Internships/Externships and Written Arrangements

1. Session 46 Internships/Externships and Written Arrangements Marcia Fediw and Mike Stein| Nov-Dec. 2016 U.S. Department of Education 2016 FSA Training Conference for Financial Aid Professionals

2. AGENDA • Written Arrangements • Consortium Agreement • Contractual Agreements • Required Disclosures • Duration of Agreement • Division of Responsibilities • Structure of Agreement

3. AGENDA • Foreign Institution Eligibility • Ineligible Programs • Distance Education • Transfer Credits • Internships

4. WRITTEN ARRANGEMENTS • Consortium Agreement • A Written Agreement Between Two or More EligibleInstitutions • Contractual Agreement • A Written Agreement Between an Eligible and an Ineligible School • Foreign Institutions May Not Enter Into Contractual Agreements

5. CONSORTIUM AGREEMENT • Student May Take Courses at a School Other Than the Home School and Have Those Courses Count Toward the Degree or Certificate at the Home School • Home School Must Give Credit for Courses Taken at Other Schools on Same Basis as if it Provided the Training Itself • Home Institution May Decline to Give Credit

6. CONSORTIUM AGREEMENT • Grades Received Through a Consortium Agreement do not Have to be Included When Calculating GPA but Must be Included in Calculating Percentage of Credits Earned Versus Attempted

7. REQUIRED DISCLOSURES • Institution Must Provide Enrolled and Prospective Students a Description of Consortium Agreements it has Entered into Including • Portion of the Educational Program the Institution that Grants the Degree is not Providing • Name and Location of Institutions that are Providing that Portion of the Program

8. REQUIRED DISCLOSURES • Method of Delivery of that Part of the Program • Estimated Additional Costs to Students

9. DURATION OF AGREEMENT • Agreements Between Schools May Go On Indefinitely and Do Not Need to be Renewed Unless Terms of the Agreement Change • Individually Initiated Agreements or Those for Specific Groups, Continue for the Length of Time Specified in the Agreement

10. DIVISION OF RESPONSIBILITIES • Either the Home or Host School May Assume Responsibility for Disbursing Loan Funds and/or Monitoring Student • Home School Generally Assumes Responsibility for Disbursing and Monitoring Students

11. DIVISION OF RESPONSIBILITIES • Under a Consortium Agreement, any Participating Institution May Make Direct Loan Calculations and Disbursements Without Being Considered a Third-Party Servicer • Institution that Disburses a Direct Loan to the Student is Responsible for Maintaining Information on the Student’s Eligibility, Calculation of Award, and Money Disbursed

12. STRUCTURE OF AGREEMENT • Consortium Agreement Can be a Blanket Agreement Between Two or More Eligible Schools or it can be for a Specific Student • Institutional Options • One Agreement for Each Student • Separate Agreement With Each Host School • Blanket Agreement With a Group of Schools

13. STRUCTURE OF AGREEMENT • No Limit on the Portion of the Eligible Program That May be Provided by the Host Institution(s) • Agreement Contents May Vary Widely Depending Upon the Interests of the Institutions Involved • No Consortium Agreements With Institutions in the United States

14. CONTENTS OF AGREEMENT • Agreement Must Include: • Institution That Will Grant the Degree or Certificate • Student’s Tuition, Fees, Room and Board Costs at Each School • Student’s Enrollment Status at Each School • School That Will be Responsible for Disbursing Direct Loan Funds and Monitoring the Student’s Eligibility, and • Procedures for Calculating Awards, Disbursing Aid, Monitoring SAP, and Other Requirements Such as Recordkeeping and Returning Funds if a Student Withdraws

15. FOREIGN INSTITUTION ELIGIBILITY • Foreign Institution is an Institution That • Has no U.S. Locations -- Medical, Veterinary, Nursing Exceptions • Has no Written Arrangements With an Institution Located in the U.S. for Students Enrolling at the Foreign Institution to Take Courses from Institutions Located in the U.S.; and

16. FOREIGN INSTITUTION ELIGIBILITY • The Regulations do not Prohibit Participating Foreign Institutions From Offering a Program in the U.S. • The Program is not Eligible for Title IV Purposes • Students Attending the Program are not Eligible for Title IV funds for any Portion of the Program

17. INELIGIBLE PROGRAMS • A Program Offered in Whole or in part Through Telecommunications, Otherwise Known as Distance Education • A Program Offered in Whole or in Part Through Correspondence • A Program Offered Through Direct Assessment

18. INELIGIBLE PROGRAMS • A Program for Which any Portion of the Program is Provided by an Entity That is not Eligible to Participate in the Title IV Programs • Except Affiliation Agreements for the Provision of Clinical Training for Foreign Graduate Medical, Veterinary, and Nursing Schools • With Limited Exceptions, a Program Offered in Whole or in Part in the United States

19. INELIGIBLE PROGRAMS • A Direct Loan Eligible Version of a Program Must be Administratively Distinct From any Version of the Program that Contains Direct Loan Ineligible Courses • A Separate Program Offered for Eligibility Reasons Does Not Require Creation of Duplicate Courses

20. ELIGIBLE VERSION OF A PROGRAM • Notify Students That the Ineligible Version is not Eligible for Direct Loan Funds • Notification to Students Must be Available to Enrolled and Prospective Students • Brief Description of the Notification Must be Included in the Notice that Must be Provided to Enrolled Students Listing the Categories of Information Available to them

21. DISTANCE EDUCATION • Not Permitted • Foreign Institutions May use Distance Education Technologies to Supplement and Support Instruction Offered in a Classroom Located in a Foreign Country where Students and Instructor are Physically Present

22. TRANSFER CREDITS • ED Does Not Restrict an Institution’s Discretion to Award Credit for Courses Completed at Other Institutions • If a Student Independently Completes a Direct Loan Ineligible Course at an Unaffiliated Institution Those Credits May be Transferred Into the Student’s Program at the Eligible Institution. The Student May Not Receive Direct Loan Funds for the Course

23. INTERNSHIPS Internships/Externships at a Foreign Institution Must be Subject to Oversight by an Accreditor or Government Entity • If the Above Cannot be Demonstrated, the Internship is Subject to the Requirements of Written Arrangements • If an Internship is Subject to the Requirements for Written Arrangements and that Internship is With a Non-Eligible Entity (e.g., a Local Company), the Program of Which That Internship is Part Would not be an Eligible Program

24. CONTACTS • Email: FSA.Foreign.Schools.Team@ed.gov • Phone: 202-377-3168 • Fax: 202-377-3486 • Mail: U.S. Department of Education Multi-regional and Foreign School Participation Division Union Center Plaza, 7th Floor 830 First Street, NE Washington DC, 20202 (20002-5340 if Overnight/Courier)

25. SCHOOL ELIGIBILITY SERVICE GROUP (SESG)Ron Bennett - Director, School Eligibility Service Group, Washington, DC (202) 377-3181School Eligibility Service Group General Number: (202) 377-3173 or email: CaseTeams@ed.gov Or call the appropriate School Participation Division manager below for information and guidance on audit resolution, financial analysis, program reviews, school and program eligibility/recertification, and school closure information. New York/Boston School Participation Division Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont, New Jersey, New York, Puerto Rico, Virgin Islands Betty Coughlin, Director (646) 428-3737 Tracy Nave – Boston (617) 289-0145Jeremy Early– Washington, DC (202) 377-3620Chris Curry – New York (646) 428-3738 Philadelphia School Participation Division District of Columbia, Delaware, Maryland, Pennsylvania, Virginia, West Virginia Nancy Gifford, Director (215) 656-6436 John Loreng – Philadelphia (215) 656-6437 Sherrie Bell– Washington, DC (202) 377-3349 Multi-Regional and Foreign Schools Participation Division Michael Frola, Director (202) 377-3364 Barbara Hemelt − Washington, DC (202) 377-4201 Joseph Smith − Washington, DC (202) 377-4321 Mark Busskohl – Washington, DC (202) 377-4572 Michelle Allred – Dallas (214) 661-9466 Atlanta School Participation Division Alabama, Florida, Georgia, Mississippi, North Carolina, South CarolinaChristopher Miller, Director (404) 974-9297 David Smittick – Atlanta (404) 974-9301 Vanessa Dillard – Atlanta (404) 974-9418 Dallas School Participation Division Arkansas, Louisiana, New Mexico, Oklahoma, Texas Cynthia Thornton, Director (214) 661-9457 Jesus Moya – Dallas (214) 661-9472 Kim Peeler – Dallas (214) 661-9471 Kansas City School Participation Division Iowa, Kansas, Kentucky, Missouri, Nebraska, TennesseeRalph LoBosco, Director (816) 268-0440Dvak Corwin – Kansas City (816) 268-0420 Angela Beam – Kansas City 816) 268-0534 Jan Brandow – Kansas City (816) 268-0409 Chicago/DenverSchool Participation Division Illinois, Minnesota, Ohio, Wisconsin, Indiana, Colorado, Michigan, Montana, North Dakota, South Dakota, Utah, WyomingDouglas Parrott, Director (312) 730-1532 Earl Flurkey – Chicago (312) 730-1521 Brenda Yette – Chicago (312) 730-1522 Sarah Adams − Chicago (312) 730-1514 San Francisco/Seattle School Participation Division American Samoa, Arizona, California, Guam, Hawaii, Nevada, Palau, Marshall Islands, North Marianas, State of Micronesia, Alaska, Idaho, Oregon, WashingtonMartina Fernandez-Rosario, Director (415) 486-5605 Gayle Palumbo − San Francisco (415) 486-5614 or Seattle (206) 615-3699 Dyon Toney − Washington, DC (202) 377-3639 Erik Fosker – San Francisco (415) 486-5606

26. QUESTIONS?