Susan Bowder and Michael Rhodes | Dec. 2015 U.S. Department of Education 2015 FSA Training Conference for Financial Aid Professionals Maintaining Your

Susan Bowder and Michael Rhodes | Dec. 2015U.S. Department of Education

2015 FSA Training Conference for Financial Aid Professionals

Maintaining Your Institutional Eligibility

Session 39

School AEligible for

Financial Aid

School BNot Eligible for

Financial Aid

These students CAN NOT get financial aid even if they are eligible

These students may get financial aid IF they are eligible

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Institutional Eligibility• Eligibility Requirements• Eligibility Documents• Steps for Maintaining Eligibility

• Meeting New Requirements• Timely Recertification• Timely Reporting Changes

• New Educational Programs• New Locations

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Eligibility Requirements

Eligibility Requirements34 CFR Part 600 Institutional Eligibility identifies requirements including:

• Legally Authorized by a State• Accredited• Provides an Eligible Program• Correspondence courses 50% or fewer • Correspondence students less than 50% of regular students• Incarcerated students 25% or less of regular students• No bankruptcy, crime with Title IV, or fraud by school or owner

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Eligibility Documents

Eligibility DocumentsRefer 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)

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Steps for Maintaining Eligibility

Steps for Maintaining Eligibility: Meeting New Requirements• Watch for New Requirements in Dear Colleague Letters

and Electronic Announcements ifap.ed.gov

• Example: Gainful Employment (GE)• EA 2015-06-11Gainful Employment Electronic Announcement #54 -

Certification Requirements for Gainful Employment• Transitional Certification or New PPA with GE Certification due by

December 31, 2015

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Steps for Maintaining Eligibility Timely Recertification• Refer to PPA:

• Reminders will be sent• Meet Reapplication Date to ensure month-to-month

continued approval if not processed by Expiration Date

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Steps for Maintaining Eligibility Timely Reporting ChangesReport within 10 days the following “acknowledgement” changes (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 servicers

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Steps for Maintaining Eligibility Timely Reporting ChangesReport within 10 days the following “acknowledgement” changes (no need to wait for approval) (continued):

• 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 25% or greater owner

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Steps for Maintaining Eligibility Timely Reporting ChangesReport the following changes which have special reporting requirements:

• New educational programs seeking Title IV eligibility• New locations seeking Title IV eligibility• Increase in the level of educational programs beyond the scope of

current approval• Change in ownership resulting in a change in control• Change in accreditor

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New Educational Programs

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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 include new programs

• In some cases, the school may make a self-determination of program eligibility and report at next recertification

• In some cases, the school must report and obtain approval before disbursing funds to enrolled students

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Steps for Maintaining Eligibility New Educational Programs• There are two cases in which a school may determine

program eligibility without prior ED approval

1. 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

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Steps for Maintaining Eligibility New Educational Programs

2. A fully certified school adds a program that 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)

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• 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

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• School must report and receive approval:• For any program under 600 clock-hours, regardless of school’s eligibility

(short term program)• For any program added by a provisionally certified school (per PPA)• For a new non-degree program at a fully certified school in a program of

study different or unrelated to already eligible programs• For a new Direct Assessment Program • For a new Comprehensive Transition and Postsecondary (CTP) Program

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Steps for Maintaining Eligibility New Educational Programs• ED will review all reported educational programs

• Ensure program meets eligibility requirements• Evaluate school’s administrative and financial capability (if program

approval is required)• If approved, a revised ECAR and Approval Letter is issued• School may disburse funds after receiving Approval Letter (if program

approval is required)• If not approved, Denial Letter is issued; school may request

reconsideration; school is liable if disbursements made

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• ED will ensure program meets 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

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• ED will ensure program meets 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 is calculated based on clock-hours if licensing requirement stated clock-hours

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• ED will ensure program meets eligibility requirements (continued):• Program meets special requirements if Direct Assessment Program - See

DCL GEN-13-10• Program meets special requirements if Comprehensive Transition and

Postsecondary (CTP) Program - See DCL GEN-11-01

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New Locations

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Steps for Maintaining Eligibility New Locations• ECAR lists the main and additional locations offering 50%

of a program that are eligible• Eligibility does not automatically include 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

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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 report and wait

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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

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Steps for Maintaining Eligibility New Locations

• ED will review all locations• Ensure location meets eligibility requirements• Evaluate school’s administrative and financial capability (if location approval

is required)• If approved, a revised ECAR and Approval Letter is issued• School may disburse funds after receiving Approval Letter (if location

approval is required)• If not approved, Denial Letter is issued; school may request reconsideration;

school is liable if disbursements made

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Steps for Maintaining Eligibility New Locations

• ED will ensure location meets 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

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Application Process

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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

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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

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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

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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

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• ED Response to E-App• E-mail instructs school to go to the PPA/ECAR page of the E-App website

to view Approval or Acknowledgement Letter• School prints and reviews copy of Approval/Acknowledgement Letter and

ECAR• E-mail also provides contact information for questions about the action

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• 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

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SCHOOL ELIGIBILITY SERVICE GROUP (SESG)Ron Bennett - Director, School Eligibility Service Group, Washington, DC (202) 377-3181

School Eligibility Service Group General Number: (202) 377-3173 or e-mail: [email protected]

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 CarolinaChristopher Miller, Director (404) 974-9297 David Smittick – Atlanta (404) 974-9301Vanessa Dillard – Atlanta (404) 974-9418

Dallas School Participation Division Arkansas, Louisiana, New Mexico, Oklahoma, TexasCynthia Thornton, Director (214) 661-9457Jesus Moya – Dallas (214) 661-9472Kim 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) 268-0420Jan Brandow − Kansas City (816) 268-0409

Clery/Campus Security Jim Moore – Washington, DC (202) 377-4089

Chicago/Denver School Participation DivisionIllinois, Minnesota, Ohio, Wisconsin, Indiana, Colorado, Michigan, Montana, North Dakota, South Dakota, Utah, WyomingDouglas Parrott, Director (312) 730-1532Earl Flurkey – Chicago (312) 730-1521Brenda Yette – Chicago (312) 730-1522Sarah Adams − (312) 730-1514

San Francisco/Seattle School Participation DivisionAmerican 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) 486-5614or Seattle (206) 615-3699Dyon Toney − Washington, DC (202) 377-3639Erik Fosker – San Francisco (415) 486-5606

New York/Boston School Participation Division Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont, New Jersey, New York, Puerto Rico, Virgin IslandsBetty Coughlin, Director (646) 428-3737 Tracy Nave – Boston (617) 289-0145Patrice Fleming – Washington, DC (202) 377-4209 Chris Curry – New York (646) 428-3738

Philadelphia School Participation DivisionDistrict of Columbia, Delaware, Maryland, Pennsylvania, Virginia, West VirginiaNancy Gifford, Director (215) 656-6436 John Loreng – Philadelphia (215) 656-6437Sherrie Bell– Washington, DC (202) 377-3349

Multi-Regional and Foreign Schools Participation DivisionMichael Frola, Director (202) 377-3364Barbara Hemelt − Washington, DC (202) 377-4201Joseph Smith − Washington, DC (202) 377-4321Mark Busskohl – Washington, DC (202) 377-4572

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mailto:[email protected]

Session Contacts: Your feedback and comments are appreciated.

• Susan Bowder• Phone: 206-615-2654 (Seattle)• E-mail: [email protected]

• Michael Rhodes• Phone: 214-661-9484 (Dallas)• E-mail: [email protected]

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QUESTIONS?

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