Session 107

Study Abroad Issues

Marianna Deeken
Federal Student Aid
Anthony Jones
Office of Postsecondary Education
 Overview
• Student Eligibility
• Program Eligibility
• Written Agreements
– Consortium, Contractual, Study Abroad
specific
• Title IV Program Issues
– Pell, Loans, LEAP, Byrd
– Determining eligibility
2
 Student Eligibility
• Student in a study abroad program is eligible for aid
if program is approved for academic credit toward
student’s degree by eligible home school at which
student is enrolled as a regular student
• In order for study abroad program to be eligible,
home school must have written agreement with:
– Foreign school;
– Another U.S. school that contracts with foreign school; or
– Single written arrangement with a study-abroad
organization to represent an agreement between the
home school and the foreign school
HEA Sec. 484(o), 34 CFR 668.39
3
 Student Eligibility
• 1992 HEA Amendments clarified that
student enrolled/accepted for
enrollment in study abroad program is
eligible for Title IV assistance if
– Study-abroad program is approved for
credit by the student’s home school
• Even if study abroad is not a required part of
the student’s degree program

4
 Student Eligibility
• PPA Requirements
– School cannot deny Title IV funds on
grounds that student is studying abroad if
student is studying in an approved-for-
credit program
– School must establish procedures that
ensure its students studying abroad
receive Title IV funds to which they are
entitled

5
 Program Eligibility
• Participating institution may establish
programs of study abroad through which its
students are eligible to receive Title IV aid
– Study abroad program is an eligible program if:
• Students studying abroad concurrently remain
enrolled at their eligible home school; and
• Eligible home school awards academic credit
for the program of study abroad

6
 Program Eligibility
• To be eligible, study abroad program must be
considered part of student’s eligible program
– However, it does not have to be a required part of
the student’s eligible degree program in order to
be an eligible study abroad program
• Study abroad program must meet
requirements for written agreement
• In information it provides to students about a
study abroad program, a school must inform
students about the availability of FSA
program assistance
7
 Program Eligibility
• Study abroad program configurations
include:
– Home school sends students to a study
abroad program at an eligible or ineligible
foreign (host) school
• Home school must have a written agreement
with the foreign school

8
 Program Eligibility
• Study abroad program configurations include
(cont’d):
– Home school allows a student to complete a
portion of student’s program at an eligible host
school in U.S. and that host school offers a study
abroad program in conjunction with either an
eligible or ineligible foreign school
• Home and host schools in U. S. must have consortium
agreement.
• Host school in U. S. must have a consortium or
contractual agreement with foreign school.

9
 Program Eligibility
• Study abroad program configurations include
(cont’d):
– Home school has a written arrangement with a
study abroad organization that represents one or
more foreign institutions instead of a separate
agreement directly with each foreign school that its
students are attending (34 CFR 668.5)
• For purposes of administering FSA programs, written
agreement between the eligible institution and study
abroad organization must adequately describe duties
and responsibilities of each entity and meet requirements
of the regulations

10
 Program Eligibility
• Study abroad program configurations
include (cont’d):
– Variants of a study abroad program such
as when a home school sends faculty and
students to a foreign site
• This does not represent a consortium or
contractual study abroad program
• Foreign site is considered an additional location
under 34 CFR 600.32
11
 Written Agreements
• Consortium Agreement – a written agreement
between two or more eligible schools
• Contractual Agreement – a written agreement
between an eligible school and an ineligible
school
• Home School – the school where student is
enrolled in a degree or certificate program
• Host School – the school where student is
taking part of his or her program through
either a consortium or contractual agreement
12
 Written Agreements
• When there is a written arrangement
between eligible institutions
– Any of the institutions participating in a
written arrangement may make Title IV
program calculations and disbursements
without that institution being considered a
third party servicer
• True even if student is not taking courses at the
institution that is calculating and disbursing the
aid.
13
 Written Agreements
• Two or more schools may enter into a
consortium or contractual agreement so
that student can continue to receive
Title IV funds while studying at a school
or organization other than his or her
“home” school
– “Home” school is the one that will grant the
student’s degree or certificate
14
 Written Agreements
• Under a written agreement (consortium or
contractual), home school must give credit for
courses taken at the other school on the
same basis (in terms of instructional time) as
if it provided the training itself
– Underlying assumption of such an agreement is
that home school has found academic standards
of the other school or organization to be equivalent
to its own, and a completely acceptable substitute
for its own instruction

15
 Written Agreements
• Home school may decline to give credit for
courses in which a student earns a grade that
is not acceptable at home school:
– Regardless of whether host school has policy of
accepting that grade for its resident students.
– However, these courses must be included when
calculating the quantitative component of the
student’s SAP progress at the home school, even
though grades received from a host school do not
have to be included in the student’s GPA at the
home school.
16
 Consortium Agreements
• Consortium agreement can apply to all Title
IV programs
– Under a consortium agreement, students may
take courses at a school other than home school
and have those courses count toward degree or
certificate at home school
– Student can only receive Title IV funds for courses
that are applicable to the student’s degree or
certificate program

17
 Consortium Agreements
• Consortium agreement can apply to all Title
IV programs
• A consortium agreement can be:
– Blanket agreement between two or more eligible
schools; or
– Written for a specific student or group of students
• No limit on portion of eligible program that
may be provided by eligible schools other
than the home school
18
 Consortium Agreements
• If written agreements are not written for
an individual student or group of
students, agreements between schools
can go on indefinitely
– Agreements do not have to be renewed
unless the terms of agreement change

19
 Consortium Agreements
• Agreement contents can vary widely
and will depend upon the interests of
the schools involved and accrediting or
state agency standards
• ED does not dictate format of the
agreement or where it is kept

20
 Consortium Agreements
• The following items must be in all
agreements:
– School that will grant degree or certificate
– Student’s tuition, fees, and room & board costs at
each school
– Student’s enrollment status at each school
– School that will be responsible for disbursing aid
and monitoring student eligibility, and
– Procedures for calculating awards, disbursing aid,
monitoring SAP and other student eligibility
requirements, keeping records, and distributing
funds 21
 Consortium Agreements
• Usually home school is responsible for
disbursing funds
– If student is enrolled for a full term or
academic year at the host school, it may
be easier for the host school to monitor
student’s eligibility and make payments

22
 Consortium Agreements
• The school that disburses Title IV funds is
responsible for:
– Maintaining information on student’s eligibility;
– How the award was calculated;
– What money has been disbursed; and
– Any other documentation associated with award
• Even if some of that documentation comes from other
schools
• School paying student must return Title IV
funds as required
23
 Contractual Agreements
• Eligible institution may enter into a
contractual agreement with an ineligible
school/organization under which
ineligible school/organization provides
part of the educational program of
students enrolled at eligible school

24
 Contractual Agreements
• Eligible institutions are prohibited from
entering into contracts with ineligible schools
or organizations if the ineligible school or
organization:
– Has had its eligibility to participate in the Title IV,
HEA programs terminated by ED, or
– Has voluntarily withdrawn from participation in the
Title IV, HEA programs under a termination, show-
cause, suspension, or similar type proceeding
initiated by the institution’s state licensing agency,
accrediting agency, guarantor, or by ED
25
 Contractual Agreements
• Under a contractual agreement, eligible
school is always the home school
• Home school performs all aid processing and
disbursement functions for its students
attending ineligible school or organization
• Home school is responsible for maintaining
all records necessary to document student
eligibility and receipt of aid

26
 Contractual Agreements
• For schools in a contractual agreement, there
is a limit on portion of program that can be
offered by the ineligible school
– If both home and ineligible schools are owned or
controlled by the same individual, partnership, or
corporation, no more than 25% of educational
program can be provided by the ineligible school
– If the 2 schools are separately owned or
controlled, ineligible school can provide up to 50%
of the educational program
27
 Written Agreements:
Study Abroad
• Study abroad program must be part of a
written consortium or contractual agreement
between 2 or more schools
– Home school must be located in the U.S.
• Study abroad program does not have to be a
required part of eligible program at the home
school in order for student to be eligible to
receive Title IV funds
– Credits earned through study abroad must be
acceptable toward degree or certificate.
28
 Written Agreements:
Study Abroad
• Examples:
– Home school sends students to study abroad
program at foreign (host) school
• Home school must have written agreement with foreign
school
– Home school allows student to complete a portion
of program at eligible host school in U.S. and host
school offers study abroad program in conjunction
with foreign school
• Home and host schools in U.S. must have written
agreement
• Host school in U.S. must have written agreement with
foreign school
29
 Written Agreements:
Study Abroad
• Examples (cont’d):
– Home school has written agreement with a study
abroad organization that represents one or more
foreign schools instead of a separate agreement
directly with each foreign school that students
attend
• For purposes of administering Title IV, HEA programs,
written agreement between home school and
organization must adequately describe duties and
responsibilities of each entity and meet requirements of
the regulations

30
 Written Agreements:
Study Abroad
• Students participating in a study abroad
program approved by home school are
eligible for Title IV funds regardless of
whether study abroad program is required for
the student’s regular, eligible program of
study, as long as:
– Student is an eligible regular student enrolled in an
eligible program at the home school; and
– Eligible institution approves the program of study
abroad for academic credit

31
 COA & Pell COA
• Law addresses costs associated with
study abroad programs as follows:
– “For a student enrolled in an academic
program in a program of study abroad
approved for credit by the student’s home
institution, reasonable costs associated
with such study (as determined by the
institution at which the student is enrolled).”
• For example, travel costs to or from the place
of study might be included
32
 COA & Pell COA
• Student enrolled in study abroad
program with COA higher than home
school’s COA should have those extra
costs reflected in the COA on which
Title IV aid is based

33
 Loan Issues
• Exceptions to delayed delivery and multiple
disbursement requirements
– If a school's cohort default rate for each of the 3
most recent fiscal years for which data are
available is < 10%, school may choose to exempt
itself from the delayed delivery and multiple
disbursement requirement
– If eligible for exemption, the school may also apply
it to its study abroad students
• If the school's cohort default rate for each of the 3 most
recent fiscal years is not < 10%, an exemption may be
applied to cover study abroad periods if school's single
most recent cohort default rate is < 5% 34
 Loan Issues
• You may pay a student in an eligible
study abroad program in a single
disbursement, regardless of length of
the loan period
– School’s most recently calculated Stafford
Loan default rate must be < 5% for single
most recent fiscal year for which data is
available

35
 Loan Issues
• Schools must conduct initial counseling with
each first-time Federal Stafford Loan or Direct
Loan borrower prior to the release of the first
disbursement
– In the case of a student enrolled in a study abroad
program, the school must provide written
counseling materials by mail prior to disbursing the
loan
– School may also use on-line counseling for study
abroad students

36
 Loan Issues
• A student enrolled in an approved
program of study abroad may give
power of attorney to another individual
to approve an EFT by a lender to the
school account
– Separate EFT authorization statement is
required in this circumstance because the
Common Form is not designed to allow for
power of attorney
37
 Loan Issues
• Direct disbursement of loan proceeds
are permitted directly to the student at
the student’s request
– GA or lender must verify enrollment prior to
each disbursement
• Applies to FFEL only

38
 Perkins Loans
• School may disburse Perkins Loan to student
engaged in a program of study abroad if the
student meets all eligibility requirements and
is enrolled in an eligible program at the
school that will accept credits earned abroad
– If the reasonable costs of foreign study program
exceed cost of attending the home school, the
awarded Perkins Loan may exceed the annual
and/or aggregate loan limits by up to 20%

39
 FSEOG
• Maximum award of FSEOG for a full
academic year is usually $4,000.
– You may award as much as $4,400 to a
student participating in a study-abroad
program that is approved for credit by the
home school
– Minimum FSEOG amount is $100
• You may prorate this amount if student is
enrolled for less than an academic year

40
 FWS
• FWS for period preceding study abroad
– Student in an eligible program of study abroad
may be employed during a period of
nonattendance preceding the study abroad if:
• student will be continuously enrolled in his/her U.S.
school while abroad; and
• student’s study is part of U.S. school’s own program
– In this situation, student may be employed in
qualified position:
• in U.S.;
• at U.S. school’s branch campus in foreign country; or
• at U.S. government facility abroad
41
 LEAP/SLEAP
• Many states exclude students who attend
schools out of state, but some have
reciprocal arrangements with neighboring
states so that students may receive LEAP
funds from their home state even though they
are enrolled in another state
– LEAP funds may be awarded to students
participating in study-abroad programs that are
approved for credit by the home school

42
 Byrd Scholarship
• A Byrd scholar may not use his
scholarship to attend a foreign school
• Scholar studying abroad through an
eligible institution (home school) that is
located in a state is eligible to receive
funds as long as she is enrolled at
home school and receives credit from it

43
 Questions?
Comments?
Feedback?

Marianna.Deeken@ed.gov
206-615-2583
Anthony.Jones@ed.gov
202-502-7652

44