Cybersecurity Policy for Title IV Eligibility

Title IV financial aid. It’s not typically the first item promoted on the cover of a college admissions pamphlet, but its availability is a critical component for numerous students and their families. Not to mention, it is also the funding of most colleges and universities.

Imagine this scenario for a moment… You receive a call from the United States Department of Education. The university’s security department (that you manage) failed to meet compliance standards. Your Title IV eligibility was just revoked. Suddenly, droves of students can no longer afford their tuition and begin to drop out. Campus administration knocks at your door and asks what happened. You begin to explain, but before you even finish a notice of termination is placed on your desk. 

Scenarios like this seem far-fetched, but they are actually very possible if a college or university fails to implement a cybersecurity policy.

What is Title IV funding?

Title IV funding refers to the federal financial aid provided to schools through the United States Department of Education and includes the following:

  • Direct Subsidized/Unsubsidized Loans (Stafford Loan) 
  • Direct PLUS Loans
  • Federal Pell Grants 
  • Federal Supplemental Educational Opportunity Grants (FSEOG) 
  • Federal Perkins Loans

How can an institution lose its eligibility?

Even though numerous families rely on Title IV financial aid, many colleges don’t realize its availability is at risk. If a higher ed institution fails to meet certain compliance standards, they are subject to incur fines. One standard that colleges and universities must adhere to is the Safeguards Rule in the Gramm-Leach-Bliley Act. This rule states that an institution must implement a written security program to protect their sensitive information. Failure to comply can result in a variety of penalties, including the loss of Title IV eligibility.

How does the Gramm-Leach-Bliley Act affect Title IV eligibility?

The GLBA, which we discuss more in depth in our recent blog, The Gramm-Leach-Bliley Act: A Guide for Higher Ed, states that financial institutions (yes, colleges and universities are included) must create a cybersecurity policy. This in depth policy must define items such as which employees coordinate the institution’s information security program, what risks to customer information are in existence, which service providers are overseeing the handling of customer information, etc. Failure to comply can result in monetary fines, prison time and as mentioned, the loss of Title IV eligibility.

Next Steps

If this information leaves you feeling a little unsettled, you’re not alone. Many IT departments in the higher education industry already find themselves challenged with overbooked schedules and budget cuts. We acknowledge implementing a strategy this comprehensive is challenging for most institutions. That is why we suggest hiring an outside vendor.

BitLyft’s cybersecurity team understands GLBA compliance standards. Let our team help your institution make sure it is not at risk of losing its Title IV eligibility. To learn more about how we can help, contact us today or read more about the GLBA in this whitepaper.


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Emily Miller

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