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1. Clarify the reporting requirements for a change in ownership to better reflect the many types of changes in people or entities that may occur and that must be reported to the Department, including clarifying when a “person” (defined in 34 CFR 600.31) refers to a natural person or an entity.
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- Numerator
- Denominator
- General Information
- Going Forward
What’s the Same
As always, Title IV aid is included in the 90/10 calculation’s numerator, while exceptions remain to exclude Federal Work Study (FWS) and the institutional match for Federal Supplemental Educational Opportunity Grants (FSEOG).
What’s New
In addition to Title IV aid, the numerator now includes Federal Funds, defined as “any other education assistance funds provided by a federal agency directly to an institution or a student, including the federal portion of any grant funds provided by a non-federal agency.” The most impactful funds that will now be included in the numerator are benefits awarded by the Veterans Administration and the Department of Defense. This change could cause significant increases to some institutions’ 90/1...
What’s the Same
Despite initial attempts to eliminate payments for a variety non-Title IV programs from the denominator, the regulations discussed prior to the consensus vote continue to include most of this revenue. Institutions may continue to count revenue from non-Title IV eligible education and training programs offered by the institution as long as it is taught by one of its instructors at its main campus, one of its approved locations or an employer facility. Revenue for training required to uphold st...
What’s New
As touched on above, certain non-Title IV program payments were eliminated from the denominator. Specifically, revenue generated when an institution is only providing its facilities for test preparation courses, acts as a proctor or oversees a self-study course can no longer be counted. The regulations do specifically indicate that non-Title IV training revenue must come from sources unrelated to the institution. Proceeds from the sale of receivables, with or without recourse, are also no lon...
What’s the Same
As always, the 90/10 calculation must be performed on a student-by-student basis for an institution’s fiscal year. The Presumptive Rule remains in effect, which means Federal Funds are counted first, except for: 1. Grant funds from non-federal public agencies (with caveat noted above requiring federal portion of these funds to be allocated to the numerator) and private sources unrelated to the institution; 2. Funds from contracts with the institution to provide job training to low-income indi...
What’s New
Historically, the 90/10 calculation has always been performed on the cash basis. However, the new regulations include a qualifier to this method, with the apparent intent to prohibit institutions from delaying drawdowns until the subsequent fiscal year to circumvent and pass the 90/10 rule. The qualifiers direct: 1. Institutions on advanced payment methods or heightened cash monitoring 1 (HCM1) to drawdown all funds that students are eligible to receive prior to the fiscal year end; or 2. Ins...
With the NPRM expected soon, institutions and financial aid professionals soon will have their chance to provide comment on the regulatory changes, including the 90/10 rule. We encourage everyone to share their opinion on the new rule by submitting a comment to the NPRM. For more information on the 90/10 rule and other questions about Title IV regu...
Aug 31, 2023 · Our objective was to determine the U.S. Department of Education’s (Department) processes for (1) overseeing proprietary institutions’ compliance with 90/10 revenue requirements and (2) reporting of 90/10 revenue information to Congress and the public. Our audit covered the Department’s oversight and monitoring processes for
What GAO Found. The Department of Education makes loans available to students to help them pay for higher education at public, private non-profit, and proprietary schools, and the students who attend proprietary schools are most likely to default on these loans, according to analysis of recent student loan data.
Jul 31, 2023 · 2023 Title IV Audit Guide. Guide for Financial Statement Audits of Proprietary Schools and For Compliance Attestation Examination Engagements of Proprietary Schools and Third-Party Servicers Administering Title IV Programs (March 2023) and Transmittal Letter.
In addition, the Department’s 90/10 revenue report to Congress for award year 2019–2020 was incomplete. Finally, the Department did not publicly disclose the proprietary institutions that did not meet 90/10 revenue requirements on the College Navigator website as required by the Higher Education Act of 1965, as amended (HEA).
Aug 17, 2009 · In order to protect against the use of high school diplomas from diploma mills to obtain Title IV eligibility and help ensure that only students with the ability to benefit from higher education receive federal aid, the Secretary of Education should: (1) create guidance, using information gathered from public hearings or other forums regarding ...
