ED Confirms Declaration of Major is Not a Title IV Eligibility Requirement

Karen McCarthy, Policy and Federal Relations staff 

Although a student generally must be a regular student [34 CFR 668.32(a)] in a degree or certificate program to be Title IV-eligible, a declared major is not a student eligibility requirement, per verbal confirmation from Department of Education (ED) staff.

The confusion seems to have arisen as a result of the following Q&A posted on IFAP in ED’s guidance related to the 150 percent subsidized loan reporting requirements.

“MEP-Q11: A school allows students to be in an “undecided” status as opposed to being enrolled in a specific academic program, at least for some period of time. What program length should schools report to the COD System and NSLDS for such students? 

MEP-A11: To be eligible for Title IV aid, a student must be a “regular student”. Under 34 CFR 600.2, a regular student is one who is enrolled for the purposes of receiving a degree, certificate, or other credential awarded by the school. Therefore, to be eligible for Title IV aid, even a student whose major may be “undecided” must still be enrolled in a program that leads to a degree, certificate, or other credential. Schools must report the program length associated with the program in which the student is enrolled to the COD System and NSLDS. [December 20, 2013]”

Some schools have misunderstood ED’s answer to mean that a student must have declared a major in order to be Title IV-eligible. This is not the case. Students who have not declared a major must still be enrolled in an eligible program to be eligible for Title IV aid, but there are no requirements under the statute or the regulations for students to declare a major within a prescribed timeframe. Schools may choose to establish their own institutional policies governing timeframes for major declarations for any number of reasons but doing so is at the school’s discretion. .

In other training materials and webinars, ED staff has noted that a CIP code must be reported for all students, even those with undeclared/undecided majors. They have suggested that institutions report using CIP code 24.0102 (General Studies) until a student has declared a major.  For program length, schools would report the length of the student’s degree or certificate program (even if the student has not declared a major within that program) to COD and NSLDS.

ED staff will clarify the answer to this specific question when they update the 150 percent Q&A.

For guidance regarding students who are not enrolled in a program of study, please see AskRegs Knowledgebase Q&A, “What CIP Code Should Be Reported for Students Not Enrolled in a Program of Study”? 


Publication Date: 11/14/2014

Karen M | 11/14/2014 4:33:11 PM

Hi all, thanks for your questions. For this purpose, the program is considered to be the academic credential (e.g., degree, certificate) that the student is working toward. A student can be enrolled in a baccalaureate degree program and be eligible for Title IV aid, even if that student has not yet declared an academic major within that baccalaureate degree program.
Karen McCarthy, NASFAA

Raymond G | 11/14/2014 12:6:21 PM

Isn't declaring a major the same as choosing a program? If non-degree status is acceptable then what about MTF. How do you monitor that?

Patricia B | 11/14/2014 11:51:32 AM

So, is it accurate to say a student can have their educational goal on file with the institution stating they are working towards a Bachelor's degree, A.A. or A.S. degree, or a certificated program, and we can go ahead and process/package them for federal aid--and they don't need to have a declared major (Academic Program) on file with the institution, so don't hold up their awarding for only that reason? That's what I got from this article, but I'm stretching the understanding, as it's confusing on the "must still be enrolled in an eligible program" part...to our institution that means a declared major/declared academic program. Please clarify.

Stephen A | 11/14/2014 10:8:19 AM

Clear as mud... How can a student be in an eligible program that leads to a degree or certificate if she has not chosen a program? We don't confer degrees or certificates in "Undeclared"! So is "eligible program" referring to the institution?

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