The Catholic University of America

Summary of Federal Laws


Miscellaneous Laws Affecting Students

The Student Right to Know Law and Disclosures Required with Respect to Athletically Related Student Aid

Compliance Partners

Director of Institutional Research and Assessment

20 U.S.C. § 1092; 34 C.F.R. §§ 668.41; 668.45 (graduation rates) and 668.48 (on athletically related aid)

This law requires an institution that participates in federal student aid programs to disclose graduation rates for the student body. Collection of the graduation rate data began with a cohort in 1996. The disclosure date is July 1 following 150% of the normal time for completion/graduation from its programs.

For purposes of the completion and graduation rate, an institution must count as entering students only first-time undergraduate students. First-time undergraduate student means an entering undergraduate who has never attended any institution of higher education. It includes a student enrolled in the fall term who attended a postsecondary institution for the first time in the prior summer term, and a student who entered with advanced standing (college credit earned before graduation from high school). 

An institution must count as an entering student a first-time undergraduate student, who is enrolled as of October 15, the end of the institution's add/drop period, or another official reporting date as defined in 34 C.F.R. § 668.41(a). Changes made pursuant to the Higher Education Act amendments of 1998 are codified at 34 C.F.R. § 668.45, 64 Fed. Reg. 59,060 (Nov. 1, 1999). 

Completion of the Graduation Rate Survey (GRS) (part of IPEDS reporting) meets the reporting requirements of the Student Right to Know Law. However, following changes made by HEOA (see below) the IPEDS form was not updated to include the disaggregated information. Accordingly, data on Pell grants and other information must be collected and made available upon request separately. Note that there is no reporting requirement per se for the 2008 list of  disaggregated information.

For more on the IPEDS reporting requirements see the NCES webpage on IPEDS. 

In terms of the disclosure requirements, the graduation rates are part of the information that institutions that participate in Title IV student aid must make available to current and prospective students. Pursuant to the 1998 Higher Education Act amendments, institutions must annually provide students with a list of all the information required to be disclosed and with instructions on how to access the information.

Additional disclosure requirements apply to schools that offer athletically related student aid. Athletically related student aid means any scholarship, grant, or other form of financial assistance, offered by an institution, the terms of which require the recipient to participate in a program of intercollegiate athletics at the institution. Other student aid, of which a student-athlete simply happens to be the recipient, is not athletically related student aid. 

By July 1st of each year, an institution that offers athletically related student aid must submit a report to the Secretary of Education that covers the 1 year period ending August 31 of the previous year. For a full list of the requirements, see 20 U.S.C. § 1092 (e) and 34 § CFR 668.48. The report must also be made available to prospective student-athletes and their parents, high school coach and guidance counselor. If the school is a member of the NCAA, then the reporting requirements are considered met through distribution of the NCAA report, which is made available to all secondary and postsecondary schools around the country through the Web. 

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.


NAICU HEA 101 Quick Guide



updated 5-14/15 mlo to update ecfr links