[Oasfaa] FW: Certificate program requirement question

Tue May 13 08:19:55 CDT 2014

Good Morning Fellow FAAs.

Want to share an email response I received from DOE regarding minimum length of Certificate Programs we could offer, etc.

Susan Prater
Director
UCO Student Financial Services
405.974.2300

From: Rhodes, Michael [mailto:Michael.Rhodes at ed.gov]
Sent: Friday, May 02, 2014 3:48 PM
To: Susan Prater
Cc: Summers, Trevor
Subject: RE: Certificate program requirement question

Susan,

As you cited from the Handbook, on page 2-4, we see the definitions of the three types of institutions:

*         Institution of Higher Education (IHE) - A public or private nonprofit educational institution located in a state

*         Proprietary Institution of Higher Education - a private for-profit educational institution located in a state

*         Postsecondary Vocational Institution (PVI) - A public or private nonprofit educational institution located in a state

You and I agree your school meets the definition of the IHE.  We also agree your school does not meet the definition of a proprietary school. Given these facts, let's concentrate on the PVI.

PVI's can sometimes be considered only as a PVI. Examples would be those nonprofit schools that offer only vocational/certificate programs. They have no degrees, AA, BA, BS, MBA, etc. Because they otherwise meet the definition as mentioned above, these schools are allowed to offer certification programs less than one year in length, as long as these programs lead to gainful employment.

Two-year and four-year schools may also be defined as PVI's if the certificate programs being offered also lead to gainful employment. The fact that an IHE offers degree programs does not prevent that school from also meeting the requirements of a PVI. Both types of schools are defined with the same basic language. For purposes of this discussion, the basic difference between an IHE and a PVI is the ability to grant degrees. Both types of schools qualify to offer certificate programs of less than one year.

My only caution in creating new programs is to ensure your school is very familiar with the types of aid students may or may not be eligible for and the various responsibilities a school may have for programs of different length. For example:

*         Students in programs of 600 clock hours or longer (or its equivalent in credit hours) could qualify for both Pell Grants and Direct Loans, if otherwise eligible. Students enrolled in programs of 300 - 599 clock hours (which must be offered in clock hours, not credit hours) will only qualify for Direct Loans, no Pell Grants)

*         Programs of 300 - 599 clock hours, also termed as short term programs, must also meet what is called the 70/70 rule. These programs must

o   have verified completion and placement rates of at least 70%,

o   not be more than 50% longer than the minimum training period required by the state or federal agency, if any, for the occupation for which the program of instruction is intended, and

o   have been in existence for at least one year.

I hope this is helpful. Please let me know if you have further questions.

Thank you,

Michael K Rhodes
Institutional Improvement Specialist
Federal Student Aid
U.S. Education Department
1999 Bryan St Suite 1410
Dallas, TX 75201-6817
214-661-9484
214-661-9662 (fax)

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From: Susan Prater [mailto:SPrater4 at uco.edu]
Sent: Friday, May 02, 2014 2:34 PM
To: Rhodes, Michael
Subject: FW: Certificate program requirement question

Michael,

Thank you for attempting to respond so quickly to my Certificate program question.  My institution is in the process of considering offering more Certificate programs that would be eligible for financial aid and I have been invited to an Academic Affairs meeting next Tuesday to discuss the federal regulations involved.

My understanding per Vol. 2, Ch. 2, p. 16 of the Student Federal Aid Handbook is that if you meet the definition of a post-secondary vocational or proprietary institution, you can offer a Certificate program less than one year, and additional guidance is provided in the handbook.  But, if you don't meet the post-secondary vocational institution definition, a Certificate program offered at a 4 year public/private or 2 year community college must be at least one academic year in length.    In both cases, the program must prepare for gainful employment.

Upon review of our ECAR, #26G is checked that includes several bullets regarding undergraduate program information but doesn't include the differences of an institution of higher education versus meeting the definition of a postsecondary vocation institution.  I did read the regulations 34 CFR 668.6 on Postsecondary vocational institution, if that is where the definition is supposed to be, but that really didn't clear up my question relating to what's stated in the SFA handbook and whether UCO meets that definition.

Any guidance you could provide would be appreciated.  My understanding was that for financial aid eligibility, our school could only offer Certificate programs of 1 academic year.  What definition is the SFA Handbook referencing?

Thank you.

Susan Prater
Director
UCO Student Financial Services
405.974.2300

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**Bronze+Blue=Green** The University of Central Oklahoma is Bronze, Blue, and Green! Please print this e-mail only if absolutely necessary! 

**CONFIDENTIALITY** This e-mail (including any attachments) may contain confidential, proprietary and privileged information. Any unauthorized disclosure or use of this information is prohibited.

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