On July 1, 2021, several regulatory packages take effect including changes to the Clock-to-Credit Conversion formula.  If you offer undergraduate non-degree programs in credit hours the new rules will determine the number of Title IV credit hours associated with each class in a program.

According to an electronic announcement from FSA, under the previous formula, schools were required to use a ratio of 37.5 in-class clock hours to each semester/trimester credit hour, or 25 in-class clock hours to each quarter hour, except that institutions could include “work outside of class” (out-of-class) hours as long as the in-class hours met a lower ratio – 30 clock hours to one semester hour or 20 clock hours to one quarter hour and the institution’s accrediting agency had not identified any problems with the institution’s establishment of credit hours. But under the new rules, out of class work time has been eliminated for the purposes of determining the number of Title IV credits in an eligible program.

Beginning on July 1, 2021the new conversion formula must be applied unless:

  • The program is at least two academic years in length and provides an associate degree, a bachelor’s degree, a professional degree, or an equivalent as determined by the Department (Note that this does not permit an institution to ask for a determination that a non-degree program is equivalent to a degree program); or
  • Each course within the program is acceptable for full credit toward a single associate degree, bachelor’s degree, or professional degree provided by that institution, or equivalent degree as determined by the Department, provided that the institution’s degree requires at least two academic years of study and the institution can demonstrate that students enroll in, and graduate from the degree program.

Make a note – if these changes affect your programs, you will need to report the change to ED on your E-App.

  • If the new calculations result in a change in the number of Title IV credit hours in a program, the institution must submit an E-App immediately at to update both the number of clock hours and Title IV credit hours in the program; or
  • If the new calculation does not change the number of Title IV credit hours in the program, the institution should update the E-App to change the number of clock hours reported for the program when the next update or recertification application is submitted.

Several other changes to regulatory requirements that were also part of the Distance Education and Innovation Final Regulations released on September 9, 2020, take effect on July 1, 2021, unless an institution decided to implement them early, including:

  • Satisfactory Academic Progress
  • Return to Title IV Funds
  • Distance Education
  • Institutional Eligibility
  • Subscription-Based Programs