[Oasfaa] Bartnicki Bulletin - GE, Perkins, ATB, Repeats, Credit Conversion, Training

[Schmerer, Mendy M. (HSC)]

All, please see below for a few updates, courtesy of the SASFAA region's federal trainer.

Thanks,
Mendy


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Dear SASFAA,

School is back in session.  I now have one in 2nd grade, 5th grade and 6th grade (though he thinks he is in high school and is practicing being a teenager - serenity now!)

Below are just a few reminders and updates I wanted to make sure we were all aware of when administering the Title IV programs.

Gainful Employment

Just a reminder to make sure that you periodically check the gainful employment website for the latest and greatest information -  http://www.ifap.ed.gov/GainfulEmploymentInfo/index.html. 
We have recently posted new Q & As and will continue to provide information as it becomes available.

A couple of key pieces of information related to GE programs contained in recent Q & As - 
-	While the regulations provide that the deadline for institutions to report GE Program information for the 2006-2007 through 2009-2010 award years is October 1, 2011, the August 2 Federal Register notice provides that the Department will continue to accept information from these earlier award years through November 15, 2011, the same date as the reporting date for the 2010-2011 award year. 
-	All 'regular students' enrolled in a GE Program must be reported and included in the GE Program's disclosures, including high school student IF the school has enrolled them as "regular" students.
-	The amount reported for institutional financing plans is the amount owed by the student as of the day the student completed or withdrew from the GE program and only includes aggregate amounts owed over $200.

Please see the Q & A section of the GE website for more detailed discussions on these topics and others.

Perkins Liquidation and Loan Assignments

ED just recently posted a new electronic announcement dated August 5, 2011 that contains attachments that provide updated information about the required processes for liquidating a Federal Perkins Loan (Perkins Loan) portfolio when a school ends participation in the Perkins Loan Program as well as processes for assigning Perkins Loans to the Department of Education (the Department).  This announcement replaces any previous ED guidance about this process.

In addition, ED created a new Perkins liquidation email address (perkinsliquid at ed.gov) for communication between schools and the Department's Perkins Liquidation Team concerning the Perkins Loan portfolio liquidation process.  Schools can send in required information and ask questions through this new mailbox.

Charging for ATB Tests

I have gotten numerous questions from schools lately around whether or not a school can charge a student to take an ATB test for Title IV purposes.  Our answer from policy is as follows - 

 Institutions may not charge a fee to a student for taking an approved ATB test to determine Title IV, HEA program eligibility.  To do so would be a violation of section 487(a)(2) of the Higher Education Act of 1965, as amended, and the regulations at 34 CFR 668.14(b)(3) which state that a school may not charge any fee for applying for or determining eligibility for Title IV aid.   Institutions specifically affirm this provision in their Program Participation Agreement.
 
In the case where an institution directs a student to an assessment center located at another institution or uses an independent test administrator, the assessment center or the independent test administrator may charge the student a fee for taking the test.   However, in both instances the student's cost of taking the test cannot be included in the student's cost of attendance.

Repeat Coursework

I have also had several schools provide me with situations where a student is repeating previously passed coursework for the sole purpose of getting more financial aid (e.g. student only has one class left, but decides to repeat a class already passed in order to be ½ time to receive loans or get more Pell, etc.).   In reference to this situation policy has indicated that it is permissible for a school to develop a repeat coursework policy whereby  they may choose not to pay students TIV aid who are repeating coursework for the sole purpose of getting more financial aid.  That was not the intent of the regulation, and seems to have produced an unintended consequence.  

Clock -to-Credit Hour Conversion

For those of you that are NASFAA members or attended the NASFAA conference, please be aware that OPE updated their Program Integrity Regulation presentation from this year's conference with corrected data surrounding an example dealing with the clock to credit hour exception.  For any school subject to the clock to credit hour conversion, the example is quite detailed and does a good job of walking you through the conversion process.  

You can find the presentation online at NASFAA.org.   If you are unable to access the information, please feel free to contact me and I can forward you the pertinent data.

Clock Hour Program Training

As many of you know, the new regulations defined what a clock hour program is for undergraduate programs and due to the definition, many schools are now having to administer some programs (degree or certificate) in a clock hour environment for Title IV purposes.  

I recently did a Clock Hour Webinar with North Carolina in an effort to help schools primarily in their community college system that are now having to work with clock hours but have little or no experience in this area.   This Webinar was recorded.  So, in an effort to help other schools, please feel free to go to the link provided and view the clock hour recording.  You will be prompted to enter a name and email address - https://www302.livemeeting.com/cc/fsatraining/view?id=TB081111

Retirement

And just in case you have not heard, Yolanda Adams, Region IV training Officer, retired from government service at the end of July.  Your remaining training officers in Region IV are Michael Roberts and, of course, myself.   We wish Yolanda all the best.

I hope you have a great week.

Your neighborhood FED,

DAVE

David Bartnicki
Federal Training Officer
ED/FSA/Atlanta
 



  
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