Determining Financial Aid Eligibility

On June 1, 2011, the Department of Education released details for a new process for demonstrating the extent to which certificate programs prepare students for gainful employment* in a recognized occupation. IU must be able to defend its assertion that this is true when requesting that a non-degree program be eligible for federal aid. IU follows this method to ensure each program is rigorously evaluated prior to any request for financial aid eligibility.

* According to the Department of Education, a program leads to gainful employment if estimated annual loan payments of typical graduates do not exceed 20 percent of discretionary income or 8 percent of total earnings. Programs that exceed these levels would be at risk of losing their ability to participate in taxpayer-funded federal student aid programs.

The following information, if required, is to be submitted using the "Notice of Intent" form.

Financial Aid Eligiblity Rules pertaining to “Gainful Employment” require that campuses demonstrate that a program prepares students for credible vocational fields in order to be considered for Title IV student aid programs.

  1. The requestor must indicate if the certificate is for a vocational education program that prepares completers for gainful employment in a recognized occupation; otherwise, this program cannot be considered for aid eligibility.
  2. If the certificate program prepares completers for gainful employment in a recognized occupation, the requestor should provide a Standard Occupation Code (SOC). If none is provided, the proposed certificate program is ‘not eligible.’
  3. If the program is presented as eligible for financial aid, the requestor must attach a completed Notice of Intent to Offer a Gainful Employment Program, to include:
    • Institution Name
    • OPEID (campus Federal Identification Code)
    • Program Name(s) and Program CIP Code(s) supported by this documentation
    • Narrative description of how the institution determined the need for the program. For example, describe what need this program will address and how the institution became aware of that need. If the program is replacing a current program(s), identify the current program(s) being replaced by the new program(s) and provide details describing the benefits of the new program(s). If the program will be offered in connection with, or in response to, an initiative by a governmental entity, provide details of that initiative. The institution must retain documents that support this description for review or submission to the Department upon request.
    • Narrative description of how the program was designed to meet local market needs, or for an online program, regional or national market needs. For example, indicate if Bureau of Labor Statistics data or State labor data systems information was used, and/or if State, regional, or local workforce agencies were consulted. Include how the course content, program length, academic level, admission requirements, and prerequisites were decided, including information received from potential employers about course content, and information regarding the target students and employers. The institution must retain copies of documents and its analysis for review and submission to the Department upon request.
    • Narrative description of any wage analysis the institution may have performed, including any consideration of Bureau of Labor Statistics wage data related to the new program. The institution must retain copies of analysis documents for review and submission to the Department upon request.
    • Narrative description of how the program was reviewed or approved by, or developed in conjunction with, one or more of the following:
      • Business advisory committees
      • Program integrity boards
      • Public or private oversight or regulatory agencies (not including the state licensing /authorization agency and accrediting agency)
      • Businesses that would likely employ graduates of the program
      • Date of the first day of class. Include both the first day the program was or will be offered by the institution, and the day you would like to begin disbursing Title IV funds to students enrolled in the program.
  4. For example, describe the steps taken to develop the program, identify when and with whom discussions were held, provide relevant details of any proposals or correspondence generated, and/or describe any process used to evaluate the program. The institution must retain, for review and submission to the Department upon request, copies of meeting minutes, correspondence, proposals, or other documentation to support the development, review, and/or approval of the program.