Description: Tags: Edcr
Description: Tags: Edcr
Disadvantaged and
Completion Rates
Appeal
This section is divided into two parts. The first part (pages 289
through 319) provides background information on the economically
disadvantaged and completion rates appeal and outlines the
process and procedures for submitting an economically
disadvantaged and completion rates appeal. The second part
(pages 320 through 328) provides sample material as it would
pertain to an economically disadvantaged and completion rates
appeal.
PART I: Background,
Process, and Procedures
QUALIFYING
What is an economically disadvantaged rate?
An economically disadvantaged rate is the percentage of at least
half-time students enrolled in a school’s Title IV eligible programs
who are eligible to receive at least one-half of the maximum
Federal Pell Grant award regardless of the school’s enrollment
status or cost of attendance or who have an adjusted gross income
below the poverty level. 1
Q . What is a regular Please refer to page 293 for a more in depth discussion of how to
student? calculate an economically disadvantaged rate.
A. A regular student
is defined as a person
who is enrolled, or What is a completion rate?
accepted for
enrollment, at a school
for the purpose of
A completion rate is the percentage of a school’s regular students
obtaining a degree, that completed their program of study, as defined in the Higher
certificate, or other
recognized educational
Education Amendments of 1965, as amended (HEA), Section
credential offered by 435(a)(4)(A)(ii).
that school as defined
in 34 CFR Section
600.2. Please refer to page 299 for a more in depth discussion of how to
calculate a completion rate.
♦ be subject to sanctions;
1
HEA Section 435(a)(4)(A)(i)
2
HEA Section 435(a)(4)(A)
♦ be a degree-granting school;
Q . What if the school
♦
is not sure whether it is
demonstrate that at least 66 2 3 percent of its students classified as a degree-
granting or non-degree-
came from economically disadvantaged granting school?
backgrounds as defined in HEA Section A. A school should
435(a)(4)(A)(i); refer to its Eligibility and
Certification Approval
Report generated by
AND the Department’s Case
♦
Management and
demonstrate that at least 70.0 percent of its regular Oversight Office.
AND/OR
v 2
enrolls at least 66 3 percent of its students from
economically disadvantaged backgrounds as defined
in HEA Section 435(a)(4)(A)(i);
AND
Please refer to the “Cohort Default Rate Effects” section for more
information on sanctions associated with cohort default rates.
3
34 CFR Section 668.17(c)(5)
4
34 CFR Section 668.17(a)(5)
100 X
number of regular students enrolled on at least a
half-time basis in a Title IV eligible program during
the selected 12-month period
A school must select a 12-month period that
ends during the six months immediately
preceding FY 1998. Information on how to
select an acceptable 12-month period is
provided on page 227 in the "Exceptional
Mitigating Circumstances Appeals" section.
5
HEA Section 435(a)(4)(A)(i)
AND
♦ enrolled on at least a half-time basis for one or more
days during the selected 12-month period.6
A student’s entire enrollment period does not have to
Note fall within the selected 12-month period. A student
who enrolled prior to the 12-month period but
completed/withdrew during the 12-month period is
considered to have been enrolled during the 12-
month period. In addition, a student who enrolled
during the 12-month period but completed/withdrew
after the 12-month period is considered to have been
enrolled during the 12-month period. Finally, a student
that enrolled prior to the 12-month period and
continued to be enrolled until after the 12-month
period is considered to have been enrolled during the
12-month period.
6
HEA Section 435(a)(4)(A)(i)
Page 294 FY 1998 Official Cohort Default Rate Guide
Information for Schools on Adjustments and Appeals Economically Disadvantaged and Completion Rates Appeal
OR
♦ the student has an adjusted gross income that is
below the U.S. Department of Health and Human
Services poverty level for a calendar year that
overlaps with the 12-month period selected by the
school.8
7
HEA Section 435(a)(4)(A)(i)(I)
8
HEA Section 435(a)(4)(A)(i)(II)
1996/1997 1997/1998
Award Year Award Year
7/11/1996 7/10/1997
12-month period
7/11/1996 7/10/1997
12-month period
AND/OR
♦ entered active duty in the U.S. Armed Forces
within a year of leaving the school.
100 X
number of regular students who were initially enrolled
on a full-time basis in a Title IV eligible program who
were originally scheduled to complete their programs
during the same 12-month period selected for the
economically disadvantaged rate.
9
HEA Section 435(a)(4)(A)(ii)
80 + 70 + 45 + 45 = 240
100 X = 80.0%
300
♦
credential offered by that
school as defined in 34 enrolled in a Title IV eligible program;
CFR Section 600.2.
10
HEA Section 435(a)(4)(A)(ii)
AND/OR
AND
♦ the signature of the school’s President/
CEO/Owner, followed by a signature block
providing the signer’s name and job title
OR
♦
Q . What is a regular
student? the Social Security numbers, in numerical
A. A regular student is order, of all the school’s regular students who
defined as a person who
is enrolled, or accepted were:
for enrollment, at a
school for the purpose of v initially enrolled on a full-time basis;
obtaining a degree,
certificate, or other
recognized educational v enrolled in a Title IV eligible program;
credential offered by that
school as defined in 34
CFR Section 600.2.
v originally scheduled to complete their
program of study during the selected 12-
month period.
OR
AND
AND
AND
AND
Step 8: Within 60 calendar days after receiving the school’s Due date for
submitting
official cohort default rate notification letter, a school the appeal to
must submit the following to the Department at the the
address on page 319: Department.
♦
to page 327
the independent auditor's opinion on Example for a sample
management's written assertions. auditor’s
opinion.
The following page provides an overview of the MATERIAL that
should be included in a school's economically disadvantaged and
completion rates appeal submitted to the Department.
AND
Forrest University
1212 Wedgewood Lane
Leonardtown, Wisconsin 12345-6789
(123) 456-7890
Sample Letter
October 12, 2000
Sincerely,
Larry Lloyd
Larry Lloyd, President
Fill out Column 5 or Column 6 of the spreadsheet: For those student identified as
Header: Enter FY 1998 Economically Disadvantaged Rate in economically disadvantaged in column 4, provide either:
the center of the header area. In the left-hand area,
enter the school’s name, the school’s OPE ID number, Column 5: The student’s EFC (in Column 5a) and the award year
the school’s selected 12-month period, the applicable associated with the EFC (in Column 5b).
award years, and the applicable calendar years.
In order to be considered economically disadvantaged, the
student’s EFC must be associated with an award year that
overlaps the selected 12-month period.
Economically Disadvantaged and Completion Rates Appeal
Column 6: The student’s AGI (in Column 6a), family size (in Column
Footer: Enter the date the spreadsheet was prepared in the left 6b), and calendar year (in Columns 6c).
side of the footer area. Set up automatic pagination in the
right side of the footer area so that the specific pages and In order to be considered economically disadvantaged, the
the total number of page numbers show on each page student’s AGI must be associated with a calendar year that
(example: page 1 of 10 pages). overlaps the selected 12-month period.
Sort: Sort the students in social security number order OR in Instructions for Box B (located in the shaded area on the sample
order by last name, followed by first name. spreadsheet)
On Rows 1, 2, 3, and 4, use the draw tool to draw a rectangle. Using the text-
box tool, draw another box for Box B information. In this box, enter exactly the ♦ Count and record the number of X’s that appear in
same information in exactly the same order as listed on the sample Column 4. This is B1 in the calculation. This is the
spreadsheet. number of students from economically
disadvantaged backgrounds.
On Row 5, enter exactly the same column names in exactly the same order as
listed on the sample spreadsheet.
♦ Count and record the number of students listed in
Column 1. The total number of students will be B2
On Row 6 and below, include the following data for each student who will be in the calculation. This is the number of students
included in the school’s economically disadvantaged rate.
enrolled on at least a half-time basis at the school
during the selected period.
Economically Disadvantaged Rate SPREADSHEET INSTRUCTIONS
Box B
# of Economically Disadvantaged Students (from Column 4) [B1] 140
# of Students (from Column 1) [B2] 200
Economically Disadvantaged Rate [100 x B1/B2] 70.0%
SSN name enrollment dates qualifies as is marked 5a has an EFC, is marked and 6a has an AGI, 6a has an AGI,
Information for Schools on Adjustments and Appeals
(sort in numerical (from MM/DD/CCYY economically and enter the economically enter family enter calendar
Page 323
List and count the students who will be included in the calculation of the school’s
completion rate using a spreadsheet software application such as Excel or Lotus 1-2- Column 6: Enter the MM/DD/CCYY to identify the date the degree was
received for each regular student who met the successful
Page 324
3. The resulting spreadsheet must be sent to the Department.
completion conditions by receiving a degree from the
The spreadsheet should be on 8 ½” x 11” paper in a landscape (horizontal) layout. A school.
sample spreadsheet follows these instructions.
Column 7a: Enter the program of study for each regular student who
met the successful completion conditions by transferring to
Header: Enter FY 1998 Completion Rate in the center of the header a higher level educational program. Do NOT use
area. In the left-hand area, enter the school’s name, the school’s abbreviations.
OPE ID number, and the school’s selected 12-month period.
Column 7b: Enter the MM/DD/CCYY to identify the transfer date for
A school must base the completion rate on the same 12- each regular student who met the successful completion
month period used for the school’s economically conditions by transferring to a higher level educational
disadvantaged rate. However, the students contained in program.
each rate may NOT be the same.
Column 7c: Enter the name and address of the school to which the
student transferred for each regular student who met the
successful completion conditions by transferring to a higher
Footer: Enter the date the spreadsheet was prepared in the left side of level educational program.
the footer area. Set up automatic pagination in the right side of
the footer area so that the specific pages and the total number of Column 7d: Enter the name of the higher-level educational program to
Economically Disadvantaged and Completion Rates Appeal
page numbers show on each page (example: page 1 of 10 which the student transferred for each regular student who
pages). met the successful completion conditions by transferring to
a higher level educational program.
Sort: Sort the students in Social Security number order OR in order by
last name, followed by first name. Column 8: Enter the GPA for each regular student who met the
successful completion conditions by remaining enrolled and
On Rows 1,2, 3, and 4, use the draw tool to draw a rectangle. Using the text-box maintaining satisfactory academic progress at the school at
tool, draw another box for Box D information. In this box enter exactly the same the end of the selected 12-month period.
information in exactly the same order as listed on the sample spreadsheet
Column 9: Enter the date the regular student entered the U.S. Armed
On Row 5, enter exactly the same column names in exactly the same order as listed Forces for each student who met the successful completion
on the sample spreadsheet. conditions by entering into the U.S. Armed Forces.
On Row 6 and below, include the following data for each regular student who will be Instructions for Box D (located in the shaded area):
included in the school’s completion rate.
Column 1: Enter the Social Security number using hyphens to separate the
numbers (example: 000-00-0000) for all of the school’s regular ♦ Count and record the number of Xs that appear in Column
students who meet the conditions identified on page 300. 5. The total number of Xs will be D1 in the calculation.
This is the number of regular students who
Completion Rate SPREADSHEET INSTRUCTIONS
Column 3: Enter MM/DD/CCYY (month, day, and year) to identify the date ♦ Count and record the number of regular students listed in
that each regular student was originally scheduled, at the time of the Completion Rate spreadsheet by counting the number
enrollment, to complete his or her program of study. of entries in Column 1. The total number of regular
students will be D2 in the calculation. This is the number
Column 4: Enter MM/DD/CCYY (month, day, and year) to identify the of regular students who were scheduled to complete
beginning and ending dates of the regular student’s enrollment. their programs during the selected 12-month period.
Column 5: Enter X if the regular student meets one of the successful ♦ Calculate and record 100 x D1/D2 and record the result in
completion conditions as identified on pages 301 through 303. Box D on the Completion Rate spreadsheet. This
percentage is the school’s completion rate.
Box D
# of Regular Students Who Met Successful Completion Conditions (from Column 5) [D1] 240
# of Regular Students Originally Scheduled to Complete Programs (from Column 1) [D2] 300
Completion Rate [100 x D1/D2] 80.0%
(sort in scheduled to (from MM/DD/CCYY completion received to a higher to which the to which the point entered the
numerical complete to MM/DD/CCYY) conditions, level program student student average U.S. Armed
order) program enter X (MM/DD/CCYY) transferred transferred Forces
of study (MM/DD/CCYY)
(MM/DD/CCYY)
(MM/DD/CCYY)
Page 325
Economically Disadvantaged and Completion Rates Appeal Information for Schools on Adjustments and Appeals
Forrest University
1212 Wedgewood Lane
Leonardtown, Wisconsin 12345-6789
(123) 456-7890
Sample Letter
November 1, 2000
Forrest University, OPE ID# 000070, is submitting its FY 1998 exceptional mitigating
circumstances appeal based on our economically disadvantaged and completion
rates.
Please see the attached spreadsheets for the economically disadvantaged and
completion rates, along with the independent auditor's attestations on our school's
management assertions.
Sincerely,
Larry Lloyd
Larry Lloyd, President
Enclosures
Global Accounting
1212 Hickory Lane
Hughesville, Florida 12345-6789
(123) 456-7890
October 19, 2000 Sample Letter
U.S. Department of Education OPE ID#: 000070
Default Management Division
Attn: Economically Disadvantaged and Completion Rates Appeal
Portals Building, Room 6300
1250 Maryland Avenue, S.W.
Washington, D.C. 20024
We have examined management’s written assertions that the information contained in Forrest
University’s OPE ID# 000070 exceptional mitigating circumstances appeal based on its
economically disadvantaged and completion rates, is complete, accurate and determined in
accordance with the requirements of HEA Section 435(a)(4)(A). Management is responsible for
Forrest University’s compliance with those requirements. Our responsibility is to express an
opinion on management’s assertions about the institution’s compliance based on our
examination.
Our examination was made in accordance with standards established by the American Institute
of Certified Public Accountants and, accordingly, included examining, on a test basis, evidence
about Forrest University’s compliance with HEA Section 435(a)(4)(A) and performing such other
procedures as we considered necessary in the circumstances. We believe our examination
provides a reasonable basis for our opinion. Our examination does not provide a legal
determination on Forrest University’s compliance with specified requirements.
In our opinion, management’s written assertion that Forrest University has an economically
disadvantaged rate of 70.0% and a completion rate of 80.0% for the twelve-month period
beginning on July 11, 1996 and ending on July 10, 1997, is complete, accurate, and determined
in accordance with the requirements set forth in HEA Section 435(a)(4)(A), and is fairly stated, in
all material respects.
This report is intended solely for the information of an audit committee, management, and the
U.S. Department of Education. However, this report is a matter of public record and its
distribution is not limited.
Respectfully submitted,
Mary Smith
Mary Smith, CPA
President, Global Accounting, Inc.