Determining Eligibility For and Adding New Programs

1. Determining Eligibility For and Adding New Programs PASFAA Conference, Harrisburg PA Annmarie Weisman | 10.29.2012

2. Agenda: • Reporting new and updated information using the Electronic Application for Approval to Participate in the Federal Student Financial Aid Programs (E-App) • Resources • Q & A

3. Adding Programs • Eligibility and Certification Approval Report (ECAR) identifies programs that are Title IV eligible • Institutional Title IV eligibility does not automatically include new programs • Remember: Program Participation Agreement (PPA) is the institution’s contract with ED

4. Eligibility Documents • E-App • Program Participation Agreement (PPA) • Eligibility and Certification Approval Report (ECAR)

5. *Approval generally required for Short-term programs*

6. Adding Programs – Notification Not Required • An institution is not required to notify ED of a new program if fully certified, has no growth restriction on its PPA, andmeets one of the following: 1. Public or Private Non-Profit Institutions: adds a program leading to an associate, bachelor’s, or graduate/professional degree* --or-- *If not approved for that level or higher, institution must request an Increased Level of Offering

7. Adding Programs – Notification Not Required • All institutions: program meets all of the following: • Has the same CIP Code and is offered at the same credential level as an approved program • Is not a short-term program • Is not considered to be an additional program by its accreditor* • Prepares students for gainful employment in a recognized occupation * Include program on next recertification application

8. Adding Programs – Notification Not Required 3. All institutions: program meets all of the following: • Has the same CIP Code and is offered at the same credential level as an approved program • Is a short-term program at the graduate level –or- at the undergraduate level and requires at least an Associate’s degree for entry • Is not considered to be an additional program by its accreditor* • Prepares students for gainful employment in a recognized occupation * Include program on next recertification application

9. Adding Programs – Approval Not Required • Reporting self-determined programs on the E-App If you have added programs that you did not need to report to ED, add them to the e-app at your next recertification.

10. Adding Programs--Approval Not Required • ED will review the new program and add the program to the institution’s ECAR if program meets eligibility requirements • ED will provide written notification when review is complete • Institution may disburse funds prior to receiving ED notification

11. Adding Programs – Approval Not Required • If program does not meet eligibility requirements in 34 CFR 668.8, ED will deny eligibility Caution: institution liable for funds disbursed if program determined to be ineligible

12. Adding Programs – Approval Required • Approval is required before disbursement if the institution is (any of the following): • provisionally certified • adding a Direct Assessment Program • adding a Comprehensive Transition and Postsecondary (CTP) Program

13. ED Evaluation of Program • Accreditor and state approval matches E-App (name and program length) • CIP Code consistent with program name • Meets minimum weeks and clock/credit hours • Leads to gainful employment (SOC code)* • Meets clock to credit conversion where required

14. Adding Programs • ED’s decision • If not approved, denial is issued • School may request reconsideration • If approved, a revised ECAR and approval issued • Institution may disburse funds after receiving approval Programs are eligible on the date of ED’s approval. Eligibility for grants is back to the beginning of the payment period; eligibility for loans is back to the beginning of the loan period.

15. Adding Programs – Limitations • For institutions subject to the 2-year rule, during the initial period of participation • ED will not approve programs that expand eligibility beyond current ECAR unless institution demonstrates program has been offered for at least 2 years • May not award FSA funds for a program not included in approval documents

16. ED Evaluation of New Program • 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 • Special requirements for Comprehensive Transition and Postsecondary (CTP) Program (see slides at the end for more information)

17. Report and Wait–Changes Requiring Approval • Increase in the level of offering of education programs beyond the scope of current approval • Update application – change in level of offering

18. Report and Go–Changes not Requiring Approval • Change from or to clock hours or credit hours • Name Change (school or staff) • Address change • 3rd-party servicer change

19. ApplicationProcess

20. How to Submit Changes • Use E-App to submit changes and updates • www.eligcert.ed.gov • In Section A, Q. 1, select UpdateInformation box • Select updates from the pick list; if purpose doesn’t appear in list, select Other, and type the purpose in space provided

21. 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

22. Features of the E-App • Pre-populated questions • Help text • Edit checks • Status messages • Skip logic skips “N/A” questions and sections

23. Application Process ED + 8-digit OPE ID No. ED + 9-digit Taxpayer ID No.

24. Application Process www.eligcert.ed.gov

25. Application Process

26. Additional Information – Section K (Q. 69) Use this area to provide additional information or an explanation

27. Application Process Go to the signature page

28. Application Process Go to Section M

29. Application Process A message will indicate if entries are still needed If OK, click on the Submit Application button

30. Application Process Check that the president will sign the app and print the page

31. Section M - Required Supporting Documents Click on the Application Submission page link

32. Application Process Receipt Send the signature page (Section L) and copies of required supporting documents to us. Regular mail/commercial overnight mail: U.S. Department of Education, FSA School Eligibility Channel Integrated Partner Management 830 First Street, NE Washington, DC 20202-5402 32

33. ED Response Sent via E-mail • E-mail instructs institution to go to the PPA/ECAR page of the E-App website to view Approval (or Acknowledgement) Letter • Institutionprints and reviews copy of Approval Letter and ECAR • E-mail includes contact information for questions about the action

34. Application Status • Go to the E-App (eligcert.ed.gov website) • Click on “Application Status” in the left margin • For detailed information, contact the analyst who is working with your application (see contacts list) • NOTE: To add items to an application while any prior application is under review, contact the School Participation Division to request update access

35. Avoid Common Errors • Don’t forget to: • Click “SUBMIT” • Submit the signed signature page • Submit copies of the state and accreditation approval letters • Check a box for each purpose (if reporting more than one update)

36. CIP, SOC, and O-Net Codes • Classification of Instructional Programs (CIP) codes are developed by ED’s National Center for Education Statistics(NCES) • http://nces.ed.gov/pubs2002/cip2000 • Standard Occupational Classification (SOC) codes are developed by OMB • Occupational Information Network (O*NET-SOC) are developed by the Dept. of Labor • http://online.onetcenter.org

37. Eligibility References • Code of Federal Regulations (CFR) • 600.2 – Definitions, incl. Recognized Occupation • 600.10 – Extent of Eligibility • 600.20 – Application Procedures • 600.21 – Updating Application Information • 600.32 – Additional Locations • 668.8 – Eligible Program • 668.14 – PPA • 668.25 – Third-Party Servicer Contracts • FSA Handbook, Volume 2, Chapter 5

38. Comprehensive Transition and Postsecondary (CTP) Program • HEA allows an eligiblestudent with an intellectual disability attending an eligible comprehensive transition and postsecondary (CTP) program to receive: • Federal Pell Grant • Federal SEOG • Federal Work-Study

39. Comprehensive Transition and Postsecondary (CTP) Program • Implementing regulations can be found at 34 C.F.R. 668, Subpart O • Use CIP Code 30.9999 on e-app • To be eligible, the CTP Program must • Include an advising and curriculum structure • Require students with ID to participate in courses and activities with students without disabilities

40. Comprehensive Transition and Postsecondary (CTP) Program • To be eligible, the CTP Program must • Be offered by an Institution of Higher Education (IHE) participating in Title IV • Be delivered to students physically attending • Be designed to support students with intellectual disabilities (ID) in preparation for gainful employment

41. Comprehensive Transition and Postsecondary (CTP) Program • FSA Review Process: • Internal Review of E-App and SAP Policy for general eligibility requirements • External Review of narrative description for clear explanation of how all CTP program specific required elements are met • Performed by professionals with expertise in CTP programs

42. Comprehensive Transition and Postsecondary (CTP) Program • To ensure CTP Program description is complete: • Use page numbers and institution name in the header • Include supporting materials • To ensure E-App is complete: • Verify that program length is correct • Include non-credit classes and internship/work-based training

43. Help with Title IV Questions • For Schools & Other Professionals • Research and Customer Care Center (RCCC) • 1-800-433-7327 • fsa.customer.support@ed.gov • For Students • Federal Student Aid Information Center (FSAIC) • 1-800-4FED-AID

45. Contact Information • For follow-up questions on this session, contact me at: Annmarie Weisman, Training Officer annmarie.weisman@ed.gov 215-656-6456 • To provide feedback to my supervisor, contact: Jo Ann Borel, Supervisor joann.borel@ed.gov 281-758-8122

46. Evaluation Your attention is appreciated at today’s session! To provide feedback to me and my supervisor, please complete an evaluation form. Thank you!!!

47. QUESTIONS?