# 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.

- URL: https://neurobird.com/tradeschool/
- Product: Neurobird Trade School Compliance Compliance Platform
- Niche: trade school compliance
- Buyer: career and trade schools
- Status: in development, open for early access
- Updated: 2026-08-22

## What Neurobird Trade School Compliance does

- 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
- Hold three award years of records where a program review can be answered in an afternoon

## How it works

1. **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.
2. **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.
3. **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.

## From the source material

> 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.

Source: 34 CFR 668.171, general standards of financial responsibility, https://www.law.cornell.edu/cfr/text/34/668.171

## Industry context

- **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. (source: 34 CFR 668.8, https://www.law.cornell.edu/cfr/text/34/668.8)
- **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. (source: 34 CFR 668.28, https://www.law.cornell.edu/cfr/text/34/668.28)
- **45 days** Deadline 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. (source: 34 CFR 668.22, https://www.law.cornell.edu/cfr/text/34/668.22)
- **1.5** Composite 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. (source: 34 CFR 668.171, https://www.law.cornell.edu/cfr/text/34/668.171)
- **25 percent** Cohort 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. (source: 34 CFR 668.187, https://www.law.cornell.edu/cfr/text/34/668.187)
- **3 years** Retention 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. (source: 34 CFR 668.24, https://www.law.cornell.edu/cfr/text/34/668.24)

## Pricing

- Single campus: $229 per month
- School group: $649 per month
- System: $1,450 per month

## Questions

### 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.

## Sources

- [34 CFR 668.8, eligible program](https://www.law.cornell.edu/cfr/text/34/668.8)
- [34 CFR 668.22, treatment of title IV funds when a student withdraws](https://www.law.cornell.edu/cfr/text/34/668.22)
- [34 CFR 668.28, non federal revenue (90/10)](https://www.law.cornell.edu/cfr/text/34/668.28)
- [34 CFR 668.171, general standards of financial responsibility](https://www.law.cornell.edu/cfr/text/34/668.171)
- [34 CFR 668.187, consequences of cohort default rates](https://www.law.cornell.edu/cfr/text/34/668.187)
- [34 CFR 668.24, record retention and examinations](https://www.law.cornell.edu/cfr/text/34/668.24)

## Contact

- office@neurobird.com
- https://neurobird.com/