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