Trade school compliance software that keeps every clock hour, refund clock and revenue test on one record
Trade school compliance is the running proof a career school owes the Department of Education to keep its Title IV eligibility. An eligible undergraduate program must run at least 15 weeks and at least 600 clock hours under 34 CFR 668.8. A proprietary institution must draw at least 10 percent of its revenue from sources other than federal funds under 34 CFR 668.28. Unearned aid goes back within 45 days of the withdrawal determination. Neurobird holds the hours, the withdrawal and the deadline on one record.
Neurobird Trade School Compliance in short
- Track scheduled and attended clock hours against the 600 hour and 15 week floors that make a program eligible
- Start the 45 day return clock from the withdrawal determination date rather than from the day the file lands
- Tag every dollar as federal or non federal at receipt so the 90/10 test is a query and not a reconstruction
- 600 clock hours Minimum length for an undergraduate program to be Title IV eligible, together with at least 15 weeks of instruction, or 16 semester hours, or 24 quarter hours. A shorter program needs at least 300 clock hours and 10 weeks to reach Direct Loan and Pell eligibility. 34 CFR 668.8
- 10 percent Share of revenue a proprietary institution must derive from sources other than federal funds. Failing for two consecutive fiscal years costs Title IV eligibility for at least two fiscal years, and failing in any single year means provisional certification for the two years that follow. 34 CFR 668.28
- Pricing runs 229 to 1450 US dollars per month across 3 tiers. Early access is free.
What career and trade schools actually deal with
Why it stays broken
A career school is regulated three times over and each regulator wants a different record. The Department of Education measures clock hours, refunds and revenue mix, the accreditor measures completion and placement, and the state board measures the catalog and the enrollment agreement. Student information systems were built for degree granting colleges that count credit hours and semesters, so the clock hour school ends up running the federal half of its obligations on spreadsheets nobody can audit.
Under 34 CFR 668.28 a proprietary institution that fails the 10 percent non federal revenue test for two consecutive fiscal years loses Title IV eligibility for at least two fiscal years.
To begin and to continue to participate in any title IV, HEA program, an institution must demonstrate to the Secretary that it is financially responsible under the standards established in this subpart.
Neurobird Trade School Compliance Compliance Platform
One record per student and per program: hours scheduled against hours attended, the withdrawal determination and the date it was made, the return calculation that follows from it, and the revenue tag that feeds next year's 90/10 test.
- 1Track scheduled and attended clock hours against the 600 hour and 15 week floors that make a program eligible
- 2Start the 45 day return clock from the withdrawal determination date rather than from the day the file lands
- 3Tag every dollar as federal or non federal at receipt so the 90/10 test is a query and not a reconstruction
- 4Hold three award years of records where a program review can be answered in an afternoon
What changes with Neurobird Trade School Compliance?
The same work, read left to right: how it runs today, and how it runs once the record is in one place.
| Today | With Neurobird Trade School Compliance |
|---|---|
| Attendance sits in one system and the withdrawal date in another, so the 45 day return clock starts from whichever one somebody opens first | Track scheduled and attended clock hours against the 600 hour and 15 week floors that make a program eligible |
| The 90/10 calculation gets rebuilt from scratch each year because nobody tagged the revenue when it arrived | Start the 45 day return clock from the withdrawal determination date rather than from the day the file lands |
| A program review asks for three award years of files and the answer is a cabinet plus two people who left | Tag every dollar as federal or non federal at receipt so the 90/10 test is a query and not a reconstruction |
Who is this for?
The same clock hours, three very different obligations.
You run one program list and one aid office
Two hundred students, four programs, one person who knows the refund math. You need the calculation to survive that person taking a holiday.
You carry one agreement across several sites
Each campus enrolls on its own calendar and the 90/10 test is measured on the institution. You need revenue tagged at every location the day it arrives.
You are building the file before you certify
State authorization, accreditation and financial statements all point at the same application. You need one place that shows what is done and what is missing.
How does Neurobird Trade School Compliance work?
Post the hours
Scheduled and attended clock hour tracking per student and per payment period, measured the way 34 CFR 668.8 measures a program instead of the way a semester calendar does.
Determine and return
The withdrawal determination sets the date, the 60 percent point sets the earned share, and the 45 day clock for returning unearned funds runs from that same date on the same screen.
Answer the review
Revenue tagged when it arrives, records held three years past the award year, and the composite score inputs sitting beside the files a reviewer will actually ask for.
The compliance board, as your aid office would work it
Close a withdrawal and watch the earned percentage, the return amount and the 45 day clock move together.
| Requirement | Status | Next due | |
|---|---|---|---|
| W-2304, welding 600 hour program, 62 percent of the payment period complete | current | in 42d | |
| PR-7, program review file pull covering 3 award years | due soon | in 9d | |
| R-118, 90/10 revenue tagging review for the current fiscal year | current | in 120d | |
| W-2291, HVAC 900 hour program, withdrawal determined 4 days ago | overdue | 3d late | |
| W-2304, welding 600 hour program, 62 percent of the payment period complete | current | in 64d |
Tick a requirement to file evidence against it.
What the rules say about running a Title IV trade school
Program length, the revenue mix test, the refund clock, the default rate cliff, the financial responsibility score and the retention period, all federal and all measured on the school.
Minimum length for an undergraduate program to be Title IV eligible, together with at least 15 weeks of instruction, or 16 semester hours, or 24 quarter hours. A shorter program needs at least 300 clock hours and 10 weeks to reach Direct Loan and Pell eligibility.
34 CFR 668.8Share of revenue a proprietary institution must derive from sources other than federal funds. Failing for two consecutive fiscal years costs Title IV eligibility for at least two fiscal years, and failing in any single year means provisional certification for the two years that follow.
34 CFR 668.28Deadline to return unearned Title IV funds after the date the institution determined the student withdrew. A student who withdraws after completing 60 percent of the payment period has earned 100 percent of the aid for that period.
34 CFR 668.22Composite score from the equity, primary reserve and net income ratios that an institution must reach to be treated as financially responsible. A recalculated score under 1.0 after a mandatory trigger event forces the school to post financial protection.
34 CFR 668.171Cohort default rate that ends Title IV participation when the three most recent rates are each at or above it, with eligibility lost 30 days after the notice arrives. A single rate above 40 percent ends loan program participation on its own.
34 CFR 668.187Retention period for Pell, Federal Work Study, FSEOG and TEACH records, counted from the end of the award year in which the aid was awarded and disbursed, with loan records held three years past the award year the student last attended.
34 CFR 668.24Trade school compliance software questions, answered
Key terms
- What is trade school compliance?
- Trade school compliance is the set of federal, accreditor and state obligations a career school carries in order to enroll students and disburse federal aid. The federal half is the largest: program length under 34 CFR 668.8, the 90/10 revenue test under 34 CFR 668.28, the return of Title IV funds under 34 CFR 668.22, and record retention under 34 CFR 668.24.
- What are the clock hour rules for Title IV eligibility?
- 34 CFR 668.8 requires an eligible undergraduate program to run at least 15 weeks and at least 600 clock hours, or 16 semester hours, or 24 quarter hours. A program of at least 300 clock hours and 10 weeks can reach Direct Loan and Pell eligibility under narrower conditions. Where clock hours are converted, a semester hour must include at least 30 clock hours of instruction.
How does the 90/10 rule work?
A proprietary institution must derive at least 10 percent of its revenue from sources other than federal funds, calculated for its latest complete fiscal year. Failing in a single year means provisional certification for the two following years. Failing twice in a row means losing Title IV eligibility for at least two fiscal years.
How long do we have to return unearned Title IV funds?
No later than 45 days after the date the institution determined the student withdrew. If the withdrawal happens after 60 percent of the payment period is complete, all of the aid for that period is earned and nothing is returned. Grant overpayment notices go out within 30 days of the same determination.
Does this replace our student information system?
No. It sits beside it. Your student information system keeps the roster, the transcript and the schedule. This keeps the federal record: hours attended against hours scheduled, the determination date, the return calculation, the revenue tag and the retention clock.
Why we are building this
We went looking for work where the record is the whole job, and Title IV compliance kept coming back. The hours are federally defined, the refund is federally calculated, the revenue mix is federally tested, and in most schools all three live in different spreadsheets owned by different people. That is a record problem, and record problems are what we build. The sections we read while scoping this are linked above so you can check our reading instead of taking our word for it. If we have the refund math wrong, tell us.
Where the requirement comes from
Primary sources, straight from the regulators.
- 34 CFR 668.8, eligible program The clock hour and week floors that decide whether a program can carry federal aid at all.
- 34 CFR 668.22, treatment of title IV funds when a student withdraws The 60 percent point, the 45 day return deadline and the 30 day overpayment notice.
- 34 CFR 668.28, non federal revenue (90/10) What counts as revenue, what is excluded, and the sanctions for one year and for two.
- 34 CFR 668.171, general standards of financial responsibility The 1.5 composite score, the mandatory triggers and the reporting deadlines that follow one.
- 34 CFR 668.187, consequences of cohort default rates The 25 percent and 40 percent thresholds and how long the loss of eligibility runs.
- 34 CFR 668.24, record retention and examinations Which records must be kept, for how long, and from which date the clock is counted.
How much does Neurobird Trade School Compliance cost?
Priced per institution because the participation agreement, the revenue test and the retention duty belong to the school rather than to the seat. Students, programs and payment periods are unlimited on every tier.
- Up to 300 active students
- Clock hour tracking
- Return of Title IV worksheets
- Record retention vault
- Unlimited students
- Multi campus revenue tagging
- 90/10 running total
- Program review export
- Multiple institutions
- Composite score workpapers
- Accreditor reporting pack
- Priority support
Get free early access
Early access means we model your programs, your payment periods and your refund policy before you type anything, and the account stays free while we do it.
Straight answer on where this is: The software is in development. Nothing is purchasable today. Early access means you shape it and pay nothing while we build.
Prefer email? Write to office@neurobird.com and a person will reply. No autoresponder.