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Community Service Crackdown

October 11, 2007

The U.S. Education Department is toughening its enforcement of a federal law that requires colleges to award at least 7 percent of their federal work study funds to students engaged in community service.

The department has long required postsecondary institutions to reach a minimum threshold on the proportion of work study funds for community service, and while college officials overwhelmingly support the concept, administrators at some institutions -- particularly in rural areas, where opportunities to participate in community service may be few -- have struggled to meet it. The law also requires that each institution sponsor at least one project in which work study students tutor children in reading or work on family literacy. (The education secretary is empowered to exempt an institution from the requirement when "enforcing the requirements ... would cause a hardship for students at the institution," according to federal rules.)

As the percentage requirement has increased over the years, from the pre-2000 figure of 5 percent of an institution's total federal work study funds to the current 7 percent, colleges have taken various steps to try to ensure that they meet the standard, and the Education Department has regularly reminded them of their obligation. But the cost of failure has been negligible, as there was no penalty for noncompliance.

That is now changing. The department announced in a "Dear Colleague" letter in May that beginning in the 2007-8 award year that started this month, "[a]n institution that participates in the [work study program] that fails to meet one or both of the ... community service requirements ... will be required to return [federal work study] funds in an amount that represents the difference between the amount that the institution should have spent for community service and the amount that it actually spent." The department also warned institutions that failure to comply with the requirements could result in the financial aid death penalty: a "limitation, suspension and termination proceeding," which could lead to a college's inability to award any federal aid to its students.

The department's Federal Student Aid office followed that general warning with a letter in June to nearly 300 colleges that had fallen below the 7 percent threshold in the 2005-6 fiscal year. Inside Higher Ed requested a list of the institutions and information about their compliance with the community service requirements under a Freedom of Information Act request, and the list appears below. It included a broad mix of types of colleges (two-year, four-year, public, private, for-profit) that varied widely in the extent and apparent scope of their shortfalls.

Upper Iowa University awarded 6.92 percent of its $332,158 federal work study dollars to students engaged in community service, just narrowly missing the 7 percent ceiling, for instance, while Norwich University, in Vermont, is shown as directing not a single dollar of its $544,840 in federal work study funds to community service. Same for Southern University and A&M College,

Rhodes College awarded just $2,915 (or 1.6 percent) of its $180,233 in federal work study funds to students engaged in community service, according to the Education Department's data. Forrest M. Stuart, director of financial aid at Rhodes, said in an interview that the independent institution in Memphis had met the community service requirement just once since he arrived there in 2000, a fact that he "hated." Seventy percent of students at Rhodes perform some kind of community service, Stuart said, so the problem isn't that its students don't want to contribute to society.

But fewer than half of the students at Rhodes qualify for federal need-based financial aid, and Stuart said that "most of the people who are doing community service work don't qualify for federal aid," and many "high need" students "don't have transportation to go off campus" to the heart of downtown Memphis, where most of the community service jobs are.

Rhodes' failure to meet the requirement has aggravated and frustrated Stuart and other officials there, but the stakes went way up this spring, when college administrators were alerted after a required federal financial aid audit that they would be required to repay the portion of the 7 percent requirement that Rhodes did not spend. "It took me by surprise; I did not know they could do that," Stuart said. The college later received the Federal Student Aid office's letter, he said, which made it clear that "they are putting teeth into that" requirement for the first time.

Rhodes began adapting its policies immediately, paying higher hourly wages to work study students who do community service while participating in the college's innovative Student Associate Program, which is aimed at giving students management-style responsibilities instead of more menial campus jobs. For instance, the college is giving work study funds where appropriate to students who are coordinating reading tutors in local schools, and paying them significantly more than minimum wage. Rhodes has also significantly increased the number of social service organizations with which it collaborates, and those changes, among others, helped the college fulfill the community service requirement in 2006-7, with between 8 and 9 percent of its federal work study funds going to community service participants, Stuart said.

Palm Beach Community College also fell short of the community service requirement in 2005-6, according to the Education Department's data, allocating $15,596, or 3.93 percent, of its $396,882 in federal work study funds for community service participants. The two-year institution has been "in and out of compliance" over the years, says its financial aid director, David Bodwell, mainly because under county law, its officials must sign new contractual agreements each year with the school districts social service groups that employ its students, and "executing them in a timely fashion proves to be difficult" because employees turn over, rules change, etc.

Palm Beach made several changes in the 2006-7 fiscal year, including employing many of its work study students over the summer and contracting with one agency that can accommodate many more students than the college needs to fulfill the requirement. "With those two efforts, we're going to exceed the minimum requirement by threefold" this year, Bodwell said.

While some college officials might rue it when the Education Department comes knocking on their door (or, in this case, their mailbox, to mix a metaphor), Kristin Tichenor, vice president for enrollment management at Worcester Polytechnic Institute, said she actually welcomes the department's heightened scrutiny of colleges' compliance with the work study rules. "From a philosophical standpoint, what we're most excited about -- as excited as you can get about a government enforcement operation, I suppose -- is that it elevates the importance of community outreach for our students" and "gives us the ammunition we need to make this a priority for colleagues on campus," Tichenor said.

Although many students Worcester Polytechnic participate in community service, she said -- students logged 95,000 community service hours as part of the campus "project experience" that is a graduation requirement -- just 3.24 percent of its federal work study funds went to students working in the community. That's mostly because students who would qualify for work study funds are often doing low-level campus jobs for their federal money and performing community service on their own time, and the institution did a "woeful" job of tracking the community work its students did, Tichenor said.

Worcester Polytechnic is crafting a new system that will prod campus managers to direct work study students to community-related work that can qualify under the federal program's guidelines. Not only will the new arrangement result in the institution easily surpassing the federal requirement, said Tichenor, but it will allow the institution to keep much better track of its students' civic activities on a campus where "if you threw a stick, you’d hit somebody who was doing community service."

"We wouldn't have done it without the push" from the Education Department, Tichenor added. "For my purposes, this has turned out to be a blessing."

The following is a list of institutions that received letters this summer from the Education Department because they failed to comply with the community service requirement -- presumably some of whom may not see the inquiries as quite the blessing Tichenor does:

Recipients of Letter on Work Study Community Service Requirement and Their Level of Compliance With It

Institution State Final Federal
Work Study
Allocation
Share Spent
on Community Service
% of Work Study Funds
for Community Service
Marion Military Institute AL $20,000 $0 0.00%
Southern Community College AL 31,628 0 0.00
Arkansas Baptist College AR 35,715 0 0.00
Everest College CA 22,557 0 0.00
Everest College CA 47,438 0 0.00
Everest College CA 30,918 0 0.00
Everest College CA 25,000 0 0.00
Everest College CA 47,335 0 0.00
Church Divinity School of the Pacific CA 14,915 0 0.00
Strayer University DC 0 0 0.00
Middle Georgia Technical College GA 2,000 0 0.00
Southern U. and A&M College at Baton Rouge LA 1,243,085 0 0.00
Bryman Institute MA 4,086 0 0.00
WyoTech - Bedford MA 10,000 0 0.00
Fisher College MA 85,308 0 0.00
Hellenic College & Holy Cross Greek Orthodox School of Theology MA 17,613 0 0.00
Concordia University MI 76,608 0 0.00
Dunwoody College of Technology MN 120,000 0 0.00
Wentworth Military Academy & Junior College MO 1,809 0 0.00
American Academy of Dramatic Arts NY 45,286 0 0.00
Bryant & Stratton Business Institute NY 136,250 0 0.00
Maria College NY 11,814 0 0.00
Sage Colleges NY 205,076 0 0.00
SUNY Maritime College NY 33,325 0 0.00
Villa Maria College of Buffalo NY 48,140 0 0.00
American Baptist Theological Seminary TN 7,391 0 0.00
ATI Technical Training Center TX 5,000 0 0.00
Angelina College TX 156,406 0 0.00
Prairie View Agricultural & Mechanical University TX 1,446,422 0 0.00
Stevens Henager College UT 30,000 0 0.00
Norwich University VT 544,840 0 0.00
Kee Business College VA 13,074 0 0.00
Saint Paul's College VA 351,638 0 0.00
Perry Technical Institute WA 35,000 0 0.00
Bellin College of Nursing WI 8,291 0 0.00
Lincoln Technical Institute MD 29,363 0 0.00
Berean Institute PA 12,491 0 0.00
AMI American Motorcycle Institute FL 25,000 0 0.00
American College of Hairstyling-Des Moines IA 5,000 0 0.00
Southeastern Business College OH 13,318 0 0.00
Bais Binyomin Academy CT 0 0 0.00
Rasmussen College - Minnetonka MN 35,291 0 0.00
American College of Hairstyling-Cedar Rapids IA 5,000 0 0.00
Dance Theatre of Harlem (The) NY 3,082 0 0.00
International Academy of Design and Technology PA 118,689 0 0.00
Missouri School of Barbering & Hairstyling-St. Louis MO 5,000 0 0.00
American Academy of Art IL 10,000 0 0.00
Savannah River College GA 5,000 0 0.00
Modern Hairstyling Institute PR 25,937 0 0.00
Modern Hairstyling Institute PR 7,941 0 0.00
Modern Hairstyling Institute PR 12,411 0 0.00
Gwinnett Technical College GA 100,000 0 0.00
Las Vegas College NV 37,570 0 0.00
MTI College of Business and Technology TX 114,284 0 0.00
Capitol City Careers TX 27,000 0 0.00
Mountain West College UT 59,298 0 0.00
Everest College AZ 10,438 0 0.00
Akron Machining Institute OH 9,266 0 0.00
Rabbi Jacob Joseph School NJ 0 0 0.00
Magnolia Bible College MS 2,772 0 0.00
Florida National College FL 75,000 0 0.00
New England Technical Institute CT 0 0 0.00
Southern Careers Institute TX 32,457 0 0.00
Central Florida College FL 50,000 0 0.00
Cooking & Hospitality Institute of Chicago (The) IL 25,051 0 0.00
Lamson College AZ 4,686 0 0.00
Arlington Baptist College TX 999 0 0.00
Academy of Court Reporting CA 0 0 0.00
American College of Medical Technology CA 17,746 0 0.00
Platt College OK 7,759 0 0.00
Saint Vincents Catholic Medical Centers of New York Bklyn &Qns. Region NY 9,600 0 0.00
Academy College MN 1,079 0 0.00
Bryman College WA 16,386 0 0.00
Trinity College of Nursing and Health Sciences Schools IL 7,748 0 0.00
Miami Ad School FL 10,574 0 0.00
Davis College NY 23,147 0 0.00
Apollo College ID 36,684 0 0.00
Apex School Of Theology NC 5,000 0 0.00
Williamson Christian College TN 20 0 0.00
North Florida Institute FL 50,000 0 0.00
Connecticut Culinary Institute CT 40,964 0 0.00
Remington College - San Diego Campus CA 36,560 0 0.00
Virginia College at Pensacola FL 45,831 0 0.00
Winner Institute of Arts & Sciences PA 3,137 0 0.00
Lamar Institute of Technology TX 25,000 0 0.00
Rosedale Bible College OH 10,851 0 0.00
Sanford-Brown Institute NY 29,146 0 0.00
Chicago School of Massage Therapy IL 4,360 0 0.00
East Valley Institute of Technology AZ 0 0 0.00
Community Enhancement Services CA 5,000 0 0.00
PC Tech Learning Center NJ 5,000 0 0.00
Culinary Institute Alain and Marie LeNotre TX 5,000 0 0.00
Utah College of Massage Therapy UT 200,000 0 0.00
South Florida Institute of Technology FL 5,000 0 0.00
California School of Culinary Arts CA 241,946 355 0.15
ABI-AccuTech Business Institute MD 33,271 81 0.24
Cogswell Polytechnical College CA 25,729 100 0.39
Berkeley College NJ 98,769 468 0.47
Ohlone College CA 89,006 591 0.66
Austin Graduate School of Theology TX 5,618 39 0.69
Rochester Business Institute NY 39,226 291 0.74
Augusta Technical College GA 90,000 741 0.82
Antonelli Institute PA 19,121 187 0.98
Atlanta Metropolitan College GA 130,530 1,307 1.00
ATI-Career Training Center TX 41,685 452 1.08
Fisk University TN 244,247 2,784 1.14
New England Culinary Institute VT 72,905 842 1.15
North Carolina School of the Arts NC 48,999 578 1.18
Stratford University VA 33,771 423 1.25
Judson College IL 113,986 1,445 1.27
American Educational College PR 60,000 778 1.30
National Institute of Technology TX 50,715 686 1.35
Capitol City Trade & Technical School TX 92,000 1,296 1.41
Rosemont College PA 92,075 1,314 1.43
Pennsylvania College of Art & Design PA 10,470 157 1.50
Western Career College CA 277,060 4,311 1.56
Rhodes College TN 180,233 2,915 1.62
National Polytechnic College of Engineering and Oceaneering CA 38,385 639 1.66
Central Maine Community College ME 51,847 973 1.88
Aquinas College MI 151,303 3,312 2.19
McCormick Theological Seminary IL 30,000 657 2.19
ECPI Technical College -- Roanoke VA 35,246 772 2.19
Luther Seminary MN 66,237 1,457 2.20
University of the Arts PA 401,905 8,890 2.21
Ner Israel Rabbinical College MD 67,262 1,492 2.22
Cambridge College MA 200,000 4,475 2.24
Apollo College AZ 261,932 5,871 2.24
Southwest Institute of Technology TX 28,172 652 2.31
Salem International University WV 333,332 7,957 2.39
ECPI College of Technology - Virginia Beach VA 248,268 5,981 2.41
Southwest Tennessee Community College TN 601,320 14,560 2.42
Shimer College IL 85,900 2,154 2.51
Miles College AL 322,846 8,208 2.54
Florida Metropolitan University FL 132,713 3,375 2.54
Lincoln University PA 279,204 7,340 2.63
Advanced Technology Institute VA 22,474 593 2.64
Camelot College LA 42,033 1,119 2.66
Everest College CA 31,778 877 2.76
Rosedale Technical Institute PA 25,934 716 2.76
ECPI Technical College - Richmond VA 105,946 2,992 2.82
Watkins Institute College of Art & Design TN 19,204 544 2.83
Hawaii Business College HI 45,543 1,356 2.98
Fashion Careers of California College CA 15,252 466 3.06
Full Sail Real World Education FL 425,000 13,017 3.06
Marylhurst University OR 70,657 2,174 3.08
San Francisco Conservatory of Music CA 95,514 2,988 3.13
Ramapo College of New Jersey NJ 245,015 7,725 3.15
Creative Circus (The) GA 18,390 593 3.22
Worcester Polytechnic Institute MA 548,296 17,771 3.24
Sanford-Brown College MO 325,945 10,569 3.24
Northwestern Health Sciences University MN 150,000 4,920 3.28
Orleans Technical Institute PA 43,943 1,442 3.28
Taylor Business Institute NY 114,840 3,798 3.31
Fond du Lac Tribal & Community College MN 43,842 1,467 3.35
David Lipscomb University TN 112,069 3,933 3.51
Glendale Career College CA 25,000 900 3.60
Caldwell College NJ 109,738 3,962 3.61
University of Texas Medical Branch at Galveston TX 189,747 6,888 3.63
Anoka Technical College MN 50,000 1,818 3.64
Hill College TX 82,074 2,987 3.64
Southwest Florida College FL 188,856 6,940 3.67
Brown Mackie College-South Bend IN 21,993 815 3.71
Capitol College MD 51,396 1,905 3.71
Rush University IL 300,000 11,280 3.76
University of South Carolina-Beaufort SC 69,577 2,623 3.77
Parker College of Chiropractic TX 125,000 4,762 3.81
Erie Business Center PA 10,000 384 3.84
Grand Canyon University AZ 223,660 8,653 3.87
College of Wooster OH 270,916 10,556 3.90
Palm Beach Community College FL 396,882 15,596 3.93
Ashmead College WA 50,000 1,973 3.95
Louisiana College LA 99,644 3,991 4.01
Brooks Institute of Photography CA 223,004 8,939 4.01
National Institute of Technology MI 89,355 3,616 4.05
Saint Charles County Community College MO 70,000 2,861 4.09
Midwest Theological Seminary MO 3,346 137 4.09
Drew University NJ 267,773 10,981 4.10
Thunderbird -- Garvin School of International Management AZ 130,000 5,343 4.11
Sanford-Brown Institute FL 124,960 5,188 4.15
Missouri Valley College MO 156,409 6,525 4.17
SUNY Empire State College NY 394,950 16,563 4.19
Kean University NJ 440,172 18,570 4.22
Union Institute & University OH 188,504 7,960 4.22
Edison College FL 185,973 7,959 4.28
National School of Technology FL 120,000 5,239 4.37
Oklahoma Panhandle State University OK 44,222 1,955 4.42
Saint Martin's College WA 120,724 5,342 4.42
Brown Mackie College-Cincinnati OH 200,000 8,868 4.43
Christian Brothers University TN 172,372 7,702 4.47
Philander Smith College AR 141,682 6,341 4.48
Texas Southern University TX 1,127,687 50,582 4.49
Fuller Theological Seminary CA 159,010 7,147 4.49
Schiller International University FL 20,000 910 4.55
Wesley Theological Seminary DC 21,733 1,000 4.60
Bryman College WA 50,000 2,321 4.64
Eagle Gate College UT 40,810 1,903 4.66
Luzerne County Community College PA 200,000 9,332 4.67
Indiana University - Northwest IN 175,097 8,210 4.69
Blair College CO 56,315 2,705 4.80
University of Houston - Clear Lake TX 156,292 7,529 4.82
Westwood College of Aviation Technology CA 40,665 1,961 4.82
Wake Technical Community College NC 70,000 3,416 4.88
Fort Scott Community College KS 78,585 3,885 4.94
William Jessup University CA 24,868 1,244 5.00
La Salle University PA 572,794 28,747 5.02
Gibbs College CT 85,000 4,303 5.06
Walla Walla Community College WA 111,391 5,644 5.07
Elgin Community College IL 180,490 9,178 5.09
Ogden Weber Applied Technology College UT 84,187 4,341 5.16
New Mexico Military Institute NM 17,000 878 5.16
Brevard Community College FL 288,129 14,996 5.20
Fontbonne University MO 90,000 4,689 5.21
Free Will Baptist Bible College TN 17,822 932 5.23
Northland Mission WI 29,145 1,558 5.35
Interboro Institute NY 225,000 12,036 5.35
Bramson ORT College NY 54,355 2,923 5.38
Alfred University NY 266,204 14,640 5.50
Vanguard University of Southern California CA 145,947 8,033 5.50
Floyd College GA 105,688 5,878 5.56
Reinhardt College GA 70,000 3,897 5.57
California Maritime Academy CA 15,000 836 5.57
Bacone College OK 83,333 4,655 5.59
South College NC 20,310 1,136 5.59
International College FL 108,924 6,132 5.63
National Institute of Technology WV 37,995 2,139 5.63
Southern Vermont College VT 102,944 5,818 5.65
All-State Career School MD 32,341 1,834 5.67
Davis College OH 30,000 1,714 5.71
Parks College CO 123,100 7,034 5.71
Saginaw Valley State University MI 282,330 16,197 5.74
Art Center Design College (The) AZ 89,062 5,118 5.75
Sanford-Brown Institute TX 77,294 4,458 5.77
Elizabeth City State University NC 362,889 21,074 5.81
Career Colleges of America CA 52,635 3,071 5.83
Webster University MO 614,716 35,890 5.84
Sanford-Brown Institute GA 419,332 24,549 5.85
All-State Career School PA 36,597 2,148 5.87
Border Institute of Technology TX 35,751 2,100 5.87
Martin University IN 77,511 4,562 5.89
Art Institute of California - San Diego CA 115,298 6,794 5.89
SUNY College of Technology at Canton NY 171,765 10,124 5.89
Life University GA 300,206 17,757 5.91
Everest College CA 40,915 2,423 5.92
Everest College CA 15,809 944 5.97
Pittsburgh Technical Institute PA 181,780 10,887 5.99
Olympia Career Training Institute MI 62,608 3,751 5.99
North-West College CA 8,749 525 6.00
Western School of Health & Business Careers PA 85,401 5,179 6.06
Centenary College of Louisiana LA 142,182 8,625 6.07
Community College of Denver CO 272,591 16,550 6.07
Georgia Medical Institute GA 85,399 5,196 6.08
Gibbs College NJ 201,768 12,358 6.12
ATI Career Training Center TX 44,600 2,748 6.16
Dover Business College NJ 22,961 1,419 6.18
Kettering College of Medical Arts OH 38,754 2,408 6.21
Nashville State Technical Community College TN 78,963 4,908 6.22
International Institute of the Americas AZ 100,000 6,235 6.24
Central Oklahoma Area Vocational-Technical School District No. 3 OK 5,994 374 6.24
Pyramid Career Institute IL 4,915 308 6.27
Baptist University of the Americas TX 5,623 354 6.30
Kansas City Art Institute MO 89,969 5,679 6.31
Barton College NC 209,392 13,315 6.36
Manhattanville College NY 238,692 15,210 6.37
University of Texas at Dallas TX 461,240 29,666 6.43
University of South Carolina Upstate SC 200,000 12,891 6.45
Little Big Horn College MT 20,000 1,297 6.49
School of Automotive Machinists TX 8,446 550 6.51
Virginia College of Birmingham AL 671,883 43,930 6.54
University of Central Oklahoma OK 438,185 28,774 6.57
Daytona Beach Community College FL 304,969 20,124 6.60
City Colleges of Chicago System Office IL 2,104,974 139,844 6.64
Asbury Theological Seminary KY 141,106 9,425 6.68
El Paso Community College TX 1,031,212 68,967 6.69
Franciscan University of Steubenville OH 135,855 9,179 6.76
Florida Metropolitan University FL 148,388 10,066 6.78
Luther Rice Seminary GA 20,468 1,390 6.79
Drury University MO 253,023 17,200 6.80
Art Center College of Design CA 373,744 25,614 6.85
Southeastern Oklahoma State University OK 256,509 17,601 6.86
College of Visual Arts MN 27,096 1,860 6.86
Northwestern State University LA 288,356 19,885 6.90
Wilberforce University OH 1,425,055 98,314 6.90
Upper Iowa University IA 332,158 22,989 6.92
College of the Holy Cross MA 640,478 44,496 6.95
Gulf Coast College FL 13,874 966 6.96

 

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