MiscellaneousTopics

Program Integrity

Evaluating the Validity of High

School Diplomas

High School Diploma

School must develop and follow procedures to evaluate the validity of a student’s high school diploma If the school or the Department has reason

to believe that the high school diploma is not valid or was not obtained from an entity that provides secondary school education

§668.16(p)

High School Diploma

New question #27 on 2011-2012 FAFSA What is the name of the high school where

you received or will receive your high school diploma?

High school name, city, and state Department will maintain list of high

schools populated by National Center for Education Statistics (NCES)

Definition of a Full-Time Student:

Retaking Coursework

Retaking Coursework

Allows repeated coursework to count towards a student’s Title IV enrollment status in term-based programs

Allows a single repetition of previously-passed coursework

Does not allow for repeated coursework due to failure of other previous coursework

§668.2

Incentive Compensation

Incentive Compensation Adds new definitions

Commission, bonus, or other incentive payment

Securing enrollments or the award of financial aid

§668.14 (b)(22)

Incentive Compensation

Examples of covered activities:-Recruitment – solicitations, contacting

potential students, assisting prospective students in completing enrollment applications, targeted information dissemination

-Financial Aid - completing financial aid applications for prospective students, including FAA Access tool

Incentive Compensation

Examples of exempt activities: -Recruitment – advertising to groups of

prospective students, collecting contact information, determining whether an enrollment application is ‘materially complete’

-Financial Aid – general student counseling, financial aid counseling, online course support, tutoring

Incentive Compensation

A school must not provide any commission, bonus or other incentive

payments based directly or indirectly on success in

securing enrollments or financial aid to any person or entity engaged in student

recruiting or admissions activities, or in making decisions about the awarding of student financial assistance

§668.14(b)(22)

Incentive compensation

A school, its contractor, or other entity may make merit-based compensation adjustments that are NOT based in any part, directly or indirectly, on success in securing enrollments or awarding financial aid

§668.14 (b)(22)

Incentive Compensation Profit-sharing payments cannot be

made to any person engaged in student recruitment or admission activity, or in making decisions about Title IV funding awards if based on number of students enrolled due to the covered activities of that person

Incentive compensation

If an employee receives multiple compensation adjustments in a calendar year and is engaged in any student enrollment or admission activity, or in making decisions about Title IV awards, this will be considered to be a violation IF those adjustments are based on these activities in any manner.

§668.14(b)(22)

Incentive Compensation This restriction does not apply to the

recruitment of foreign students living in foreign countries who are not eligible to receive federal student aid.

§668.14(b)

Misrepresentation

Misrepresentation Program integrity principles

A potential student needs to have a clear understanding of any program in which he may enroll.

A school is responsible for providing complete and accurate information about its programs.

Misrepresentation

Requirements of HEA and regulations A school must not make any substantial

misrepresentation regarding the following: Nature of its educational programs Financial charges to students Employability of its graduates

§668.72-74

Misrepresentation Definition expanded

Any false, erroneous, or misleading statement

Made directly or indirectly To a student, prospective student or

any member of the public, or To an accrediting agency, to a State

agency, or to the Department By. . .

§668.71

Misrepresentation Definition (cont’d)

an eligible school one of its representatives, or any ineligible school, organization, or

person with whom the eligible school has an agreement to provide educational programs, or to provide marketing, advertising, recruiting or admissions services

§668.71

Misrepresentation Misleading statement includes any

statement that has the likelihood or tendency to deceive or confuse

Substantial misrepresentation still includes any misrepresentation on which the person to whom it was made could reasonable be expected to rely, or has reasonably relied, to that person’s detriment

§668.71