School Closure of Branch Campuses/Additional Locations

Introduction:

The term “closed” refers to a main campus or location of an institution where the institution has ceased to provide educational instruction in all

programs for reasons other than a normal vacation period or a natural disaster that directly affects the school and its students.

A closure of a main campus or an eligible additional location involves a two-step process at Federal Student Aid (FSA). First, it is coded in FSA’s

systems as a loss of Title IV eligibility due to closure. Then, FSA’s closed school analyst conducts research to verify the closure and determine if it 

meets the regulatory requirements for closure. If it does, the date of the closure is determined, and the location is added to the Department’s closedschool database and students in attendance at that location become eligible for a closed school discharge.

The chart below provides a summary of different circumstances and whether the Department’s current procedures would consider the institution as 

closed.

Circumstance Result Considered a 

closure? 

An additional location moves to a new location that is more than 20 miles away 

from the current location (or less in an area where 20 miles is not a typical 

commuting distance such as when students rely on a public transportation 

system and that system does not serve the new location, or the new location is 

more than a 30 minute drive from the old location) and/or the additional 

location moves to another state where a majority of the teachers, students and 

staff members are not able to attend the new location.

The new location could still apply for 

approval, but the old location would lose 

Title IV eligibility and be considered closed.

Yes

An additional location moves to a new location that is more than 20 miles away 

from the current location (or less in an area where 20 miles is not a typical 

commuting distance such as when students rely on a public transportation 

system and that system does not serve the new location, or the new location is 

more than 30 minute drive from the old location) and/or the additional location 

moves to another state where the institution can document that a majority of the 

teachers, students and staff members are able to attend the new location.

This is considered a move/address change

and the location would not be considered 

closed.

No

Circumstance Result Considered a closure? 
An additional location moves to a new location that is less than 20 miles away 

from the current location (or in an area where 20 miles is not a typical 

commuting distance such as when students rely on a public transportation 

system and that system does not serve the new location, the new location is a 30 

minute or less drive from the old location) and/or the additional location moves 

to another state where the institution can document that a majority of the 

teachers, students and staff members are able to attend the new location.

This is considered a move/address change

and the location would not be considered 

closed.

No

An additional location moves to a new location and the institution is making 

teach-out arrangements for students at the old location.

The new location could apply for approval, 

but the old location would lose Title IV

eligibility and be considered closed.

Yes

An institution purchases another institution and becomes an additional location 

of the institution being purchased without an interruption in instruction.

The institution becoming the additional 

location will be approved as an additional 

location under the purchased institution and 

will lose Title IV eligibility as a stand-alone 

institution based on the merger.

No

An institution purchases another institution, and the institution being purchased 

becomes an additional location without an interruption in instruction.

The institution becoming the additional 

location will be approved as an additional 

location under the purchasing institution 

and will lose Title IV eligibility as a standalone institution based on the merger.

No

An institution is purchased by another institution, but both remain open and 

continue to provide instruction.

Once the change in ownership is complete, 

both institutions are eligible and unless they 

apply for merger, they retain separate 

OPEID numbers.

No

An institution closes to provide instruction at its main campus or a location, but 

another institution or entity acquires the assets of the location.

The location is considered closed. The sale 

of assets after closure does not impact the 

location’s status as “closed.”

Yes

An institution purchases an additional location of another institution with no 

interruption in instruction.

This would be considered a change of 

affiliation and the location would not be 

considered closed.

No

Circumstance Result Considered a closure? 
An institution’s main campus closes, and the institution also has approved 

additional locations.

The main campus and all locations lose

Title IV eligibility. The main campus would 

be considered closed as well as any 

locations that closed.

Yes. However, any 

locations that remain 

open would lose Title 

IV eligibility, but 

would not be 

considered closed.

An approved additional location stops offering a single program but remains 

open, where the institution continues offering instruction for other programs.

The location could continue operating as an 

approved additional location as long as it is 

providing 50 percent or more of instruction 

in at least one approved program. The 

location would not be considered closed as 

long as instruction continued to be offered

at that location for at least one other eligible 

program.

No

An approved additional location ceases providing at least 50% of an eligible 

program (for example, offering only 25% of an eligible program) but remains 

open.

If 50% or more of an eligible program is not 

offered at the additional location, it is not 

required to be reported to the Department. 

Therefore, the location would lose official 

designation as an eligible location but 

would not be considered closed.

No

An institution permanently ceases providing any instruction at an additional 

location and instructs students to attend virtually.

The additional location would lose Title IV

eligibility and be considered closed.

Yes

A main campus or location is forced to close temporarily due to a natural 

disaster (hurricane, flood, earthquake, fire, outbreak, etc.)

Unlike cessation of providing an 

educational program for other reasons, 

closure due to a natural disaster does not 

automatically result in a loss of eligibility or 

participation. An institution should 

promptly contact its School Participation 

Division (SPD) to discuss its situation. SPD

staff work with the institution to determine 

when it plans to reopen and what impact 

that interruption will have on its students. 

See DCL GEN-17-08.

No. However, if the 

location is not able to 

reopen, it would be 

considered closed.