PROGRAM INTEGRITYFinal Regulations Published 10/29/10

INCLUSION IN LAW

Repeating Coursework Ability to Benefit rules Validity of High School Diploma Gainful Employment Definition of Credit Hour Verification Misrepresentation SAP

INCLUSIONS IN LAW

R2T4 – attendance Disbursement R2T4 – defining “withdrawals” Written arrangements Incentive Compensation State Authorizations

LINKS

NASFAAhttp://www.nasfaa.org/Main/Centers/Program_Integrity_Final_Rule_Resources.aspx

DOEhttp://ifap.ed.gov/eannouncements/attachments/110110ProgramIntegritydated102910.pdf

CREDIT HOUR DEFINITION

An institutionally established equivalency that reasonably approximates not less than- One hour of classroom or direct faculty

instruction and a minimum of two hours of class student work per week

OR Equivalent work for other academic activities as

established by the institution Including lab work, internships, practica, and studio

work.

CONT.

The Department of Education (ED) states in the preamble to the new rule that it believes the definition to be consistent with general practice, and that many institutions "are already following the definition of a credit hour or a reasonably comparable standard that would require minimal or no adjustment for purposes of participating in Federal programs."

SATISFACTORY ACADEMIC PROGRESS (SAP)

For programs longer than an academic year in length, SAP is measured at the end of each payment period or at least annually to correspond to the end of a payment period.

SAP – CONT.

Elements of SAP standards will still include qualitative component (GPA), a quantitative component referred to as the student’s pace, and a maximum timeframe (referred to as the 150% of the published length of the program).

You must also continue to include – How GPA and pace of completion if affected by, incompletes, w/d, repetitions, and transfer credit from other schools.

SAP – CONT.

Programs of study that are one academic year or less in length – MUST evaluate SAP at the end of each payment period.

Programs longer than one academic year – Must evaluate at least annually to

correspond with end of the payment period School may evaluate at end of each

payment period.

SAP – CONT.

SAP Warning – Status assigned to a student who fails to

make SAP at an institution that evaluates SAP at the end of each payment period

Student may continue to receive T4 aid for one payment period

No appeal necessary for this status

SAP – CONT.

SAP Probation – Status assigned by an institution to a

student who fails to make SAP and who has appealed and has had eligibility for T4 aid reinstated.

You may impose conditions for student’s continued eligibility to receive T4 aid

Student may receive aid for one payment period

SAP – CONT.

SAP Failure – Status assigned by an institution to a

student who fails to make SAP After Warning period and non-SAP continues; After Probation period and non-SAP is

determined; After non-successful appeal

SAP PROCESS

1. End of 1st term = Non-SAP2. Go to a Warning Status (if checked each

term)3. After 2nd term – AND remains Non-SAP –

student must appeal4. If appeal is approved – student goes on

Probation (stipulations on next slide)5. If not successful – SAP Failure – not eligible. 6. If only checked annual – non-SAP student

automatically go to failure.

SAP- CONT.

Probation – The student MUST be mathematically able

to complete and make SAP by end of next term. If not – the student cannot receive T4 aid.

The student must be successfully following an academic plan (which requires a policy, i.e., who designs, who meets with the student, how is success tracked, etc.).

DEFINITION OF A “FULL-TIME STUDENT” Includes language regarding repetition of a

previously passed course The final rule allows repeating any

coursework previously taken in a program as long as it is not a result of:

1. More than one repetition of a previously passed course, or

2. Any repetition of a previously passed course due to the student failing other coursework.

REPEATED COURSEWORK

It amends definition of full-time student to allow repeated coursework to count toward enrollment status in term-based programs1. May repeat previously passed course

once2. May repeat failed course until it is passed

REPEATS

Schools must monitor this to determine eligibility based on enrollment status and T4 eligibility.

The law does not require institutions to allow repetitions – it only addresses the treatment of T4 funds regarding repeats.

VERIFICATION

Changes definitions – 1. Subsidized – applies to T4 funds

where eligibility is based upon EFC

- Pell, FSEOG, FWS, Perkins, DL Sub

2. Unsubsidized – applies to T4 funds NOT based on EFC

- TEACH, DL Unsub, DL PLUS

VERIFICATION – CONT.

All applicants selected for verification (either by CPS or school) – must be verified BEFORE any PJ adjustments made to FAFSA

Removes the 30% applicant pool Revises exclusions, i.e., Palau, etc., no

longer included. Allows updating of marital status

(optional!). This is not a PJ. School may set a cut off date.

VERIFICATION – CONT.

Beginning 2012-2013 – verification items will be specified for individual applicant (may not require all “5-item” verification elements).

Tolerance is eliminated ($400). If more than $25 (dollar items) – must resubmit.

All non-dollar item changes – MUST be resubmitted – regardless if EFC does not change.

VERIFICATION – CONT.

No longer limits students to lesser Pell amount (highest EFC) if verification is completed after enrollment.

IRS retrieval is acceptable for verification – ONLY code “02”

GAINFUL EMPLOYMENT

Any program at a public school that is NOT –

1. A program leading to a degree2. A transfer program of a least two

years

Institutions must annually report on students enrolled in programs leading to gainful employment in a recognized occupation.

GAINFUL EMPLOYMENT – CONT.

Reporting deadlines By 10/1/2011

- 2006-07 award year info- 2007-08, 08-09, 09-10 award year info

2010-2011 and beyond –- No earlier than 09/30 but no later than the

date established by the Secretary.

GAINFUL EMPLOYMENT – CONT.

Disclosures must include: Occupations (by name and SOC codes) its

programs prepare students to enter Links to occupational profiles on O*NET

Costs – tuition/fees, r/b and b/supp. May include additional costs.

On-time completion rate for each program Placement rate for students completing

each program Median loan debt incurred by students

FAFSA CHANGES

1. Deleted questions regarding enrollment status, whether student wants a loan or not, planning to complete course work to become an elementary or secondary teacher.

2. Added FAFSA question 27Collects name, city and state of HSPaper applicantsWeb applicantsOutput files

FAFSA CHANGES – CONT.

3. Asset threshold filtering questionsDependent StudentsIndependent Students

4. ACG – SMART5. IRS Retrieval