The Catholic University of America

Director Of Institutional Research and Assessment

Program Participation Agreements
20 U.S.C. § 1094; 34 C.F.R. § 668.1 et seq.

The Director Institutional Research and Assessment is responsible for IPEDS filing. IPEDS stands for Integrated Postseconday Education Data System. Institutions with Program Particpation Agreements (PPAs) are require to complete IPEDS and are subject to follow up for non-response.

Changes made by the HEOA will require updated insitutitonal characteristics forms for data collection for 2008-09. These forms can be found on the IPEDS site. A list of new information that must be collected is set forth on the NAICU HEO page. Completion of the IPEDS also fulfulls certain Title VII requirements. See below.

34 CFR 668.14 Program Participation Agreement
(a)(1) An institution may participate in any Title IV, HEA program, other than the LEAP and NEISP programs, only if the institution enters into a written program participation agreement with the Secretary, on a form approved by the Secretary. A program participation agreement conditions the initial and continued participation of an eligible institution in any Title IV, HEA program upon compliance with the provisions of this part, the individual program regulations, and any additional conditions specified in the program participation agreement that the Secretary requires the institution to meet.

This position is responsible for ensuring that the Program Participation Agreement is recertified no later than 90 days prior to the expiration date of the Agreement, along with any supporting documentation. The next recertification date for CUA is Sept. 30th, so the Agreement must be filed by June 30th, 2009. Generally the agreements are good for six years.

Title VI & VII of the Civil Rights Act of 1964
42 U.S.C. § 2000d; and 42 U.S.C. § 2000e

Title VI prohibits discrimination on the basis of race, color or national origin under any program or activity receiving federal financial assistance. Employment discrimination is covered by Title VI if the primary objective of the financial assistance is the provision of employment or where employment discrimination causes discrimination in providing services under such programs. Title VII prohibits discrimination in employment on the basis of race, color, religion, sex or national origin. In certain instances, differential treatment is allowed for religion, sex, or national origin if it is a bona fide occupational qualification.

The Director of Institutional Research and Assessment is responsible for the recordkeeping and filing components of this law as it relates to IPEDS and with respect to racial composition of the faculty and staff.

IRS Revenue Procedure 75-50
Summary: This Revenue Procedure is in place to assure non-discrimination in admissions and operations of the university. See Federal Tax law. It is the responsiblity of the Director of Institutional Research and Assessment to keep records for three years of the racical composition of the students, faculty and staff, to the extent they can be obtained.

Final Guidance on Maintaining, Collecting, and Reporting Racial and Ethnic Data to the U.S. Department of Education; 72 Fed. Reg. 59266 (Oct. 19, 2007)
Effective Dec. 3, 2007, but not implementation not required until Fall 2010 for the 2010-2011 school year. The guidance addresses two issues at the postsecondary level:

1) How educational institutions and other recipients will collect and maintain racial and ethnic data from students and staff; and
2) How educational institutions and other recipients will aggregate racial and ethnic data when reporting those data to the Department.

What is new is that students and staff may now report ethnicity and race separately, and are permitted to select more than one race. The 2 part inquiry includes expanded race categories.

Student Right to Know Law

This law requires an institution that participates in federal student aid programs to disclose graduation rates for the student body.

Changes made by HEOA:

Graduation data will have to be disaggregated by gender, by major racial and ethnic subgroup, by recipients of Pell Grants, by recipients of a subsidized federal loan who did not receive a Pell Grant and by recipients of neither a Pell Grant or subsidized loan. This provision is effective August 14, 2008, but for 2 year institutions, not until the 2011-12 academic year. See the NAICU HEA 101 Quick Guide on this new requirement.

The Director of Institutional Research and Assessment is responsible for collecting and reporting data under this law. Data is reported annually by July 1st. Note completion of the Graduation Rate Survey (GRS) (part of IPEDS reporting) meets the reporting requirements of the Student Right to Know Law.

EO 11246

Prohibits employment discrimination based on race, color, religion, sex, or national origin. Governs any entity with government contracts that total $10,000 or more in a 12-month period. The Director of Institutional Research and Assessment is responsible for collecting and reporting data under this law. (IPEDS)

Accreditation for Middle States

The Director of Institutional Research and Assessment is responsible for completing the Middle States Institutional Profile on an annual basis. This report is due each spring. The actual *open dates* for reporting purposes vary slightly, but are generally from Feb. to April of each year.


Middle States Institutional Profile

Changes to 2008-2009 IPEDS Prompted by Higher Education Opportunity Act:
A summary of the many tweaks to the IPEDS collection necessitated by HEOA.

Dates for collection of data

NCES update on changes to the HR Survey