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 institution’s compliance with these program responsibilities, the Commission relies on documentation forwarded to it by the U.S. Department of Education.)

Judgment of Compliance

PVAMU SACS Accreditation - Judgement Compliance

Narrative of Compliance

Prairie View A&M University is in compliance with Title IV of the 1998 Higher Education Amendments. The university awards the following Title IV funds: Federal Pell Grant, Federal Supplemental Educational Opportunity Grant, Academic Competitiveness Grant, National SMART Grant, Federal Perkins Loan, Federal Stafford Loan, Federal PLUS Loan, and work-study.

Over 90% of Prairie View students receive some form of financial aid. During the 2008-09 academic year federal awards totaled $82,368,298.00; $13,617,936.00 in Pell Grants was disbursed and $62,810,208 from the William D. Ford Federal Direct Loan Program [1]. To ensure that all awards are processed in keeping with federal requirements, the Office of Student Financial Aid provides necessary forms [2], such as a Graduate PLUS Loan Pre-Application [3], Title IV Authorization for Account Credit [4] and Asset Verification Worksheet [5]. Approximately 30% of students receiving Title IV aid are selected for verification under the Department of Education's Quality Assurance program, and no funds are disbursed until all documentation is submitted.

Additionally, the Office closely monitors the cumulative grade point average and credit hours completion rates of students on financial aid as its two measures of satisfactory academic progress. Instructors even submit class attendance information with midterm grades each semester [6]. If a student fails to meet all standards, the Office places the students on financial aid probation, and students who continue to fail to meet satisfactory academic progress are placed on financial aid suspension. Students may appeal the suspension to their financial aid counselor [7].

As required by the reauthorized Higher Education Act, the university publishes clear statements about Title IV rights and responsibilities in several places, including the undergraduate catalog [8], graduate catalog [9], and the webpage for the Office of Student Financial Aid [10]. Students are informed about costs, policies, and eligibility standards regarding the award and disbursement of financial aid both on the Office webpages [11] and the new call center, PV Live, which has eighteen categories of questions and answers on financial aid topics [12]. For aid eligibility, the Satisfactory Academic Progress (SAP) Policy described above appears in catalogs as well as online. Additionally, "Return to Title IV Policy" explanations also are disseminated so students understand that they must complete at least 60% of a term to avoid repayment.

Continued institutional eligibility for Title IV funding also depends on cohort default rates remaining below 25% for three straight years and below 40% for the most recent year. Prairie View A&M's cohort default rates for fiscal years 2001-03 were 20.8%, 17.1%, and 13.0%, respectively, representing an average default rate of 17.0% [13]. By 2006, the university's average default rate dropped to 11.4% [14]. Even though no Department of Education sanctions are in place, the Office of Student Financial Aid still seeks to lower default rates further, by using web links for repayment assistance, loan consolidation, and mandatory Department of Education entrance and exit counseling that includes consequences for not repaying loans [15]. Prairie View also has sought external programs and assistance in reducing default rates, such as Financial Aid TV, which has a playlist of 10 repayment videos [16] and USA Funds. Through a partnership with the latter, each year all students receiving aid must complete online "Life Skills" financial literacy modules on managing a budget, avoiding identity theft, and understanding credit [17] [18].

In addition to maintaining satisfactory cohort default rates, as explained in Comprehensive Standard 3.10.3, state audits of Prairie View's financial aid office have reported no significant findings. The independent firm of KPMG LLP applies OMB Circular A-133 requirements to its scrutiny of financial aid programs, and between 2001 and 2008, the auditors found no questioned costs. Two minor findings in 2002 involved submission of student status changes and loan counseling verification; both were rectified by procedural changes [19]. In 2007, the Office of Student Financial Aid had findings for incorrect disbursement dates for Pell Grants and FFELP loans. The institution corrected the procedures during the transition from SIS to Banner financial aid management software [20].

One final compliance measure that Prairie View A&M University has implemented is more substantial. In 2004, the University was determined eligible for Title IV participation, granted Provisional Certification through December 31, 2006, and issued a Program Participation Agreement (PPA) [21]. During the reapplication process for full certification, it was determined that two Prairie View A&M University sites in Dallas, Texas were not among the officially approved, additional locations offering 50% or more of a degree program. In response, the university closed those sites and pursuant to federal rules and regulations, has supplied all of the requested information to the U.S. Department of Education's representatives. No sanctions have been placed, and Prairie View A&M's ability to award federal aid has not been terminated, limited, or suspended.

Supporting Documentation and Links

Federal Requirements 4.7

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