NASFAA continues its examination of the Department of Education's Nov. 1 Final Rule on the Student Assistance General Provisions that included the Academic Competitiveness Grant (ACG) and National Science & Mathematics Access to Retain Talent (SMART) Grant programs. In this article we examine the final rules on three issues: proprietary institutional eligibility, certificate program eligibility, and the eligibility of programs that lead directly to a graduate degree.
Eligibility of Proprietary Institutions' Participation In ACG/SMART
In response to interim final regulations published on July 3, 2006, the Department received questions concerning the ability of for-profit, proprietary schools to participate in the ACG/SMART Grant programs. Many felt it was unclear whether proprietary institutions could participate in these programs because, under Federal Register Part 600, an institution of higher education is defined as a public or private non-profit institution.
Final Rule: Any institution that offers an eligible program as defined in 691.2 may participate in the ACG and SMART Grant programs. Proprietary and vocational institutions which offer two- or four-year degree granting programs are eligible to participate in the ACG and SMART Grant programs.
Certificate Programs Not Included As "Eligible Programs"
Many commenters protested that certificate programs were not listed as eligible programs in the Interim Final Regulations posted in July. Critics argued that certificate programs were just as important as degree granting programs and students pursuing those certificates deserved these funds just as much as their degree-seeking counterparts. Given that certificate programs are allowed to participate in other Title IV Federal Student Aid (FSA) programs and that many certificate students go on to enroll in baccalaureate degrees, some argued that the Department should allow ACG/SMART Grant funds for students who would be able to transfer all of the their certificate credits into a two- or four-year degree.
Final Rule: The Secretary of Education determined that the Higher Education Act (HEA) specifically limits ACG and SMART Grant funds to students enrolled in a two- or four-year degree-granting institution as defined in 691.2. Because the HEA is so explicit in its definition, students enrolled in certificate programs are not eligible for ACG/SMART Grant funds.
However, students enrolled in two-academic-year programs, with full credit towards a bachelor's degree may qualify if they meet all other eligibility requirements. Thus, students enrolled in a program that awards them a certificate after two years and can also fully apply their certificate credits to a bachelor's degree program qualify for ACG funds.
Eligibility For Programs That Lead Directly To A Graduate Degree
Many colleges have recently introduced undergraduate programs that lead directly to a graduate degree in a condensed amount of time. For example, a student attending a four-year college might be able to obtain both a master's degree in an accelerated, integrated program in only five years as opposed to the usual six needed to obtain both a bachelor's and master's degree. Several commenters asked the Department to clarify eligibility for students enrolled in accelerated programs that lead directly to a graduate degree.
Final Rule: The Department determined that students enrolled in programs that lead directly to graduate degrees "have a period of undergraduate work for which they should be eligible for ACG and National SMART Grand funds" despite the fact that these programs are structured differently than traditional bachelor's/master's degree programs.
NASFAA is continuing to discuss some of the implications of the November 1 Final Rules with the Department of Education. As we learn more information over the coming days, we will continue to publish articles in Today's News to inform NASFAA members of what we have learned through additional articles.
Click here to read part 1 on prior enrollment and federal pell grant eligibility.
Click here to read part 2 on mandatory institutional participation and administrative cost allowance.
By Justin Draeger
NASFAA Assistant Director for Communications
Posted November 15, 2006 on www.NASFAA.org, the Web Site of the
National Association of Student Financial Aid Administrators (NASFAA).
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