Title III Grants

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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.

Why Title III SIP is Unique

Among all the U.S. Department of Educations grant opportunities, the Title III Strengthening Institutions Program (SIP) is most unique. The JCCI Resource Development Services team monitored the federal budget proposals presented in 2017 and was shocked to learn that the initial budget from the president’s office removed the entire line item for Title III SIP. The Trump administration stated that funding was removed from the budget because they felt Title III SIP duplicates other grant funding opportunities. Every educational institution that has ever received an SIP grant award understands how this program is different from most other DOE grants. Fortunately, Congress’s final budget returned that line item funding to cover grantees at least during the 2018 year. With much debate about government spending and the national debt and an uncertain future for Title III SIP, it seems appropriate to consider what makes SIP different and why continuing this type of funding will, indeed, strengthen our higher educational institutions.

Problem Solving

Though there are many federal grants that target under-resourced institutions serving low-income students, only Title III SIP compels an institution to examine a significant problem that is unique to their operations and their student body. Successful applicants will not only identify this problem, but will also propose a research- and evidence-based solution to that problem. Project evaluations must demonstrate successful problem solving and achievement of outcomes within the 5-year grant time frame. The grantee is responsible for showing that the problem has been resolved with no future need for additional DOE funding. This grant enables institutions to solve problems that impact the long-term future of the organization and the students they serve and requires grantees to resolve the issues “on time and within budget.” In fact, awardees cannot re-apply for the same problem, and they must wait a minimum of two years before applying for a Title III SIP grant to assist in resolving a different issue. If a grantee applies in another grant cycle, the institution receives no benefits for being a prior SIP recipient.

By Comparison

For those who are unfamiliar with the way other federal grant programs work, the problem-solving and time-frame benchmarks for Title III SIP grants may not seem that unique; however, by comparison to other DOE grants, the unique nature of SIP becomes clear. Consider SIP in comparison to DOE TRIO grant programs. Like Title III, there are several specific grants under the TRIO umbrella. For example, Talent Search and Upward Bound are under the TRIO umbrella of grant funds. Like Title III, TRIO grants are intended to help higher educational institutions provide educational services to students from disadvantaged backgrounds who may have to overcome challenges to completing a degree program. Challenges might include low income, disabilities, or being a first-generation college student. TRIO grants provide important funding to address a variety of socio-economic challenges to student success and higher education.


Unlike Title III SIP grants, though, TRIO grantees can literally receive continual funding for decades without a waiting period between grant applications, and, for most programs, previous grantees are awarded an additional 15 points for prior experience in the competitive grant cycle. The additional points which previous grantees receive make it even more challenging for new and innovative programs to obtain enough points to be funded.


The TRIO programs’ goal of helping institutions serve segments of the population that may need additional support to accomplish educational goals is, of course, a worthy goal. Title III SIP grant competition is fierce, but equitable, as no organization automatically receives points for prior award status. SIP awardees are held accountable for resolving identified issues with a specified time frame in a manner that is sustainable without continual federal funding. No other DOE grant program is designed specifically to support under-resourced institutions (defined by the institution’s educational and general expenditures compared to a national mean for its sector) serving low-income students while ensuring institutional efficiency and sustainability within a 5-year period. Title III SIP remains a unique and transformational investment in our educational system.