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4.7 Title IV Program Responsibilities

The institution is in compliance with its program responsibilities under Title IV of the 1998 Higher Education Amendments. (In reviewing the institutionís compliance with these program responsibilities, the Commission relies on documentation forwarded to it by the U.S. Department of Education.)

Link to Original Submission

http://sacs.pvamu.edu/pages/federal_requirements/4.7.html

Off Site Committee Review Findings

Prairie View A&M University provides information to students about their rights and responsibilities under Title IV through the undergraduate catalog, the graduate catalog, and the Office of Student Financial Aid website. PVAMU has a Satisfactory Academic Progress Policy under which students receiving financial aid from federal, state, and/or university sources must make satisfactory academic progress to continue receiving financial aid, or if the student is enrolled and applying for student aid for the first time, the student must demonstrate satisfactory academic progress before applying for financial aid. To ensure awards are processed in compliance with federal requirements, roughly 30% of students receiving Title IV funds are verified under the Department of Educationís Quality Assurance Program. The default rates for PVAMU have declined from 20.8% in 2001 to 11.4% in 2006. Efforts to lower default rates include special videos and modules that teach students how to manage budgets, avoid identity theft, and understand credit. Completion of the USA Funds ďLife SkillsĒ module is a requirement of all financial aid students effective Fall 2008. KPMG, LLP conducts the A-133 audit for the State of Texas, which includes financial aid programs. No questioned costs have been discovered in recent years and the findings noted have been addressed by PVAMU. The institution was issued a Program Participation Agreement in 2004. As part of its reapplication process, the institution closed two sites in Dallas, Texas, that were not officially approved to offer 50% or more of a degree program. PVAMU attests that no sanctions were issued. More recently, the U.S Department of Education notified PVAMU that it plans to perform an off-site review of a distance education (DE) program where requirements call for notification before changing the physical location of the program. PVAMU affirms in its self-assessment that a sanction has not been placed on the institution that limits, suspends, or terminates its ability to award financial aid. Any supplemental information available on the previously mentioned DOE matters should be provided to the on-site committee at the time of its visit.

Prairie View A& M Response to Off Site Review

As noted in the Prairie View A&M University Compliance Certification, the U.S. Department of Educationís Dallas Office initiated an off- site program review of the Universityís compliance with regulations applicable to the Universityís being eligible to award federal student aid under Title IV: (1) notification, and depending upon specified conditions, requested approval of an institutionís initiation of an educational program at a new physical location and (2) approval to offer 49% or more of the coursework required for completion of a degree [1].

Upon receiving the notice of the planned off-site review, the Office of Student Financial Aid became responding to requests for information related to the offering of courses leading to the Masterís degree in Educational Leadership and to the Masterís degree in Counseling.

It was determined by the University that, though unintentional, a pattern of changes in academic leadership, transitions between modes of delivery, interpretations of policy, and physical facilities, the University had not effected the appropriate USDOE notifications or sought the applicable approvals.

The University had notified the Commission on Colleges ĖSouthern Association of College, (COC-SACS) of its intention to offer at Paul Quinn College in Dallas up to 25% of the coursework required for the Masterís Degree in Educational Administration and for the Masterís Degree in Counseling. It did not notify the Commission that at some point between 200l and 2005, more than 50% of the courses required for completion of each of the degrees had been made available [2][3].

The University had notified the Commission that it had, of necessity, relocated from the initial site, Paul Quinn College, to the Dallas Urban League to gain interactive video capability [4]. According to the individual closest to the offerings in Dallas, the Head, Department of Educational Leadership and Counseling, there was an interpretation of the classification of the interactive video site, Dallas Urban League, that led to its not being regarded as a separate site but, instead, as an extension of the main campus since the classes were being taught by faculty on campus[5]. The July 2007 correspondence to the Commission also indicated that the University had relocated from Paul Quinn College to the Center at Cedar Hill located 12.1 miles from Paul Quinn College.

The University acknowledges that, though unintentional, it did not provide notification or seek USDOE approval regarding the 2001 initiation of the offering of courses at Paul Quinn College and, further, that, it did without approval of the USDOE, allow the amount of coursework needed to complete a Masterís degree in Educational Leadership and a Masterís degree in Counseling at the site where federal aid was awarded to exceed 49% of the coursework required for completion of the degree.

In August, 2008, the University voluntarily discontinued offering any educational programs or components thereof in Dallas, Texas. Notice was provided to students and assistance was provided to support their continued enrollment in the Universityís courses and programs for Fall 2008 if they so chose [6].

The University fully understands that USDOE is authorized to issue a range of sanctions if, indeed, there are findings of non-compliance with any rules and regulations regarding, Title IV Program Regulations. It further understands that the Commission is authorized to issue a range of sanctions if, indeed, there are findings of non-compliance with its Comprehensive Standard 4.7, Title IV Program Requirements. Records reveal that the 133- year -old University, first accredited under the self-study reaffirmation process in 1959, has never found itself out of compliance with USDOE rules and regulations associated with the offering of academic programs whether on the main campus or at distance sites. Initiation of distance locations has been conservative and has been accompanied by full adherence to the principles affecting the preservation of quality and access.

As of February, 2010, the University was actively responding to requests for information from USDOE. There has not been a notification of final disposition and the University has not faced limits, suspensions, or terminations of authority in its federal aid program.

Most potent is the corrective actions taken to eliminate the potential for a reoccurrence of the non-compliance with notification or the seeking of approval from USDOE in instances where distance educational offerings are planned include: (1) a change in the organizational structure that has the Assistant Provost for Student Financial Aid reporting directly to the Provost and Senior Vice President for Academic Affairs who is also the Liaison to the Commission on Colleges-Southern Association of Colleges and Schools[7]; (2) employment of an Assistant Provost for Student Financial aid with knowledge and experience at a level to support training of financial aid professionals in Title IV regulations[8]; (3) a change in the organizational structure that has created a Compliance Office that reports directly to the Vice President for Business Affairs where internal auditing and enterprise risk management reside [9] ;and (4) an updating of the institutional Substantive Change Policy to incorporate the review of both COC- SACS and Title IV compliance requirements in planning educational offerings and site locations where the University plans to offer federal aid [10][11].

Additional Supporting Documentation and Links

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