MAY | 2016


 I’ve gotten a lot of questions lately about the new regs that go into effect in a few months. Back in October, the U.S. Department of Education published a number of final regulations in the federal register that go into effect on July 1, 2016. If you’re looking for dear colleague letters, aside from the fact that ED hasn’t published much implementation guidance; you’re probably looking in the wrong place. Guidance will be provided primarily through the program integrity Q&A website. I’ve summarized the recent guidance below so you don’t have to go digging through the crumby fed register. You’re Welcome!

 Cash Management – Ensure that students have convenient access to their Title IV HEA program funds, do not incur unreasonable and uncommon financial account fees on their Title IV funds and are not led to believe they must open a particular financial account to receive their Federal Student Aid.

Under the final rules, an institution that charges a student up front for more than one payment period (for example, for the entire program of study) must prorate those charges for the purpose of crediting Title IV funds to a student’s ledger account. The purpose of this new provision is to ensure that a student receives a credit balance to use for non-institutional educational expenses in each payment period, rather than having to wait until a final payment period to receive any credit balance. Proration would include charges for books and supplies that are allowed to be included in tuition and fees.

 If your school is on one of the Heightened Cash Monitoring statuses, the rules are a bit more onerous. By July 1st, HCMI and HCMII schools will have to pay any credit balance that is due before they request disbursements. The new rules also prevent schools from obtaining commonly used authorizations to hold credit balance funds.

 Repeat Coursework – Allow an institution offering term-based programs to count for enrollment status purposes, courses a student is retaking that the student has previously passed, up to one repetition per course, including when a student is retaking a previously passed course due to the student failing other coursework.

RC-Q4: A graduate student must complete a dissertation writing course each term of enrollment. Is this subject to the restriction on repeating courses?

RC-A4: Yes. The new regulations related to retaking coursework apply to the definition of full-time for undergraduate and graduate students. [Guidance issued April 28, 2016]

Clock-To-Credit-Hour Conversion – Removed the provisions under which a State or Federal approval or Licensure action could cause a program to be measured in clock hours.

CH-Q9. The revised regulations streamlining the clock to credit hour conversion will go into effect on July 1, 2016. For affected institutions that wish to transition back to credit hours, what if the payment period doesn’t end at the end of a term? When can an institution transition to credit hours?

CH-A9. An institution may transition to credit hours from clock hours at three different times:

  • Institutions can teach the remainder of the current program to currently enrolled students as a clock hour program;
  • New students (enrolled after 7/1/16) may be enrolled under the new regulations;
  • An institution may choose to switch from clock hours to credit hours at the end of a payment period (as long as the payment period ends after 7/1/16).

CH-Q10. When can an institution update its Eligibility and Certification Approval Report (ECAR) to reflect the new status of the program?

CH-A10. An institution can update its ECAR starting July 1, 2016, after the revised regulations take effect.

You can read the full Federal Register here:

 Read on for more of the latest and , remember “The obstacle is the way!”

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