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May 23, 2011
Dear COMTA Community Members,
As many of you know, several changes to the eligibility criteria for programs participating in Title IV financial aid programs take effect July 1st, 2011. COMTA has been carefully evaluating the changes to understand them and respond to our schools when they pose questions about these changes to us.
The information we have received indicates that, per 34 CFR 668.8 (k)(2)(B), all massage educational programs will be considered as clock hour programs for financial aid purposes. There have been lingering questions about how this will be applied to academic institutions and programs within states which do not have a state license or certification for practicing massage therapy. These remaining questions are the reason behind our delay in publishing any definitive procedures for consideration of “outside work” for financial aid purposes as many other accrediting agencies have done already. From our conversations with the U.S. Department of Education, “outside work” is not applicable for programs which are to be considered clock hour for financial aid, as all massage and bodywork programs will be.
At this time we encourage all schools participating in financial aid programs to be in contact directly with their financial aid representatives to determine what may need to be done to be in compliance after July 1st, 2011. If your school has been approved by COMTA to utilize a conversion from clock hours to academic credits, you are allowed to continue using those credits for academic purposes. If your school was using a conversion to credits for financial aid awards and disbursements, you may need to make changes to your Satisfactory Academic Progress (SAP) policies, procedures for evaluating SAP, as well as schedules for disbursing aid, to convert to the clock hour guidelines for financial aid.
The following types of changes do need to be reported to COMTA now but will not require any fees:
1) Change of number of clock hours in your program; if it amounts to less than 25% of the total program hours. (If greater than 25%, follow the COMTA Substantive Change procedures.)
2) Changing from credits to clock hours for academic purposes; if the change is made by July 1, 2011.
Changes in the areas below do not need to be reported to COMTA until your regularly scheduled Annual Report:
1) Revised SAP policy and procedures.
2) Scheduling of courses or terms, changing academic years or completion timelines which affect the Completion, Placement and Licensure statistics required by COMTA.
If you have any questions about details for your particular institution or program, please contact the COMTA staff at (202) 895-1518 or by email at lvaughn@comta.org and khenrioulle@comta.org.