Activity 1: PPA Checklist

Are you familiar with the requirements outlined on the Program
Participation Agreement (PPA) signed by your President or other
designated official? Review the checklist below to refresh your memory,
and ensure compliance at your school. As you review the Checklist and
find areas of concern, click on the [Management Enhancement
Worksheet](http://ifap.ed.gov/qahome/mgtenhancementwk.html) to assist
you in the development of an action plan. Review each related module to
assist you in the evaluation of the federal requirements listed in the
PPA.

+---------------------------------------------------+------------------+
| PPA Requirement                                   | Related Modules  |
+---------------------------------------------------+------------------+
| -   Your school complies with all statutory       | [Fiscal          |
|     provisions of or applicable to Title IV of    | Managemen        |
|     the HEA, all applicable regulatory provisions | t](http://www.if |
|     prescribed under that statutory authority,    | ap.ed.gov/qamodu |
|     and all applicable special arrangements,      | le/FiscalManagem |
|     agreements and limitations entered into under | ent/FiscalManage |
|     the authority of statutes to Title IV of the  | mentModule.html) |
|     HEA, including the requirement that the       |                  |
|     school will use funds it receives under any   |                  |
|     Title IV, HEA program for the purposes        |                  |
|     specified in an in accordance with that       |                  |
|     program.                                      |                  |
+---------------------------------------------------+------------------+
| -   As a fiduciary responsible for administering  | [Fiscal          |
|     Title IV funds, if your school is permitted   | Managemen        |
|     to request funds under a Title IV, HEA        | t](http://www.if |
|     program advance payment method, you school    | ap.ed.gov/qamodu |
|     times its requests for funds under the        | le/FiscalManagem |
|     program to meet the school's immediate Title  | ent/FiscalManage |
|     IV HEA program needs.                         | mentModule.html) |
+---------------------------------------------------+------------------+
| -   Your school does not request from or charge   | [Student         |
|     any student a fee for processing or handling  | E                |
|     any application, form, or data required to    | ligibility](http |
|     determine a student's eligibility for, and    | ://www.ifap.ed.g |
|     amount of, Title IV, HEA program assistance.  | ov/qamodule/Stud |
|                                                   | entEligibility/A |
|                                                   | ssessmentC.html) |
+---------------------------------------------------+------------------+
| -   Your school establishes and maintains         | [Fiscal          |
|     administrative and fiscal procedures and      | Managemen        |
|     records necessary to ensure proper and        | t](http://www.if |
|     efficient administration of funds received    | ap.ed.gov/qamodu |
|     from the Secretary or from students under the | le/FiscalManagem |
|     Title IV, HEA programs.                       | ent/FiscalManage |
|                                                   | mentModule.html) |
+---------------------------------------------------+------------------+
| -   Your school assures that it will provide,     | [Fiscal          |
|     upon request and in a timely manner,          | Managemen        |
|     information relating to the administrative    | t](http://www.if |
|     capability and financial responsibility of    | ap.ed.gov/qamodu |
|     the school to the Secretary, a guaranty       | le/FiscalManagem |
|     agency, the nationally recognized accrediting | ent/FiscalManage |
|     agency that accredits or preaccredits the     | mentModule.html) |
|     school or any of its branch campuses,         |                  |
|     locations or educational programs, the State  |                  |
|     agency that legally authorizes the school to  |                  |
|     provide postsecondary education, and any      |                  |
|     other state agency recognized for approval of |                  |
|     public postsecondary vocational education (if |                  |
|     your school is a public postsecondary         |                  |
|     vocational school).                           |                  |
+---------------------------------------------------+------------------+
| -   Your school complies with the provisions      | [Fiscal          |
|     relating to factors of financial              | Managemen        |
|     responsibility                                | t](http://www.if |
|     [66                                           | ap.ed.gov/qamodu |
| 8.15](http://frwebgate.access.gpo.gov/cgi-bin/get | le/FiscalManagem |
| -cfr.cgi?TITLE=34&PART=668&SECTION=15&TYPE=TEXT). | ent/FiscalManage |
|                                                   | mentModule.html) |
+---------------------------------------------------+------------------+
| -   Your school complies with the provisions      |                  |
|     relating to administrative capability         |                  |
|     [66                                           |                  |
| 8.16](http://frwebgate.access.gpo.gov/cgi-bin/get |                  |
| -cfr.cgi?TITLE=34&PART=668&SECTION=16&TYPE=TEXT). |                  |
+---------------------------------------------------+------------------+
| -   Your school submits reports to the Secretary, | [Satisfactory    |
|     and in the case of participation in the       | Academic         |
|     Federal Stafford Loan, Federal PLUS, or the   | Progress         |
|     Federal Perkins Loan Program, to holders of   | ](http://www.ifa |
|     loans made to the school's students under     | p.ed.gov/qamodul |
|     that program at such times and containing     | e/SAPModule/SAPM |
|     such information as the Secretary reasonably  | oduleIntro.html) |
|     requires to carry out the purpose of the      |                  |
|     Title IV, HEA programs.                       |                  |
+---------------------------------------------------+------------------+
| -   Your school does not provide any statement to | [Student         |
|     any student or certification to any lender in | E                |
|     the case of an FFEL Program loan, or          | ligibility](http |
|     origination record to the Secretary in the    | ://www.ifap.ed.g |
|     case of a Direct Loan Program loan that       | ov/qamodule/Stud |
|     qualifies the student or parent for a loan or | entEligibility/A |
|     loans in excess of the amount that the        | ssessmentC.html) |
|     student or parent is eligible to borrow.      |                  |
+---------------------------------------------------+------------------+

+---------------------------------------------------+------------------+
| PPA Requirement                                   | Related Modules  |
+---------------------------------------------------+------------------+
| -   Your school complies with the requirements of | [Consumer        |
|     [Subpart D (668.40 through                    | Infor            |
|                                                   | mation](http://w |
|   668.48)](http://ecfr.gpoaccess.gov/cgi/t/text/t | ww.ifap.ed.gov/q |
| ext-idx?c=ecfr&sid=777dc255a9dcabf0bf9cd75e1595dc | amodule/Consumer |
| 5c&rgn=div5&view=text&node=34:3.1.3.1.34&idno=34) | Module/ConsumerI |
|     of the Title IV regulations concerning        | nformation.html) |
|     institutional and financial assistance        |                  |
|     information for students an prospective       |                  |
|     students.                                     |                  |
+---------------------------------------------------+------------------+
| -   If your school advertises job placement rates | [Consumer        |
|     as a means of attracting students to enroll   | Infor            |
|     in the school, it makes available to          | mation](http://w |
|     prospective students, at or before the time   | ww.ifap.ed.gov/q |
|     that those students apply for enrollment:     | amodule/Consumer |
|                                                   | Module/ConsumerI |
| -   The most recent available data concerning     | nformation.html) |
|     employment statistics, graduation statistics, |                  |
|     and any other information necessary to        |                  |
|     substantiate the truthfulness of the          |                  |
|     advertisements relevant state licensing       |                  |
|     requirements of the state in which the school |                  |
|     is located for any job for which an           |                  |
|     educational program offered by the school is  |                  |
|     designed to prepare those prospective         |                  |
|     students.                                     |                  |
+---------------------------------------------------+------------------+
| -   If your school participates in the FFEL       |                  |
|     program, it informs all eligible borrowers    |                  |
|     enrolled in the school about the availability |                  |
|     and eligibility of those borrowers for State  |                  |
|     grant assistance from the state in which the  |                  |
|     school is located, and informs borrowers from |                  |
|     another state of the source of further        |                  |
|     information concerning State grant assistance |                  |
|     from that state.                              |                  |
+---------------------------------------------------+------------------+
| -   Your school can certify that it has in        | [Consumer        |
|     operation a drug abuse prevention program     | Infor            |
|     that is accessible to any officer, employee,  | mation](http://w |
|     or student at the school, has established a   | ww.ifap.ed.gov/q |
|     campus security policy in accordance with     | amodule/Consumer |
|     section 485(f) of the HEA, and has complied   | Module/ConsumerI |
|     with the disclosure requirements of Sec.      | nformation.html) |
|     [6                                            |                  |
| 68.47](http://frwebgate.access.gpo.gov/cgi-bin/ge |                  |
| t-cfr.cgi?TITLE=34&PART=668&SECTION=47&TYPE=TEXT) |                  |
|     as required by section 485(f) of the HEA.     |                  |
+---------------------------------------------------+------------------+
| -   If your school has students who receive       | [Student         |
|     financial assistance pursuant to section      | E                |
|     484(d) of the HEA, the school makes available | ligibility](http |
|     to those students a program proven successful | ://www.ifap.ed.g |
|     in assisting students in obtaining the        | ov/qamodule/Stud |
|     recognized equivalent of a high school        | entEligibility/A |
|     diploma.                                      | ssessmentC.html) |
+---------------------------------------------------+------------------+
| -   Your school does not deny any form of Federal | [Student         |
|     financial aid to any eligible student solely  | E                |
|     on the grounds that the student is            | ligibility](http |
|     participating in a program of study abroad    | ://www.ifap.ed.g |
|     approved for credit by the school.            | ov/qamodule/Stud |
|                                                   | entEligibility/A |
|                                                   | ssessmentC.html) |
+---------------------------------------------------+------------------+
| -   The school uses a default management plan     | [Default         |
|     approved by the Secretary with regard to its  | Manag            |
|     administration of the FFEL or Direct Loan     | ement](http://ww |
|     programs, or both for at least the first two  | w.ifap.ed.gov/qa |
|     years of its participation in those programs, | module/DefaultMa |
|     if the school is participating in those       | nagement/Default |
|     programs for the first time, or the school    | Management.html) |
|     has undergone a change in ownership that      |                  |
|     results in a change in control and is         |                  |
|     participating in the FFEL or Direct Loan      |                  |
|     programs (unless the school does not have a   |                  |
|     cohort default rate in excess of 10 percent,  |                  |
|     and the owner of the school does not own and  |                  |
|     has not owned any other school that had a     |                  |
|     cohort default rate in excess of 10 percent   |                  |
|     while the owner owned the school).            |                  |
+---------------------------------------------------+------------------+
| -   The school is aware that the Secretary,       | [Institutional   |
|     guaranty agencies and lenders as defined in   | Eligibi          |
|     34 CFR part                                   | lity](http://www |
|     [682](http://ecfr.gpoaccess.gov/cgi/t/text/te | .ifap.ed.gov/qam |
| xt-idx?c=ecfr&sid=777dc255a9dcabf0bf9cd75e1595dc5 | odule/Institutio |
| c&rgn=div5&view=text&node=34:3.1.3.1.40&idno=34), | nalEligibility/A |
|     nationally recognized accrediting agencies,   | ssessmentA.html) |
|     the Secretary of Veteran Affairs, State       |                  |
|     agencies recognized under 34 CFR part         |                  |
|     [603](http://ecfr.gpoaccess.gov/cgi/t/text/   |                  |
| text-idx?c=ecfr&sid=777dc255a9dcabf0bf9cd75e1595d |                  |
| c5c&rgn=div5&view=text&node=34:3.1.3.1.4&idno=34) |                  |
|     for the approval of public postsecondary      |                  |
|     vocational education, and State agencies that |                  |
|     legally authorize schools and branch campuses |                  |
|     or other locations of school to provide       |                  |
|     postsecondary education, have the authority   |                  |
|     to share with each other any information      |                  |
|     pertaining to the school's eligibility for or |                  |
|     participation in the Title IV, HEA programs   |                  |
|     or any information on fraud and abuse.        |                  |
+---------------------------------------------------+------------------+

+---------------------------------------------------+------------------+
| PPA Requirement                                   | Related Modules  |
+---------------------------------------------------+------------------+
| -   Your school does not knowingly employ in a    |                  |
|     capacity that involves the administration of  |                  |
|     Title IV, HEA programs or the receipt of      |                  |
|     funds under those programs, any individual    |                  |
|     who has been convicted of, or has pled nono   |                  |
|     contendere or guilty to, a crime involving    |                  |
|     the acquisition, use, or expenditure of       |                  |
|     federal, state, or local government funds, or |                  |
|     has been administratively or judicially       |                  |
|     determined to have committed fraud or any     |                  |
|     other material violation of law involving     |                  |
|     Federal, State, or local government funds.    |                  |
+---------------------------------------------------+------------------+
| -   Your school does not knowingly contract with  |                  |
|     a school or third-party servicer that has     |                  |
|     been terminated under section 432 of the HEA  |                  |
|     for a reason involving the acquisition, use,  |                  |
|     or expenditure of federal, state, or local    |                  |
|     government funds, or that has been convicted  |                  |
|     of, or has pled nolo contendere or guilty to, |                  |
|     a crime involving the acquisition, use, or    |                  |
|     expenditure of federal, state, or local       |                  |
|     government funds, or has been                 |                  |
|     administratively or judicially determined to  |                  |
|     have committed fraud or any other material    |                  |
|     violation of law involving federal, state, or |                  |
|     local government funds.                       |                  |
+---------------------------------------------------+------------------+
| -   Your school does not knowingly contract with  |                  |
|     or employ any individual, agency, or          |                  |
|     organization that has been, or whose officers |                  |
|     and employees have been convicted of, or pled |                  |
|     nolo contendere or guilty to, a crime         |                  |
|     involving the acquisition, use, or            |                  |
|     expenditure of federal, state, or local       |                  |
|     government funds, or has been                 |                  |
|     administratively or judicially determined to  |                  |
|     have committed fraud or any other material    |                  |
|     violation of law involving federal, state, or |                  |
|     local government funds.                       |                  |
+---------------------------------------------------+------------------+
| -   Your school completes, in a timely manner and | [Consumer        |
|     to the satisfaction of the Secretary, surveys | Infor            |
|     conducted as part of the [Integrated          | mation](http://w |
|     Postsecondary Education Data System           | ww.ifap.ed.gov/q |
|     (IPEDS)](http://nces.ed.gov/ipeds/) or any    | amodule/Consumer |
|     other federal collection effort, as designed  | Module/ConsumerI |
|     by the Secretary regarding data on            | nformation.html) |
|     postsecondary schools.                        |                  |
+---------------------------------------------------+------------------+
| -   If your school is co-educational and has an   | [Consumer        |
|     intercollegiate athletic program, it complies | Infor            |
|     with the provisions of Sec.                   | mation](http://w |
|     [66                                           | ww.ifap.ed.gov/q |
| 8.48](http://frwebgate.access.gpo.gov/cgi-bin/get | amodule/Consumer |
| -cfr.cgi?TITLE=34&PART=668&SECTION=48&TYPE=TEXT). | Module/ConsumerI |
|                                                   | nformation.html) |
+---------------------------------------------------+------------------+
| -   Your school does not impose any penalty,      | [Student         |
|     including but not limited to, the assessment  | Elig             |
|     lf late fees, the denial of access to         | ibility](http:// |
|     classes, libraries, or other institutional    | www.ifap.ed.gov/ |
|     facilities, or require that the student       | qamodule/Student |
|     borrow additional funds for which interest or | Eligibility/Asse |
|     other charges are assessed, on any student    | ssmentC.html)*,* |
|     because of the student's inability to meet    | [Institutional   |
|     his or her financial obligations to the       | Eligibi          |
|     school as a result of the delayed             | lity](http://www |
|     disbursement of the proceeds of a Title IV,   | .ifap.ed.gov/qam |
|     HEA program loan due to compliance with       | odule/Institutio |
|     statutory and regulatory requirements of or   | nalEligibility/A |
|     applicable to the Title IV, HEA programs or   | ssessmentA.html) |
|     delays attributable to the school.            |                  |
+---------------------------------------------------+------------------+
| -   Your school does not provide any commission,  | [Institutional   |
|     bonus, or other incentive payment based       | Eligibi          |
|     directly or indirectly upon success in        | lity](http://www |
|     securing enrollments or financial aid to any  | .ifap.ed.gov/qam |
|     person or entity engaged in any student       | odule/Institutio |
|     recruiting or admission activities or in      | nalEligibility/A |
|     making decisions regarding the awarding of    | ssessmentA.html) |
|     Title IV, HEA program funds, except that this |                  |
|     limitation does not apply to the recruitment  |                  |
|     of foreign students residing in foreign       |                  |
|     countries who are not eligible to receive     |                  |
|     Title IV, HEA program funds (note: there are  |                  |
|     acceptable activities and arrangements that a |                  |
|     school may carry out without violating the    |                  |
|     provisions of this requirement (see [668.14   |                  |
|     (b)(22)                                       |                  |
|     (                                             |                  |
| ii)](http://frwebgate.access.gpo.gov/cgi-bin/get- |                  |
| cfr.cgi?TITLE=34&PART=668&SECTION=14&TYPE=TEXT)). |                  |
+---------------------------------------------------+------------------+
| -   Your school meets the requirements            | [Fiscal          |
|     established pursuant to [part H (Program      | Managemen        |
|     Integrity) of Title IV of the                 | t](http://www.if |
|     HEA](http:/                                   | ap.ed.gov/qamodu |
| /www.ed.gov/policy/highered/leg/hea98/index.html) | le/FiscalManagem |
|     by the Secretary and nationally recognized    | ent/FiscalManage |
|     accrediting agencies.                         | mentModule.html) |
+---------------------------------------------------+------------------+

+---------------------------------------------------+------------------+
| PPA Requirement                                   | Related Modules  |
+---------------------------------------------------+------------------+
| -   Your school complies with the requirements of | [Return of Title |
|     Sec.                                          | IV](http:/       |
|     [6                                            | /www.ifap.ed.gov |
| 68.22](http://frwebgate.access.gpo.gov/cgi-bin/ge | /qamodule/Return |
| t-cfr.cgi?TITLE=34&PART=668&SECTION=22&TYPE=TEXT) | TIVFunds/ReturnT |
|                                                   | IVFunds.html)*,* |
|                                                   | [Fiscal          |
|                                                   | Managemen        |
|                                                   | t](http://www.if |
|                                                   | ap.ed.gov/qamodu |
|                                                   | le/FiscalManagem |
|                                                   | ent/FiscalManage |
|                                                   | mentModule.html) |
+---------------------------------------------------+------------------+
| -   If your school uses third party servicers,    | [Institutional   |
|     your school accepts liability for all         | Eligibi          |
|     improperly spent or unspent funds received    | lity](http://www |
|     under the Title IV, HEA programs, including   | .ifap.ed.gov/qam |
|     any funds administered by a third-party       | odule/Institutio |
|     servicer.                                     | nalEligibility/A |
|                                                   | ssessmentA.html) |
+---------------------------------------------------+------------------+
| -   Your school accepts liability for returns of  | [Return of Title |
|     Title IV, HEA program funds that the school   | IV](http:/       |
|     or it servicer may be required to make.       | /www.ifap.ed.gov |
|                                                   | /qamodule/Return |
|                                                   | TIVFunds/ReturnT |
|                                                   | IVFunds.html)*,* |
|                                                   | [Fiscal          |
|                                                   | Managemen        |
|                                                   | t](http://www.if |
|                                                   | ap.ed.gov/qamodu |
|                                                   | le/FiscalManagem |
|                                                   | ent/FiscalManage |
|                                                   | mentModule.html) |
+---------------------------------------------------+------------------+
| -   If the stated objectives of an educational    | [Institutional   |
|     program of the school are to prepare a        | Eligibi          |
|     student for gainful employment in a           | lity](http://www |
|     recognized occupation, the school             | .ifap.ed.gov/qam |
|     demonstrates a reasonable relationship        | odule/Institutio |
|     between the length of the program and entry   | nalEligibility/A |
|     level requirements for the recognized         | ssessmentA.html) |
|     occupation for which the program prepares the |                  |
|     student. (The Secretary considers the         |                  |
|     relationship to be reasonable if the number   |                  |
|     of clock hours provided in the program does   |                  |
|     not exceed by more than 50 percent the        |                  |
|     minimum number of clock hours required for    |                  |
|     training in the recognized occupation for     |                  |
|     which the program prepares the student, as    |                  |
|     established by the state in which the program |                  |
|     is offered, if the State has established such |                  |
|     a requirement, or as established by any       |                  |
|     federal agency).                              |                  |
+---------------------------------------------------+------------------+
| -   If the stated objectives of an educational    | [Institutional   |
|     program of the school are to prepare a        | Eligibi          |
|     student for gainful employment in a           | lity](http://www |
|     recognized occupation, the school establishes | .ifap.ed.gov/qam |
|     the need for training for the student to      | odule/Institutio |
|     obtain employment in the recognized           | nalEligibility/A |
|     occupation for which the program prepares the | ssessmentA.html) |
|     student.                                      |                  |
+---------------------------------------------------+------------------+
| -   If your school is located in a state to which | [Institutional   |
|     section 4(b) of the National Voter            | Eligibi          |
|     Registration Act (42 U.S.C. 1973gg-2(b)) does | lity](http://www |
|     not apply, your school makes a good faith     | .ifap.ed.gov/qam |
|     effort to distribute a mail voter             | odule/Institutio |
|     registration form, requested and received     | nalEligibility/A |
|     from the State, to each student enrolled in a | ssessmentA.html) |
|     degree or certificate program and physically  |                  |
|     in attendance at the school, and makes those  |                  |
|     forms widely available to students at the     |                  |
|     school.                                       |                  |
+---------------------------------------------------+------------------+
| -   Your school requests the forms from the state | [Institutional   |
|     120 days prior to the deadline for            | Eligibi          |
|     registering to vote within the State (if your | lity](http://www |
|     school has not received a sufficient quantity | .ifap.ed.gov/qam |
|     of forms to fulfill this section from the     | odule/Institutio |
|     State within 60 days prior to the deadline    | nalEligibility/A |
|     for registering to vote in the State, the     | ssessmentA.html) |
|     school is not liable for not meeting the      |                  |
|     requirements of this section during that      |                  |
|     election year.                                |                  |
+---------------------------------------------------+------------------+

[Note:]{.underline} If your school is a participant in the Quality
Assurance Program or Experimental Sites, you should have an addendum to
your PPA. You are encouraged to review the requirements for that
addendum to ensure compliance.