Benefit#3– Credit hours/clock hours#2 – Repeated Coursework#1 – Return to title IV

12. If 2 or more schools are controlled by the same individual, partnership or corporation Degree/certificate-granting school must provide > 50% of program Does NOT apply to public or nonprofit institutions Written Agreements § 668.5(a)

13. Written Agreements • Required disclosures to prospective and enrolled students § 668.5(e) and 668.43(a)(12)

14. #9 – High School Diploma#8 – incentive compensation#7 – Written Agreements#6 – Verification/ IRS Datamatch#5 – Title IV Disbursement#4 – Ability to Benefit#3– Credit hours/clock hours#2 – Repeated Coursework#1 – Return to title IV

15. FY 10-11 and 11-12 IRS-retrieved information is acceptable verification documentation; IRS Request Flag will be set at “2” Verification and IRS Datamatch § 668.57(a)

16. #9 – High School Diploma#8 – incentive compensation#7 – Written Agreements#6 – Verification/IRS Datamatch#5 – Title IV Disbursement#4 – Ability to Benefit#3– Credit hours/Clock hours#2 – Repeated Coursework#1 – Return to title IV

17. Title IV Disbursement • School must provide way for Pell-eligible students to purchase or obtain required books/supplies • Options for disbursement • Process/Disbursement Disclosure • Right to opt-out § 668.164(i)

18. If student uses method provided by school, student is considered to have authorized the use of Title IV Disbursement for Books & Supplies § 668.164(i)

19. #9 – High School Diploma#8 – incentive compensation#7 – Written Agreements#6 – Verification/IRS Datamatch#5 – Title IV Disbursement#4 – Ability to Benefit#3– Credit hours/clock hours#2 – Repeated Coursework#1 – Return to title IV

20. Ability to Benefit • Students meet ATB if he/she completes: • 6 semester, trimester or quarter credit hours • 225 clock hours • Coursework may be part of any eligible program at that school; failed classes do not count • Eligibility is not retroactive to any payment period or module taken to complete those hours § 668.32(e)(5)

21. Ability to Benefit • Definitions • Test • Test Administrator • Independent Test Administrator • Assessment Center • Test Publisher • Individual with a Disability § 668.142

22. Ability to Benefit • Passing scores remain one standard deviation below the mean, but now it must be based on a sample of high school graduates in the United States who took the test within 3 years of submission for approval

23. Ability to Benefit • Agreements with the assessment center include: • Notifying the test administrator, ED and schools immediately when a test administrator is decertified • Reviewing test results of a decertified test administrator immediately and notifying affected schools and students

24. Ability to Benefit • School must keep records of: • Each individual who took ATB test • Name/address of the test administrator • Any identifier assigned to the test administrator by the test publisher or State • Documentation of an individual’s disability and testing accommodations if required/requested

25. Ability to Benefit • A school is liable for Title IV aid disbursed if: • Test was not independently administered • School or one of its employees compromised the testing process • School is unable to document the student’s passing score on an approved test.

26. #9 – High School Diploma#8 – incentive compensation#7 – Written Agreements#6 – Verification/IRS Datamatch#5 – Title IV Disbursement#4 – Ability to Benefit#3– Credit hours/ clock hours#2 – Repeated Coursework#1 – Return to title IV

27. Credit Hours/Clock Hours • Definition • Credit Hour DCL GEN-11-06

28. Credit Hours/Clock Hours • Credit or Clock Hours? • Undergraduate, non-degree credit hour programs MUST use clock-to-credit hour conversion unless each course in the program is fully acceptable to a degree program at the institution • Institution must be able to demonstrate that students enroll in AND graduate from that degree program

29. Credit Hours/Clock Hours • NEW Conversion Rate • 1 semester or trimester credit hour is equal to at least 37.5 clock hours • 1 quarter credit hour is equal to at least 25 clock hours • Options for Implementation • Current Students • New/re-enrolling on/after July 1

30. #9 – High School Diploma#8 – incentive compensation#7 – Written Agreements#6 – Verification/IRS Datamatch#5 – Title IV Disbursement#4 – Ability to Benefit#3– Credit hours/ clock hours#2 – Repeated Coursework#1 – Return to title IV

31. Full-Time Student and Repeated Coursework • Repeated coursework counts towards a student’s Title IV enrollment status in term-based programs • A single repetition of previously-passed coursework is allowed • Repetition of coursework due to the failure of other previous coursework is NOT allowed

32. #9 – High School Diploma#8 – incentive compensation#7 – Written Agreements#6 – Verification/IRS Datamatch#5 – Title IV Disbursement#4 – Ability to Benefit#3– Credit hours/ clock hours#2 – Repeated Coursework#1 – Return to title IV

33. R2T4 and Attendance • Schools are required to take attendance if: • Outside agency requires it • School requires it • School or outside agency has a requirement that can only be met by taking attendance • Attendance at an academically-related activity § 668.22

34. R2T4 and Modules • Module – course or courses in a program that do not span the entire length of the payment period or period of enrollment • Standard term “offered in modules” § 668.22

35. Example: Albert • Freedom University has a semester term-based calendar, that includes two 16-week semesters, in which there are four modules of 4 weeks apiece (A, B, C and D) • Albert enrolls in modules A, B and D. He completes A, but begins and withdraws from B • Albert is a Title IV withdrawal and an R2T4 must be done

36. Example: Albert (part 2) • Because Albert did not complete all the days for which he was enrolled, R2T4 must be done • If Albert gives the school written confirmation that he intends to return for D, an R2T4 is not required • If Albert does not return for D, an R2T4 must be done using his withdrawal date from B

37. R2T4 and Modules • Nonstandard and non-term programs • Clock hour programs • Returning after withdrawal • Calendar days • After Written Confirmation of Return § 668.22

38. R2T4 and Modules • Is my student a withdrawal? • Q#1 - Did the student cease to attend before completing or fail to begin attendance in a course she was scheduled to attend? • Yes. Go to Q#2 • No. Student is not a withdrawal Oct. 29, 2010 Federal Register, p66895-66896

39. R2T4 and Modules • Q#2 – When the student ceased to attend or failed to begin attendance in a scheduled course, was he attending other courses? • Yes. Student is not a withdrawal • No. Go to Q#3 Oct. 29, 2010 Federal Register, p66895-66896

40. R2T4 and Modules • Q#3 – Did she confirm attendance in a later module in the payment/enrollment period (45-day rule, if applicable)? • Yes. Student is not a withdrawal, although Pell may need to be recalculated • No. Student is a withdrawal Oct. 29, 2010 Federal Register, p66895-66896

41. #9 – High School Diploma#8 – incentive compensation#7 – Written Agreements#6 – Verification/IRS Datamatch#5 – Title IV Disbursement#4 – Ability to Benefit#3– Credit hours/ clock hours#2 – Repeated Coursework#1 – Return to title IVOther Topics

42. Satisfactory Academic Progress Misrepresentation State Authorization Gainful Employment Other Topics

43. 2012 Triggers • Verification – July 1, 2012 • Be on the lookout for additional guidance as the trigger date nears

44. Resources – www.ocap.org

45. Questions? Please contact us at pct@ocap.org or 405.234.4432