The draft proposed language (see page 45) crafted by the Department requires institutions to conduct initial counseling for each TEACH Grant recipient in person before making the first disbursement. Additionally, institutions must provide additional counseling each subsequent award year in person for recipients and in person exit counseling for students when they leave an institution.
Negotiators representing financial aid offices expressed serious concerns about this requirement, especially since the counseling must be in person. These negotiators stressed that in person counseling is not required by the law and that the draft language was a bit "extreme," and would place a heavy administrative burden on financial aid offices at large institutions.
Negotiators said that this requirement would be a huge burden on financial aid offices and could have several unintended, negative consequences. One negotiator said that financial aid offices need to make sure that students in all aid programs need to be counseled and this requirement might cause offices to prioritize counseling for this program above other programs. Negotiators also expressed concern that the additional administrative burden may cause some students to lose TEACH Grants or have their disbursements delayed.
Another negotiator supported the personal counseling because it limits the program in a healthy way and will reduce the amount of students who don't meet the service requirements.
Some negotiators recommended requiring institutions to provide in person counseling for students who want it, but not requiring it for students to receive TEACH Grants. Others recommended creating an interactive Web page that would require students to take some form of a quiz to demonstrate that they understand the program requirements.
Department officials said they would consider negotiators' concerns and suggestions and provide revised language for this section.
TEACH Grant-Eligible Institutions
Department officials explained that the draft proposed regulatory language (see bottom of page 8) defining a TEACH Grant-eligible institution was an attempt to make the most institutions (including community colleges and associate degree programs) eligible for the program. However, negotiators expressed concern that under the current draft language institutions could be treated unequally.
The draft language states that an institution will be eligible to participate in TEACH if it:
- Provides a teacher preparation program at the baccalaureate or master's degree level
- Provides a two-year program that is "fully transferable" to a baccalaureate teacher preparation program or degree program in a "high-need" subject area at an institution described below
- Offers a baccalaureate degree that, combined with other training, prepares students to teach in a high-need subject area and has "entered into an agreement" with an institution that offers a teacher preparation program
- Provides a post-baccalaureate program.
Negotiators noted that under this language, two-year programs would have to be fully transferable to an undergraduate degree program, while four-year institutions that don't offer a teacher preparation program would need an "agreement" with an institution that provides a baccalaureate or master's degree in teaching, or a post-baccalaureate program.
Department officials said they used the "fully transferable" phrase instead of "articulation agreement" so more institutions would be eligible. Negotiators asked what "fully transferable" meant. Department officials said they hoped negotiators would help them create a definition that everyone could agree on.
In addition to the inequality, negotiators noted that it is a complicated system that requires TEACH recipients to have sophisticated, long-range planning to ensure that they transfer from one eligible institution to another.
Confusing the matter even more, statutory language dictates that a college that provides an undergraduate degree in education and a post-baccalaureate teaching program can't award TEACH Grants to students in its post-baccalaureate program because it does not meet the Title IV definition of a post-baccalaureate program. Unfortunately, this problem can't be fixed through regulations and would need to be changed by Congress through an amendment to the law.
Availability of Funds
Negotiators asked if everyone who qualifies for TEACH get the full award, even if more people qualify for the funds than expected? Department officials made it clear that the TEACH Grant program is funded through mandatory spending, so it would be fully funded no matter how many people qualify.
Definition of Retiree
(page 7)
Department officials created draft language that provides a broad definition of a retiree who will be eligible for TEACH Grants when returning to college. Department officials also agreed to add language to make it clear that institutions can determine if a retiree has "expertise in a high-need area," which is needed to be eligible for TEACH.
TEACH Grant-Eligible Program
(page 10)
Department officials made it clear that this definition includes a master's degree program that is not specifically a teacher preparation program (i.e. math, science, etc.), but could make improve a teacher's ability to teach in high-need areas.
Teacher Preparation Program
(page 11)
Department officials noted that the law dictates that alternative teacher certification programs can only be eligible for TEACH if it is provided by an eligible institution.
Duration of Student Eligibility
(page 11)
The draft language allows less-than-full-time students to receive as many awards as needed until they reach the TEACH Grant limit ($8,000 for graduate students and $16,000 for undergraduate students). The language defines a "scheduled award" as the maximum amount of a TEACH Grant that a full-time student could receive over a year.
Eligibility to Receive a Grant
(page 17)
Negotiators advocated that institutions should be allowed to define "first-year student." ED officials said they believed this would be possible, but needed more time to discuss it further
Department officials noted that the draft language allows students taking basic requirements (not related to an education degree or a degree in a high-need area) to receive the TEACH aid. Officials said that even if a student has all remedial/ non-credit coursework, they could still be eligible.
Negotiators asked Department representatives who would determine of what majors are considered in high-need area. Officials said they didn't think it would be like SMART/ACG, instead ED would let institutions determine if a major is eligible.
Negotiators asked ED officials if institutions would need to use a final high school transcript to determine GPA eligibility, or if institutions can use the incomplete transcript students have when they apply? Sometimes final transcripts aren't available until September or later, one negotiator noted. ED officials said the final transcript was more appropriate to determine a student's GPA. "This doesn't mean you can't package until you get the final GPA or that they can't become eligible after first semester if they get a 3.25 GPA or higher," an ED official said.
ED officials said that first year graduate students would use their undergraduate GPA to determine eligibility.
Application
(bottom of page 15)
Negotiators revisited their earlier discussion about whether the Department should require applicants to fill out the entire FAFSA, since the TEACH Grant program is not need-based. Some felt that it was unnecessary to put students and parents through this, but others argued that it was not a bad idea to have them fill out the form, because they might be eligible for other forms of aid. Department officials said they were still considering a simplified FAFSA, but did not have any details about what this form might contain.
By Haley Chitty
NASFAA Assistant Director for Communications
Posted 01/23/08 to www.NASFAA.org. Redistribution to non-NASFAA institutions is prohibited. Please submit Web Site questions or comments to Web@NASFAA.org.
