prompt_front: You are given two reports by the government agency.



Question: Write a one-page summary of the report 1.



Report 2: Title IV of the Higher Education Act (HEA; P L  89-329), as amended, authorizes programs that provide financial assistance to students to attend certain institutions of higher education (IHEs)  In academic year (AY) 2016-2017, 6,760 institutions were classified as Title IV eligible IHEs  Of these IHEs eligible to participate in Title IV programs, approximately 29 4% were public institutions, 27 8% were private nonprofit institutions, and 42 9% were proprietary (or private, for-profit) institutions  It is estimated that $122 5 billion was made available to students through Title IV federal student aid in FY2017  To be able to receive Title IV assistance, students must attend an institution that is eligible to participate in the Title IV programs  IHEs must meet a variety of requirements to participate in the Title IV programs  First, an IHE must meet basic eligibility criteria, including offering at least one eligible program of education  In addition, an IHE must satisfy the program integrity triad, under which it must be legally authorized to provide a postsecondary education in the state in which it is located; accredited or preaccredited by an agency recognized by the Department of Education (ED) for such purposes, and certified by ED as eligible to participate in Title IV programs  The state authorization and accreditation components of the triad were developed independently to address the issues of quality assurance and consumer protection, and the federal government (ED specifically) generally relies on states and accrediting agencies to determine standards of educational program quality  The federal government's only direct role in determining Title IV eligibility is through the process of certification of eligibility and ensuring IHEs meet some additional Title IV requirements  Certification, as a component of the program integrity triad, focuses on an institution's fiscal responsibility and administrative capacity to administer Title IV funds  An IHE must fulfill a variety of other related requirements, including those that relate to institutional recruiting practices, student policies and procedures, and Title IV program administration  Finally, additional criteria may apply to an institution depending on its control or the type of educational programs it offers  For instance, proprietary institutions must derive at least 10% of their revenues from non-Title IV funds (also known as the 90/10 rule)  Failure to fulfill some of these requirements does not necessarily end an IHE's participation in the Title IV programs, but may lead to additional oversight from ED and/or restrictions placed an IHE's Title IV participation  This report provides a general overview of HEA provisions that affect a postsecondary institution's eligibility for participation in Title IV student aid programs  It first describes general eligibility criteria at both the institutional and programmatic level and then, in more detail, the program integrity triad  Next, it discusses several issues that are closely related to institutional eligibility: Program Participation Agreements, campus safety policies and crime reporting required under the Clery Act, the return of Title IV funds, and distance education  To be eligible to participate in HEA Title IV student aid programs, institutions must meet several criteria  These criteria include requirements related to programs offered by the institutions, student enrollment, institutional operations, and the length of academic programs  This section discusses the definition of an eligible IHE for the purposes of Title IV participation and program eligibility requirements  The HEA contains two definitions of institutions of higher education  Section 101 provides a general definition of IHE that applies to institutional eligibility for participation in HEA programs other than Title IV programs  The Section 102 definition of IHE is used only to determine institutional eligibility to participate in HEA Title IV programs  Section 101 of the HEA provides a general definition of IHE  This definition applies to institutional participation in non-Title IV HEA programs  Section 101 IHEs can be public or private nonprofit educational institutions  Section 101 specifies criteria both public and private nonprofit educational institutions must meet to be considered IHEs  Neither the HEA nor regulations specifically define a public institution of higher education  However, in general, public institutions can be described as those whose educational programs are operated by states or other government entities and are primarily supported by public funds  Regulations define a nonprofit IHE as one that (1) is owned and operated by a nonprofit corporation or association, with no part of the corporation's or association's net earnings benefiting a private shareholder or individual, (2) is determined by the Internal Revenue Service to be a tax-exempt organization under Section 501(c)(3) of the Internal Revenue Code (IRC), and (3) is legally authorized to operate as a nonprofit organization by each state in which it is physically located  To be considered a Section 101 IHE, public and private nonprofit educational institutions must admit as regular students only individuals with a high school diploma or its equivalent, individuals beyond the age of compulsory school attendance, or individuals who are dually or concurrently enrolled in both the institution and in a secondary school; be legally authorized to provide a postsecondary education within the state in which they are located; offer a bachelor's degree, provide a program of at least two-years that is acceptable for full credit toward a bachelor's degree, award a degree that is accepted for admission to a graduate or professional program, or provide a training program of at least a one-year that prepares students for gainful employment in a recognized occupation; and be accredited or preaccredited by an accrediting agency recognized by ED to grant accreditation or preaccreditation status Section 102 of the HEA defines IHE only for the purposes of Title IV participation  The Section 102 definition includes all institutions included in the Section 101 definition (i e , public and private nonprofit IHEs) and also includes proprietary institutions, postsecondary vocational institutions, and foreign institutions that have been approved by ED  Section 102 specifies that proprietary and postsecondary vocational institutions must meet many of the same Section 101 requirements that are applicable to public and private nonprofit institutions  In addition, Section 102 specifies other criteria that all types of educational institutions must meet to be considered Title IV eligible IHEs  HEA Section 102 specifies that a proprietary IHEs is an institution that is neither a public nor a private nonprofit institution  In addition to the basic Title IV eligibility criteria that all IHEs must meet (e g , state authorization, accreditation by an ED-recognized accrediting agency), proprietary IHEs must meet additional criteria to be considered Title IV eligible  Specifically, a proprietary IHE must (1) provide an eligible program of training "to prepare students for gainful employment in a recognized occupation" or (2) provide a program leading to a baccalaureate degree in liberal arts that has been continuously accredited by a regional accrediting agency since October 1, 2007, and have provided the program continuously since January 1, 2009  Additionally, it must have been legally authorized to provide (and have continuously been providing) the same or a substantially similar educational program for at least two consecutive years  HEA Section 102 defines a postsecondary vocational institution as a public or private nonprofit institution that provides an eligible program of training "to prepare students for gainful employment in a recognized occupation," and has been legally authorized to provide (and has continuously been providing) the same or a substantially similar educational program for at least two consecutive years  It is possible for a public or private nonprofit IHE that offers a degree program (e g , an associate's or bachelor's degree) to also qualify as a postsecondary vocational institution by offering programs that are less than one academic year and that lead to a nondegree recognized credential such as a certificate  Institutional participation in Title IV student aid programs allows students from the United States to borrow through the federal Direct Loan program to attend postsecondary institutions located outside of the United States  In general, a foreign institution is eligible to participate in the Direct Loan program if it is comparable to an eligible IHE (as defined in HEA Section 101) within the United States, is a public or private nonprofit institution, and has been approved by ED  Foreign graduate medical schools, veterinary schools, and nursing schools are also eligible to participate in Title IV student aid programs, but must meet additional requirements  Freestanding foreign graduate medical schools, veterinary schools, and nursing schools may be proprietary institutions  Additional requirements for foreign institutions to participate in Title IV student aid programs are beyond the scope of this report and, generally, will not be discussed hereinafter  The definitions of proprietary institutions and postsecondary vocational institutions contained in Section 102 have several overlapping components with the Section 101 definition of IHE  For instance, both proprietary and postsecondary vocational institutions must (1) admit as regular students only those individuals with a high school diploma or its equivalent, individuals beyond the age of compulsory school attendance, or individuals who are dually or concurrently enrolled in both the institution and in a secondary school; (2) be legally authorized to provide a postsecondary education by the state in which they are located; and (3) be accredited or preaccredited by an accrediting agency recognized by ED to grant such statuses  In addition, all types of institutions (including public and private nonprofit institutions) must meet requirements related to the course of study offered at the institution and student enrollment to be considered Title IV eligible under Section 102  In general, any type of institution is considered ineligible to participate in Title IV programs if more than 25% of its enrolled students are incarcerated, or if more than 50% of the its enrolled students do not have a secondary school diploma or equivalent and the institution does not provide a two-year associate's degree or a four-year bachelor's degree  Also, in general, an institution is ineligible if more than 50% of the courses offered are correspondence courses or if 50% or more of its students are enrolled in correspondence courses  These "50% rules" are discussed in more detail in the distance education section of this report  Finally, an institution is considered ineligible to participate in Title IV programs if the institution has filed for bankruptcy or the institution (or its owner or chief executive officer) has been convicted of or pled no contest or guilty to a crime involving the use of Title IV funds  While the above-described criteria generally apply to most types of Section 102 institutions, specific criteria apply to individual types of Section 102 institutions  The following sections provide information on Title IV eligibility criteria that apply to those additional types of IHEs not specified in Section 101, but specified in Section 102: proprietary IHEs, postsecondary vocational institutions, and foreign institutions  Hereinafter, unless otherwise noted, the term "institution of high education (IHE)" only refers to Section 102 institutions  To qualify as an eligible institution for Title IV participation, an institution must offer at least one eligible program, but overall institutional eligibility does not necessarily extend to all programs offered by the institution  Not all of an institution's programs must meet program eligibility requirements for an IHE to participate in Title IV, but, in general, students enrolled solely in ineligible programs cannot receive Title IV student aid  To be Title IV eligible, a program must lead to a degree (e g , an associate's or bachelor's degree) or certificate or prepare students for gainful employment in a recognized occupation  Before awarding Title IV aid to students, an IHE must determine that the program in which a student is participating is Title IV eligible, ensure that the program is included in its accreditation notice, and ensure that the the IHE is authorized by the appropriate state to offer the program  In addition to the general criteria for all types of institutions, a program must meet specific eligibility requirements depending on whether the institution at which it is offered is a public or private nonprofit IHE, a proprietary IHE, or a postsecondary vocational IHE  At a public or private nonprofit IHE, the following types of programs are Title IV eligible: (1) programs that lead to an associate's, bachelor's, professional, or graduate degree; (2) transfer programs that are at least two academic years in length and for which the institution does not award a credential but that are acceptable for full credit toward a bachelor's degree; (3) programs that lead to a certificate or other recognized nondegree credential, that prepare students for gainful employment in a recognized occupation, and that are at least one academic year in length; (4) certificate or diploma training programs that are less than one year in length, if the institution also meets the definition of a postsecondary vocational institution; and (5) programs consisting of courses required for elementary or secondary teacher certification in the state in which the student intends to teach  For all of these, an academic year must also require an undergraduate course of study to contain an amount of instructional time in which a full-time student is expected to complete at least 24 semester or trimester credit hours, 36 quarter credit hours, or 900 clock hours  In general, eligible programs at proprietary and postsecondary vocational institutions must meet a specified number of weeks of instruction and must provide training that prepares students for gainful employment in a recognized occupation (described below)  At proprietary and postsecondary vocational institutions, the following types of programs are Title IV eligible: undergraduate programs that provide at least 600 clock hours, 16 semester or trimester hours, or 24 quarter hours of instruction offered over a minimum of at least 15 weeks ; such programs may admit, as regular students, individuals who have not completed the equivalent of an associate's degree; programs that provide at least 300 clock hours, 8 semester hours, or 12 quarter hours of instruction offered over a minimum of 10 weeks; such programs must be graduate or professional programs or must admit as regular students only individuals who have completed the equivalent of an associate's degree; short-term programs that provide between 300 and 600 clock hours of instruction over a minimum of 10 weeks ; such programs must have been in existence for at least one year, have verified completion and placement rates of at least 70%, may not last more than 50% longer than the minimum training period required by the state or federal agency for the occupation for which the program is being offered, and must admit as regular students some individuals who have not completed the equivalent of an associate's degree; and programs offered by accredited proprietary IHEs that lead to a bachelor's degree in liberal arts; the school must have been continuously accredited by an ED-recognized accrediting agency since at least October 1, 2007 and must have provided the program continuously since January 1, 2009  Most nondegree programs offered by public and private nonprofit IHEs must prepare students for "gainful employment in a recognized occupation " Gainful employment requirements also apply to almost all programs offered by proprietary and postsecondary vocational institutions, regardless of whether they lead to a degree  In response to concerns about the quality of programs that prepare students for gainful employment and the level of student debt assumed by individuals who attend these programs, ED issued final rules on gainful employment on October 31, 2014  The regulations require that educational programs subject to gainful employment requirements offered by IHEs meet minimum performance standards to be considered offering education that prepares students for gainful employment in a recognized occupation  They also require IHEs to disclose specified information about each of its gainful employment programs to enrolled or prospective students  Finally, the gainful employment rules require IHEs to report information to ED necessary to calculate the debt-to-earnings ratios  Although the gainful employment regulations became effective July 1, 2015, various aspects of them have not yet been fully implemented or have been delayed in implementation  For example, ED delayed until July 1, 2019, some portions of the rule relating to certain disclosure requirements  Additionally, to enable ED to calculate whether an IHE's programs meet the minimum performance standards (discussed below), regulations specify that ED obtains data from the Social Security Administration (SSA)  However, a memorandum of understanding relating to data sharing between ED and SSA lapsed in 2018  In August 2018, ED issued a Notice of Proposed Rulemaking that proposes to rescind the gainful employment rules in their entirety  Based on HEA requirements relating to the implementation date for Title IV regulations, the earliest possible date the proposed rules could go into effect is July 1, 2020  The gainful employment regulations establish a framework within which educational programs offered by IHEs must meet minimum performance standards to be considered offering education that prepares students for gainful employment in a recognized occupation  Under the framework, ED annually calculates two debt-to-earnings (D/E) rates for each gainful employment program offered by an IHE, the discretionary income rate and the annual earnings rate  These rates measure a gainful employment program's completers' debt (their annual loan payments) as a percentage of their post-completion earnings  Using these measures, institutions will be determined to be "passing," "in the zone," or "failing " Thresholds for each category are as follows: Passing : Programs whose completers have annual loan payments less than or equal to 8% of annual earnings (the annual earnings rate) or less than or equal to 20% of discretionary income (the discretionary income rate)  In the zone: Programs whose completers have annual loan payments greater than 8% but less than or equal to 12% of annual earnings or greater than 20% but less than or equal to 30% of discretionary income  Failing : Programs whose completers have annual loan payments greater than 12% of annual earnings and greater than 30% of discretionary income  Programs that are failing in two out of any three consecutive years or that are in the zone for four consecutive years will be ineligible for Title IV participation for three years  The gainful employment rules also contain several disclosure requirements  For any year in which ED notifies an IHE that a gainful employment program could become ineligible in the next year based on its debt-to-earnings ratios (i e , one year of failure or three years in the zone), the IHE must provide a warning to current and prospective students that the program does not meet the gainful employment standards and that if the program does not meet the gainful employment standards in the future, students would not be able to receive Title IV aid  In addition, an IHE must disclose specified information about each of its gainful employment programs to enrolled and prospective students  Information to be disclosed includes the following: the primary occupation that the program prepares students to enter; whether the program satisfies applicable educational prerequisites for professional licensure or certification in each state within the institution's metropolitan statistical area (MSA); program length and number of clock or credit hours, or equivalent, in the program; the program's completion rates for full-time and less-than-full-time students and the program's withdrawal rates; Federal Family Education Loan (FFEL) and Direct Loan program loan repayment rates for all students who entered repayment on Title IV loans and who enrolled in the program, for those who withdrew from the program, and for those who completed the program; the program tuition, fees, and additional costs incurred by a student who completes the program within the program's published length; the job placement rate for the program, if otherwise required by the institution's accrediting agency or state; the percentage of enrolled students who received Title IV or private loans for enrollment in the program; the median loan debt and mean or median earnings of students who completed the program, of students who withdrew from the program, and of both groups combined; the program cohort default rate; and the annual earnings rate for the program  Institutions must also certify that each of their gainful employment programs is included in the IHE's accreditation, meets any state or federal entity accreditation requirements, and meets any state licensing and certification requirements for the state in which the IHE is located  Title IV of the HEA sets forth three requirements to ensure program integrity in postsecondary education, known as the program integrity triad  The three requirements are state authorization, accreditation by an accrediting agency recognized by ED, and eligibility and certification by ED  This triad is intended to provide a balance in the Title IV eligibility requirements  The states' role is to provide consumer protection, the accrediting agencies' role is to provide quality assurance, and the federal government's role is to provide oversight of compliance to ensure administrative and fiscal integrity of Title IV programs at IHEs  The state role in the program integrity triad is to provide legal authority for an institution to operate a postsecondary educational program in the state in which it is physically located  There are two basic requirements for an IHE to be considered legally authorized by a state: 1  the state must authorize the IHE by name to operate postsecondary educational programs, and 2  the state must have in place a process to review and address complaints concerning IHEs, including enforcing applicable state law  An IHE can be authorized by name through a state charter, statute, constitutional provision, or other action by an appropriate state agency (e g , authorization to conduct business or operate as a nonprofit organization)  Additionally, an institution must also comply with any applicable state approval or licensure requirements  The state agency responsible for the authorization of postsecondary institutions must also perform three additional functions: upon request, provide the Secretary with information about the process it uses to authorize institutions to operate within its borders; notify the Secretary if it has evidence to believe that an institution within its borders has committed fraud in the administration of Title IV programs; and notify the Secretary if it revokes an institution's authorization to operate  On December 19, 2016, ED issued final regulations related to state authorization for IHEs offering postsecondary distance or correspondence education (discussed later in this report)  The regulations would require an IHE offering postsecondary distance or correspondence education to students residing in a state in which the IHE is not physically located to meet any requirements within the student's state of residence  Under the rules, an IHE may meet this requirement if it participates in a state authorization reciprocity agreement  These regulations were scheduled to become effective July 1, 2018  However, on July 3, 2018 (and effective June 29, 2018), the Secretary of Education (Secretary) issued a final rule delaying the implementation of these requirements until July 1, 2020  The second component of the program integrity triad is accreditation by an ED-recognized accrediting agency or association  In higher education, accreditation is intended to help ensure an acceptable level of quality within IHEs  For Title IV purposes, an institution must be accredited or preaccredited by an ED-recognized accrediting agency  Each accrediting agency must meet HEA-specified standards to be recognized by ED  From its inception, accreditation has been a voluntary process  It developed with the formation of associations that distinguished between IHEs that merited the designation of college or university from those that did not  Since then, accreditation has been used as a form of "external quality review     to scrutinize colleges, universities and programs for quality assurance and quality improvement " In 1952, shortly after the passage of the Veterans' Readjustment Act of 1952 (the Korean GI Bill; P L  82-550), the federal government began formally recognizing accrediting agencies  This was done as one means to assess higher education quality and link it to determining which institutions would qualify to receive federal aid under the Korean GI Bill  Rather than creating a centralized authority to assess quality, the federal government chose to rely in part on the existing expertise of accrediting agencies  Today, ED's formal recognition of accrediting agencies is important, because an IHE's Title IV eligibility is conditioned upon accreditation from an ED-recognized accreditation organization  As part of the accreditation system's development, three types of accrediting agencies have emerged: Regional accrediting agencies  These operate in six regions of the United States, with each agency concentrating on a specific region  Generally, these accredit entire public and private nonprofit degree-granting IHEs  National accrediting agencies  These operate across the United States and also accredit entire institutions  There are two types of national accrediting agencies: faith-based agencies that accredit religiously affiliated or doctrinally based institutions, which are typically private nonprofit degree-granting institutions, and career-related agencies that typically accredit proprietary, career-based, degree- and nondegree-granting institutions  Specialized or programmatic accrediting agencies  These operate throughout the United States and accredit individual educational programs (e g , law) and single-purpose institutions (e g
Report 2:  These centers, which can shelter as many as 20 youth, are generally supposed to be located in areas that are frequented or easily reached by runaway and homeless youth  BCP grantees must make efforts to contact the parents and relatives of runaway and homeless youth  Grantees are also required to establish relationships with law enforcement, health and mental health care, social service, welfare, and school district systems to coordinate services  Grantees maintain confidential statistical records of youth, including youth who are not referred to out-of-home shelter services  Further, grantees are required to submit an annual report to HHS detailing the program activities and the number of youth participating in such activities, as well as information about the operation of the centers  BCP grants are allocated directly to grantees for a three-year period  Funding is generally distributed to entities based on the proportion of the nation's youth under age 18 in the jurisdiction where the entities are located  The 50 states, the District of Columbia, and Puerto Rico each receive a minimum allotment of $200,000  Separately, the territories (currently, this includes American Samoa and Guam) each receive a minimum of $70,000  The amount of funding for each state or territory can further depend on whether grant applicants in that jurisdiction applied for funding, and if so, whether the applicant fulfilled the requirements in the authorizing law and grant application  For example, the authorizing law directs HHS to give priority to applicants who have demonstrated experience in providing services to runaway and homeless youth  HHS is to re-allot any funds designated for grantees in one state to grantees in other states that will not be obligated before the end of a fiscal year  See Table A-1 for the amount of funding allocated for each state in FY2017 and FY2018  The costs of the BCP are shared by the federal government (90%) and grantees (10%)  In FY2008, HHS began funding a three-year Rural Host Homes Demonstration Project , which was initiated to expand BCP shelter and support services to runaway and homeless youth who live in rural areas not served by shelter facilities  The project supported grantees that provided youth with shelter (via host home families who were recruited, screened, and trained) and preventive services, including transportation, counseling, educational assistance, and aftercare planning, among others  Over the course of the three years, the project served 781 youth, 411 of whom received shelter and 370 of whom received preventive services without shelter  Recognizing the difficulty that youth face in becoming self-sufficient adults, the Transitional Living Program provides longer-term shelter and assistance for youth ages 16 through 22 (or older if the youth entered the TLP prior to reaching age 22) who may leave their biological homes due to family conflict, or have left and are not expected to return home  Pregnant and/or parenting youth are eligible for TLP services  In FY2017, the TLP provided services to 3,517 youth  In FY2018, the program funded 229 organizations  Each TLP grantee may shelter up to 20 youth at various sites, such as host family homes, supervised apartments owned by a social service agency, scattered-site apartments, or single-occupancy apartments rented directly with the assistance of the grantee  Youth may remain at TLP sites for up to 540 days (18 months), or longer for youth under age 18  Youth ages 16 through 22 may remain in the program for a continuous period of 635 days (approximately 21 months) under "exceptional circumstances " This term means circumstances in which a youth would benefit to an unusual extent from additional time in the program  A youth in a TLP who has not reached age 18 on the last day of the 635-day period may, in exceptional circumstances and if otherwise qualified for the program, remain in the program until his or her 18 th birthday  Youth receive several types of services at TLP-funded programs: basic life-skills training, including consumer education and instruction in budgeting and the use of credit; parenting support and child care (as appropriate); building interpersonal skills; educational opportunities, such as GED courses and postsecondary training; assistance in job preparation and attainment; and mental and physical health care services  TLP grantees are required to develop a written plan designed to help youth transition to living independently or another appropriate living arrangement, and they are to refer youth to other systems that can help to meet their educational, health care, and social service needs  The grantees must also submit an annual report to HHS that includes information regarding the activities carried out with funds and the number and characteristics of the homeless youth  As part of the FY2002 budget request, the George W  Bush Administration proposed a $33 million initiative to fund maternity group homes—or centers that provide shelter to pregnant and parenting teens who are vulnerable to abuse and neglect—as a component of the TLP  Although the TLP authorized services for pregnant and parenting teens prior to FY2002, the Bush Administration sought funds specifically to serve this population  Increased funds were ultimately provided to enable these youth to access TLP services  The 2003 amendments to the Runaway and Homeless Youth Act ( P L  108-96 ) provided explicit authority to use TLP funds for this purpose  Since FY2004, funding for adult-supervised transitional living arrangements that serve pregnant or parenting women ages 16 to 21 and their children has been awarded to organizations that receive TLP grants  These organizations provide youth with parenting skills, including child development education, family budgeting, health and nutrition, and other skills to promote family well-being  TLP grants are distributed competitively by HHS to community-based public and private organizations throughout the country for a five-year period  Grantees must provide at least 10% of the total cost of the program  HHS is carrying out a study to learn more about the long-term outcomes of 1,250 youth who have used TLP services  The study seeks to describe the outcomes and to isolate and describe promising practices and other factors that may contribute to their successes or challenges  Of particular interest for the study is how services are delivered, the demographics of youth, and their socio-emotional wellness and life experiences  It involves both a process evaluation and impact evaluation, with youth randomly assigned to the treatment (i e , participation in the TLP) and control groups  The study seeks to address the following questions: (1) How do TLP programs operate, what types of program models are used to deliver services, and what services are delivered to homeless youth? (2) What are the long-term housing outcomes and protective factors for youth who participate in the TLP program immediately, six months, 12 months, and 18 months after exiting the program? (3) What interventions can be attributed to any positive outcomes experienced by youth who participate in the TLP? According to HHS, the pilot study revealed challenges "in collecting data from a large enough sample size of youth to detect any effects so that conclusions could be drawn about the impact of homeless youth served by TLPs " HHS is not certain how it will move forward with the study  In FY2016, HHS began the Transitional Living Program Special Population Demonstration project  The project funded nine grantees over a two-year period that tested approaches for serving populations that need additional support: LGBTQ runaway and homeless youth ages 16 to 21; and young adults who have left foster care because of emancipation  Grantees were expected to provide strategies that help youth build protective factors, such as connections with schools, employment, and appropriate family members and other caring adults  According to HHS, a process evaluation will assess how grantees are implementing the demonstration project  HHS separately funded a project from FY2012 through FY2014 to build the capacity of TLPs in serving LGBTQ youth  Known as the 3/40 Blueprint: Creating the Blueprint to Reduce LGBTQ Youth Homelessness , the purpose of the grant was develop information about serving the LGBTQ youth population experiencing homelessness, such as through efforts to identify innovative intervention strategies, determine culturally appropriate screening and assessment tools, and better understand the needs of LGBTQ youth served by RHY providers  The website developed by the grantee, the University of Illinois at Chicago, identifies promising practices that serve LGBTQ youth who are experiencing homelessness and publishes information about their challenges  In FY2009, HHS began the Support Systems for Rural Homeless Youth Demonstration Project   Six states received grants to support TLPs in rural communities in serving young adults who have few or no connections to a supportive family structure or community resources  The five-year project sought to provide services across three main areas: survival support, which includes housing, health care (including mental health), and substance abuse treatment and prevention; community, which includes community service, youth and adult partnerships, mentoring, and peer support groups; and education and employment, which includes high school or GED completion, postsecondary education, and job training and employment  The six states—Colorado, Iowa, Minnesota, Nebraska, Oklahoma, and Vermont—each received annual grants of $200,000  According to HHS, all of the sites engaged youth in positive youth development activities that included safe places for youth to go  In addition, they raised awareness about homelessness in rural areas and addressed some of the unique needs around employment, housing, and transportation  However, the sites also confirmed that there is a general lack of available housing for homeless youth and that transportation was the most critical impediment to serving these youth  The Street Outreach Program provides runaway and homeless youth living on the streets or in areas that increase their risk of using drugs or being subjected to sexual abuse, prostitution, sexual exploitation, and trafficking are eligible to receive services  The program's goal is to assist youth in transitioning to safe and appropriate living arrangements  SOP services include the following: treatment and counseling; crisis intervention; drug abuse and exploitation prevention and education activities; survival aid; street-based education and outreach; information and referrals; and follow-up support  Grants are awarded for a three-year period, and grantees must provide 10% of the funds to cover the cost of the program  In FY2018, 96 grantees were funded  In FY2017 grantees made contact with 24,366 youth  The Family and Youth Services Bureau initiated the Street Outreach Program Data Collection Project in 2012 to learn more about the lives and needs of homeless and runaway youth served by SOP grantees  The purpose of the project was to design services to better meet the needs of these youth  FYSB collected information through focus groups and computer-assisted personal interviews with 656 youth (ages 14 to 21 years) served by grantees in 11 cities  The project found that participants were homeless on average for nearly two years and had challenges with substance abuse, mental health, and exposure to trauma  Youth most identified that they were in need of job training or help finding a job, transportation assistance, and clothing  The top barriers to obtaining shelter were shelters being full, not knowing where to go for shelter, and lacking transportation to get to a shelter  The study researchers concluded that more emergency shelters could help prevent youth from sleeping on the street  Further, they noted that youth on the streets need more intensive case management (e g , careful assessment and treatment planning, linkages to community resources, etc ) and more intensive interventions  HHS funds the Runaway and Homeless Youth Training and Technical Assistance Center (RHYTTAC) to provide technical assistance to RHYP grantees  HHS awarded a five-year cooperative agreement, from September 30, 2017, through September 29, 2020, to National Safe Place to operate RHYTTAC  National Safe Place is a national youth outreach program that aims to educate young people about the dangers of running away or trying to resolve difficult, threatening situations on their own  RHYTTAC is designed to provide training and conference services to RHYP grantees that enhance and promote continuous quality improvement to services provided by RHYP grantees  Further, RHYTTAC offers resources and information through its website, tip sheets, a quarterly newsletter, toolkits, sample policies and procedures, and other resources  RHYTTAC also provides assistance to individual grantees in response to their questions or concerns, as well as concerns raised by HHS as part of the Runaway and Homeless Youth Program Monitoring System (see subsequent section)  A portion of the funds for the BCP, TLP, and related activities are allocated for a national communications system known as the National Runaway Safeline ("Safeline")  The Safeline is intended to help homeless and runaway youth (or youth who are contemplating running away) through counseling, referrals, and communicating with their families  Beginning with FY1974 and every year after, the Safeline, which until 2013 was called the National Runaway Switchboard, has been funded through the Basic Center Program grant or the Consolidated Runaway and Homeless Youth Program grant  The Safeline is located in Chicago and operates each day to provide services to youth and their families across the country  Services include (1) a channel through which runaway and homeless youth or their parents may leave messages; (2) 24-hour referrals to community resources, including shelter, community food banks, legal assistance, and social services agencies; and (3) crisis intervention counseling to youth  In calendar year 2017, the Safeline handled nearly 30,000 contacts with youth (via phone, computer, emails, and postings), of which nearly three-quarters were from youth and 9% were from parents; the other callers were relatives, friends, and others  Other services are also provided through the Safeline  Since 1995, the "Home Free" family reunification program has provided bus tickets for youth ages 12 to 21 to return home or to an alternative placement near their home through Home Free  HHS evaluates each RHYP grantee through the Runaway and Homeless Youth Monitoring System  Staff from regional ACF offices and other grant recipients (known as peer reviewers) inspect the program site, conduct interviews, review case files and other agency documents, and conduct entry and exit conferences  The monitoring team then prepares a written report that identifies the strengths of the program and areas that require corrective action  The Reconnecting Homeless Youth Act of 2008 required that within one year of its enactment (October 8, 2009), HHS was to issue rules that specified performance standards for public and nonprofit entities that receive BCP, TLP, and SOP grants  On April 14, 2014, HHS issued a notice of proposed rulemaking (NPRM) for the new performance standards and other requirements for the Runaway and Homeless youth program grantees  On December 20, 2016, HHS implemented a final rule that was similar to the provisions in the NPRM  These standards are used to monitor individual grantee performance  The Senate Committee on Health, Education, Labor, and Pensions (HELP) and the House Committee on Education and Labor have exercised jurisdiction over the Runaway and Homeless Youth Program  HHS must submit reports biennially to the committees on the status, activities, and accomplishments of program grant recipients and evaluations of the programs performed by HHS  The most recent report was submitted in January 2018, and covered FY2014 and FY2015  The 2003 reauthorization law ( P L  108-96 ) of the Runaway and Homeless Youth Act required that HHS, in consultation with the U S  Interagency Council on Homelessness, submit a report to Congress on the promising strategies to end youth homelessness within two years of the reauthorization, in October 2005  The report was submitted to Congress in June 2007  As mentioned above, the 2008 reauthorization law ( P L  110-378 ) required HHS, as of FY2010, to periodically submit to Congress an incidence and prevalence study of runaway and homeless youth ages 13 to 26, as well as the characteristics of a representative sample of these youth  As discussed, Congress appropriated funding to HUD for this purpose and the study, known as Voices of Youth Count , includes multiple publications about its findings  The 2008 law also directed the Government Accountability Office (GAO) to evaluate the process by which organizations apply for BCP, TLP, and SOP, including HHS's response to these applicants  GAO submitted a report to Congress in May 2010 on its findings  GAO found weaknesses in several of the procedures for reviewing grants, such as that peer reviewers for the grant did not always have expertise in runaway and homeless youth issues and feedback on grants was not provided in a permanent record  In addition, GAO found that HHS delayed telling successful grantees that the grant had been awarded to them  HHS has implemented the recommendations made in the report  Appendix A  Basic Center Program (BCP) Funding Appendix B  Additional Federal Support for Runaway and Homeless Youth Since the creation of the Runaway and Homeless Youth Program, other federal initiatives have also established services for such youth  Youth Homelessness Demonstration Program (YHDP): The omnibus appropriations laws for FY2016 through FY2018 enabled HUD to set aside up to $33 million (FY2016), $43 million (FY2017), and $80 million (FY2018) from the Homeless Assistance Grants account to implement projects that demonstrate how a "comprehensive approach" can "dramatically reduce" homelessness for youth through age 24  The appropriations laws each fiscal year direct this funding to up to 10 communities with the FY2016 funding; up to 11 communities with the FY2017 funding, including at least five rural communities; and up to 25 communities with the FY2018 funding, including at least eight rural communities  HUD has allocated $33 million to 10 communities for FY2016 and $43 million for FY2017  In addition, HUD is taking steps to evaluate the YHDP grantee communities in developing and carrying out a coordinated community approach to preventing and ending youth homelessness  100-Day Challenges to End Youth Homelessness : Since 2016, cities have partnered with public and private entities to accelerate efforts to prevent and end youth homelessness  A Way Home America and Rapid Results Institute, organizations that focus on pressing social problems, have provided support to the organizations  HHS provided training and technical assistance through RHYTTAC to the first three cities involved in the challenge: Los Angeles, CA; Cleveland, OH; and Austin, TX  In general, participating communities have housed homeless youth and have identified new housing options for this population  Youth with Child Welfare Involvement At-Risk of Homelessness (YAHR): HHS has funded grants to build evidence on what works to prevent homelessness among youth and young adults who have child welfare involvement  HHS awarded funds to 18 grantees for a two-year planning period (2013-2015)  Six of the grantees received additional funding to refine and test their service models during a second phase (2015-2018)  A subset of those grantees will then be selected to conduct a rigorous evaluation of their impact on homelessness  In school year 2016-2017, more than 1 3 million children and youth were homeless  Of these students, over 118,000 were homeless youth unaccompanied by their families  The Department of Education administers the Education for Homeless Children and Youth program, which was established under the McKinney-Vento Homeless Assistance Act of 1987 ( P L  100-77 ), as amended  This program assists state education agencies (SEAs) to ensure that all homeless children and youth have equal access to the same, appropriate education, including public preschool education, that is provided to other children and youth  Grants made by SEAs to local education agencies (LEAs) under this program must be used to facilitate the enrollment, attendance, and success in school of homeless children and youth  Program funds may be appropriated for activities such as tutoring, supplemental instruction, and referral services for homeless children and youth, as well as providing them with medical, dental, mental, and other health services  McKinney-Vento liaisons for homeless children and youth in each LEA is responsible for coordinating activities for these youth with other entities and agencies, including local Basic Center and Transitional Living Program grantees  States that receive McKinney-Vento funds are prohibited from segregating homeless students from non-homeless students, except for short periods of time for health and safety emergencies or to provide temporary, special, supplemental services  FY2019 funding for the program is $93 5 million  According to a 2017 survey of 43,000 college students at selected colleges and universities, 9% of those attending four-year universities and 12% of those attending community college had been homeless in the last year  In addition, 37% of university students and 46% of community college students were housing insecure in the past year, meaning that they had difficulty paying rent or lived with others beyond the expected capacity of the housing, among other scenarios  The Higher Education Act (HEA) authorizes financial aid and support programs that target homeless students and other vulnerable populations  For purposes of applying for federal financial aid, a student's expected family contribution (EFC) is the amount that can be expected to be contributed by a student and the student's family toward his or her cost of education  Certain groups of students are considered "independent," meaning that only the income and assets of the student (and not their parents or guardians) are counted  Individuals under age 24 who have been verified during the school year as either (1) unaccompanied and homeless or (2) unaccompanied, self-supporting, and risk of homelessness  This verification can come from a McKinney-Vento liaison for homeless children and youth in the local education agency; the director (or designee) of a program funded under the Runaway and Homeless Youth program; the director (or designee) of an emergency shelter or transitional housing program funded by HUD; or a financial aid administrator  Separately, HEA provides that homeless children and youth are eligible for what are collectively called the federal TRIO programs  This includes the following TRIO programs: Talent Search, Upward Bound, Student Support Services, and Educational Opportunity Centers  The TRIO programs are designed to identify potential postsecondary students from disadvantaged backgrounds, prepare these students for higher education, provide certain support services to them while they are in college, and train individuals who provide these services  HEA directs the Department of Education (ED), which administers the programs, to (as appropriate) require applicants seeking TRIO funds to identify and make services available, including mentoring, tutoring, and other services, to these youth  TRIO funds are awarded by ED on a competitive basis  In addition, HEA authorizes services for homeless youth through TRIO Student Support Services—a program intended to improve the retention and graduation rates of disadvantaged college students—that include temporary housing during breaks in the academic year  In FY2019, TRIO appropriations are $1 1 billion  Separately, HEA allows additional uses of funds through the Fund for the Improvement of Postsecondary Education (FIPSE) to establish demonstration projects that provide comprehensive support services for students who are or were homeless at age 13 or older  FIPSE is a grant program that seeks to support the implementation of innovative educational reform ideas and evaluate how well they work  As specified in the law, the projects can provide housing to the youth when housing at an educational institution is closed or unavailable to other students  FY2019 appropriations for FIPSE are $5 million  Recently emancipated foster youth are vulnerable to becoming homeless  In FY2017, nearly 20,000 youth "aged out" of foster care  The Chafee Foster Care Independence Program (CFCIP), created under the Chafee Foster Care Independence Act of 1999 ( P L  106-169 ), provides states with funding to support children and youth ages 14 to 21 who are in foster care and former foster youth ages 18 to 21 (and up to age 23 in states that extend foster care to age 21)  States are authorized to receive funds based on their share of the total number of children in foster care nationwide  However, the law's "hold harmless" clause precludes any state from receiving less than the amount of funds it received in FY1998 or $500,000, whichever is greater  The program specifies funding for transitional living services, and as much as 30% of the funds may be dedicated to room and board  The program is funded through mandatory spending, and as such $140 million ($143 million as of FY2020) is provided for the program each year through the annual appropriations process  The Family Violence Prevention and Services Act (FVPSA), Title III of the Child Abuse Amendments of 1984 ( P L  98-457 ), authorized funds for Family Violence Prevention and Service grants that work to prevent family violence, improve service delivery to address family violence, and increase knowledge and understanding of family violence  From FY2007 to FY2009, one of these projects focused on runaway and homeless youth in dating violence situations through HHS's Domestic Violence/Runaway and Homeless Youth Collaboration on the Prevention of Adolescent Dating Violence initiative  The initiative was created because many runaway and homeless youth come from homes where domestic violence occurs and may be at risk of abusing their partners or becoming victims of abuse  The initiative funded eight states and community-based organizations to address the issue of teen dating violence among runaway and homeless youth  The grants funded activities such as curriculum on dating violence, small groups for teens, and a sexual assault/dating violence reduction program  The initiative resulted in an online toolkit for advocates in the runaway and homeless youth and domestic and sexual assault fields to help programs better address relationship violence with runaway and homeless youth 

ground_truth: USPS is required to prefund its share of health benefits costs for its retirees. To do so, USPS is required to make payments into the RHB Fund, which is administered by OPM. However, USPS has not made any payments to the fund since fiscal year 2010. At the end of fiscal year 2017, USPS had missed $38.2 billion in payments, leaving the fund 44 percent funded. Pursuant to law, beginning in fiscal year 2017, OPM started drawing from the fund to cover USPS's share of postal retirees' health benefits premiums. GAO was asked to review issues related to the sustainability of the RHB Fund. This report examines (1) the financial outlook for the RHB Fund and (2) policy approaches for postal retiree health benefits, among other topics. GAO evaluated financial projections for the RHB Fund from OPM. GAO reviewed laws and regulations and identified policy approaches primarily by identifying legislative proposals, and literature on actions of companies and state governments to address retiree health benefits. These approaches are not exhaustive or mutually exclusive. GAO also interviewed experts in retiree health benefits and postal stakeholders, chosen on the basis of relevant publications and prior GAO work, and interviewed and obtained written responses from OPM and USPS officials. The financial outlook of the Postal Service Retiree Health Benefits Fund (RHB Fund) is poor. At the end of fiscal year 2017, the fund's assets declined to $49.8 billion and unfunded liabilities rose to $62.2 billion. Based on Office of Personnel Management (OPM) projections requested by GAO, the fund is on track to be depleted in fiscal year 2030 if the United States Postal Service (USPS) continues to make no payments into the fund. Annual payments of $1 billion or $2 billion into the fund would extend the projected depletion date by 2 to 5 years (see figure). USPS has said that its required payments to the fund are unaffordable relative to its current financial situation and outlook. For the past 11 years USPS has incurred large operating losses that it expects will continue. Additionally, USPS has stated that its opportunities for revenue generation and cost-cutting are limited. USPS reported that it did not make required fund payments in 2017 in order to preserve liquidity and cover operational costs. If the fund becomes depleted, USPS would be required by law to make the payments necessary to cover its share of health benefits premiums for current postal retirees. Current law does not address what would happen if the fund becomes depleted and USPS does not make payments to cover those premiums. Depletion of the fund could affect postal retirees as well as USPS, customers, and other stakeholders, including the federal government. About 500,000 postal retirees receive health benefits and OPM expects that number to remain about the same through 2035. GAO identified three categories of policy approaches for postal retiree health benefits, based on legislative proposals and pertinent literature. First, some approaches, such as generally requiring eligible postal retirees to participate in Medicare, would shift costs to the federal government. Second, some approaches would reduce benefits or increase costs to postal retirees and/or employees. Third, some approaches would change how benefits are financed (see table). All of these approaches have different potential effects and would require congressional action. Thus, it is up to Congress to consider the merits of different approaches and determine the most appropriate action to take. It would be preferable to take action when careful consideration is possible, rather than wait until lack of adequate funding could disrupt postal retiree health benefits. Congress should consider passing legislation to put postal retiree health benefits on a more sustainable financial footing. USPS agreed that congressional action is needed and offered views on some policy approaches discussed in this report.

prompt_front: You are given two reports by the government agency.



Question: Write a one-page summary of the report 2.

Report 1: Postal retiree health benefits are provided as part of the Federal Employees Health Benefits Program (FEHBP)  FEHBP covers federal employees and retirees, including postal and nonpostal retirees, who receive health insurance from companies that contract with OPM  Retiree participation is voluntary; in fiscal year 2018, about 500,000 postal retirees have participated in FEHBP  Funding requirements for postal retiree health benefits are established by law, which divides responsibility among USPS, the federal government, and postal retirees  USPS is responsible for a specific percentage of premiums, the federal government is responsible for paying a prorated share, and retirees are responsible for the rest  The funding requirements for these benefits changed in 2006  Before then, a “pay-as- you-go” system governed USPS’s payments, which required USPS to pay its share of premiums for current postal retirees  The 2006 Postal Accountability and Enhancement Act (PAEA) required USPS to start fully “prefunding” retiree health benefits  This meant that USPS was required to make annual prefunding payments to a newly established fund to build up funds to cover USPS’s share of future postal retiree health benefit costs  PAEA also established the RHB Fund as a new fund in the U S  Treasury for USPS to deposit money into, and specified that beginning in fiscal year 2017, the fund would be used by OPM to pay USPS’s share of postal retiree premiums for health benefits  Under PAEA, the first 10 years of prefunding payments were fixed—ranging from $5 4 billion to $5 8 billion annually from fiscal years 2007 to 2016  From fiscal years 2007 through 2016, USPS was also required to continue “pay-as-you-go” payments for its share of premiums for current retirees  The permanent schedule for USPS payments to prefund postal retiree health benefits under PAEA started in fiscal year 2017  We have reported that USPS’s financial condition continues to deteriorate and its outlook is bleak  We have separately issued reports and testimonies that examined USPS’s financial condition, including its liabilities, and identified strategies and options for USPS and Congress to reduce postal costs, generate revenue, and restructure the funding of USPS’s pension and retiree health benefits  Looking forward, we have reported that USPS is facing unsustainable financial challenges as First- Class Mail volume continues to decline  USPS has recently reported that its revenue generation options are constrained, including by the price cap on market-dominant mail, and that any cost-cutting opportunities within its control are “relatively limited and dwindling ” USPS stated that the opportunity for further cost savings within its control will not come close to filling its financial gap  With respect to actions taken by companies and state governments, we have previously reported on the long-term trend for these organizations to eliminate or reduce retiree health benefits  Factors contributing to this decline include financial challenges for companies and states, current and expected retiree health benefit costs, and the legal ability to change retiree health benefit programs  The RHB Fund is on an unsustainable path and is projected to be depleted in 12 years under the status quo  USPS has missed approximately $38 billion in payments to the fund since fiscal year 2010, and the fund’s balance is declining  Beginning in fiscal year 2017, OPM started drawing from the fund to pay USPS’s share of premiums for postal retirees’ health benefits  OPM’s payments in that year exceeded the fund’s income from interest, and OPM projects that, based on the status quo, future payments will continue to exceed the fund’s income from interest  As long as USPS continues to miss its annual payments—which were nearly $4 3 billion in fiscal year 2017 and are $4 5 billion in fiscal year 2018—the fund is on track to be depleted in fiscal year 2030 based on OPM projections requested by us (see fig  1)  We reported similar results in our December 2012 report on postal retiree health benefits  At our request, OPM conducted a sensitivity analysis in which alternative projections were made that assumed USPS made payments to the fund of $1 billion per year or $2 billion per year; these alternative projections extended the fund’s projected depletion date from fiscal year 2030 to fiscal years 2032 or 2035, respectively (see fig  2)  OPM estimates the number of postal retirees eligible for federal retiree health benefits will remain near the current level of 500,000 through fiscal year 2035  The outlook for the RHB Fund is poor as USPS has inadequate resources to cover its required payments to the RHB Fund and, in our view, based on past practices and USPS statements, appears unlikely to make partial payments  USPS has repeatedly testified that its required payments to the RHB Fund are “unaffordable” relative to its current financial situation and outlook  In this regard, USPS accumulated net losses of more than $65 billion in the last 11 years and has budgeted for a net loss of about $5 billion in fiscal year 2018  Further, USPS reached its statutory borrowing limit of $15 billion in 2012  Although USPS accumulated liquid assets (cash and cash equivalents) of about $10 5 billion at the end of fiscal year 2017, it did not make $6 9 billion in required payments for retiree health and pension benefits  According to USPS officials, USPS did not make these payments in order to preserve liquidity and cover operational costs  If the RHB Fund is depleted, PAEA requires USPS to fill the resulting financial gap by resuming “pay-as-you-go” payments for its share of retiree health premiums that are currently being paid by the fund  However, PAEA does not address how funding will be provided or whether benefits will be provided if the fund becomes depleted and USPS does not make payments to cover its share of premiums  OPM and USPS have identified the following issues should the fund be depleted: According to OPM: (1) The RHB Fund is the initial funding source for USPS’s share of postal retirees’ health insurance premiums as long as money remains in the fund  (2) If the fund is depleted, then USPS becomes the funding source responsible for paying USPS’s share of these premiums  (3) Regardless of whether funds are available to pay USPS’s share of premiums, postal retirees are statutorily entitled to remain enrolled in their FEHBP plans  (4) Therefore, if the fund is depleted and USPS does not pay its share of premiums, the providers of these FEHBP plans would be underpaid  According to USPS: (1) Current law does not appear to contemplate a situation in which USPS itself is unable to make payments to the RHB Fund after the fund is depleted  (2) The law does not condition postal retirees’ eligibility for health benefits upon the fund or the payment of government contributions by USPS and the federal government  (3) Therefore, USPS stated it is reasonable to expect that postal retirees would remain eligible for health coverage even if USPS is unable to make payments to the RHB Fund after it is depleted  Regarding who would pay for their health coverage at this point, USPS stated that ultimately, it would be up to Congress to legislate a resolution to the funding issue  As the above projections show, the RHB Fund could be depleted in as little as 12 years—and USPS may be unable to cover its share of retiree health insurance premiums should its financial condition remain precarious  Depletion of the fund could affect postal retirees—who have provided a vital service to the nation—as well as USPS, postal customers and other stakeholders, including the federal government  Survey data we reviewed indicate that most companies do not offer retiree health benefits and that the number of companies providing such benefits is decreasing over time  For example, the percentage of all private and public organizations (e g , state or local governments) with more than 200 employees that offer employee health benefits and that also offer retiree health benefits is estimated to have declined from 40 percent in 1999 to 25 percent in 2017, according to annual surveys conducted by the Henry J  Kaiser Family Foundation and the Health Research & Educational Trust (Kaiser/HRET)  Focusing specifically on the results for private for-profit companies, the 2017 Kaiser/HRET survey estimated that only 11 percent of companies with at least 200 employees that offered health benefits to active employees also offered retiree health benefits in 2017, the smallest percentage since comparable data were measured in 2012  The 2017 Kaiser/HRET survey also estimated that the percentage of companies offering retiree health benefits was greater among companies with at least 5,000 employees (35 percent) than those with 1,000 to 4,999 employees (18 percent) and those with 200 to 999 employees (9 percent) (see fig  3)  Surveys sponsored by the Agency for Healthcare Research and Quality (AHRQ) have estimated similar trends for private sector establishments with at least 1,000 employees and with 100-999 employees  According to the AHRQ surveys, an estimated 25 percent of private sector establishments with at least 1,000 employees offered health insurance coverage to retirees age 65 and older in 2016, down from 41 percent in 2003  For retirees under 65, an estimated 32 percent offered such coverage in 2016, down from 42 percent in 2003 (see fig  4)  Based on reports we reviewed and experts we interviewed, many companies that have retained their retiree health benefits have done so by making changes to control costs, including tightening eligibility and restructuring benefits  Depending on the company, the changes have applied to new hires, current employees, or retirees  Specific changes have included the following: Tightening eligibility: Some companies have made new employees and/or employees hired after a given date ineligible to receive retiree health benefits, while other companies have increased the minimum age and/or length of service requirements for eligibility, according to reports and experts we interviewed  Restructuring benefits: Many companies have restructured retiree health benefits to reduce the level of the benefit, to shift costs to retirees, and to change how the benefits are provided  For example, some companies have shifted from an approach under which a company pays a percentage of premiums for a selected health benefit plan, to an approach under which a company pays a fixed dollar amount that employees may put toward health care costs  The 2017 Kaiser/HRET survey estimated that 30 percent of private and public organizations with 200 or more employees that offer retiree health benefits provide a fixed dollar amount that the retiree can use to purchase a retiree health plan they choose  Experts on retiree health benefits that we interviewed told us such companies often shift costs to retirees by maintaining defined contributions at the same level over time, even as overall health care costs increase  Based on multiple reports and experts, nearly all state governments continue to offer retiree health benefits to at least some state government retirees but generally have shifted some costs from the state to retirees and/or active employees in various ways  For example, in 2016, the Pew Charitable Trusts and the John D  and Catherine T  MacArthur Foundation reported on the following recent changes at the state level related to eligibility for retiree health benefits, benefit levels, and aspects of how the benefits coordinate with Medicare: Tightening eligibility or limiting benefit levels: Most states varied eligibility for retiree health benefits based on factors such as age and years of service, and varied benefit levels based on factors such as date of hire, date of retirement, or vesting eligibility; some states varied benefit levels based on years of service  Between 2000 and 2015, more than a dozen states changed the minimum age or the number of state service years required for retirees to be eligible for health benefits  During that timeframe, at least 10 states adopted formulas for prorating benefits that required different premium-sharing amounts based on years of service, or altered existing prorating formulas, bringing the total to 31 states that used prorating in 2015  At least 5 states stopped making any contributions to health premiums for certain retirees  Medicare coordination: Thirty-five states provided employer- sponsored Medicare Advantage or Medicare Part D plans, known as Employer Group Waiver Plans, to provide health or prescription drug benefit coverage for Medicare-eligible retirees since these options were authorized in 2003  According to the report, “These cost- saving programs provide states with financial subsidies from the federal Medicare program to provide Medicare plus wraparound benefits ” We identified eight potential policy approaches to address the financial sustainability of postal retiree health benefits, primarily based on a review of legislative proposals and pertinent literature on actions that were taken by private companies and state governments and are discussed above  These approaches fall into three categories: (1) approaches that shift costs to the federal government; (2) approaches that reduce benefits or increase costs to postal retirees and/or postal employees; and (3) approaches that change how the benefits are financed  These eight approaches are not mutually exclusive, nor are they an exhaustive list of possible approaches  Each approach could include a range of specific options; thus, even if successfully implemented, no one approach would necessarily be sufficient to make postal retiree health benefits financially sustainable  Although our discussion of the various policy approaches specifically addresses postal retiree health benefits, most approaches could address federal retiree health benefits more broadly, as both postal and non-postal federal employees participate in the same federal health benefits program  All approaches we identified have different potential effects and would require congressional action because current law establishes certain requirements for postal retiree health benefit plans, including basic rules for benefits, enrollment, and participation, and how benefits are to be paid for  Because the RHB Fund has a large and growing financial gap, any approach that would have a significant financial impact could affect the federal government, postal retirees, postal employees, USPS, and customers to varying degrees  Medicare Integration: Various legislative proposals have been made to increase postal retirees’ participation in Medicare—a shift that would decrease USPS’s costs but increase Medicare’s costs, according to analyses by the Congressional Budget Office (CBO)  These proposals would establish a program within FEHBP for active postal employees and postal retirees  Under these bills, Medicare-eligible postal retirees enrolled in this program would generally also be required to be enrolled in Medicare Parts A, B, and D  According to CBO analyses, the bills would have resulted in USPS savings, in part because increased participation in Medicare would shift primary responsibility for covering certain health care services to Medicare for those who enroll  As we have previously reported, the primary policy decision for Congress to make is whether to increase postal retirees’ use of Medicare  Supplemental federal appropriations: If the RHB Fund becomes depleted and USPS does not fill the financial gap, supplemental federal appropriations could be an alternative if Congress wants benefits to continue at the same level  As previously noted, OPM officials told us that regardless of whether funds are available to pay USPS’s share of premiums, postal retirees are statutorily entitled to remain enrolled in their FEHBP plans  However, supplemental federal appropriations for postal retiree health benefits could increase the federal budget deficit  In addition, supplemental appropriations for postal retiree health benefits would be inconsistent with USPS functioning as a self-financing entity that covers its costs with revenue it generates  Tighten eligibility or reduce or eliminate retiree health benefits: As some companies and state governments have done, eligibility restrictions could be tightened for postal retiree health benefits, or other actions could reduce the level of benefits or even eliminate benefits, such as making new hires ineligible to receive retiree health benefits  The effects would depend on the specific changes and whether they were made to apply to current retirees, current employees, or future hires  Depending on the extent of the changes, this approach would reduce USPS’s liability for postal retiree health benefits and thereby reduce its unfunded liability  Increase premium payments by postal retirees and/or postal employees: As some companies and state governments have done, premium payments for postal retiree health benefits by postal retirees and/or postal employees could be increased  For example, as others have reported, some companies and state governments have required retirees to pay 100 percent of the health insurance premium for their retiree health benefits  Similarly, a larger share of retiree health premiums could be borne by postal retirees or postal employees could be required to pay for retiree health benefits before they retire  Such changes would require changes to current law that allocates specific financial responsibility for payments among USPS, the federal government, and retirees participating in FEHBP, as active postal employees make no payment for retiree health benefits under current law  The expenses of the RHB Fund could be decreased by these approaches that shift costs to postal retirees, postal employees, or both  Depending on how much of the costs are shifted, the additional costs could increase the challenge for retirees to ensure their accumulated resources last throughout retirement, or for postal employees to save for retirement  Further, as we have reported, rising health care costs can increase the overall amount individuals may need to save to ensure they have an adequate income once they retire  Change the federal contribution to a fixed subsidy: As some companies and state governments have done, postal retiree health benefits could be shifted to a structure with a fixed amount subsidizing the benefit  This amount could be adjusted over time; any adjustments might or might not keep up with costs  Depending on the initial size of the fixed subsidy and any adjustments over time, this approach could reduce the expenses of the RHB Fund and USPS’s required payments  RHB Fund expenses could be reduced over time if the fixed subsidy increases less than postal retiree health premiums  This approach would require changes to current law and regulations that prescribe the federal government’s financial contribution to FEHBP  For example, CBO recently identified one option to change FEHBP’s statutory structure from a premium-sharing structure that is required by law to fixed subsidies for health benefits  Under this option, the fixed subsidies would grow at the rate of inflation rather than at the average rate of growth for FEHBP premiums; CBO stated this change would be expected to slow the growth of federal contributions to FEHBP  A fixed subsidy for retiree health benefits could increase incentives for retirees to make less costly decisions with respect to health care  However, this approach could result in greater cost exposure for retirees, who may face difficult decisions regarding their health care, particularly if their financial resources are limited  As we have reported, individuals face the risk that rising and unpredictable health care or long-term care costs may lead them to draw down their retirement savings faster than expected  Establish a non-federal voluntary employees’ beneficiary association (VEBA) for postal retiree health benefits: As some companies have done to provide retiree health benefits separately from the employer, a VEBA outside the federal government could be established to manage postal retiree health benefits  This approach means that postal retiree health benefits would be provided through the VEBA instead of through the OPM-administered FEHBP  The non-federal VEBA would administer the postal retiree health benefits program, including determining the specific benefits that would be provided and the level of contributions from the VEBA members—who could include retirees and employees—and the investing of its assets  Such an approach would require determining the VEBA’s governance structure, funding sources, level of funding, type of investments, and associated market risks  One issue could be determining the source and level of initial funding for a new VEBA for postal retiree health benefits, such as whether initial funding would come from the RHB Fund, the Treasury, or both  Other issues could be what funds would be provided to the VEBA going forward, including the source(s) and level of funding, and what the benefit levels would be  If the entire RHB Fund were transferred into a VEBA, the current level of benefits would ultimately not be sustainable unless further funding is provided from one or more sources, such as from USPS, retirees, active employees, or the federal government  Thus, trade-offs would involve what level of benefits would be provided, who would bear the costs, and what might happen if VEBA assets decline or become depleted  Reduce the required level of prefunding: Proposed legislation includes an 80 percent funding target for postal retiree health benefits instead of the 100 percent target established by current law  This would reduce USPS’s required payments to the RHB Fund but could increase costs for future postal ratepayers and increase the risk that USPS may not be able to pay for these costs  As previously discussed in this report, state governments either do not prefund their retiree health benefits or generally have a low level of prefunding  We have expressed concern about a proposed 80 percent funding target for postal retiree health benefits that would have the effect of carrying a permanent unfunded liability equal to roughly 20 percent of USPS’s liability, which could be a significant amount  As we previously reported, an alternative could be to build in a schedule to achieve 100 percent funding in a later time period after the 80 percent level is achieved  Although USPS payments with an 80 percent funding target would reduce USPS’s required payments, fully funded benefits protect against an inability to make payments later, make promised benefits less vulnerable to cuts, and protect USPS’s long-term viability  Further, reducing the funding target is unlikely to have any effect as long as USPS continues to make no payments to the RHB Fund, as discussed earlier  We continue to believe that as long as USPS is required by law to pay its share of retiree health benefits premiums, it is important for USPS to prefund its retiree health benefit liability to the maximum extent that its finances permit  We recognize that multiple options exist to prefund benefits and amortize unfunded liability and that no prefunding approach will be viable unless USPS can make the payments and maintain liquidity  As we have reported, making affordable prefunding payments would protect the viability of USPS by not saddling it with bills later on, when employees are already retired and no longer helping it to generate revenue; making payments can also make the promised benefits more secure  We also have reported that deferring payments can pass costs from current to future postal ratepayers  To the extent prefunding is postponed by using a lower funding target, larger payments will be required later, when they likely would be supported by lower levels of profitable First-Class Mail volume  Outside investment: Proposed legislation would initially require 25 percent of the RHB Fund to be invested in index funds modeled after those used for federal Thrift Savings Plan investments  The objective of investing RHB Fund assets outside of U S  Treasury securities would be to seek a greater rate of return on these assets in an attempt to reduce unfunded liabilities and the amount of required prefunding payments  Such outside investment would require legislation because current law limits RHB Fund assets to U S  Treasury securities that are backed by the full faith and credit of the federal government  A higher rate of return on RHB Fund assets could reduce long-term funding needs  However, there are other considerations  For example, we have reported that if fund assets were invested in non-Treasury securities, the fund may experience losses in a market downturn and would thus have reduced assets available for health care  Assuming there would be no explicit federal guarantee of the value of the invested assets, we stated that USPS is not well positioned to deal with a potentially significant decline in their value, given its significant operating losses and continuing decline in mail volume  We also reported that the impact of any asset losses could be magnified because a market downturn that negatively affects asset value could be associated with a more general economic downturn that negatively affects USPS mail volume and revenues  About a half million postal retirees receive retiree health benefits  Postal retirees have provided a vital service to the nation, and resolving a key aspect of their future situation warrants congressional action  Failure to address the poor financial outlook of the RHB Fund could pose serious consequences for these retirees as well as USPS, postal customers, and other stakeholders, including the federal government  It is reasonable to believe that USPS will not be able to fill the financial gap once the RHB fund is depleted—a situation that could occur in as little as 12 years under the status quo  There is no certainty on what actions should be taken to address this problem  However, we have identified multiple approaches that could be used, individually or in combination, that Congress could consider to help address the financial shortfall in this area  All of these approaches have different potential effects, and it is up to Congress to consider the merits of the approaches and determine the most appropriate action to take  It would be preferable to take action when careful consideration is possible, rather than wait until lack of adequate funding could disrupt postal retiree health benefits  Congress should consider passing legislation to put postal retiree health benefits on a more sustainable financial footing  We provided a draft of this report to OPM and USPS for their review and comment  OPM provided technical comments, which we incorporated as appropriate  USPS provided a written response, which is reproduced in appendix II of this report  In its written response, USPS stated that it concurred with our matter for congressional consideration that congressional action is necessary to achieve a financially sustainable Postal Service Retiree Health Benefits Fund (RHB Fund)  However, USPS said our discussion of potential policy approaches for postal retiree health benefits would benefit from additional context and balance  USPS also put forth additional information for three of the potential policy approaches highlighted in our report  Our report presents a high-level overview of eight potential policy approaches  It was not designed to be a comprehensive catalog of possible options with an analysis of the various considerations relevant to each  With regard to the Medicare integration approach, USPS stated that increased Medicare participation by postal retirees is not limited to the “full Medicare integration option,” as represented in our report and identified variations of such an approach  USPS said readers would benefit from a fuller picture of Medicare integration practices, stating that among employers that continue to provide retiree health benefits, full Medicare integration is a uniform best practice  USPS cited a 2014 report that said Medicare integration is the most common arrangement for employer-provided retiree health benefits, adding that retiree health benefits for Medicare-eligible employees are assumed to be merely supplemental to Medicare as a matter of course  Our report discussed Medicare integration by state governments, but did not present recent data on the percentage of private companies that coordinate their retiree health benefits with Medicare because such data are not publicly available  Additionally, USPS said our report framed the issue of Medicare integration as “solely” a tradeoff between USPS and Medicare costs while there are other factors to consider, such as the relative benefits to USPS compared to the overall cost for the Medicare program  As we noted in our report, the eight potential policy approaches were not designed to be mutually exclusive, nor an exhaustive list of possible approaches  Additionally, we recognize there are various factors related to this approach, but that the primary one is whether to increase postal retirees’ use of Medicare which would lead to further increasing Medicare costs  Second, USPS said it believed our statements about approaches for changing the level of prefunding for retiree health benefits below the 100 percent level were misplaced, citing “universally accepted practices” for other entities to “pay-as-you-go” (i e , not prefund at all), or to prefund at much lower levels  We have reported on such funding levels in the past as well  However, a proposed 80 percent funding target for postal retiree health benefits would have the effect of carrying a permanent unfunded liability equal to roughly 20 percent of USPS’s liability, which could be a significant amount  As we previously reported, an alternative could be to build in a schedule to achieve 100 percent funding in a later time period after the 80 percent level is achieved  As our report also explained, although USPS payments with an 80 percent funding target would reduce USPS’s required payments, fully funded benefits protect against an inability to make payments later, make promised benefits less vulnerable to cuts, and protect USPS’s long-term viability  Finally, USPS said that our statements about potential risks associated with investment of assets outside the U S  Treasury seem disproportionate given USPS’s view that diversification of assets set aside for retiree health benefits is “universally accepted” as a best practice  We recognize that a higher rate of return on RHB Fund assets could reduce long-term funding needs for the RHB Fund  However, there are considerations specific to USPS  For example, assuming there would be no explicit federal guarantee of the value of the invested assets, we stated that USPS is not well positioned to deal with a potentially significant decline in their value, given its significant operating losses and continuing decline in mail volume  We also noted that, as we have previously reported, the impact of any asset losses could be magnified because a market downturn that negatively affects asset value could be associated with a more general economic downturn that also negatively affects USPS mail volume and revenues  In summary, we believe our report presents a balanced description of a wide range of possible policy options; it does not endorse or recommend any particular option for Congress  As we concluded, all of these approaches have different potential effects, and the information we present, as well as the additional views presented by USPS, provide critical information for congressional decision-makers to assess as they consider the merits of the approaches and determine the most appropriate action to take  As agreed with your office, unless you publicly announce the contents of this report earlier, we plan no further distribution until 30 days from the report date  At that time, we will send copies to the appropriate congressional committees; the Postmaster General; and the Director of the Office of Personnel Management  In addition, the report will be available at no charge on the GAO website at http://www gao gov  If you or your staff have any questions concerning this report, please contact me at (202) 512-2834 or rectanusl@gao gov  Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report  GAO staff that made key contributions to this report are listed in appendix III  End of year net funded status (unfunded) (55 0) Missed USPS payments to the fund (53 5) (52 0) (48 6) (46 2) (47 8) (48 3) (48 9) (54 8) (52 1) payments due on Sept  30, 2017, of $955 million for the amortization of USPS’s unfunded liability for postal retiree health benefits, and $3 3 billion for the “normal costs” of retiree health benefits  The “normal cost” is the annual expected growth in liability attributable to an additional year of employees’ service  In addition to the individual named above, Derrick Collins (Assistant Director); Kenneth John (Analyst-in-Charge); Amy Abramowitz; Taiyshawna Battle; William Colwell; Swati Deo; John Dicken; Leia Dickerson; William Hadley; James Leonard; Emei Li; Thanh Lu; Sara Ann Moessbauer; Joshua Parr; Malika Rice; Matthew Rosenberg; Amy Rosewarne; Frank Todisco; and Crystal Wesco made key contributions to this report 


Report 2: , freestanding medical schools)  Specific educational programs are often accredited by a specialized accrediting agency, and the institution at which the program is offered is accredited by a regional or national accrediting organization  Generally, an institution must be accredited by an ED-recognized accrediting agency that has the authority to cover all of the institution's programs  Alternatively, a public or private nonprofit IHE may be preaccredited by an agency recognized by ED to grant such preaccreditation, and a public postsecondary vocational institution may be accredited by a state agency that ED determines is a reliable authority  Proprietary institutions must be accredited by an ED-recognized accrediting agency  The accreditation process begins with an institution or program requesting accreditation  Institutional accreditation is cyclical, with a cycle ranging from every few years up to 10 years  Initial accreditation does not guarantee subsequent renewal of the accredited status  Typically, an institution seeking accreditation will first perform a self-assessment to determine whether its operations and performance meet the basic standards required by the relevant accrediting agency  Next, an outside group of higher education peers (e g , faculty and administrators) and members of the public conduct an on-site visit at the institution during which the team determines whether the accrediting organization's standards are being met  Based on the results of the self-assessment and site visit, the accrediting organization determines whether accreditation will be awarded, renewed, denied, or provisionally awarded to an institution  Educational programs within institutions can be accredited by programmatic accrediting agencies; however, a program is not required to be accredited by a programmatic accrediting agency for Title IV purposes  Rather, it only needs to be covered by the IHE's primary accrediting agency  Frequently, programmatic accrediting agencies review a specific program within an IHE that is accredited by a regional or national accrediting agency  An institution that has had its accreditation revoked or terminated for cause cannot be recertified as an IHE eligible to participate in Title IV programs for 24 months following the loss of accreditation, unless the accrediting agency rescinds the loss  The same rules apply if an institution voluntarily withdraws its accreditation  The Secretary can, however, continue the eligibility of a religious institution whose loss of accreditation, whether voluntary or not, is related to its religious mission and not to the HEA accreditation standards  If an institution's accrediting agency loses its recognition from ED, it has up to 18 months to obtain accreditation from another ED-recognized agency  Although the federal government does not set specific standards for institutional or programmatic accreditation, generally, it does require that institutions be accredited or preaccredited by a recognized accrediting organization to be eligible for Title IV participation  ED's primary role in accreditation is to recognize an accrediting agency as a "reliable authority regarding the quality of education or training offered" at IHEs through the processes and conditions set forth in the HEA and federal regulations  For ED recognition, Section 496 of the HEA specifically requires that an accrediting agency be a state, regional, or national agency that demonstrates the ability to operate as an accrediting agency within the relevant state or region or nationally  Additionally, agencies must meet one of the following criteria: IHE membership with the agency must be voluntary, and one of the primary purposes of the agency must be accreditation of the IHEs  The agency must be a state agency approved by the Secretary as an accrediting agency on or before October 1, 1991  The agency must either conduct accreditation through a voluntary membership of individuals in a profession, or it must have as its primary purpose the accreditation of programs within institutions that have already been accredited by another ED-recognized agency  Agencies that meet the first or third criterion listed above must also be administratively and financially separate and independent of any related trade association or membership organization  For an agency that meets the third criterion and that was ED-recognized on or before October 1, 1991, the Secretary may waive the requirement that the agency be administratively and financially independent of any related organization, but only if the agency can show that the existing relationship with the related organization has not compromised its independence in the accreditation process  All types of accrediting agencies must show that they consistently apply and enforce standards that ensure that the education programs, training, or courses of study offered by an IHE are of sufficient quality to meet the stated objectives for which the programs, training, or courses are offered  The standards used by the accrediting agencies must assess student achievement in relation to the institution's mission; this may include course completion, job placement rates, and passage rates of state licensing exams  Agencies must also consider curricula, faculty, facilities, fiscal and administrative capacity, student support services, and admissions practices  Accrediting agencies must also meet requirements that focus on the review of an institution's operating procedures, including reviewing an institution's policies and procedures for determining credit hours, the application of those policies and procedures to programs and coursework, and reviewing any newly established branch campuses  They must also perform regular on-site visits that focus on the quality of education and program effectiveness  The final component of the program integrity triad is eligibility and certification by ED  Here, ED is responsible for verifying an institution's legal authority to operate within a state and its accreditation status  ED also evaluates an institution's financial responsibility and administrative capability to administer Title IV student aid programs  An institution can be certified to participate in Title IV for up to six years before applying for recertification  ED determines an IHE's financial responsibility based on its ability to provide the services described in its official publications, to administer the Title IV programs in which it participates, and to meet all of its financial obligations  A public IHE is deemed financially responsible if its debts and liabilities are backed by the full faith and credit of the state or another government entity  A proprietary or private nonprofit IHE is financially responsible if it meets specific financial ratios (e g , equity ratio) established by ED, has sufficient cash reserves to make any required refunds (including the return of Title IV funds), is meeting all of its financial obligations, and is current on its debt payments  Even if an institution meets the above requirements, ED does not consider it financially responsible if the IHE does not meet third-party financial audit requirements or if the IHE violated past performance requirements, such as failing to satisfactorily resolve any compliance issues identified in program reviews or audits  Alternatively, if an institution does not meet the above standards of financial responsibility, ED may still consider it financially responsible or give it provisional certification, under which it may operate for a time, if it qualifies under an alternative standard  These alternative standards include submitting an irrevocable letter of credit to ED that is equal to at least 50% of the Federal Student Aid (FSA) program funds that the IHE received during its most recently completed fiscal year, meeting specific monitoring requirements, or participating in the Title IV programs under provisional certification  Along with demonstrating financial responsibility, an institution must demonstrate its ability to properly administer the Title IV programs in which it participates and to provide the education it describes in public documents (e g , marketing brochures)  Administrative capability focuses on the processes, procedures, and personnel used in administering Title IV funds and indicators of student success  Administrative capability standards address numerous aspects of Title IV administration  For example, to administer Title IV programs an institution must use ED's electronic processes and develop a system to identify and resolve discrepancies in Title IV information received by various institutional offices  The IHE must also refer cases of Title IV student fraud or criminal misconduct to ED's Office of Inspector General for resolution, and it must provide all enrolled and prospective students financial aid counseling  Finally, the IHE must have an adequate internal system of checks and balances that includes dividing the functions of authorizing payments and disbursing funds between two separate offices  Institutions are required to have a capable staff member to administer Title IV programs and coordinate those programs with other aid received by students  This person must also have an adequate number of qualified staff to assist with aid administration  Before receiving Title IV funds, an IHE must certify that neither it nor its employees have been debarred or suspended by a federal agency; similar limitations apply to lenders, loan servicers, and third-party servicers  Relating to indicators of student success, an institution must have satisfactory academic progress (SAP) standards for students receiving Title IV funds  In general, IHEs must develop SAP standards that establish a minimum grade point average (or its equivalent) for students and a maximum time frame in which students must complete their educational programs  A student who fails to meet the SAP requirements becomes ineligible to receive Title IV funds  Also related to student success indicators, an institution that seeks to participate in Title IV programs for the first time may not have an undergraduate withdrawal rate for regular students that is greater than 33% during its most recently completed award year  An institution may be deemed administratively incapable if it has a high cohort default rate (CDR)  In general, the CDR is the number of an IHE's federal loan recipients who enter repayment in a given fiscal year (the cohort fiscal year) and who default within a certain period of time after entering repayment (cohort default period; CDP), divided by the total number of borrowers who entered repayment in the cohort fiscal year  Since 2014, ED has used a three-year CDP in calculating an institution's CDR  An IHE will be found administratively incapable if one of the following conditions is met: 1  an institution's CDR is greater than 40% in one year for loans made under the FFEL and Direct Loans programs; 2  an institution's CDR is 30% or greater for each of the three most recent fiscal years for loans made under the FFEL and Direct Loans programs; or 3  an institution's CDR is 15% or greater in any single year for loans made under the Federal Perkins Loan Program  When an IHE is determined to be administratively incapable due to a high CDR, it may become ineligible to participate in the Direct Loan, Pell Grant, and/or Perkins Loan programs (but not other Title IV programs)  ED may grant provisional certification for up to three years to an institution that would be deemed administratively capable except for its high cohort default rates  If an institution is seeking initial certification, ED can grant it up to one year of provisional certification  ED can also grant an institution provisional certification for up to three years if ED is determining the IHE's administrative capacity and financial responsibility for the first time, if the IHE has experienced a partial or total change in ownership, or if ED determines that the administrative or financial condition of the IHE may hinder its ability to meet its financial responsibilities  Additionally, if an accrediting agency loses its ED recognition, any institution that was accredited by that agency may continue to participate in Title IV programs for up to 18 months after ED's withdrawal of recognition  To ensure that an institution is conforming to eligibility requirements, ED can conduct program reviews  During a program review, ED evaluates an institution's compliance with Title IV requirements and identifies actions the IHE must take to correct any problem(s)  Review priority is given to those institutions with high cohort default rates; IHEs with significant fluctuations in Pell Grant awards or Direct Loan volume that are not accounted for by changes in programs offered; IHEs that are reported to have deficiencies or financial aid problems by their state or accrediting agency; IHEs with high annual dropout rates; and IHEs determined by ED to pose a significant risk of failing to comply with the administrative capability or financial responsibility requirements  If, during a review, ED determines that an institution is not administratively capable or financially responsible or is violating Title IV program rules, ED may grant it provisional certification, take corrective actions, or impose sanctions  ED has the authority to impose a variety of sanctions and corrective actions on an institution that violates Title IV program rules, a Program Participation Agreement (discussed later in this report) or any other agreement made under the laws or regulations, or if it substantially misrepresents the nature of its educational programs, financial charges, or graduates' employability  Sanctions include fines, limitations, suspensions, emergency actions, and terminations  ED can also sanction third-party servicers performing tasks related to the institution's Title IV programs  ED may impose several types of sanctions on institutions for statutory and regulatory violations, including fines, limitations, and suspensions  ED can fine an institution up to $55,907 for each statutory or regulatory violation it commits, depending on the size of the IHE and the seriousness of the violation  Under a limitation, ED imposes specific conditions or restrictions on an institution related to its administration of Title IV funds  A limitation lasts for at least 12 months, and if an institution fails to abide by the limitation, ED may initiate a termination proceeding  Finally, under a suspension, an institution is not allowed to participate in Title IV programs for up to 60 days  Each of these sanctions may require an institution to take corrective actions as well, which may include repaying illegally used funds or making payments to eligible students from the IHE's own funds  ED can take emergency action to withhold Title IV funds from an institution if it receives reliable information that an IHE is violating applicable laws or regulations, agreements, or limitations  ED must determine that the institution is misusing federal funds, that immediate action is necessary to stop misuses, and that the potential losses outweigh the importance of using established procedures for limitation, suspension, or termination  An emergency action suspends an institution's participation in Title IV programs and prohibits it from disbursing such funds  Typically, the emergency action may not last more than 30 days  The final action ED can take is the termination of an institution's participation in Title IV programs  Generally, an institution that has had its participation terminated cannot reapply to be reinstated for at least 18 months  To request reinstatement, an institution must submit a fully completed application to ED and demonstrate that it has corrected the violation(s) for which its participation was terminated  ED may then approve, approve subject to limitations, or deny the institution's request  Several other requirements affect institutional eligibility for Title IV programs  Some of these requirements include institution Program Participation Agreements, which include provisions related to incentive compensation and campus crime reporting requirements; return of Title IV funds; and distance education  The failure to meet the requirements for any of these may result in the loss of Title IV eligibility or other sanctions  HEA Section 487 specifies that each institution wanting to participate in Title IV student aid programs is required to have a current Program Participation Agreement (PPA)  A PPA is a document in which the institution agrees to comply with the laws, regulations, and policies applicable to the Title IV programs; it applies to an IHE's branch campuses and locations that meet Title IV requirements, as well as its main campus  It also lists all of the Title IV programs in which the IHE is eligible to participate, the date on which the PPA expires, and the date on which the IHE must reapply for participation  By signing a PPA, an institution agrees that it will act as a fiduciary responsible for properly administering Title IV funds, will not charge students a processing fee to determine a student's eligibility for such funds, and will establish and maintain administrative and fiscal procedures to ensure the proper administration of Title IV programs  The PPA reiterates many provisions required for institutional eligibility and ED certification discussed earlier in this report and contains several additional notable requirements that may affect an IHE's Title IV eligibility, which are described below  Along with the general participation requirements with which an institution must comply, a PPA may also contain institution-specific requirements  As part of their PPAs, domestic and foreign proprietary IHEs must agree to derive at least 10% of their revenue from non-Title IV funds (i e , no more than 90% of their revenue can come from Title IV funds)  This is known as the 90/10 rule  Examples of non-Title IV funds include private education loans and some military and veterans' benefits, such as benefits provided under the Post-9/11 GI Bill program  If an IHE violates the 90/10 rule in one year, it does not immediately lose its Title IV eligibility  Rather, it is placed on a provisional eligibility status for two years  If the IHE violates the 90/10 rule for two consecutive years, it loses its eligibility for at least two years  In a PPA, an IHE must agree it will not provide any commission or incentive compensation to individuals based directly or indirectly on their success in enrolling students or the enrolled students' obtaining financial aid; however, some exceptions apply to this general rule  For instance, IHEs can provide incentive compensation to individuals for the recruitment of foreign students who are ineligible to receive Title IV funds or they can provide incentive compensation through a profit-sharing plan  The ban on incentive compensation only applies to the activities of securing enrollment (recruitment) and securing financial aid  Other activities are not banned, and ED draws a distinction between activities that involve directly working with individual students and policy-level determinations that affect recruitment and financial aid awards  For instance, an individual who is responsible for contacting potential student applicants or assisting students in filling out an enrollment application cannot receive incentive compensation, but an individual who conducts marketing activities, such as the broad dissemination of informational brochures or the collection of contact information, can receive incentive compensation  HEA Section 485(f), referred to as the Clery Act, requires domestic Title IV participating IHEs (1) to report to ED campus crime statistics and (2) establish and disseminate campus safety and security policies  Both the campus crime statistics and campus safety and security policies must be compiled and disseminated to current and prospective students and employees in an IHE's annual security report (ASR)  Campus crime statistics required to be reported to ED and included in an ASR include data on the occurrence on campus of a range of offenses specified in statute, including murder, burglary, robbery, domestic violence, rape, and other forms of sexual violence  In addition to campus crime statistics, ASRs must include statements of campus safety and security policies regarding, for example, procedures and facilities for students and others to report criminal actions or other emergencies occurring on campus and an IHE's response to such reports; security and access to campus facilities; campus law enforcement, including the law enforcement authority of campus security personnel, and the working relationship between campus security personnel and state and local law enforcement; programs designed to inform students and employees about the prevention of crimes; and the possession, use, and sale of alcoholic beverages and illegal drugs; enforcement of state underage drinking laws; enforcement of federal and state drug laws; and any drug or alcohol abuse education programs required under the HEA  An ASR must also include statements of policies specifically relating to incidence of domestic and sexual violence  For example, an ASR must include statements of policy regarding programs to prevent such incidents; procedures a victim should follow if such an incident as occurred; procedures an IHE will follow once such an incident has been reported and procedures for institutional disciplinary actions in cases of alleged incidents (including a statement of the standard of evidence that will be used in any school proceeding arising from the incident report); and possible sanctions and protective measures that an IHE may impose following a final determination in an institutional proceeding regarding such incidences  The Clery Act prohibits the Secretary of Education from requiring IHEs to adopt particular policies, procedures, or practices; and prohibits retaliation against anyone exercising his or her rights or responsibilities under the act  HEA Section 484B specifies that when a Title IV aid recipient withdraws from an IHE before the end of the payment or enrollment period for which funds were disbursed, Title IV funds must be returned to ED according to a statutorily prescribed schedule  In general, when a student withdraws from an IHE, an IHE first determines the portion of Title IV aid considered to be "earned" by the student while enrolled and the portion considered to be "unearned " Unearned aid must be returned to ED  Up to the 60% point of a payment or enrollment period, unearned funds must be returned on a pro rata schedule  After the 60% point of a payment or enrollment period, the total amount of funds awarded is considered to have been earned by the student and no funds are required to be returned  Whether an IHE and/or the student is required to return the funds to ED depends on a variety of circumstances, including whether Title IV funds have been applied directly to a student's institutional charges  Unearned funds must be returned to their respective programs in a specified order, with loans being returned first, followed by Pell Grants, and then other Title IV aid  In some instances, a student may have earned more aid than has been disbursed, and the difference is disbursed to the student after the student withdraws  Generally, distance education and correspondence education refers to educational instruction with a separation in time, place, or both between the student and instructor  It is a way in which institutions can increase student access to postsecondary education by offering alternatives to traditional on-campus instruction  Recently, due to the greater availability of new technologies, there has been substantial growth in the amount and types of courses institutions offer  Section 103(7)(A) and (B) of the HEA and the accompanying regulations define distance education as instruction that uses "(1) the internet; (2) one-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber optics, satellite, or wireless communications devices; [or]     (3) audio conferencing" to deliver instruction to students separated from the instructor  A course taught through a video cassette, DVD, or CD-ROM is considered a distance education course if one of the above-mentioned technologies is used to support student-instructor interaction  Regardless of the technology used, "regular and substantive interaction between the students and the instructor" must be ensured  Correspondence courses are expressly excluded from the definition of distance education  A correspondence course is one for which an institution provides instructional materials and exams for students who do not physically attend classes at the IHE, but does not include those courses that are delivered with "regular and substantive interaction between the students and the instructor" via one of the above-described technologies  In 1992, partially in response to cases of some correspondence institutions' fraudulent and abusive practices used to attract unqualified students to enroll in programs of poor or questionable quality, Congress incorporated provisions referred to as the "50% rules" into the HEA  The rules affected both the eligibility of institutions offering correspondence courses and their students' eligibility for Title IV aid  In general, under the rules, an institution is ineligible for Title IV aid if more than 50% of its courses are offered by correspondence, or if 50% or more of its students are enrolled in correspondence courses  As discussed earlier in this report, rules promulgated in 2016 would have required an IHE offering postsecondary distance or correspondence education in a state in which it is not physically located to meet any state authorization requirements within that state  Under the regulations, an IHE could meet this requirement if it participates in a state authorization reciprocity agreement  These regulations were scheduled to become effective July 1, 2018  However, on July 3, 2018 (and effective June 29, 2018), the Secretary of Education issued a final rule delaying the implementation of these requirements until July 1, 2020  The distinction between distance education and traditional instruction is also important for the purposes of Title IV program eligibility  Distance education programs provided by domestic IHEs are eligible for Title IV participation if they have been accredited by an accrediting agency recognized by ED to evaluate distance education programs  A program offered by a foreign IHE, in whole or in part, through distance education (including telecommunications) or correspondence is ineligible for Title IV participation 

ground_truth: Title IV of the Higher Education Act (HEA) authorizes programs that provide financial assistance to students to assist them in obtaining a postsecondary education at certain institutions of higher education (IHEs). These IHEs include public, private nonprofit, and proprietary institutions. For students attending such institutions to be able to receive Title IV assistance, an institution must meet basic criteria, including offering at least one eligible program of education (e.g., programs leading to a degree or preparing a student for gainful employment in a recognized occupation). In addition, an IHE must satisfy the program integrity triad, under which it must be licensed or otherwise legally authorized to operate in the state in which it is physically located, accredited or preaccredited by an agency recognized for that purpose by the Department of Education (ED), and certified by ED as eligible to participate in Title IV programs. These requirements are intended to provide a balance between consumer protection, quality assurance, and oversight and compliance in postsecondary education providers participating in Title IV student aid programs. An IHE must also fulfill a variety of other related requirements, including those that relate to institutional recruiting practices, student policies and procedures, and the administration of the Title IV student aid programs. Finally, additional criteria may apply to an institution depending on its control or the type of educational programs it offers. For example, proprietary institutions must meet HEA requirements that are otherwise inapplicable to public and private nonprofit institutions, including deriving at least 10% of their revenues from non-Title IV funds (also known as the 90/10 rule). While an institution is ineligible to participate in Title IV programs if more than 50% of its courses are offered by correspondence or if 50% or more of its students are enrolled in correspondence courses. This report first describes the types of institutions eligible to participate in Title IV programs and discusses the program integrity triad. It then discusses additional issues related to institutional eligibility, including program participations agreements, required campus safety policies and crime reporting, and distance and correspondence education.