Maintaining Your Institutional Eligibility

1. Session 27 Maintaining Your Institutional Eligibility Kai Kimbrough and Renée Schultz | Nov.-Dec. 2017 U.S. Department of Education 2017 FSA Training Conference for Financial Aid Professionals

2. School A Eligible for Financial Aid School B Not Eligible for Financial Aid These students may get financial aid IF they are eligible These students CAN NOT get financial aid even if they are eligible

3. Institutional Eligibility • Eligibility Requirements • Eligibility Documents • Steps for Maintaining Eligibility • Keep Up With New Requirements • Apply for Recertification Timely • Report Changes Timely • New Educational Programs • New Locations • Application Process

4. Eligibility Requirements

5. Eligibility Requirements Per 34 CFR Part 600 Institutional Eligibility, an institution must: • Be Legally Authorized by a State as a Postsecondary Institution • Be Accredited • Provide an Eligible Program • Admit as regular students only individuals with a high school diploma or its recognized equivalent or individuals beyond the age of compulsory school attendance in the state where the institution is located

6. Eligibility Requirements • Provide no more than 50% of its courses by correspondence • Have less than 50% of its regular students attend by correspondence • Have no more than 25% of its regular students be incarcerated • Have no bankruptcy, crime with Title IV, or fraud by school or owner

7. Eligibility Documents

8. Eligibility Documents • Program Participation Agreement (PPA) • Eligibility Certification Approval Report (ECAR)

9. Eligibility Documents Refer to signed copy on file at your school: • Program Participation Agreement (PPA) • Any PPA Amendments Access at eligcert.ed.gov: • User Name = ED + 8-digit OPE ID Number • Password = ED + 9-digit Taxpayer ID Number • Eligibility and Certification Report (ECAR)

10. Eligibility Documents The Program Participation Agreement or PPA • Is the contract between the institution and the Department which outlines regulations that the school is required to follow • Any process where a new PPA is generated by the Department, the current one is void • Your countersigned PPA must be kept on file by the school, along with a copy of the most recent Eligibility Certification Approval Report or ECAR

11. Eligibility Documents • The Eligibility Certification Approval Report or ECAR • A snapshot of the institution’s participation, programs, location, officials, etc. • A current copy of the ECAR must be kept on file by the school (accessible for viewing/printing at www.eligcert.ed.gov)

12. Steps for Maintaining Eligibility

13. Steps for Maintaining Eligibility: Keep Up With New Requirements • All new regulations effective as of the current CFR • Watch for New Requirements in: • Dear Colleague Letters, • Electronic Announcements and; • Information Pages at: ifap.ed.gov

14. Steps for Maintaining Eligibility Apply for Recertification Timely • Refer to PPA for Reapplication Date: • Reminders will be sent • Submit complete Application by Reapplication Date to ensure continued approval beyond Expiration Date

15. Steps for Maintaining Eligibility Report Changes Timely Report the following “acknowledgement” changes within 10 days (no need to wait for approval): • Change to the name of the institution or location • Address change for main or additional location • Change from or to clock-hours or credit-hours • Decrease in the level of educational programs • Change to the institution’s third-party servicer(s)

16. Steps for Maintaining Eligibility Report Changes Timely More “acknowledgement” changes to report within 10 days (no need to wait for approval): • Change to reported President of institution • Change to reported Chief Financial Officer of institution • Change to reported Financial Aid Director of institution • Closure of a previously approved location • New person/entity acquires 25% or greater ownership in institution without a change in control

17. Steps for Maintaining Eligibility Report Changes Timely More “acknowledgement” changes to report within 10 days (no need to wait for approval): • New or significantly modified contract with a third-party servicer • Termination of a contract with a third-party servicer • Third-party servicer under contract goes out of business or files bankruptcy

18. Steps for Maintaining Eligibility Report Changes Timely Report the following changes which have special reporting requirements: • New locations seeking Title IV eligibility • New educational programs seeking Title IV eligibility • Adding educational program(s) at a higher level than for which you are currently approved • Change in ownership resulting in a change in control • Change in accreditor

19. New Locations

20. Steps for Maintaining Eligibility New Locations • ECAR lists the main location and approved additional locations • Eligibility does not automatically extend to separate locations and extensions • If 50% or more of an educational program is offered at a new location, the school must report the location to ED • In some cases, the school must wait for ED approval

21. Steps for Maintaining Eligibility New Locations • School must wait for approval before disbursing FSA funds if the institution is: • Provisionally certified • On cash monitoring or reimbursement • Acquiring assets of another institution • Subject to a loss of eligibility under 668.188 (default rates), or • Required by ED to receive approval before disbursing FSA funds

22. Steps for Maintaining Eligibility New Locations • School should consult with their School Participation Division if: • Location was a facility of another institution that has closed • School is providing a teach-out of a closing school at the closing school’s location

23. Steps for Maintaining Eligibility New Locations • ED will review applications for all reported locations to: • Ensure location meets eligibility requirements • Evaluate school’s administrative and financial capability (if location approval is required) • If approved, school may disburse/continue to disburse funds after receiving Approval Letter • If not approved, school is liable for disbursements made

24. Steps for Maintaining Eligibility New Locations • Location Eligibility Requirements: • Accreditor and state/foreign government approval is appropriate • Street address provided • If located at the site of a formerly eligible location, meets all requirements to become an eligible location of another institution • If located at the site of a currently eligible location, relationship between the two institutions and/or if the location is changing affiliation

25. New Educational Programs

26. Steps for Maintaining Eligibility New Educational Programs • ECAR lists the eligible program levels • ECAR lists the eligible programs approved by ED • Eligibility now may automatically extend to new programs at fully certified institutions • Fully certified institutions may make a self-determination of program eligibility, report within 10 days and may disburse funds after reporting • Provisionally approved institutions, must report and obtain approval before disbursing funds to enrolled students

27. Steps for Maintaining Eligibility New Educational Programs • Generally, a school with a fully certified PPA may determine program eligibility and disburse funds to enrolled students without prior ED approval when the following conditions are met: • The added program leads to an associate, bachelor, professional, or graduate degree; the school has already been approved to offer programs at that level; and the school’s PPA does not require approval of the program; or

28. Steps for Maintaining Eligibility New Educational Programs • The added program is a graduate or undergraduate program for students that already have an associate degree or higher, and is at least: • 10-weeks (of instructional time) in length AND • 8 semester hours, 12 quarter hours, or 600 clock-hours AND that • Prepares students for gainful employment in the same or related recognized occupation as an educational program that the Department already has designated as an eligible program at the school • (“Recognized Occupation” as defined in 34 CFR 600.2)

29. Steps for Maintaining Eligibility New Educational Programs • The added program is an undergraduate program for students that have not yet completed an associate degree, and is at least: • 15-weeks (of instructional time) in length AND • 16 semester hours, 24 quarter hours, or 600 clock-hours AND that • Prepares students for gainful employment in the same or related recognized occupation as an educational program that the Department already has designated as an eligible program at the school • (“Recognized Occupation” as defined in 34 CFR 600.2)

30. Steps for Maintaining Eligibility New Educational Programs • If a school makes a self-determination: • It must have received the required state and accrediting agency approvals before making the decision • Each program must meet all required GE Disclosure, Reporting, and Certification requirements • Must report the “self-certified” program(s) to the Department within 10 days, per 34 C.F.R. §600.21 • It is liable for FSA funds disbursed if self-determination is found to be incorrect

31. Steps for Maintaining Eligibility New Educational Programs • Schools must report and receive approval for: • Programs added by provisionally certified schools (per PPA) • Programs under 600 clock-hours (short term programs) • Direct Assessment Programs • A Comprehensive Transition and Postsecondary (CTP) Program

32. Steps for Maintaining Eligibility New Educational Programs • ED will review applications for all reported educational programs to: • Ensure reported programs meet eligibility requirements • Evaluate school’s administrative and financial capability (if program approval is required) • If approved, school may disburse/continue to disburse funds after receiving Approval Letter • If not approved, school is liable for disbursements made

33. Steps for Maintaining Eligibility New Educational Programs • Program Eligibility Requirements: • Accreditor and state approval matches E-App (name and program length) • CIP Code consistent with name of program • Leads to a recognized occupation (SOC code) where required • Meets minimum weeks and clock- or credit-hours • Meets clock to credit conversion where required

34. Steps for Maintaining Eligibility New Educational Programs • Meets placement and completion rates, and has been in existence for one year, if short term (less than 600 hours) • Does not exceed by more than 50% the minimum number of clock-hours established by the state for training in the occupation for which the program prepares students • As of 7/1/2016, regulations have changed permitting programs, which are required by the state to be based on clock-hours, to now allow aid to be calculated based on credit-hours, if the school chooses

35. Steps for Maintaining Eligibility New Educational Programs • Meets special requirements if Direct Assessment Program - See DCL GEN-13-10 • Meets special requirements if Comprehensive Transition and Postsecondary (CTP) Program - See DCL GEN-11-01

36. Application Process

37. Steps for Maintaining Eligibility Application Process • Application for Approval to Participate in the Federal Student Financial Aid Programs • Located at www.eligcert.ed.gov • Is where you apply for Recertification • Is the application where a school reports all types of changes regarding its eligibility, including, change of officials, additional locations, and educational programs

38. Steps for Maintaining Eligibility Application Process • Use E-App to submit changes and updates • www.eligcert.ed.gov • User Name = ED + 8-digit OPE ID Number • Password = ED + 9-digit Taxpayer ID Number • In Section A, Question 1, select “Update Information” box • Select the specific updates from the pick list; if purpose doesn’t appear in list, select “Other,” and type the purpose in the space provided

39. Steps for Maintaining Eligibility Application Process • When a reportable change occurs, school must notify ED: • Via E-App • Within identified time frame • School must send to ED: • Copies of the approval for the change • Any required documentation • Section L of the E-App containing original signature of the appropriate person

40. Steps for Maintaining Eligibility Application Process • Complete the appropriate questions for the change(s), and Section L of the E-App • Skip Logic will take you to appropriate sections based on the application purpose selected • To provide additional information use Section K, Question 69 • Mail the signature page (Section L) and the supporting documents listed in Section M to the address indicated

41. Steps for Maintaining Eligibility Application Process • Features of the E-App • Pre-populated questions • Help text • Edit checks • Status messages • Status check • Click on “Application Status” in the left margin

42. Steps for Maintaining Eligibility Application Process • If Reported Changes Acknowledged/Approved: • Email provides instructions to view Approval/Acknowledgement Letter • Print and review Approval/Acknowledgement Letter and ECAR • Begin/Continue making disbursements • If Reported Changes Not Approved: • Denial letter explains reason(s) • May request reconsideration • Arrange to pay liabilities if disbursements made

43. Steps for Maintaining Eligibility Application Process • Avoid Common Mistakes • Don’t forget to click “SUBMIT” • Don’t forget to send in the signed signature page • Don’t forget to send in copies of the state and accreditation approval letters • If reporting more than one update on the E-App, check a box for EACH purpose • If updates are reported on a Recertification Application, select only Recertification as the purpose

44. SCHOOL ELIGIBILITY SERVICE GROUP (SESG)Ron Bennett - Director, School Eligibility Service Group, Washington, DC (202) 377-3181School Eligibility Service Group General Number: (202) 377-3173 or e-mail: CaseTeams@ed.gov . Or call the appropriate School Participation Division manager below for information and guidance on audit resolution, financial analysis, program reviews, school and program eligibility/recertification, and school closure information. Atlanta School Participation Division Alabama, Florida, Georgia, Mississippi, North Carolina, South Carolina Christopher Miller, Director (404) 974-9297 Vanessa Dillard – Atlanta (404) 974-9418 Dallas School Participation Division Arkansas, Louisiana, New Mexico, Oklahoma, Texas Cynthia Thornton, Director (214) 661-9457 Jesus Moya – Dallas (214) 661-9472 Kim Peeler – Dallas (214) 661-9471 Kansas City School Participation Division Iowa, Kansas, Kentucky, Missouri, Nebraska, Tennessee Ralph LoBosco, Director (816) 268-0440Dvak Corwin – Kansas City (816) 268-0420 Jan Brandow − Kansas City (816) 268-0409 Angie Beam – Kansas City (816) 268 - 0534 New York/Boston School Participation Division Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont, New Jersey, New York, Puerto Rico, Virgin Islands Betty Coughlin, Director (646) 428-3737 Tracy Nave – Boston (617) 289-0145Jeremy Early – Washington, DC (202) 377-3620Chris Curry – New York (646) 428-3738 Philadelphia School Participation Division District of Columbia, Delaware, Maryland, Pennsylvania, Virginia, West Virginia Nancy Gifford, Director (215) 656-6436 Steven Marcucio– Philadelphia (215) 656-5554 Sherrie Bell– Washington, DC (202) 377-3349 Multi-Regional and Foreign Schools Participation Division Michael Frola, Director − Washington, DC (202) 377-3364 Joseph Smith − Washington, DC (202) 377-4321 Mark Busskohl – Washington, DC (202) 377-4572 Michelle Allred – Dallas (214) 661-9466 Julie Arthur – Seattle (206) 615-2232 Chicago/DenverSchool Participation Division Illinois, Minnesota, Ohio, Wisconsin, Indiana, Colorado, Michigan, Montana, North Dakota, South Dakota, Utah, Wyoming Douglas Parrott, Director (312) 730-1532 Brenda Yette – Chicago (312) 730-1522 Sarah Adams − (312) 730-1514 San Francisco/Seattle School Participation Division American Samoa, Arizona, California, Guam, Hawaii, Nevada, Palau, Marshall Islands, North Marianas, State of Micronesia, Alaska, Idaho, Oregon, Washington Martina Fernandez-Rosario, Director (415) 486-5605 Gayle Palumbo − San Francisco (415) 486-5614 or Seattle (206) 615-3699 Dyon Toney − Washington, DC (202) 377-3639 Erik Fosker – San Francisco (415) 486-5606

45. Session Contacts: Your feedback and comments are appreciated. Kai Kimbrough – Washington, DC Renée Schultz – San Francisco, CA • Phone: 202-377-3173 • Email: CaseTeams@ed.gov

46. QUESTIONS?