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

Three Types of Eligible Institutions Institution of Higher Education Proprietary Institution of Higher Education Postsecondary Vocational School

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

Institution of Higher Education (public or private nonprofit) Associate, bachelor’s, graduate or professional degree At least a 2 year program acceptable for full credit toward a bachelor’s degree At least a one year training program –Leads to a degree or certificate –Prepares students for gainful employment in a recognized occupation

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)

Proprietary Institution of Higher Education (for-profit) Postsecondary Vocational School (public or private nonprofit) 1.Undergraduate program 16 semester or trimester, 24 quarter or 600 clock hours 15 weeks of instructional time

Proprietary Institution of Higher Education (for-profit) Postsecondary Vocational School (public or private nonprofit) 2.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

Proprietary Institution of Higher Education (for-profit) Postsecondary Vocational School (public or private nonprofit) 3.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

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.

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

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

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

Flight School Must maintain current valid certification from the Federal Aviation Administration

Academic Competitiveness Grant One year undergraduate certificate program Associate or Bachelor’s degree Two year transfer program Graduate degree that includes at least three years of undergraduate education

National SMART Grant Bachelor’s 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

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— 1.Must provide a high-quality teacher preparation program at the baccalaureate or master’s 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

TEACH Institutional Eligibility 1.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

TEACH Institutional Eligibility 2.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

TEACH Institutional Eligibility 3.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

TEACH Institutional Eligibility 4.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

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

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

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

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 ED’s approval, others you can report and go.

Apply and Wait The program is at a different level of offering – Examples: –Currently approved for Associate degree, now want to offer a Bachelor’s degree. –Currently approved for ¾-year program and now want to offer a 2-year program.

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 ( clock hours).

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

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.

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.

Clock to Credit Hour Formula Examples in Semester Hours

Clock to Credit Hours Exemptions Each course within the program is acceptable towards that school’s associate degree, bachelor’s degree, or professional degree provided that the institution’s degree requires at least two academic years of study. Public or private nonprofit hospital-based school of nursing that awards a diploma.

Applying for Approval of New Programs Use the electronic Application for Approval to Participate in the Federal Student Financial Aid Programs.

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

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

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 posted to IFAP on June 3, 2008

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.

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.

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.

Outcome If approved, the SPT sends an 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.

WHAT DO I DO NOW? The School Perspective: Program Approvals, CIP Codes, and E-Apps

We have a program in what?? Montgomery College Starts New Certificate Program in Polysomnography Published at Feb :00AM 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 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.

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?

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

Know Your School – the process How do you work with curriculum committees to make sure they create aid-eligible programs? –Never tell them they “can’t” 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

Preparing a Clean E-App 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 “Nondegree/Vocational Program” or “Short-term Training Program” or “Increase Level of Offering of Educational Programs”

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?

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.

Sample Collection Chart for a New Certificate Program Information Systems Security Certificate (HEGIS: ; CIP )

Questions???