Maintaining Your Institutional Eligibility

1. Session 34 Maintaining Your Institutional Eligibility Susan Bowder and Arva Thomas | Nov-Dec. 2016 U.S. Department of Education 2016 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

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 • 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

6. Eligibility Documents

7. 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)

8. Steps for Maintaining Eligibility

9. Steps for Maintaining Eligibility: Keep Up With New Requirements • Watch for New Requirements in Dear Colleague Letters and Electronic Announcements at ifap.ed.gov • NSLDS Program-Level Enrollment Reporting • 150% Direct Subsidized Loan Limit: Electronic Announcement #22 • The threshold certifying students with the required program data has now been established at 90 percent, but it may vary (NSLDS Newsletter #49) • Schools who fall below 90% of the portfolio certified with a program will be notified of non-compliance in early 2017 • Schools who do not improve their performance will be referred to FSA Program Compliance for action

10. 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

11. 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)

12. 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

13. 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

14. 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

15. New Locations

16. 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

17. 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

18. 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

19. 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

20. 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

21. New Educational Programs

22. Steps for Maintaining Eligibility New Educational Programs • ECAR lists the eligible program levels • ECAR lists the eligible programs approved by ED • Eligibility does not automatically extend to new programs • In some cases, the school may make a self-determination of program eligibility, disburse funds, and report at next recertification • In some cases, the school must report and obtain approval before disbursing funds to enrolled students

23. Steps for Maintaining Eligibility New Educational Programs • There are three cases in which a school with a fully certified PPA may determine program eligibility and disburse funds to enrolled students without prior ED approval: • The added program leads to an associate, bachelor’s, 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

24. 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)

25. 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)

26. 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 • If must meet all required GE Disclosure, Reporting, and Certification requirements • It must include the “self-certified” program on the next recertification E-App, or may report the program sooner • It is liable for FSA funds disbursed if self-determination is found to be incorrect

27. Steps for Maintaining Eligibility New Educational Programs • Schools must report and receive approval for: • Programs added by provisionally certified schools (per PPA) • Non-degree programs added by fully certified schools in an area of study different from, or unrelated to, already eligible programs • Programs under 600 clock-hours (short term programs) • Direct Assessment Programs • A Comprehensive Transition and Postsecondary (CTP) Program

28. 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

29. 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

30. Steps for Maintaining Eligibility New Educational Programs • Program Eligibility Requirements (continued): • 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 • Aid must be calculated based on clock-hours if state requires program to be conducted in clock-hours

31. Steps for Maintaining Eligibility New Educational Programs • Program Eligibility Requirements (continued): • 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

32. Application Process

33. Steps for Maintaining Eligibility Application Process • When a reportable change occurs, school must notify ED: • Via E-App • Within identified timeframe • 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

34. 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

35. 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

36. 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

37. 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

38. Steps for Maintaining Eligibility Application Process • If Reported Changes Acknowledged/Approved: • E-mail 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

39. 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. 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 John Loreng – Philadelphia (215) 656-6437 Sherrie Bell– Washington, DC (202) 377-3349 Atlanta School Participation Division Alabama, Florida, Georgia, Mississippi, North Carolina, South CarolinaChristopher Miller, Director (404) 974-9297 David Smittick – Atlanta (404) 974-9301 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, TennesseeRalph LoBosco, Director (816) 268-0440Dvak Corwin – Kansas City (816) 268-0420 Angela Beam – Kansas City 816) 268-0534 Jan Brandow – Kansas City (816) 268-0409 Multi-Regional and Foreign Schools Participation Division Michael Frola, Director (202) 377-3364 Barbara Hemelt − Washington, DC (202) 377-4201 Joseph Smith − Washington, DC (202) 377-4321 Mark Busskohl – Washington, DC (202) 377-4572 Michelle Allred – Dallas (214) 661-9466 Chicago/DenverSchool Participation Division Illinois, Minnesota, Ohio, Wisconsin, Indiana, Colorado, Michigan, Montana, North Dakota, South Dakota, Utah, WyomingDouglas Parrott, Director (312) 730-1532 Earl Flurkey – Chicago (312) 730-1521 Brenda Yette – Chicago (312) 730-1522 Sarah Adams − Chicago (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, WashingtonMartina 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

40. Session Contacts: Your feedback and comments are appreciated. • Susan Bowder • Phone: 206-615-2654 (Seattle) • E-mail: susan.bowder@ed.gov • Arva Thomas • Phone: 404-974-9412 (Atlanta) • E-mail: arva.thomas@ed.gov

41. QUESTIONS?