The Catholic University of America

Responsibilities of the Director of Student Financial Assistance

Higher Education Act of 1965 as amended by the Higher Education Opportunity Act (HEOA) of 2008

To participate in Title IV financial assistance programs the University must obtain from the U.S. Secretary of Education certification that it is an eligible institution of higher education and must administer HEA programs pursuant to the requirements of the Act.  Specific requirements that are the responsibility of the Director of Student Financial Assistance are as follows:

Staffing:  The University must have adequate full-time financial aid staff to assist students and meet legislative/regulatory compliance. 

Program Participation Agreement:  To participate in Title IV assistance programs the University must execute a program participation agreement.  Requirements of the agreement include, but are not limited to:

1.     Maintaining administrative and fiscal procedures for proper and efficient administration of Title IV funds;

2.     Demonstrating that the University has financial responsibility and administrative capability;

3.     Certifying that the University is in compliance with financial support data disclosures;

4.     Not knowingly employing or contracting with individuals or entities in any capacity involving administration of HEA programs if they have been found to have committed fraud or other violations involving federal/state/local funds; and

5.     Not providing incentive compensation to any person or entity engaged in any student recruiting, admission activities, or award decision-making based on success in securing enrollments or financial aid. 

Student Aid Application Verification:  The University must have written policies and procedures for verifying information contained in student aid applications that include: 

1.     Verification requirements and the method for notifying applicants of the results of the verification process;

2.     Time periods for provision of necessary documents and consequences for failure to do so;

3.     How to correct erroneous application information; and

4.     How to make referrals to the U.S. Department of Education’s Office of Inspector General for suspected criminal conduct by students in applying for aid. 

Preferred Vendor List:  The University may maintain a preferred vendor list for loan vendors so long as it is:

1.     Not used to deny or impede a borrower's choice of lenders;

2.     Offers 3 or more lenders not affiliated with one another; and

3.     Doesn't include on the list lenders who have offered financial or other benefits. 

The University also:

1.     Must disclose to borrowers the method and criteria used to select preferred lenders;

2.     Offer comparative information to borrowers about each lender's benefits;

3.     Must include in its preferred lender materials a prominent statement that borrowers are   not required to use any lender on the list;

4.     May not delay award certification because a preferred lender is not used; and

5.     Must update annually the preferred lender list and associated information.

The University also must report annually to the Department of Education detailed information regarding preferred lender arrangements (if one is used).

Relations with Lending Institutions:  The University may not co-brand or revenue share with lending institutions, and may not accept the following from lending institutions:

1.     Advisory board compensation;

2.     Loan premiums, payments, stock/securities, prizes, travel, entertainment expenses, tuition payment, or other inducements; and

3.     Funding of functions that the University is required to provide (except exit counseling). 

4.     The University also must report annually to the Department of Education detailed information regarding advisory board expense reimbursement by private lenders.

Code of Conduct for Financial Aid Practices:  The University must develop a Code of Conduct for financial aid practices that prohibits conflicts of interest, and that is published prominently on the University’s website and distributed annually to relevant personnel.  The University is a signatory to the District of Columbia Code of Conduct or Financial Aid Practices regarding financial assistance and must abide by all terms contained therein.  The University also abides by the NASFAA Statement of Ethical Principles and Ethical Conduct (http://www.nasfaa.org/WorkArea/linkit.aspx?LinkIdentifier=id&ItemID=299)

Required Disclosures: Annually the University must make readily available to enrolled students a list of institutional information and the procedures for obtaining that information.  Certain institutional information also must be made available to prospective students.  Notice and provision of information may be achieved through publications, mailings and/or electronic media.  The disclosures that are the responsibility of the Director of Financial Assistance include those set forth below, which are included in the University’s Notice of Availability of Institutional and Financial Aid Information:

To Enrolled Students:

1.     Preferred lending arrangements; and

2.     Private loan terms and conditions;

To both Enrolled and Prospective Students:

1.     Financial aid programs available

2.     Methods of distributing assistance among recipients;

3.     Means and requirements for applying for aid;

4.     Rights and responsibilities when receiving aid;

5.     Cost of attendance;

6.     Refund policy, and grant return and withdrawal requirements;

7.     Penalties for drug violations vis-à-vis financial aid eligibility; 

8.     Names of financial aid personnel;

9.     Loan deferral and cancellation terms;

10.   Applicability of aid for study abroad

Exit Counseling: The University must provide exit counseling for borrowers of Title IV program funds.

Record Retention:  The University must maintain any application for Title IV program funds, and must maintain program records regarding:

1.     Its program eligibility;

2.     Its administration of program funds, disbursement and delivery of funds, and financial responsibility; 

3.     Applications for program funds and documentation of borrower eligibility;

4.     Documentation collected at initial or exit loan counseling;

5.     Reports and forms used in participating in an HEA program; and

6.     Calculations of the University’s completion or graduation rates.

Executive Order 13607, April 27, 2012 – Principles of Excellence for Educational Institutions Serving Service Members, Veterans, Spouses, and Other Family Members

Institutions agreeing to Executive Order 13607 must provide additional disclosures and educational plans to prospective students. Responsibilities of the Director of Financial Assistance under the Order include:

1.     Providing a "Know Before You Owe" form to students eligible for military and veterans educational benefits to help them understand the total cost of an educational program;

2.     Explaining federal aid the student is eligible to receive and having policies in place for doing so;

3.     Assigning a point of contact for aid counseling; and

4.     Agreeing to an institutional refund policy aligned with the refund of unearned student aid rules applicable to aid provided under Title IV.

District of Columbia College Access Act (Public Law 106-98), amended by D.C. College Access Improvement Act 2002

The Director of Student Financial Assistance is responsible for administration of the D.C. Tuition Assistance Grant (TAG). Residents enrolled in the University on at least a half-time basis in an undergraduate degree-granting program and who are in good academic standing, as defined by the University, are eligible for a TAG, which only may be used to assist in paying for schools in the D.C. area.  To participate in the program the University must complete a participation agreement, fill out a Minimum Requirements Invoice including the W-9 form, and submit certifications and invoices in accordance with DCTAG procedures.

The Family Educational Rights and Privacy Act (FERPA)

All records regarding a student’s financial aid are to be kept confidential pursuant to FERPA. The Director, Student Financial Assistance, is responsible for compliance with this legal requirement as it relates to records maintained by the Office of Student Financial Assistance, whether such records are paper, electronic or maintained in another medium.

Resources

Federal Student Aid Handbook

Notice of Availability of Institutional and Financial Aid Information

Office of General Counsel Summary of Federal Laws – Financial Aid Programs

Related Policies

Academic Transfer of Credit Policy

District of Columbia Code of Conduct or Financial Aid Practices

Financial Aid Policy (Graduate)

Financial Aid Policy (Undergraduate)