DoD MOU: Title IV Participation Requirement

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A notice from Dawn Bilodeau, Chief, DoD Voluntary Education

Your participation in the Department of Defense’s Voluntary Education Programs provides valuable educational opportunities to our Service members in direct support of their professional and personal development.  We applaud your efforts and look forward to a continued partnership in support of new Voluntary Education Program policies and objectives.

We anticipate issuance of the final rule and change 2 to DoDI 1322.25, Voluntary Education Programs, in the coming months.   As you are aware, this issuance includes several new requirements in support of the President's Executive Order 13607, "Establishing Principles of Excellence for Educational Institutions Servicing Service Members, Veterans, Spouses, and Other Family Members", signed April 27, 2012 (available at  In conjunction with the new issuance, ALL participating educational institutions will be required to sign the new DoD Voluntary Education Partnership Memorandum of Understanding (MOU).  The sign-by date has not yet been established but will be no sooner than 60 days following the publication of the final rule in the Federal Register. 

This notice focuses on clarifying the proposed Title IV participation requirement in order to jump-start your preparations.  The new issuance requires educational institutions to be certified to participate in federal student aid programs through Department of Education (ED) under Title IV of the Higher Education Act of 1965.  Title IV certification may be provisional so long as the educational institution maintains eligibility to participate in the Federal Direct Loan Program.

As an educational institution with a current DoD Voluntary Education Partnership MOU, you will have 18 months following the publication of the final rule in the Federal Register to successfully meet the Title IV requirement.  During this time, you will be allowed to continue participating in the Tuition Assistance program, enrolling new and current students as long as you are actively pursuing Title IV eligibility.

If you are not currently certified to participate in federal financial aid programs, the first step toward meeting the Title IV requirement is issuance of an official OPE ID number by ED.  IMPORTANT NOTE:  Only educational institutions with an OPE ID number issued by ED will be able to initiate an application for the new DoD Voluntary Education Partnership MOU.  Your institution can apply for an OPE ID following the guidelines outlined at     

Your institution can request and be issued an OPE ID within a few weeks.  Issuance of an OPE ID number; however, does not make an educational institution Title IV eligible or meet the new requirement for Title IV participation….it is only the first step.  Your institution will still need to complete and submit the electronic application and all supporting materials in accordance with ED guidance.  Because we understand the application and approval process may take from 2 – 12 months, depending on the preparedness of the educational institution to meet Title IV requirements, we are providing the previously discussed 18 month window to become compliant. 

To learn more about applying for an OPE ID and Approval to Participate in Federal Student Financial Aid Programs, visit:  If you have questions on the application process, please contact ED directly for assistance.

Note: 1. This notice and instructions on how to apply for an OPE ID will be posted in the DoD MOU Resources section at

2. This email was sent to all institution Primary and Secondary POCs along with the Signing Authority.   


Dawn Bilodeau

Chief, DoD Voluntary Education

Military Community & Family Policy