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Ask a Fed: GE, Modules, State Authorization, and More

December 21, 2016

Federal Training Officer David Bartnicki recently provided these updates:

Student Transfers from Closed Schools

We continue to receive lots of questions from schools accepting students who have transferred from a closed school especially around the topic of closed school loan discharges. ED recently posted some additional guidance around some of the specific criteria that we review when considering whether or not to approve a closed school discharge. Some of the highlights include –bartnicki

A number of factors may be relevant in making a determination of comparability of a program of study, including:

  • The academic or professional nature of the two programs;
  • The similarity in course requirements;
  • The treatment of transfer credits by the institution accepting the credits (for example: as general education credits or electives, or as credits toward completion of the core program);
  • The disposition of a state approving agency or accrediting agency on the comparability of the programs.

Factors that indicate a borrower is completing a comparable educational program “by any other comparable means” include, but are not limited to, the receiving school evaluating the borrower’s competencies through testing or interviews that translate to credit or steps toward completion of core credits for the comparable program.

For more information please review the December 7, 2016 electronic announcement.  

Accrediting Council for Independent Colleges and Schools (ACICS)

On December 12, 2016, the Secretary upheld the Senior Department Official decision and the recommendations of NACIQI and ED staff to cease recognition of ACICS. His decision is considered final and officially starts an 18-month timeframe for institutions to find another accreditor in order to continue participating in federal student aid programs.

For schools currently accredited by ACICS, please review the December 13, 2016 electronic announcement and information located at There are several adjustments automatically happening to ACICS schools from a Title IV perspective and many steps a school must take to ultimately remain TIV eligible in the future. Any specific Title IV eligibility questions should be directed to your regional school participation team.

Gainful Employment

In a recent electronic announcement dated December 16, 2016, the Department indicated that the 2017 GE Template is not expected to be released until the latter part of this coming January. Once the Department releases the 2017 GE Disclosure Template, institutions will have at least 60 days to be in compliance with the regulatory posting and dissemination requirements. In a future Electronic Announcement, we will provide notification that the 2017 GE Disclosure Template is available for use and indicate the deadline date by which institutions will be expected to post the new template to the GE Program’s website, provide the template in all promotional materials for the program, and provide prospective students with the template (via hand-delivery or email).

Please note that separate from the disclosures, once a school has received a Notice of Determination from ED (due to final GE rates) that a program could become ineligible, the school must provide a warning to its GE program students and prospective students no later than 30 days after the institution received the Secretary’s Notice of Determination.

In addition, ED is clarifying that the 2017 GE Disclosure Template must also be distributed to prospective students as a separate document (once available) before the student signs an enrollment agreement, completes registration, or makes any financial commitment to the institution. The disclosure template may be provided by hand-delivering (individually or as part of a group presentation) it to the prospective student, or by sending it to the primary email address used by the institution for communicating with that student, ensuring that the disclosure template is the only substantive content in the email.

For more detailed information please read the December 16, 2016 electronic announcement.

State Authorizations

Final regulations for state authorizations were posted in a final federal register dated December 19, 2016. Please note that these regulations become effective July 1, 2018. Highlights include:

  • Multiple Routes to State Authorization for Distance Education: The final regulations require institutions offering distance education or correspondence courses to be authorized by each State in which the institution enrolls students, if such authorization is required by the State. The regulation recognizes authorization through a state’s participation in a State authorization reciprocity agreement, as long as the agreement does not prevent a state from enforcing its own laws.
  • State Complaint Process Documentation: The final regulations require institutions to document the state process for resolving student complaints regarding distance education or correspondence courses in States in which the institution enrolls students.
  • Disclosure Requirements: The final regulations mandate certain public and individualized disclosures to enrolled and prospective students in distance education or correspondence courses, including the disclosure of adverse actions taken against the institution, the institution’s refund policies, and whether each program meets applicable state licensure or certification requirements. The regulation also requires institutions’ to explain to students the consequences of the student moving to a state where the institution is not authorized, which could include loss of eligibility for federal student aid.
  • Branch Campuses or Additional Locations in a Foreign Location Authorization: The final regulations make clear that foreign branch campuses or additional locations be authorized by the appropriate foreign government agency and, if at least half of a program can be completed at the foreign location or branch campus, be approved by the accrediting agency and reported to the state where the main campus is located.

Please review the 12/19/16 federal register for the complete regulations, along with school comments and ED discussions in the preamble –

R2T4 and Modules

Policy has recently clarified some guidance for the training officers based upon some school questions that I wanted to share with my SASFAA colleagues.

Once a student attends a module within a term, they are considered to be in a module setting throughout the entire term even if they later drop the module and are only enrolled in full-term courses.

In a case where a student is only enrolled in module 1 and completes that module, then during the time between modules adds and then drops a course in a subsequent module before ever attending it, the student would be considered to have simply completed the period and no R2T4 calculation would be required. If the student had actually started the second module and then dropped the course, R2T4 would apply and it would include all days in modules 1 and 2.

Abbreviated Loan Periods

I have gotten a few questions on awarding loans during an abbreviated loan period (occurs with certain nonterm and nonstandard term programs with overlapping AYs between schools) and wanted to clarify that the COA used to determine the loan amounts for the abbreviated loan period is based on the costs and time period associated with the abbreviated loan period.

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