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hello everyone hello you know we get lucky and we get the session right after lunch that is not fair so no falling asleep please we would appreciate that or at least no snoring so my name is Rene Schultz I'm an institutional improvement specialist with the Department out of the San Francisco regional office and with me is Kimbrough hello and Kye is out of Washington DC and she's with our performance improvement group and also with us somewhere is Susan Powter and Susan is one of our is also with the same group that Chi is with but she's out of Seattle but all of us work primarily in the area of eligibility so if you don't mind we're gonna sit down through the presentation lots of walking lots of walking so how many of you are relatively new to the whole process of dealing with the e app anybody okay it kind of gives us an idea and I know it's a little you don't use it that often right so when you get back into it it's a little it can be a little intimidating so hopefully this session we're gonna talk about that a little bit we'll talk about the app and we're going to talk about a lot of other things but we are going to be covering a lot of information so we would ask if you wouldn't would be so kind as to hold your questions until the end and then we'll ask you to step up to the mic and ask your questions and we'll also ask you to tell us if you could your name and your type of school whether your public proprietary private nonprofit etc it helps us to better answer your question because there are differences sometimes when we give that answer and if your question is really specific to your institution then I would ask that you catch us on offline afterwards or head to the Resource Center to the eligibility table it's not gonna learn how to use this new clicker there we go so in order for a student to be eligible for title for federal student aid they also have to attend a school that is eligible so if your school is eligible for for federal student aid and the students are eligible you have the happy students on your left if your school loses their eligibility and a student wants to attend your school they cannot get financial aid and that makes them very unhappy like the picture on the right while I'm making light of the situation it is truly an important thing to maintain your school's eligibility so that students can access the fitting of the federal student aid that they're eligible for when they attend your school so here's what we plan to cover in our session today eligibility requirements in other words what it takes to be an eligible institution we'll discuss the basics not everyone is sure what the differences between an app the ECAR the PPA so we'll talk about that we'll also talk about why and when you need to update the e app also known as the electronic application and about the many different considerations when making those updates we'll talk about recertification and how that works in the requirements involved and lastly we'll share the common mistakes we see when we are reviewing e apps from all types of schools and that can cause delays in processing your application so first let's talk about what makes the school an eligible institution for purpose as a federal student aid so perd the 30 34 CFR part 600 any institution that meets these requirements in order to participate in federal student aid these basic requirements are the same whether you're defined as an institution of higher education a proprietary institution or if you're considered a post-secondary vocational institution so again regardless of what type of school you are you must be legally authorized by a state as a post-secondary school be accredited provide an eligible program at least one annum it is regular students only individuals with a high school diploma or its recognized equivalent or individuals beyond the age of compulsory school attendance in the state in which the school is located so in 34 CFR 600 point 7 we talked about several limitations which can affect a school's eligibility an otherwise eligible institution that does not offer at least an associate's degree becomes ineligible if it violates among other requirements the incarcerated student limitation of 25 percent or the Correspondence School limitation of 50 percent or the correspondence student limitation of 50 percent so what's the question is what's the difference what's the definition of correspondence so volume 2 of the handbook defines it as a correspondence course is a home-study course for which the school provides instructional materials including examinations on the materials to students who are not physically attending classes at the school the interaction between the instructor and student is limited not regular and substantive and primarily initiated by the student and you can find a definition of that real clearly in volume to roughly page 2 - 36 so waivers are available for the correspondence student limitation the incarcerated student limitation and the limitation on students without a high school diploma or equivalent and also a school is not eligible for files for relief from bankruptcy or as entered against entered against it an order for bankruptcy the school is also ineligible if any either these circumstances apply to an affiliate of the school that has the power by contract or management or ownership authority to direct or cause the direction of the management of policies of the school it's always a good idea to check officials for debarment so that's something we do internally is we do check to determine if any officials in the higher levels of the school or owners for that matter have have been debarred so debarment happens when an official has pled guilty or nolo contendere to or found guilty of a crime involving the acquisition use or expenditure of FSA program funds or has been judicially determined to a committed fraud involving FSA program funds so keep in mind that any of you can check for a potential office officials debarment on sam.gov you all heard have you guys heard of sam.gov so a system for awards management so whenever you're looking to hire someone it's always a good idea to check them out on that just run them through as a make sure they're not excluded from participating in any federally funded type programs so when a school is being considered for approval for participation by the department whether they're a brand new school for title four or are applying for recertification there are two distinct types of approval full certification or provisional certification so there's one case when the type of certification that the school receives is clear all schools that are being approved to participate for the first time in title four are always provisionally approved what we want to look at at that point is we want to see one full year one full fiscal year of compliance audit and financials before we pull a school we allow a school to become fully certified when a school applies for recertification we look at many different things and we're going to talk about a lot of those in a little bit but that's what we look at we look at these there and things to determine if we'll offer full certification or provisional certification and for how long in each case when we're a school when we're determining if a school should be provisionally or fully certified we look at financials and compliance audits we look at whether they were submitted timely did the financials have a passing composite score will a letter of credit be required for failing scores will the school be required to be on HCM one which is heightened cash monitoring one of course public schools don't have composite scores but private nonprofits and proprietary schools do so we also look at if there were any audit findings and if so how many or how serious were they once we reviewed these things as well as any recent program review findings we as analysts can make a wreck make a recommendation to the team if a school has had any findings or the program reviews pretty bad that will most likely prompt us to put the school on a provisional status for a period of up to three years now if all of the aforementioned items a review look good little to no findings good financials everything submitted on time then we would most likely fully certify the school now keep in mind our preference our preferences that we fully certify you that means we see your paperwork coming through a lot less often let's work on our side right just like on yours cuts down on the workload so since we don't typically have to touch your yep again that is of course unless you're reporting changes to us it makes things go a lot quicker on both sides so let's talk about some of the basics so we're all on the same page so many of you know these terms but let's talk about these acronyms like the thousands so we already have right so they have different meanings and purposes that we'll talk about each of these individually so what is an app what is a PPA and how are these different from the e car so the electronic application is the application for approval to participate in the federal student aid programs it is located at the website listed there which is Elledge cert IDI gov that's where you apply for recertification but that's also where you do all these other changes change of officials adding additional locations removing additional locations and any alleged updates the PPA or the program participation agreement is basically a requirement excuse me a requirement for certified or participating schools to sign but it is a contract between the school and the department which out which outlines the regulations if the school is required to follow how many of you guys have actually sat down and read all 14 to 17 pages of the PPA okay I'm impressed pretty good I had to sit down I mean there's a lot in there that you really don't realize and it's not all stuff that the Department puts out there it's other regulatory requirements that schools are expected to follow that are not Department regulations so I would encourage you if you haven't done so to take a moment and read your PPA you'll be very it'll be very interesting when the schools go through any process where new PPA is generated by the Department the previous PPA is void as of the new PPA date so the PPA is signed by both the school and the department and the signed PPA must be kept on filed by the school along with your copy of your most recent ECAR or eligibility certification approval report so keep in mind the PPA located on the eledge sir website because you guys can get a copy any time but this countersigned copy that we send you after your recertification that's it so can we get it for you yes but it may take some time so I would highly suggest that you keep it in a safe place so you know where it's at and the reason being is that who's gonna ask for it your auditor if you get a program review will ask for it when we do new school visits which is primarily what I do I ask the school where's your PPA and they always rent and scramble for it I'm like no no no I just need to know that you know where it's at the PPA also tells you when it expires and the ECAR has that same information as well so the ECAR the eligibility certification approval report so that's really a snapshot of the schools participation your programs your locations your officials everything all in one neat package so a current copy of the ECAR must be kept on file by the school and you want to keep it with your PPA so anytime you make changes even if it's in between you know let's say that you did your PPA two years ago but since then you made numerous changes to programs and officials etc every time you do those changes and that that application that yep is processed you get a new ECAR or it's updated so you want to make sure you print out the most recent copy because that's what your auditor is going to ask for so this time I'm going to hand off the presentation to my co-presenter Kai yes No you gotta sleep okay great thank you for the thumbs up we're gonna talk about updating the application once you have completed your application and you are now participating whether you are participating on a fully certified PPA or provisional PPA there are certain actions that happen throughout the course of the years at your institutions that we need to know about and that you have to update us on some things are just acknowledgments and some things that you have to submit to us have to go through an approval process so we're going to talk about what those acknowledgments are first and then we'll go through the approval process well the what those approval items are and then there are depending on the type of certification that you are on whether it's provisional or whether it's fully certified you actually could self certify or you may have to wait for approval from the department before you do anything I know in past conferences this has been this has been an area that you know it's kind of eye-opening so I just want to make sure that if you have questions that are specific to your school as Renee stated earlier we do have computers set up in the Resource Center where you can come reach out to either one of us or other colleagues so we can actually look up your ope ID and give you specific information on your institution so acknowledgments what kind of acknowledgments do we have to let the department know so we can just say thanks for telling us if you change the name of the school that's something that we would need to know if you change the address of a main or any of your additional locations if you close the previously approved location if you change from or two o'clock hours to credit hours that's something that we also need to know as we all know that there is a conversion that we actually need to make sure that that program remains eligible if you decrease in level of educational program offerings so at one point you were offering master's degree excuse me or a bachelor's degree and now you're only offering associate's degree if you decrease it this is something that we would also need to be made aware of changes to members of the Board of Directors as Rene stated earlier any changes to a Board of Directors presidents financial aid officers CFOs we need to know all of that because of the whole debarment check so again that's the reason why you need to let the let us know these things to ensure that the people that you have in the higher offices of your institutions that they are eligible and capable of actually performing these duties at your institution if a new person or entity acquires 25 percent or greater ownership without a change of control so there's no change of control and ownership they're just acquiring more than we just need to we just need to know about it finally any acknowledgments regarding the third-party servicers so if you have a change in third party servicers you have a modified contract as your third party service they're doing any additional work have they have you taken some of the items on their contract away and you've actually given it to another third party servicer if you're terminating the contract with them altogether and if the one under contract goes out of business or if they file for bankruptcy so any changes to your third party servicer again these are some of the things that you would need to let us know with it you have to report that to us within ten days of the change so again if you change the school you change the address just know that within ten days of that change happening go ahead - Ellis cert IDI gov open it up make the change and then submit it to us there's no need to wait for approval for acknowledgement actions again it's just letting us know that these things have taken place now what do we need to know for approvals or what is it that you all need to know that you all have to send to us for approvals if your institution is seeking a new location and you would like to offer title for that location that requires an approval most new educational programs if you have a new educational program that you're looking to offer at your school that also may need approval if you're adding programs at a program level offerings at a higher level than you currently have which is the exact opposite if you were decreasing if you had a bachelor's degree and you were going to an associate's degree that's just an acknowledgment but if you have an associate's degree and now you want to offer bachelor's master's or a PhD program that is something that you have to get approval for same thing with distance education offered in the state where a school has no physical location that is something also that you need to get approval for I believe session 13 talks about distance education so if you all are offering distance ed if you're thinking about offering distance ed session 13 here at the conference is talking about that as there are several new rules that came out about that recently changes in ownership resulting in a change of control remember we only need an acknowledgment if there's an entity acquired 25 percent or more but there was not a change in control if there is going to be a change in control then we would need to you all would need to have an approval before you can move on with that there's a lot that goes on in a change of ownership and also a change in a creditor so if you guys are your leaving one creditor and going to another one that's another one where we would need to make sure that you have the proper accreditor and that their accrediting the proper I want to say what I wanna say credit the proper entity so if they're accrediting program or is an institutional creditor so we need to make sure that you have the right one as well as to make sure that the accreditor is recognized by the Department of Education if you go to ed gov and look on the creditors you can see which of creditors the department actually recognizes so not all accrediting agencies out there are recognized by the department so if you're looking to go to a new accreditor for whatever reason before you start entertaining them please go on to Ed gov and look under creditors and make sure that they are an accreditor that the department recognizes I'd like to add something to that so we recently in a San Francisco office we had a school that generally the schools will let us know when they have they want to make an accreditor change which is great that's what we expect you to do but this particular school didn't notify us beforehand they went ahead and dropped their old accreditor before getting approval for their new accreditor and lost eligibility so not to scare you but I want to make sure this is the type of thing changing an accreditor is a big deal so I would encourage you to reach out to your regional your school participation division and talk with them before you do any changes with your accreditation sorry and also along with the PPA ECAR look at your accreditation letters see when the expiration is coming around accreditation visits they are not they're not done in a weekend there's a lot that has to be done with the accreditation visits and there's usually a long time span before you can actually get that approval before they can come out so just make sure you keep up with your accreditation letter as well to see when that expiration date is coming up so you all can get prepared especially the new FA s that are in here please please please go and get the accreditor letter reach out to your accrediting agency this could be the very first time that you've actually met with them or that you talk to them get together with the with the other officers in your school the Registrar's Office the Bursar's Office Controller whichever one you guys have and make sure that when the accrediting visit happens that you all have everything that you need to present to them so that way it can make the visit smooth and you can get your approval letter you can get your your approval letter more quickly than we've seen some takes we've had horror stories on that but please please please just make sure you pay attention to your accreditation expiration date so when you we also have you update the application when you're seeking new locations on the e car that Renee had talked about it has several sections that are on there one of the sections it lists all of your locations it lists your main location that has been approved it also lists any additional locations that have been approved to offer title for just because you open up another location the approval to offer title for does not automatically extend to any new locations that you have opened up so if your school is growing and you have acquired a building down the street that you can actually sit this new program that you you know that's going there and they're actually going to be there 100% of the time you have to let us know and update in order to get that location approved so you can offer title for to those students that are sitting at that location for that program pretty much what I just said if 50 percent or more of an educational program is offered at the new location the school must report the location to us in some cases schools must wait for Ed's approval we'll talk about that in a coming slide if you're not required to wait for approval you have to report it to us within 10 days of disbursing title for aid so if you you have to wait for approval before you can disperse title for a if the school the main location is provisionally certified and you will see that on your PPA the PPA actually says provisional certification you're on some type of heightened cash monitoring or reimbursement so if your school is on HCM one or HCM two or if you're on the reimbursement method if you're acquiring the assets of another school you have to wait you cannot just automatically disburse aid to students of the assets at that school if we have not gone through the process as far as moving over opt IDs and transferring funds subject to a loss of eligibility for default rates so if your school is going under if you have high CDR and you just receive a sanction that you're about to lose eligibility program eligibility because of high cohort default rates at that point you cannot just automatically disperse title for funds and if you're required by it to receive approval before dispersing title for if you look on your PPA there are provisional codes that are on there if you have a provisional code that says that you cannot expound in locations until you receive approval from IDI that is another reason why you would not be able to disperse funds to any new locations prior to getting approval from it you should talk to your arm school participation division in the region that you are located if the location that you are if the new location that you are trying to acquire was a facility of another school that has since closed or if you're doing a teach out of a closing school at that schools location there is an additional process that you have to go through in order to be eligible to acquire that location or to perform the teach out at the location and for those students to still receive aid so if that is the situation that is going on please reach out to the SPD as their additional there's additional information that we need from you before we can go ahead and approve that so we will look at all applications received whether you can go ahead and disperse right away or if you have to wait to disperse all applications for new locations the IDI analysts will review we have to make sure that the location meets all eligibility requirements we have to make sure that we evaluate the school's administrative and financial capability if the location approval is required so if you are approved then you may disperse and continue to disperse funds after receiving the approval letter if you are not approved after we have reviewed the application for whatever reason the school is liable for any title for disbursements that they have made to students from the onset so if you started making disbursements in May and you get your denial letter in September all the disbursements that you made through there you are liable for so what makes a location eligible what are we looking for when we are reviewing the application to ensure that the new location that you want to add will meet the requirements one we have to have the accreditor and state approval if you are a foreign school than the foreign government or the Ministry of Education we would have to have approval from them we have to make sure that there's a street address the location cannot have a peel box we have to have a street address for the location if it's located at the site of a formally eligible location it has to meet all the requirements to become an elder location of another school so has that location is that location now disassociated with the ope ID that it was associated with before is it completely closed down has the closure gone through or is everything still active in our system so these are some of the things that we would look at if it's located at the site of a currently eligible institution you have to let us know what is that relationship is this the partnership are you just sharing the building do students from that ope ID do can they attend classes in this building we need to establish what the relationship is first before we can move forward with a location that is attached to a currently operational ope ID number and if the location is changing affiliation and we have been notified of the change so that we can do the funds delivery so if this is a location that is associated with one ope ID and your school is now acquiring it you will have to let us know we have to go through a change of affiliation process to ensure that the fun codes all been moved over properly as well as the ope ID that the location was formerly under has now been switched to your current main ope ID so these are the location eligibility requirements and if you're thoroughly confused just call your SPD update the application the final update that we actually look for are when you're requesting new educational programs so the e card lists all Edgeville eligible program level offerings so this would be again if you have an associate's degree bachelor's degree master's degree so all of that is also on the e car it also lists the eligible programs that have been approved so if you have certificate programs vocational programs those programs are also listed on the e card not all of the programs so not all of your bachelor's degree programs not all of your master's degree programs are on there just those are just those certificate programs or those vocational programs will be listed on your eeeek are fully certified schools can make a self determination of program eligibility in some cases we'll talk about that a little bit later and then provisionally approved schools must report and obtain approval before dispersing funds to any new programs that that you wish to add to your arm to your portfolio so schools must submit an app reporting the new educational programs before dispersing funds if the school is provisionally certified you're receiving funds under reimbursement or any of the other heightened cash monitoring ACM 1 or ACM 2 conditions the program is measured by direct assessment so if you have a direct assessment program that also that needs to be submitted in the app in order for us to approve it the program is a CTP program a comprehensive transition or post-secondary program you also have to submit an application for that that go through the review process before you can start and have it approved before you start dispersing funds to students in that program also if the schools P PA says approval is required before adding additional programs same thing with locations there are provisional codes on the PPA if you are provisionally certified that states you cannot add new programs without first coming through and depending on what the provisional certification is for it may be a situation where we ask that you wait to add this new program to have the administrative capability issues rectified before we do that or if you're showing progress and at that point the program may be approved and you can start dispersing aid to that program the school is in this initial period of participation and subject to a two-year rule so new schools this is your first year in participating in the program new programs are subject to the two-year rule and if you've gone through the initial application process the two year old is something that you should be familiar with where the school the program has to be operating for two consecutive years 24 consecutive months and you have continued enrollment in that program let's see so schools can make self-determination of new programs and disperse funds to students if it's not required to receive approval provided that it determines the programs are eligible and they have received both state and accrediting agency approvals before dispersing funds here is this is key because there are some programs where you have to get not only do you have to have state approval for the institution but some programs you need state approval just to offer the program so just make sure depending on the state that you live in that you check with them to make sure you have the proper approvals because once the information comes in to us and you submit the application this is the documentation that we are going to be asking for for any new gainful employment GE programs the school must submit and yet within ten days of the school receiving final approval from both its state and accrediting agencies in order to make the change and that each program meets all required GE disclosure and certification requirements now this morning and the general session and the federal update general Brown and I believe Cynthia had alluded to the new changes that have come about I believe it was ei 122 they came out in June that let the community know that the GE disclosure and certification requirements have been rescinded effective July 1 2020 as of July 1 2019 institutions can early implement this rule however you have to early implement the rule if you have not early implements it then you are still review are still bound by the requirement that is in effect until July 120 funny now if you opt into early implementation you would let the department know by going into question 69 on the e app and let us know that pretty much you know we're early implementing the GE rescission and then if at any time during the program review or a school visit we ask you for the documentation what we are looking for is some type of correspondence that stated ABC University has as of this date has elected to early implement the GE rescission based off of EA 122 it doesn't even have to be that formal but email letter memo but there has to be something stating as of what dates after July 1 2019 that the school has decided to early implement and so that way you don't when you come out for a program review if you're up for recertification if you submit any other application that requires approval these are the things that we're looking at and if you don't have the disclosure templates up or if we don't have the certifications then we won't hold up your application as long as you tell us hey by the way we're early implementing we don't need to have this and then we can just move on and we don't question less you and can i clarify something so we're telling you in the prod that in the process of adding programs when you're updating the application that's when you tell us that you are early implementing that you're implementing early rescission I don't we don't want you to tell us now unless you're doing something else so in other words just keep that in mind when or if you update your application to add new new GE programs that we then want you to tell us if you're doing using early recession if you're not you don't have to come you don't have to contact us to tell us that you're choosing to do that if you're not making any changes okay just clarify although we'd love to hear from you okay coming up to the final slides on new educational programs reporting of disarming programs on the E AB schools are encouraged to report programs for which they have made a self determination during the recertification process or sooner except for GE programs again which must be reported in ten days and eligibility of these programs will be reviewed prior to the program being added to the e car as an eligible program so again edie reviews applications for all reported educational programs to ensure that the reported programs meet the eligibility requirements schools admin and financial capability has been is set and is in place and if approved you can go ahead and disperse or continue dispersing funds after receive approval and the same thing with locations if you have if after you have sent in your application and the application has been has been denied then you will be liable for any disbursements that you've made for that new program so the program eligibility requirements accreditor and state approvals matches the e app name and program length make sure that the zip code is consistent with the name of the program make sure that it leads to a recognized occupation we're required and that's the standard occupational classification or the sock code and those are on the zip and socket WEP is really what is it just stopped we'll get that for you - senator so to check on that it meets the minimum weeks and clock or credit hours and it meets the clock to credit our conversion where required does not exceed by more than 50% the minimum number of clock hours established by the state for training in an occupation for which the program prepares the student and programs which are required by the state to be based on clock hours can now allow AE to be calculated based on credit hours if the school chooses so if your so if you choose if you want to calculate based on credit hours and if because your state at one point had you know required it based on I'm sorry if the state y cannot get this right so programs which are required by the state to be based on clock hours can now be calculated based on credit hours if the school chooses so if the state says it has to be clock hours you can now do it based off of credit hours I love that Bureau of Labor Statistics Falco's Bureau of Labor Statistics their website all right we're rounding this up so program eligibility requirements and also has to meet special requirements that there's a direct assessment program cdcl gen 13.10 and that's just a Dear Colleague letter it came out in the year 2013 and it's the number ten and that's on the icebag website and then meets the special requirements of the ccp program which is the Dear Colleague letter gen 1101 so finalizing the update this is probably the most important part of the update is to make sure that you send in all accrediting and state authorization approvals for any changes or additions any required documentation that comes up in a section M of the e app once you go through and then the most important part is to make sure that you submit the signature page we have to have the signature page of the application in order for us to actually work on it and process that you have no idea how many applications we have just sitting because we do not have the signature page from the from the authorizing officer at your institution so now give it over to Renee to talk about recertification my favorite subject not-so recertification means that the school is applying for continued participation within the title for HEA programs and just like all communication with the department this process has completed online via the e app it's funny though sometimes you get schools especially new schools they'll call up and say hey Renee just want to let you know that we're we add a new new program or we've got a new official we just hide that's awesome but you got to do it on the Yap oh that's right that's right so let's talk specifically about recertification so all participating schools must go through recertification and as we talked about a bit ago that could be in a year it could be in six years so ideally you calendar the date out so you'll remember to complete the yeah we do send out Ihram email reminders to school officials but that only helps if your school officials are kept up to date and are correct aunt hen in other words keep them correct please because it helps us tremendously and we don't want a problem where you end up not getting reminded because that official is gone and then we've have had schools lose eligibility that way temporarily of course but it's critical that a school is aware of when their participation agreement expires and when they need to reapply and whether that's the owner of the school or the director financial aid the president I mean not typically the president unless it's smaller school but whoever the official is its responsible for completing the e-app and there are two dates I'd like to call your attention to and I apologize because when we did this presentation I was so busy changing other content I didn't change the date I should have gotten a new so it says 2018 and 2017 but the first date listed is the approval expiration date so that's the day that your schools PPA actually expires very important date the second date where this new red arrow is is the deadline you need to reapply for recertification by you'll notice there 90 days apart so why is it so critical that you reapplied by that recertification date well here's what can happen if your reapplication date like you see here December 31st 2017 and you totally forgot to get the recertification application completed or you didn't hit that submit button by December 31st and your recertification is not complete by the time that PPA expires then come April 1st in this example your school will lose eligibility so if you're ever concerned about timelines and this situation happens to you please reach out to your school participation division so that we can work with you and get you guys back on board as soon as possible so last year we had that very such actually as two years ago last that year we had that very situation of the FSA conference a school came up to the eligibility table and it was Cayenne dye that were sitting there and because she hadn't heard anything from her SPD about the application and it turned out I'm pulling her up in our mainframe I'm not seeing anything she hasn't heard anything I pull it up on the e app website she had not hit submit she literally did everything she was supposed to do and she did not hit submit and if that woman is here today I am sorry and again because she she was very very understandably upset so it's not a good situation we don't want to see your school as lose eligibility any more than you do the individual SPD's work really hard to in those cases to ensure the school stays ineligible for a small amount of period of time as possible but ideally you want to make sure that your reapplication deadline that you make that deadline and then your PPA will extend your eligibility month to month until you can be reproved so again that reapplication deadline is critical make that date and from then on even if it takes six months for us to complete your PPA your recertification your month-to-month until we get it done okay wait a minute I didn't skip to the next slide I'm so sorry okay so what exactly do you need to have ready to complete your recertification application when it's time so you're going to want to have your ope ID and your tin or your EIN number available in order to log in you're gonna want the most recent copy of your accreditation documents both the approval letter and if applicable the list of approved programs your most recent copy of state authorization documents both the approval letter and list of a programs list of approved programs that that's applicable for your school and if you they didn't change it okay so there's been some slight changes to this slide as we talked about earlier with the gainful employment with the early rescission electronic announcement that came out in June we talked about it on slide 32 so that's one change to this particular slide it will be updated and uploaded the gainful employment early rescission gives schools the opportunity in the option to resend their participation in the GE requirements for their GE programs so if you choose to implement that and then you are when you're doing your research ocation we're going to ask if you if you didn't put something on section k question 69 you know that's that freeform box where you can type a note to us or whatever you can put something in there that indicates that your school has chosen to early implement the GE rescission and that's what we need okay and then we won't ask for any additional information on that we may ask for clarification on something else but that that suffices so the other thing you'll want to talk about is keep in mind that if you're choosing two we had actually one school that so far that I know of on our team that is choosing to still cooperate with the GE regulations I don't know why but I mean I wouldn't but but okay so that yeah it's more work so that means the reporting still the disclosure still so they're choosing to do it okay that's fine so we had to make sure that their disclosures are updated and on and uploaded on the website okay most schools made corrections to their zip codes when we went into the whole gainful employment thing several years back but you'll still there's still a requirement so you still want to make sure that the zip codes are correct and as Cynthia said this morning and in general session number two the zip codes are changing in 2020 so you'll want to make sure that your sip codes are updated and still valid with all your programs and for the schools like the community colleges that have a lot of GE programs non-degree programs I'm sorry but I will tell you that we also check those programs to make the zip codes are correct to make sure they're suit codes are correct also when applying for recertification it's always a good time to review your policies and procedures your Clery Act compliance and compliance with the other consumer information there's a document which I don't know how many of you are familiar with the consumer information disclosures at a glance document it's under it's under tools for schools on ifap and if you're unsure where that's at you can check with us afterwards I'll tell you it is the best document ever it's 37 pages last time I looked at it's updated all the time and it has all the requirements for consumer information that a school's expected to comply with so if you haven't seen it great document and great document to share with the rest of your staff internally that may not understand how it's not just financially that's responsible for this stuff right so I wanted to give you guys a quick look what what the Yap website looks like if you for whatever reason have you know new to the game and haven't seen the Yap website these next few slides will walk you through at least a little bit of it with the login process so in this side you see the LH cert website and we call it edge 'l Elledge cert because that's the name of the website Elledge searched gov and that's where the e app is located so if you look at the red arrow that's where you would click on in order to be able to log in so the next screen that pops up you'll need to select one of the links on the left of the screen oops nope just kidding' so this box pops up asking you for a user ID and a password so one thing to keep in mind is the user ID and password is specific to your school and not a user so I know a lot of times we'll get when we have a someone that's not familiar with it and they come on and add a new school and they've never been in a director role before and never had to do this and they Colin I need to update this I need to add myself as a new director but I can't login I don't know what to do so it's the the user ID and password we'll talk about that in a second so the but the username is always Eddie starts with ed they're all caps or lowercase and then your full ope ID number it's always the ope ID number for the main campus in other words ending with a 0-0 are we a question right we're gonna hurry up I'm talking too much so section a so once you log in with the user ID the password the password is the e D also and then the ten number or ein number so if you need help as you're going through the e app and your questions on the additional on the additional sections this is a great help section that you can go to so you want to again please make sure you keep your officials and contact information up to date documents to send in for recertification the most recent copy of your accreditation documents your state authorization documents copies of some policies may be asked for in advance we're starting to do that but just on the limited case so you don't have to send them in anymore for all situations which is nice section L with an original signature section M as well if you're a proprietary institution and form 501 C 3 if you're a private nonprofit institution so how do you know if a recertification of recertification application process is complete on our side well you'll get an email from the end from the department that tells you what the next steps are so you're gonna have 30 days to print out two copies of your new PPA sign them both send them in to us you'll get one copy back that's a copy that I talked about in the beginning of the presentation that's the countersign one you'll want to keep that in a very safe place you'll want to pay close attention to the expiration date of your new PPA and mark the next application deadline on your calendar and know whether the school has been approved for a full participation or provisional participation in a provisional why you'll want to know why I thought we run out of time I was all panicked so avoiding common mistakes so here's the thing we all make mistakes when completing something it's that's important especially right but remember that nothing is etched in stone changes can be made to the e-app after you submit the application no need to worry so to avoid common mistakes when you're working on the e app you'll want to select ok if you're when you're working on the e app and it's not for recertification you need to select and identify each purpose of the application so if you're reporting new officials if you're adding a new location of you're updating programs totally fine you can do 15 things on there we don't care but because it's you're letting us know all the different things that you're wanting to do fine if it's a recertification application we expect you to do that anyway so all we want you to mark is recertification that one thing you can make again 15 updates we don't care anything that needs to be changed but just mark recertification that helps us on our site to pre-op prioritize who which level of analyst gets your school assigned to them that's all it's for but when in doubt if you're not sure contact your school participation Division we are more than happy to answer your questions and we do really try to respond to the schools as quickly as we possibly can usually within 24 hours ideally sooner like we answer the phone so whenever you have officials at your school that need to be updated you'll see that there's a radio button that you check to indicate that there's a change and then you type after you'd make that hit that little button then you type the new officials information please make sure to provide your officials direct lines that's very helpful for us because when we have a question about your app or we have a student complaint or some other reason why we're trying to reach out to your dirac Durer or other officials we really need to be able to reach you a little bit quicker than going through your long voice response unit your VR you sometimes it gets a little frustrating if you've had a board member change and need to make updates please if you remember nothing else from this presentation please don't type overboard members you have to end date those board members then add new want to add the new ones down below in the blank areas don't ever type over those officials the board member it makes a nightmare on our side it's just the way the system is are right now so just do them separately you'll want to ensure that your CI pote ACIP codes are correct as we talked about you want to ensure that you go through all the sections as you're completing the recertification application make sure any updates are done as needed in Section K questions 69 you'll need to add emergency contact information for your school and it needs to be for the officials that are listed in questions 10 through 12 so we need at least two officials emergency contact information we need personal we need their name their title personal either cell phone number or home phone number and personal email not the school stuff because think about all the different national the different emergencies we've had with the weather and so forth over the last few years we've had a lot of cases where we've had natural disasters or the fires in California or flooding somewhere yeah hurricanes oh my gosh so it's important that we know how to get ahold of some official at the institution and we do if any of you guys have had been in one of those schools that we have reached out to we always reach out to make sure what you guys need from the financial aid perspective to help your students as I shared earlier there are times when schools complete all the information but don't hit that submit button please don't be one of them that woman was inconsolable two years ago crying and I was it was very hard to watch until we receive all of the required documents such as the signature page which is section L your accreditation and state approval documents any application is not considered complete including recertification so please make sure you get all your supporting documents in timely as soon as you hit that submit button bless you so it is time for the question and answer section of our presentation and we ask that you please step to one of the microphones to ask your it looks like we only have one microphone this year if you have questions are really specific to your school we can just chat afterwards or we can talk about in the main Resource Center we do hope the presentation was helpful for you and that you enjoy the rest of the conference if you have questions and would like to stay or feathers have questions awesome here is this is the SPD list with the phone numbers for the division the division director at the top who's actually my boss she's doing double duty right now as our regional director and as the national director and then each region's compliance managers so feel free look at your region write down their information reach out if you need because that's what we're we're here for and we want to thank you for attending anybody have any questions anything they'd like to before we start with the questions there was something that I noticed in this presentation where we are asking you all to add things to question 69 question 69 is the freeform box but it is not infinite it only accepts 2,000 characters so as you're going through and you notice that there are certain things that you need to add in the current application that you are in please be mindful of the words that you use because after 2,000 characters it you type it but we only pull in the first 2,000 characters so we know that that is something that we have to get updated but this is something that we discovered just on a whim because we actually missed some important information at the school submitted to us so whereas we say add all of this stuff to question 69 is only limited to the first 2,000 characters that would actually be imported over to our system hi my name is Valerie Richard I'm with the private not-for-profit school and my question is for recertification the accreditation letters at uni are they just the general college we're a Health Sciences College so we have a lot of program accreditation zyou nursing OTA things like that do we have to send all of those program accreditation zazz well letters good question so whenever you have as a private nonprofit school usually you have institute you have institutional accreditation as opposed to programmatic and you may have programmatic as well what we care about is what you're using for financial aid and that would be your institutional accreditation and generally as we all know institutional creditors don't approve program by program so we won't expect to see from you ABC university has added five non degree programs we're not going to expect to see that okay perfectly hi I'm Artie and I'm from Henderson State University and I can saw I have two questions one is very quick and is anytime too early to do reapplication I have a notice that we have to have ours in by March 31 for a June 30th deadline is it too early to get that done now if you know what there's a really bad echo in here so the question what let me just make sure I understand the question with it so the question is it what's too early to redo your to do your research off occation application correct I would say you know 4 months before is probably okay okay things because you don't do it six months before the expiration okay thank you and then my other question is we are a state institution but we are now joining the rest of Arkansas State University system now is that really considered a change of ownership oh you said that now you all are being absorbed by the state of Arkansas well we already it were a state institution but we were just offering independently now we're gonna join the asu system just kind of we're not changing our name we're not messing that's just a change of affiliation that's not a change in ownership the state it depends on the if you guys are joining the state it depends on if you are joining it just as a system as a group or if you are joining meaning that you are if you're not changing your name you're not changing anything you are now just a part of this group the state group there isn't anything maybe financials there are you public where'd you go yeah let's talk afterwards proprietary institution have a question about self-determination I was wondering she can elaborate on that it says that the institution is not required to receive approval in order to start a program you know it can you step a little closer I know it's a cross between not being able to hear in the echo in here so I wanted to ask you to elaborate on the self-determination process so I know we complete the app and then you may you add the change in the program a new program and then what happens do I have to wait for an approval we're here doesn't say I do not have to what is the process will self-determination for self do it so the process for self-determination self-determination for primary school for adding new probe for adding new programs correct Road so what is the process for proprietary schools for adding new programs do you can use self certify or do you have to wait for approval that's your question is that the question well the question is here so it's the school may make a self determination of eligibility mm-hmm without having to wait for an approval right with certain criteria how does that process work for the e/m so as a representation institution I complete EF I add that new program is now approved not approved I add the new program and then what happens okay so you're talking about applying weight so when you go into the EF and you add the new program and what you say you want to know what does the process look like for after adding the program and then waiting to hear back for the approval but here it says I don't have to wait for an approval here it says I don't have to wait for an approval it's a self determination process they stop based off of your PP right based off of your PPA so depending on what it says on your PPA if you're a fully certified institution and it says that you do not have to wait then you can self certify what happens is that you would submit the application within ten days after you have dispersed funds we would look at the application and then we would make the determination if the program that you are dispersing funds to is actually eligible to receive it you would then receive a letter from us stating that congratulations your program has been approved there's nothing that needs to be done you can continue dispersing aid if at the time you receive a letter that says based off of the documentation you've submitted this program cannot be approved at this time then you will be liable for any disbursements that you have made so it's better to wait for an approval first I'm sorry it's better to wait for an approval to avoid the risk he said it's best to wait for the approval and correct it it really just depends on the school and what your PPA says if the program that you have that you are praying that you are applying for approval for if you have all of the documentation that you need your school is in good standings there's no financial administrative capability issues then I don't see a problem with you going ahead and dispersing those funds if it's only at the time during review if there is something it's usually within the paperwork that shows that the program didn't meet eligibility and to be honest with you we would actually tell you that and give you time to try to rectify that but if it cannot be rectified then at that point we would let you know it can't be rectified the program is it's not approved and you'll be liable for any disbursements that you have made hi I'm at a private nonprofit school I am very new to the EAP car all of that so I'm just trying to wrap my head around it I may have misunderstood you so I need some clarification on like reporting programs so like do all of our bachelors programs all of our master's programs everything gets reported and if we offer for example we added some programs that were very similar to other programs they just kind of change classes up a little bit but it's a it's just a separate major so do we report that or how does that work because I kind of understood like anything that was originally like GE has to be reported and then if we have bachelors masters then how does that work for that umbrella like all the different majors in a masters or bachelors yes oh okay so with the private nonprofit or public institution the school does not have to report as long as the school is approved for that level of education so bachelors associates bachelor's master's etc they don't have to individually get approval or list out their individual degrees but what I've found is what's interesting is there are some schools and some directors based on prior experience or what have you that will want that want to list out all their degrees and totally fine there are other situations where you as a new director may pull up the e app or the e car and you're in look at that ECAR and you say well I'm a private nonprofit but I see some of the programs are listed here wire and wire and all the programs listed here it's possible that that institution had at one time been provisional and one of the provisional requirements was that in order to get approval in order to be approved for a new program they had to request that approval so we would make them list it out so that's what can happen sometimes it gave me kind of confusing but if you but if you're a prude for that level of education you don't have to list out proprietary institutions have to list out all programs regardless of educational level or degree or non degree does it answer your question yes okay thank you Thanks you got about three more minutes thanks you guys and you're still all the way core unless you're falling asleep and that's okay have a great conference stay warm not too warm