Beware of Doing This Without Help

I used to attend monthly meetings of The Dean’s Roundtable, a meeting of academic deans of universities in Southern California. You would be familiar with several of the schools represented there. At one meeting, one of the deans said something like this:
I have something to tell you. I couldn’t talk about it while we were going through it, but now I can. Until a surprise visit by the Department of Education [DOE], we thought everything was fine in our financial aid office. It was not. The DOE found a number of violations. What was so awful was not the huge fines they were ready to impose. More terrible was that they were threatening to take away our authorization to distribute federal student financial aid. We have had financial aid for years. Most of our students receive it. If we had lost our authorization, we might have gone out of business.
When this dean finished, another dean raised his hand and said the same thing happened at his school. I took this to heart as a lesson learned. Having seen how even experienced schools can get in trouble, serious trouble, with the DOE, Agron & Associates, Inc. recommends that a school applying to distribute Federal Student Financial Aid work with a “Third-Party Servicer,” such as FAME, Inc. We further recommend that the school take advantage of the Third-Party Servicer’s ongoing training. Keep in mind that the regulations are complex, detailed, and constantly changing. Your school may have trouble keeping up to date, so the experience and expertise these companies offer are quite necessary.  

When Can You Apply?

In short, candidate membership in the ABHE or TRACS qualifies schools to apply to the US Department of Education for distributing Federal Student Financial Aid. With ATS, institutional accreditation is required.




Upon achieving candidacy, ABHE’s status with the US Department of Education allows their schools to qualify to distribute Federal Student Financial Aid (FSFA) to bachelor students and graduate students. The Department of Education authorized the ABHE to distribute aid to graduate students in 2020. ATS’ status with the US Department of Education allows their institutionally-accredited schools to qualify to distribute Federal Student Financial Aid (FSFA) to Master or Doctoral students. But, this does not include candidate members or programmatically-accredited schools. Upon achieving candidacy, TRACS’ status with the US Department of Education allows their schools to qualify to distribute Federal Student Financial Aid (FSFA) to Bachelor students and graduate students.
Close-up of 5 dollar bill.

Offering financial aid begins with a complex process of paperwork and regulations that “Third Party Servicers” are available to help with (Photo Credit: Didier Weemaels from Unsplash).

How to Gain Access to Federal Funding for Your Students

To provide Federal financial aid (Title IV) funding to your students, you must meet institutional eligibility requirements with the US Department of Education. The first step is to apply for an OPE (Office of Postsecondary Education) ID number at This will be your institution’s identification number relative to the Department of Education and accessing Title IV funding and reporting. Once you receive an OPE ID number, you can apply to participate in the Federal Student Financial Assistance Programs. However, there are several criteria an institution must meet prior to approval. To apply, the institution must have
  1. Taxpayer Identification Number (TIN),
  2. Dun & Bradstreet (DUNS), and
  3. two years of teaching students with continuous enrollment for each program submitted prior to the date of application to participate. You can’t combine short programs to make a longer eligible program.
And there are minimum program lengths:
  1. Pell Grant eligible programs must be at least 15 weeks in length and provide instructional time equal to at least 600 clock hours, 16 semester credits, or 24 quarter credits (allows for partial Pell and Direct Loan eligibility).
  2. Pell Grant eligible programs that are at least 900 clock hours and 26 weeks in length, or 24 semester or 30 quarter credits and 30 weeks in length (allows for a full annual Pell and Direct Loan eligibility, depending upon student eligibility).
  3. Programs at least 10 weeks in length and that offer at least 300–599 clock hours of instructional time are Direct Loan eligible only, but they must meet the 70% placement and 70% completion rule for the 12-month period ending June 30 of the most recently completed Federal financial aid award year. The calculation for both rates must have an auditor’s attestation.
The institution must also have
  1. less than a 33% withdrawal rate of all regular enrolled students for the last completed award year (July 1–June 30);
  2. an approved accrediting status, which means at least having candidate membership with an agency approved by the US Department of Education (Agron & Associates, Inc. can help you achieve that status); authorization that approves the school as a postsecondary institution;
  3. a method for grievances to be reported to the state;
  4. two years of audited financial statements in accordance with GAAP and GAGAS accounting standards. If you do not meet the 1.5 ratio on the most recent financial statement you will be required to put up a letter of credit equal to 50% of the estimated total of Pell and Direct Loans based on the estimate of the number of students that are entered on the Eligibility application (E-App); and
  5. several specific written policies for Admissions, Institutional Refunds, Satisfactory Academic Progress (SAP), and Return to Title IV (R2T4) funds. ED may ask for additional information during the approval process. Many institutions also utilize a Third-Party Servicer to assist them in writing acceptable policies and procedures to ensure they meet regulatory standards as well as complete the initial application for the institution.
Though the requirements for offering Federal Student Financial Aid may seem daunting, the accreditation professionals at Agron & Associates, Inc. as well as the financial aid experts at FAME, Inc. are available to help.


  • Sally Samuels

    Sally Samuels is the Director of Compliance at FAME, Inc. and one of the country’s leading authorities on Federal financial aid administration with more than 40 years of “in the trenches” experience. As a respected Industry leader, she is frequently called upon to speak at School, Accrediting, Regional and State conferences as well as to act as school liaison during program reviews and compliance audits. Having processed, reviewed and taught financial aid for over 38 years Sally’s experience includes representation at over 300 program reviews and certification visits for postsecondary institutions. In addition, Sally brings real life experiences, observations and illustrations to her audience, adding a touch of humor to regulatory compliance. Her style makes the sometime complex topics easy to understand and audiences always come away with practical knowledge that they can apply to their everyday situations. Sally is a board member for the Private Career Colleges & Schools (PCCS), a former board member and now serves on several committees for the American Association of Cosmetology Schools (AACS), as well as a member of NASFAA & SASFAA. Her experience and regulatory knowledge make her uniquely qualified to bring you the latest regulatory information and training.

  • David Agron, Ph.D.

    Dr. Agron is the managing editor of Christian Academia Magazine. He also serves as an accreditation consultant. Since 1999, Agron & Associates, Inc. has specialized in helping Christian colleges achieve accreditation. In both roles, his mission is to help raise up Christian colleges in quality, quantity, reputation and impact for the Kingdom of God. If you would like to discuss how his firm can help your school achieve accreditation, contact him at [email protected].

FREE Bonus with Subscription

FREE Bonus with Subscription


The Authentically Christian College:  
Strategies for Facilitating Spiritual Formation on Campus

How do we keep a focus on God as a significant part of our schools? There is so much more that can be done other than weekly chapel and classroom devotionals. This book offers: practical concepts, outside of the box ideas, and cost effective strategies. A must have resource for Christian Academia!
EXISTING subscribers:
Check our next issue for your download link.

Please check your email for confirmation. Then download link will be sent.

Share This