Why you need a Title IV check-up

As you move forward in 2018, you may have already started to act on personal health or financial issues, but not items of concern in your institution’s Federal funding program.

Some of those issues may seem insignificant and not worth the effort to review, but if not addressed and acted upon, they will likely result in penalties and restrictions on your Title IV funding when the U.S. Department of Education (DOE) performs its program review.

Here are some of those small but highly significant items to review as you begin your school’s administrative health checkup in this new year:

Getting the Dates Right is one of the most important procedures your institution can regularly perform. Which dates? You must ensure that the issuance date of Federal Pell Grant and Federal Direct Subsidized, Unsubsidized, and PLUS Loan disbursements are posted to a student’s account on the SAME date that these disbursements are reported to the Common Origination and Disbursement System (COD).

Any variance from this procedure could be deemed out of compliance and could have disciplinary consequences for the institution.

Crime and fire safety statistics for your institution must be reported to the DOE and appear on the school’s website.  Therefore, another important procedure is to maintain precise records and be ready to respond to any inquiries about them.

The date your reports are due is stated on the letter from the DOE, usually sent in the early summer. Information on filing your 2017 annual reports indicating that the institution has retained records of all crime and fire infractions or absence of infractions is found at the DOE 2017 Campus Safety and Security Survey webpage.

Gainful employment reporting (usually required of schools with non-degree diploma or certificate programs) must be submitted by October 1 after the award year has ended.

As with all reports required by the Federal government, you can avoid due date panic and rush errors by putting policies and procedures in place throughout the year to gather accurate data. Reporting requirements you need to follow are found in the Financial Student Aid Handbook volume 2, chapter 4.

IPEDS (Integrated Postsecondary Education Data System) surveys begin in February each year and are reported to the National Center for Education Statistics.

In February, institutions are required to submit student financial aid usage reports, graduation rates, 200% graduation rates, admissions information, and outcome measurements.

In April, fall enrollments, financial information, human resource information, and academic libraries are reported.

In October, institutional characteristics, completion rates, and 12-month enrollment data are reported.

These reports require serious data collection and much advanced preparation before the reporting deadlines.

Disclosures regarding the institution must be available or published.

  • >Academic programs offered, degrees provided, information about facilities, faculty and instructional personnel must be published.
  • Accreditation, approvals and licensure information must be available.
  • If an institution advertises or uses job placement statistics to recruit students, those statistics must be published on the institution’s website or otherwise made available to students.
  • Completion / graduation and transfer out rates must be published or otherwise made available to prospective students prior to the students entering into any financial arrangements with the institution.
  • The institution must publish or make available to its students the institution’s annual retention rates of first time undergraduate students seeking certificates and degrees.
  • The institution must publish or make available on request an annual report regarding student body diversity. This report indicates the percentage of students enrolled, full-time students who are male, female, Federal Pell Grant recipients and self-identified members of major racial or ethnic groups. These items are also reported through the annual IPEDS reports.
  • Institutions must publish their Transfer of Credit policies.

Student Financial Aid information must be published. As well, students must be advised how to apply for financial aid and where to obtain assistance.

Net Price Calculator must be posted. Each Institution that participates in Title IV federal student assistance programs must post a net price calculator on its website to provide estimated net price information to current and prospective students.

Observance of the United States Constitution is required under federal regulation.

The regulation states that “each institution that receives federal funds for a fiscal year shall hold an educational program about the United States Constitution on September 17 of such year for the students served by the educational institution.”

If September 17 falls on a Saturday, Sunday or holiday, ceremonies should be held during the preceding or following week. The method or procedure for performing Constitution and Citizenship Day is not prescribed, but some recognition process must be performed.

Voter Registration. Institutions in most states and the District of Columbia must make a good faith effort to distribute voter registration forms to their students. Schools in Idaho, Minnesota, New Hampshire, North Dakota, Wisconsin, and Wyoming are exempt from this requirement. Accordingly, the school must make voter registration forms readily available to its degree, diploma, or certificate-seeking (FSA-eligible) students.

Drug and Alcohol Abuse Prevention Materials must be made available to educate and advise students of the prohibitions against the possession, use, or distribution of illicit drugs. In addition, schools must advise students of legal sanctions for violation of the illicit drug policies.

A description of the health risks associated with the use of illicit drugs along with available counseling, treatment, and rehabilitation must also be provided to students.

Family Rights and Privacy Act (FIRPA) Notice. Institutions receiving federal funds must provide a notice to all students currently in attendance or parents of students currently in attendance about their right to inspect and review the student’s educational records and to seek amendment of the student’s educational records that might be inaccurate, misleading, or otherwise in violation of the student’s privacy rights.

Vaccination Policies for the institution must be published on the institutions website or in the institution’s publications.


Failing to carry out these Federal requirements are normally discovered in an audit or U.S. Department of Education Program Review, and the gravity of such findings would fall in the lap of the reviewer.

If one or two required items were overlooked, corrective action would be required but probably no penalties would be assessed. On the other-hand, if several items were not performed or improperly performed, minor to serious penalties could be assessed, depending on the judgment of DOE officials.

With all these reporting requirements ahead of you, now really is a good time to assess your institution’s administrative health. For more information, review “Institution Reporting and Disclosure Requirements” in Appendix F of the Federal Student Aid Handbook.


  • Harry Weber

    Dr. Harry V. Weber is President of Weber & Associates, Inc., specializing in managing Pell Grant, Campus-Based financial aid programs, and Federal Direct Loan processing. Dr. Weber leads a qualified team that manages every type of academic measurement, working with 1,000 different programs, including clock-hour, credit-hour, non-standard term programs, in-class and online programs, certificate, diploma, associate, baccalaureate, masters, and doctoral degree programs. Weber’s team currently serve over 200 institutions in over 300 locations in 35 states and 3 foreign countries with a total financial aid experience in excess of 350 years among its staff in the service of higher education institutions. www.weberassociatesinc.com

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