Session C-28 Keeping Your School's Title IV Participation Current: Everything you need to know about...

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Session C-28

Keeping Your School's Title IV Participation Current:

Everything you need to know about adding new programs and locations,

and reporting critical information about your school

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Presenters

Douglas Laine

Julie Arthur

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This Session will Cover:

• What changes and updates need to be reported, and when to report

• Which changes and updates require FSA approval prior to disbursing Title IV aid

• How to report changes and updates using the E-App

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Eligibility Documents and References• Electronic Application for Approval to

Participate in the Federal Student Financial Aid Programs (E-App)

• Program Participation Agreement (PPA)

• Eligibility and Certification Approval Report (ECAR)

5

Eligibility Documents and References• Code of Federal Regulations (CFR)

– 668.14 – PPA– 600.10 – Extent of Eligibility– 600.20 – Application Procedures– 600.21 – Updating Information– 600.31 – Change in Ownership– 668.25 – Third-Party Servicer

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Reporting – Two Categories

• Report and wait for approval—must receive approval before disbursing aid

–Look for:

• Report and go—not required to wait for approval before disbursing aid

–Look for:

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Reporting - Locations

• New Locations

- Always must be reported

- If 50% or more of an educational program is offered at that location

-Sometimes report and wait

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Report and Wait - Locations

• Must wait for approval if institution

– Is provisionally certified

– Is on Cash Monitoring

– Acquires assets of another institution

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Report and Wait - Locations

• Must wait for approval if institution

– Would be subject to loss of eligibility under 668.188 (default rates)

– Is notified by the Secretary that it must report and wait

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Reporting - Programs

• Must wait for approval for

– Short term programs

– Increased level of offering

– Nondegree programs beyond current approval

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Report and Wait - Programs

• Short-term programs (300–599 clock hours) must always be approved prior to disbursing Title IV aid (includes graduate short-term programs)

• Undergraduate short-term programs must have been provided continuously for at least 12 months and meet 70 percent completion and placement rate thresholds

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Report and Wait - Programs

• Increasing the level of offering

– Institution previously offered only AA or AS degrees, adds BA or BS degrees

– Institution previously offered one-year non-degree programs, now offers two-year non-degree programs

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Report and Wait - Programs

• Nondegree programs beyond current approval

– Program prepares students for gainful employment in dissimilar or unrelated occupations as the currently approved programs

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Report and Go - Programs

• Institution may self-determine program eligibility if adding – A degree program at level currently

approved– A Non degree program that prepares

students for gainful employment in same or related recognized occupation as a currently approved program•Report at recertification

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Report and Wait – Other Changes

• Must report and wait if– Institution changes its primary, institution-wide

accrediting agency*, or state authorizing agency– Change in structure– Change in ownership

*Note: the change must be approved, but prior to the change, the institution must notify FSA in writing when it begins the process to change its accrediting agency, including the reason for the change

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Report and Wait – Other Changes

• Must report and wait if– Adding new Title IV program

•Teach Program•Campus-Based Programs•FFEL•Direct Loan

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Report and Go – Other Changes

• Report and go– Certain changes must be reported within

10 days of the change– Changes must have prior approval from

state and accreditor, if applicable– Materially complete application must be

submitted

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Report and Go – Other Changes

• Institution’s and Location’s– Name – Address – Phone – Fax – Internet addresses

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Report and Go – Other Changes

• Change in educational measurement (e.g. change from clock hours to credit hours, or semester credit hours to quarter credit hours)

• Decrease in level of offering (e.g., institution drops its graduate programs)

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Report and Go – Other Changes

• Change in a person’s ability to affect the actions of the institution including– Changes in levels of ownership – Change in officials

•President•Fiscal Officer•Financial Aid Administrator

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Report and Go – Other Changes

• Closure of a branch campus or additional location that the institution was required to report

• Governance of a public institution (e.g., change from county control to state control)

• Add/drop third-party servicer

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Report and Go – Other Changes

• Foreign gift reporting (HEA Sec. 117 and DCL GEN-04-11)—must report applicable gifts by January 31 or July 31, depending upon when gift received

• Voluntary withdrawal from some or all Title IV Programs

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How to Submit Changes

• Use E-App to submit changes and updateswww.eligcert.ed.gov

• 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 next box, “Other,” and type the purpose in space provided

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How to Submit Changes

• Complete the information for the appropriate questions and Section L of the E-App

• Mail the signature page (Section L) and the supporting documents listed in Section M to the address indicated

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Features of the E-App

• Pre-populated questions

• Help text

• Edit checks

• Status messages

• Skip logic (automatically skips “not applicable” questions)

ED + 8-digitOPE ID No.

ED + 9-digitTaxpayer ID No.

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Adding Comments to E-App

• To provide additional information about the application, or data on the application, Use Section K, Question 69

Note: Institutions use Question 69 to document eligibility criteria for participation in TEACH Grant Program (see DCL GEN 08-07)

Use this area to provide additionalinformation or anexplanation

Go to the signature page

Check that the president will sign the app and print the page 09/26/200

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Go to Section M

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Section M Identifies Required Supporting Documents

Click on the Application

Submission page link

School Eligibility Channel, U.S. Department of Education

If okay, click on the Submit Application button

A message will indicate if entries are still needed

Receipt

You must receive written approval from ED for your new location(s) before you disburse Title IV funds to students at the new location(s)

U.S. Department of EducationSchool Participation Management School Eligibility ChannelIntegrated Partner Management Division830 First Street, NEWashington, DC 20002-5402

09/26/2008 9:30 am Eastern Time

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Checking the Status of the Application

• Go to the E-App

• Click on “Application Status”

Status

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FSA Response Sent via E-mail

• E-mail instructs institution to go to the PPA/ECAR page of the E-App web site to view Approval Letter (or Acknowledgement Letter)

• Institution prints and reviews copy of Approval Letter and ECAR

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

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You can access

your PPA, ECAR &

Update Notice

from the web

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Other Reasons to Submit E-App

• Initial Application– Eligibility (Deferment) Only– Certification

• Recertification– Apply at least 90 days prior to

expiration of PPA– Reminder e-mail will be sent (keep e-

mail addresses updated)

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Other Reasons to Submit E-App

• Change in Ownership– Pre-acquisition review—45 days prior to

date of purchase– Materially complete application required

within 10 days of purchase to prevent loss of eligibility

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Other Reasons to Submit E-App

• Merger

• Reinstatement

• Redesignation of main location

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School Participation Team Contacts• New York/Boston team – (617) 289-0133 & (646) 428-3750

– Connecticut, Maine, Massachusetts, New Hampshire, New Jersey, New York, Puerto Rico, Rhode Island, Vermont, and the Virgin Islands

• Philadelphia team - (215) 656-6442– Delaware, the District of Columbia,

Maryland, Pennsylvania, Virginia, and West Virginia

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School Participation Team Contacts

• Atlanta team - (404) 562-6315– Alabama, Florida, Georgia, Mississippi,

North Carolina, and South Carolina

• Chicago team - (312) 730-1511– Illinois, Indiana, Minnesota, Ohio, and

Wisconsin

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School Participation Team Contacts

• Dallas team - (214) 661-9490– Arkansas, Louisiana, New Mexico,

Oklahoma, and Texas

• Kansas City team – (816) 268-0410– Iowa, Kansas, Kentucky, Missouri,

Nebraska, and Tennessee

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School Participation Team Contacts

• Denver team - (303) 844-3677– Colorado, Michigan, Montana, North Dakota,

South Dakota, Utah, and Wyoming

• San Francisco/Seattle team – (415) 486-5677 & (206) 615-2594

– Arizona, Alaska, California, Hawaii, Idaho, Nevada, Oregon, Washington, American Samoa, Guam, Federated States of Micronesia, Palau, Marshall Islands, and Northern Marianas

• Foreign School team - (202) 377-3168

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Contact Information

We appreciate your feedback and comments.

Our contact information:

Douglas Laine douglas.laine@ed.govBetty Coughlin betty.coughlin@ed.govJulie Arthur julie.arthur@ed.gov

For general questions, contact your School Participation Team