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Thursday, August 22, 2013

Institutional Eligibility for Participation in Title IV Student Financial Aid Programs



Alexandra Hegji
Analyst in Social Policy

Shannon M. Mahan
Specialist in Education Policy


Title IV of the Higher Education Act (HEA) authorizes programs that provide financial assistance to students to assist them in obtaining a postsecondary education at certain institutions of higher education (IHEs). These IHEs include public, private nonprofit, and proprietary institutions. For students attending such institutions to be able to receive Title IV assistance, an institution must be

• licensed or otherwise legally authorized to operate in the state in which it is physically located,

• accredited by an agency recognized for that purpose by the Department of Education (ED), and

• certified by ED as eligible to participate in Title IV programs.

These three requirements are known as the program integrity triad and are intended to provide a balance between consumer protection, quality assurance, and oversight and compliance in postsecondary education.

Institutions also must offer at least one eligible program. Eligible programs are those that lead to certain defined degrees or certificates, prepare students for gainful employment, and fulfill durational requirements.

Proprietary institutions must meet additional HEA requirements that are otherwise inapplicable to nonprofit institutions, including deriving at least 10% of their revenues from non-Title IV funds (also known as the 90/10 rule).

Specific criteria are required for Title IV participation if an institution offers distance or correspondence education. In addition to being authorized to operate within the state in which it is located, an institution offering distance or correspondence education must also be accredited by an agency recognized by ED as an accrediting agency able to evaluate distance education programs. Finally, an institution is ineligible to participate in Title IV programs if more than 50% of its courses are offered by correspondence or if 50% or more of its students are enrolled in correspondence courses.

As the 113
th Congress begins to consider HEA reauthorization, several issues related to institutional eligibility for Title IV programs may become a focus. These issues may include the sources from which proprietary institutions derive their revenue and whether current or new requirements should be applied to the rapidly expanding online education market.

This report first describes the types of institutions eligible to participate in Title IV programs and discusses the program integrity triad. Next, it discusses additional issues related to institutional eligibility, including recent statutory and regulatory changes pertaining to institutional eligibility requirements. Finally, this report explores some of the emerging issues that the 113
th Congress might consider.


Date of Report: July 23, 2013
Number of Pages: 36
Order Number: R43159
Price: $29.95

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