January 2019

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Federal Grant Eligibility for Title III and Title V Programs

Knowing your organization’s federal grant eligibility is key to monitoring and applying for grants that help sustain and grow institutional programs and priorities, but questions of federal grant eligibility can often be confusing. That’s especially true regarding eligibility for the multiple programs offered under the Title III and Title V umbrellas. The U.S. Department of Education (DOE) has taken steps to simplify the eligibility determination process by using data that’s readily available; however, higher education institutions still need to understand the process and take steps to ensure their information is accurate and, if appropriate, apply for a waiver of eligibility. Competition for these grants is rigorous, and even if your organization doesn’t receive grant funding through the Title III and Title V programs, there are many benefits to having this federal grant eligibility designation.

A Little History

The Title III grant program was part of the Higher Education Act (HEA) that Congress passed in 1965. The grant program was designed to bolster postsecondary institutions whose student populations included a high percentage of low-income and minority students and was aimed primarily at supporting what are now Historically Black Colleges and Universities (HBCU). DOE awarded Title III funding to help these institutions improve the quality of academic programs, strengthen institutional management, and ensure fiscal stability, and that’s still the purpose of the grant program even after a long history of Congressional renewal of the HEA and changes over the grant’s 50+-year history. In 1998, Congress added Title V as a separate grant category under HEA. Title V grants support postsecondary institutions that serve a large percentage of Hispanic and low-income students.

Who’s Eligible?

DOE determines eligibility for these two grant programs based on two factors: 1) core expenses per FTE and 2) percentage of needy students served. DOE considers an institution’s core expenses in proportion to the number of students enrolled in undergraduate programs during the academic year and compares data across similar institutions to determine an average value. To obtain federal grant eligibility under Title III and Title V, an institution’s core expenses per FTE must be lower than the average for similar institutions. The second factor affecting eligibility is student need. To be eligible, an institution must show that half of its degree-seeking student enrollment receives aid through programs such as Pell Grants and the Federal Work Study Program. Alternatively, an institution can demonstrate student need if the percentage of students enrolled at least half-time who receive aid through federal programs such as Pell Grants and Federal Work Study is greater than the percentage of these students enrolled at similar institutions.

What’s the Process?

Early in the calendar year, a notice will appear in the Federal Register announcing the availability of the Application for Designation as an Eligible Institution from the OPE Institutional Service (IS) office. (Federal Student Aid will also publish an announcement so financial aid staff are aware that the application process is open.) Institutions can check eligibility for Title III and Title V funding by entering their OPE identification numbers. Institutions will fall in one of two categories at this point:

  • Pre-Determined as Eligible: Each year, the Office of Postsecondary Education (OPE) automatically pulls data from the Integrated Postsecondary Education Data System (IPEDS) and uses this data to determine an institution’s eligibility for Title III or Title V programs. Once the automated process is complete, institutions can check their eligibility by simply entering the college’s OPE ID number to see if the organization is pre-determined as Title III- and Title V-eligible. If OPE’s process pre-determines your institution is eligible for Title III and/or Title V programs, great! No further action is needed, and your institution can immediately print its letter of eligibility.   

But if your organization does not appear on the list of pre-determined eligible colleges, you can submit an application for eligibility/waiver request.

  • Not Pre-Determined as Eligible—Can Submit an Application/Waiver for Eligibility: The application process gives institutions who weren’t pre-determined as eligible a chance to correct or submit critical information to demonstrate eligibility. Organizations must submit this application prior to the annual deadline, which is typically in March.

Historically, 99% of institutions that submit waivers become eligible (in 2017, only six colleges that applied were not deemed eligible, and those failed to submit all data requested). If you feel your institution meets the criteria, you should definitely complete the application for eligibility.

The Department of Education has created a helpful document outlining the steps for checking eligibility and for completing a waiver application. JCCI Resource Development Services has also successfully worked with clients to prepare waiver requests that were approved, thereby making the institution Title III- and Title-V eligible.

What are the Benefits?

Obviously, federal grant eligibility for these two grant programs benefits institutions because they can apply for grant funding, but there are other benefits to being eligible and to understanding the federal grant eligibility rules.

  • Institutions that are eligible for Title III and Title V funding are also eligible for a waiver of their cost-sharing requirements under some categories of the Federal Work Study (FWS) and the Federal Supplemental Education Opportunity Grant (FSEOG) programs. Without a waiver, institutions are generally responsible for supplying 25% of any earnings through these federally-sponsored student work opportunities.
  • Eligibility opens the door to multiple grant programs within Title III and Title V.
  • Eligible institutions can use their eligibility designation to substantiate service demographics when seeking funding from private and corporate funders interested in supporting education initiatives for under-served students.

How Often Should You Check Eligibility?

Already receiving Title III or Title V funding? Fantastic! You should still check your federal grant eligibility under these programs each year to ensure your institution’s information is still accurate and to take advantage of additional benefits of eligibility. If your college isn’t receiving Title III or Title V funding, but you want to apply, you’ll definitely want to review your eligibility status annually as you monitor grant announcements and plan for grant submission.