S ESSION T ITLE I T ’ S T IME TO L IGHT THE L IGHTS 2016 ILASFAA A NNUAL C ONFERENCE A PRIL 6 – 8, 2016, H ILTON, L ISLE, IL N ON -F INANCIAL A ID I SSUES THAT A FFECT F INANCIAL A ID E LIGIBILITY B RIGET B IERNAT J ANS D E P AUL U NIVERSITY 2016 ILASFAA A NNUAL C ONFERENCE A PRIL 6 – 8, 2016, H ILTON, L ISLE, IL

Don’t Get Upstaged! 2016 ILASFAA Annual Conference 2

Financial aid isn’t just about financial aid Large amounts of money come with substantial responsibilities Not all of which appear to be related to helping students pay for college Congress uses institutional eligibility for financial aid as a way to control or rectify many seemingly unrelated issues 2016 ILASFAA Annual Conference 3

Dean: This feels like the tail wagging the dog ILASFAA Annual Conference 4

Dean: This feels like the tail wagging the dog. Me: Yes, but the feds are paying for the dog food ILASFAA Annual Conference 5

Program Participation Agreement (PPA) The document that gives your institution the right to participate in the Federal Student Aid Programs. Spells out institutional obligations rather broadly 2016 ILASFAA Annual Conference 6

Drug Abuse Prevention Certify that you have a drug abuse prevention program in operation Must be deemed accessible to any officer, employee or student 2016 ILASFAA Annual Conference 7

Campus Security Policy & Crime Statistics Certify that you are in compliance with the disclosure requirements of Section 485(f) of the Higher Education Act (HEA) "Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act" 2016 ILASFAA Annual Conference 8

Campus Security Policy & Crime Statistics Procedure and facilities for reporting security concerns, emergencies and crimes Law enforcement authority of campus security and their relationship to local law enforcement Policy that encourages accurate, prompt reporting of all crimes when the victim in unable 2016 ILASFAA Annual Conference 9

Campus Security Policy & Crime Statistics Description of type and frequency of programs designed to inform students and employees about campus security procedures and practices Description of programs designed to inform students and employees about the prevention of crimes 2016 ILASFAA Annual Conference 10

Campus Security Policy & Crime Statistics Statistics concerning occurrences on campus in or on non-campus buildings or property, and on public property most recent calendar year, and during the 2 preceding calendar years for which data are available 2016 ILASFAA Annual Conference 11

Campus Security Policy & Crime Statistics Must provide specific statistics for murder sex offenses, forcible or non-forcible robbery aggravated assault burglary motor vehicle theft manslaughter arson arrests or persons referred for campus disciplinary action for liquor law violations, drug-related violations, and weapons possession 2016 ILASFAA Annual Conference 12

Campus Security Policy & Crime Statistics Must break out any of the above if they are classified as hate crimes, based on perceived or actual Race Gender Religion National origin Sexual orientation Gender identity Ethnicity Disability of the victim 2016 ILASFAA Annual Conference 13

Campus Security Policy & Crime Statistics Report crime statistics to ED Distribute to campus populations October 1 st each year 2016 ILASFAA Annual Conference 14

Campus Security Policy & Crime Statistics Policy concerning monitoring and recording criminal activity at off-campus student organizations Policy regarding the possession, use, and sale of alcoholic beverages and enforcement of underage drinking laws Policy regarding the possession, use, and sale of illegal drugs 2016 ILASFAA Annual Conference 15

Campus Security Policy & Crime Statistics Statement advising where to get information about registered sex offenders Campus policies regarding emergency response and evacuation Policy regarding timely reports to the campus community on crimes considered to be a threat to other students and employees Must withhold the names of victims Maintain a crime log 2016 ILASFAA Annual Conference 16

Title VI Civil Rights Act of 1964 Bars discrimination based on race, color or national origin Applies to programs or activities receiving federal financial assistance Enforced by ED’s Office of Civil Rights 2016 ILASFAA Annual Conference 17

Title IX Education Amendments of 1972 Bars discrimination based on sex Requires gender equity for boys and girls in every educational program that receives federal funding Include sexual harassment, the failure to provide equal opportunity in athletics, and discrimination based on pregnancy Enforced by Office of Civil Rights within the Department of Education 2016 ILASFAA Annual Conference 18

Section 504 Rehabilitation Act of 1973 Bars discrimination based on physical handicap Applies to all programs receiving federal funding Paved the way for the Americans with Disabilities Act (ADA) 2016 ILASFAA Annual Conference 19

Standards for Safeguarding Customer Information 16 CFR Part 314 Standards set in Gramm-Leach-Bliley Act Financial Services Modernization Act of 1999 Ensure security and confidentiality of customer records and information Any breach in data security is seen as a demonstration of a lack of administrative capability Strongly encouraged to advise students of breaches 2016 ILASFAA Annual Conference 20

Accreditation & State Regulation Acknowledge that accreditors and state are authorized to share institutional information with ED Under the HEA, accreditation cannot be recognized by ED unless the institution agrees to submit to initial arbitration prior to any legal action involving the institution’s accreditation 2016 ILASFAA Annual Conference 21

Miscellaneous Charging fees Institution cannot charge fees to students for administering federal funds Job Placement rates If advertising job placement rates, institutions must provide statistics to prospective students State licensing requirements Must publish requirements for jobs for which an educational program is offered 2016 ILASFAA Annual Conference 22

Miscellaneous Not knowingly hire anyone for the administration of Title IV funds who has been convicted or pled guilty of a crime involving federal funds or fraud Can’t impose penalty on students if federal funds are delayed No bonuses or incentive pay to employees for enrolling students Acceptable for enrolling foreign students 2016 ILASFAA Annual Conference 23

Miscellaneous Must demonstrate a reasonable relationship between the length of GE programs and the recognized occupations for which they prepare students Program length annot be more than 50% of the state requirements Annually develop, publish, administer and enforce an education loan code of conduct 34 Code of Federal Regulations Section NASFAA makes a version available 2016 ILASFAA Annual Conference 24

Miscellaneous Annually compile, maintain and make available a preferred lender list, if institution has a preferred lender arrangement Develop and implement written plans to combat unauthorized distribution of copyright materials Including disciplinary procedure for violations of the policy 2016 ILASFAA Annual Conference 25

Miscellaneous Submit teach out plans to accreditor in cases of Limitation, suspension or termination of Federal Student Aid eligibility Loss of accreditation Loss of state authorization Closure of a location offering 100% of a program Institutional intention to cease operations 2016 ILASFAA Annual Conference 26

Miscellaneous Must have a drug abuse prevention program Mentioned again Voter registration National Voter Registration Act of 1993 – Motor Voter Law Requires good faith effort to distribute a mail voter registration form, requested and received from the State, to each student enrolled in a degree program Not required for students studying through distance education only 2016 ILASFAA Annual Conference 27

Miscellaneous Cant use federal funds to lobby members, officers or employees of Congress Must disclose institutional funds spent on lobbying 2016 ILASFAA Annual Conference 28

Miscellaneous Drug-free workplace statement Mentioned yet again Distribute to everyone Must include what actions may be taken against employees who violate the prohibition Establish a drug-free awareness program Dangers of drug abuse Institutional policy Available counseling and rehabilitation services Penalties for violations in the workplace Employers must provide notice of convicted employees to ED’s Director of Grants and Contracts Service 2016 ILASFAA Annual Conference 29

Miscellaneous Debarment, suspension and other responsibility matters No fraud or criminal offenses committed by the institution’s principals Bribery Anti-trust violations Embezzlement Theft Forgery Bribery Falsification or destruction of records Making false statements Tax evasion Receiving stolen property Making false claims Obstruction of justice Not currently under indictment 2016 ILASFAA Annual Conference 30

Miscellaneous Annual distribution of drug and alcohol prevention policy Déjà vu? All employees and any student taking at least one class Not required for students only taking continuing education units Biennial review of drug and alcohol abuse prevention program 2016 ILASFAA Annual Conference 31

Constitution & Citizenship Days September 17 th each year educational institutions receiving Federal funding are required to hold an educational program pertaining to the United States Constitution If falls on religious holiday, you can celebrate either the week before or the week after. Federal Register: May 24, 2005, Vol. 70, No. 99 Not listed in either your PPA or FSA Handbook 2016 ILASFAA Annual Conference 32

Resources Program Participation Agreement Available at FSA Assessments The Handbook for Campus Safety and Security Reporting ml ml 2016 ILASFAA Annual Conference 33

Questions??? 2016 ILASFAA Annual Conference 34

Contact Information Briget Jans ILASFAA Annual Conference 35