Title IV Funding: How To's of New Program Approval

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Title IV Funding How To's of New Program Approval

• Carney McCullough, Senior Policy Analyst, Office
  of Postsecondary, ED
• Patricia Patterson, Federal Student Aid Program
  Compliance, ED
• Melissa Gregory, College Director, SFA,
  Montgomery College

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Three Types of Eligible Institutions

• Institution of Higher Education
• Proprietary Institution of Higher Education
• Postsecondary Vocational School

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Basic Requirements

• Accredited by a recognized accrediting agency
• Legally authorized to operate in a State
• Admissions standards

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Institution of Higher Education(public or
private nonprofit)

• Associate, bachelors, graduate or professional
  degree
• At least a 2 year program acceptable for full
  credit toward a bachelors degree
• At least a one year training program
• Leads to a degree or certificate
• Prepares students for gainful employment in a
  recognized occupation

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Proprietary Institution of Higher Education
(for-profit)Postsecondary Vocational
School(public or private nonprofit)

• Eligible programs must provide training for
  gainful employment in a recognized occupation
• One exception, proprietary institutions may
  provide a baccalaureate degree in liberal arts.
  Program must have been offered since January 1,
  2009 and the institution must have been
  accredited by a regional accrediting agency since
  October 1, 2007 or earlier.
• (Effective July 1, 2010)

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Proprietary Institution of Higher Education
(for-profit)Postsecondary Vocational
School(public or private nonprofit)

• Undergraduate program
• 16 semester or trimester, 24 quarter or 600 clock
  hours
• 15 weeks of instructional time

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Proprietary Institution of Higher Education
(for-profit)Postsecondary Vocational
School(public or private nonprofit)

• Graduate program
• 8 semester or trimester, 12 quarter or 300 clock
  hours
• 10 weeks of instructional time
• Admits as regular students only those with
  associate degree or equivalent

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Proprietary Institution of Higher Education
(for-profit)Postsecondary Vocational
School(public or private nonprofit)

• Undergraduate program
• 300 clock hours
• 10 weeks of instructional time
• 70 completion rate, 70 placement rate, and not
  more than 50 longer than minimum training period
  required by State or Federal agency for the
  occupation
• In existence for at least one year
• Eligible only for FFEL and Direct Loans

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Short Term Programs

• Rates must be reported in the annual FSA audit
  (financial/compliance).
• If rates are not met, the program is not eligible
  for the next award year.
• Institution can apply for re-approval of the
  program once it again meets the program
  eligibility requirements.

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ESL Program

• Admit only students who need English to be able
  to use already existing knowledge, skills or
  training
• Eligible only for Pell Grants

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Direct Assessment

• Use direct assessment rather than credit or clock
  hours
• Must apply to ED for approval of the program

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Study Abroad Program

• Eligible if
• Students remain enrolled at eligible home school
  while studying abroad, and
• Eligible home school awards academic credits for
  study abroad program
• Must have written agreement

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Flight School

• Must maintain current valid certification from
  the Federal Aviation Administration

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Academic Competitiveness Grant

• One year undergraduate certificate program
• Associate or Bachelors degree
• Two year transfer program
• Graduate degree that includes at least three
  years of undergraduate education

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National SMART Grant

• Bachelors degree
• Graduate degree that includes at least 3 years of
  undergraduate education
• Eligible major (physical, life, or computer
  science, engineering, mathematics, technology or
  a critical foreign language)
• Categorized by CIP code

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TEACH Institutional Eligibility

• Must be financially responsible in accordance
  with 34 CFR 668, subpart L, or meet an
  alternative standard
• May establish eligibility in any of 4 ways
• Must provide a high-quality teacher preparation
  program at the baccalaureate or masters degree
  level that
• Is accredited by an agency specializing in
  professional teacher education programs
• Is approved by a State and includes at least 10
  weeks of full-time pre-service clinical
  experience and must provide/assist in providing
  pedagogical coursework

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TEACH Institutional Eligibility

• Continued
• Must provide or assist in providing supervision
  and support services to teachers such as
• Information on effective teaching strategies
• Information on effective practices in supervision
  and coaching of novice teachers
• Mentoring focused on effective teaching skills

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TEACH Institutional Eligibility

• Institution provides a two-year program that
• Is acceptable for full credit in an eligible
  baccalaureate teacher prep program
• Is acceptable for full credit in a baccalaureate
  program in a high-need field offered by a TEACH
  Grant-eligible institution
• The institutions must be able to demonstrate
  this relationship

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TEACH Institutional Eligibility

• Institution offers a baccalaureate degree that,
  in combination with other training or experience,
  will prepare students to teach in a high-need
  field and
• Has entered into an agreement with an eligible
  institution that offers a high-quality teacher
  prep program or one that offers a
  post-baccalaureate program of study

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TEACH Institutional Eligibility

• Institution provides a post-baccalaureate program
  of study that
• Does not lead to a graduate degree
• Consists of courses required by a State for a
  student to receive a professional certification
  in teaching
• Is an undergraduate program for Title IV student
  financial assistance purposes

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TEACH Grant Program Eligibility

• TEACH Grant-eligible institutions have wide
  latitude to designate the TEACH Grant-eligible
  programs offered by the institution
• Post-bacc program is not a TEACH Grant-eligible
  program at institutions that offer both a
  post-bacc and a BA in Education

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TEACH Grant Program Eligibility

• Different way of thinking about program
  eligibility
• Title IV regs do not specifically define
  program
• For most Title IV purposes, the term is used in a
  very general way
• For most Title IV purposes, a baccalaureate
  program is four years in length

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TEACH Grant Program Eligibility

• For TEACH, the term program is used to mean
  something more specific
• Programs must be defined in context of majors
• A TEACH Grant-eligible program that leads to a
  baccalaureate degree may be shorter than four
  years in length
• When the student enters the program is important
  e.g., at time he declares a major, is admitted
  to College of Education, etc

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New Educational Programs

• If you want to give Title IV funds to students in
  a new program, the institution must tell ED about
  the program.
• For some programs you must apply and wait for
  EDs approval, others you can report and go.

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Apply and Wait

• The program is at a different level of offering
  
• Examples
• Currently approved for Associate degree, now want
  to offer a Bachelors degree.
• Currently approved for ¾-year program and now
  want to offer a 2-year program.

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Apply and Wait (continued)

• The Institution is provisionally certified.
• The educational subject matter of the new program
  is different from the currently approved
  programs.
• The program is a short-term program (300-599
  clock hours).

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Report and GO

• Institution may self-determine program
  eligibility if adding
• A degree program at a level currently approved
  (unless the under growth restrictions)
• If you do not meet any of the criteria under
  apply and wait, the institution can
  self-determine eligibility for a non degree
  program that prepares students for gainful
  employment in the same or related educational
  area as a currently approved program
• Must report the program at recertification

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Clock to Credit Hours

• ED uses the number of clock hours to apply the
  clock to credit hour formula.
• ED will only approve credit hours up to the
  amount that is approved by the state
  accrediting agencies AND meets the clock to
  credit hour formula.

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Clock to Credit Hour Formula

• Calculate by dividing 30 into the number of
  semester or trimester hours.
• Calculate by dividing 20 into the number of
  quarter hours.
• Must round down.

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Clock to Credit Hour Formula Examples in
Semester Hours
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Clock to Credit Hours Exemptions

• Each course within the program is acceptable
  towards that schools associate degree,
  bachelors degree, or professional degree
  provided that the institutions degree requires
  at least two academic years of study.
• Public or private nonprofit hospital-based school
  of nursing that awards a diploma.

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Applying for Approval of New Programs

• Use the electronic Application for Approval to
  Participate in the Federal Student Financial Aid
  Programs.
• www.eligcert.ed.gov

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Applying for Approval of New Programs

• Section A
• Question 1 Check Update Information
• Select the correct application purpose from the
  pick list
• Increase Level of Offering of Educational
  Programs
• Non degree/Vocational Program

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Applying for Approval of New Programs

• Complete the information for the appropriate
  question(s) in Section E
• Name of the Program
• CIP Code
• Date first provided
• Number of weeks
• Number of clock hours
• Number of credit hours and type of credit hours
• If short-term program, the completion and
  placement rates for the program

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Applying for Approval for the TEACH Grant Program

• Follow the instructions in the Dear Colleague
  Letter on Institutional Eligibility for the TEACH
  Grant Program - GEN-08-07 posted to IFAP on June
  3, 2008

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Applying for Approval for the TEACH Grant Program

• Section A Question 1 Check Update
  Information.
• Select Add TEACH Grant from the pick list.
• Go to Section K, Question 69 and enter
  information regarding how the institution meets
  the eligibility criteria for the TEACH Grant
  Program.

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Applying for Approval of New Programs

• Complete and print Section L (signature page).
• Have the President/CEO/Chancellor sign the
  signature page.
• Mail the signature page and the supporting
  documents to the address provided.
• Submit the Application electronically.

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Outcome

• Once ED receives the application and supporting
  documentation (state and accreditation approval
  and signature page), the School Participation
  Team (SPT) reviews the application and makes a
  decision.

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Outcome

• If approved, the SPT sends an email to the
  institution with instructions to go to the
  website for the approval letter and updated
  Eligibility and Certification Approval Report
  (ECAR).
• If not approved, the SPT sends the institution a
  denial letter explaining why the program was not
  approved.

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What do I do Now?

• The School Perspective
• Program Approvals, CIP Codes, and E-Apps

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We have a program in what??

• Montgomery College Starts New Certificate Program
  in
• Polysomnography
• Published at Feb 12 2009 1200AM
• Category College/Campus News
• To meet rising demands in the health care
  industry, Montgomery College will offer a
  one-year certificate
• program in polysomnography at the Takoma
  Park/Silver Spring Campus, starting in fall 2009.
  The
• deadline to apply is March 1.
• Polysomnography is a diagnostic test that
  measures and records a patient's physiologic
  variables during
• sleep. Polysomnographers, or sleep technicians,
  set up the equipment and monitor and score the
  test
• results, which are then interpreted by a
  physician.
• The demand for registered polysomnographers
  continues to rise as state and national
  regulations are put
• in place and laboratories seek qualified
  applicants. Polysomnographers work in
  freestanding sleep labs,
• physician offices and polysomnography labs
  within hospitals. Salaries in this field are
  competitive with
• other health care professions.

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Know Your School the basics

• What is your highest level of program offering?
• Some new programs need ED approval prior to
  offering aid some do not.
• Who accredits your institution?
• Do some programs have separate or specific
  accreditation?
• Is a new program within the scope of your current
  accreditation? If it was created after your last
  accreditation, probably not.
• When was your last accreditation?
• Do you have a copy of the current letter of
  accreditation?
• If not, who does?
• What is your state licensing agency?
• Do you have a copy of your valid state license or
  other authorization?
• If not, who does?

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Know Your School the process

• How do new programs get approved at your school?
  What is the process?
• Curriculum committee
• Academic affairs office
• Can you be involved, ex. a resource person on
  curriculum committee?
• Who is your curriculum contact?
• Someone who can help you stay on top of new
  programs
• Works with accrediting agencies and state
  agencies to get appropriate certifications and
  licenses
• Calculates clock hours on certificate programs
• Determines CIP codes for certificates

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Know Your School the process

• How do you work with curriculum committees to
  make sure they create aid-eligible programs?
• Never tell them they cant create a program
• Provide guidelines for eligible programs
• Become a resource for new program components and
  changes to existing programs
• Financial aid office is a partner, because no aid
  may mean no students
• Make sure whoever you report to is informed of
  potential new cost of any new program

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Preparing a Clean E-App

• In Section A, Question 1, select Update
  Information box
• Select the specific updates from the pick list
  if purpose doesnt appear in list, select next
  box, Other, and type the purpose in space
  provided
• Nondegree/Vocational Program or
• Short-term Training Program or
• Increase Level of Offering of Educational
  Programs

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Preparing a Clean E-App

• Section E -- Please provide the following
  information for each educational program that you
  are requesting to be eligible to participate in
  federal student aid programs
• Section E. e. must provide program name, CIP
  code, number of weeks in program, clock hours of
  instruction, number of credit hours, type of
  credit hours
• Section E. g. or h. must provide program name,
  CIP code, date program first provided, number or
  weeks in program, clock hours of instruction,
  number of credit hours, type of credit hours, and
  is each course within the program acceptable for
  full credit toward your associate degree or
  higher degree?

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Preparing a Clean E-App

• Section E. i. must provide program name, CIP
  code, date program first provided, number of
  weeks in program, clock hours of instruction,
  maximum number of credit hours authorized by the
  state licensing agency, type of credit hours,
  completion rate, placement rate.
• Documentation to submit will depend on which type
  of program.
• Will always need state license and letter of
  accreditation indicating new program is approved.

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Sample Collection Chart for a New Certificate
Program
Information Systems Security Certificate (HEGIS
5101-01 CIP 11.1003)
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Questions???Carney.McCullough_at_ed.govPatricia.Pa
tterson_at_ed.govMelissa.Gregory_at_montgomerycollege.e
du