Chief Academic Officers Minneapolis, MN June 19, 2012

Title IV Policies and Regulations 2012 and Beyond AIHEC Title IV Policies and Regulations 2012 and Beyond

AIHEC Pell LEU Program Integrity Regulations ATB SAP Course repeats Overawards as it relates to scholarships Consumerism Information Online courses

AIHEC Private Loans Graduation/Retention Gainful Employment Cleary Act Late audits Questions

AIHEC Pell Lifetime Eligibility Used (LEU) Reduce eligibility from 18 full time semesters/quarters to 12 full time semesters/quarters beginning 2012-13. We reported to FAD who has used 450% of eligibility This is a money saving change in program eligibility

AIHEC Overawards Cost of Attendance EFC EFA Total Award Pell only? If student received FSEOG and FWS?

AIHEC Consumer Information A variety of information you must provide to students, parents, faculty and staff Athletic programs Housing IPEDS data (can be fined)

AIHEC Private Loans These loans do not factor into your default rate (only 3 TCUS participate) Student signs promissory note They should read carefully Cancellation clauses not same as DL

AIHEC Cleary Act Part of consumerism Campus crime statistics Updated annually Should be on your schools website We check for the data and website Can be fined

AIHEC Audits Taking aggressive action on late submission of audits Cannot request extension You will be fined We will take further action

Program Integrity Regs NPRMs published June 18 - To improve the integrity of the Title IV student assistance programs. Comment Period Ended August 2, 2010 Final regulations published on Oct. 29, 2010 Generally effective July 1, 2011 (2011-2012 AY) Verification effective with the 2012-2013 AY The Program Integrity Regulations was published in the NPRMs on June 18, 2010, for the purpose of improving the integrity of the Title IV Student Financial Assistance Programs. Comments were accepted through August 2, 2010, with final regulations published October 29, 2010. Award Year 2011-2012 is the effective implementation of these regulations, with the Verification effective with the 2012-2013 Award Year. 47

Program Integrity Regs. – Part 1 Policy Objectives – Ensuring that only eligible students receive federal funds. Protecting consumers (students and families). Clarifying eligible coursework. A few others. These Program Integrity Regulation’s Policy Objectives includes: assuring that only eligible students receive SFA Funds, protecting student and their families (consumers), to clarify eligible coursework & a few others. 12

Program Integrity Regs - Part 1 Ensuring that only eligible students receive federal funds. High School Diploma: FAFSA will ask student to indicate high school. First-year students only Being on the list does not mean “approved” Not being on the list does not mean “unapproved” or “questionable” Further, to ensure Program Integrity, the FAFSA will ask the student to indicate the high school attended (for first year students only), and to validate that the high school is legitimate (when there are questions about the validity to offer high school diplomas). 13

Program Integrity Regs – Part 1 Ensuring that only eligible students receive federal funds. Satisfactory Academic Progress: Requires a structured and consistent approach to evaluating a student's academic work, while continuing to provide flexibility to institutions in establishing their policies. If SAP monitored each payment period, can use warning, then probation. If SAP monitored only once each year, must use “probation”. Probation requires a plan for resolution. This SAP provision is designed to provide a structured and consistent approach to evaluating academic work of students while continuing to provide flexibility to institutions. If SAP is monitored on a per semester basis, both warning and probation can be used, however, if monitored annually, only probation can be used. Probation requires a plan for resolution. 14

Program Integrity Regs – Part 1 Ensuring that only eligible students receive federal funds. Verification: Replaces the five verification items for all selected applicants with a targeted selection of items based upon each student’s characteristics. Eliminates the 30 percent institutional verification cap. Requires the processing of all changes and corrections to an applicant’s FAFSA information. Regarding Verification, the regulations propose the replacement of the five selected items to verify an applicant’s file with a targeted selection of items base upon each student’s characteristics. Additionally, it propose to eliminate the 30% institutional verification cap, and requires the processing of all changes and corrections to an applicant’s FAFSA, regardless of its significance to the outcome of the change. 15

Program Integrity Regs – Part 1 Protecting consumers. State Authorization: Clarifies state responsibility What about TCUS? As relates to the Protection of Consumers, the Department is strengthens it’s authority to take action against Misrepresentation - Institutions engaging in deceptive advertising, marketing, and sales practices. The Department clarifies the important responsibility of State Authorization. 16

Program Integrity Regs – Part 1 Protecting consumers Credit Hour: Defines a credit hour and establishes procedures for accrediting agencies to determine whether an institution's assignment of a credit hour is acceptable Further, the regulation protecting consumers defines credit hours and establishes procedures for accrediting agencies to determine whether an Institution’s assignment of a credit hour is acceptable.

Program Integrity Regs – Part 1 Clarifying eligible coursework: Written Agreements (Consortiums): Limits the amount of a program that can be provided by another school. Requires disclosures to students and potential students. Prohibits arrangements between ineligible institutions that have had their federal student aid participation revoked. In clarifying eligible coursework, an Institution’s Written Agreements will limit the amount of a program that can be provided by another school. The Written Agreements will also provide disclosures regarding these requirements to students and potential students. Arrangements with ineligible institutions that have had their federal student aid participation revoked is prohibited under these regulations. 18

Program Integrity Regs – Part 1 Other: Return of Title IV Aid: Modifies and clarifies the definition of when a student is considered to have withdrawn from a program. Clarifies the circumstances under which an institution is required to take attendance for the purpose of determining last date of attendance. Return of Title IV Aid, in the Program Integrity Regulations, modifies and clarifies the definition of when a student is considered to have withdrawn from a program, and clarifies the circumstances under which an Institution is “Required to take attendance” for the purpose of determining the “last date of attendance”. 19

Program Integrity Regs – Part 1 Other: Disbursing Federal Student Aid Funds: Requires institution to ensure that Pell Grant recipients have resources to obtain books and supplies by the seventh day of payment period. Retaking Coursework: Allows repeated coursework to count toward enrollment status. Must have a policy Changing majors: Policy Disbursing FSA Funds, under these regulations, requires Institutions to ensure that Students receiving Pell Grants have resources to purchase books & supplies by the seventh day of the payment period. It also allows repeated coursework to count towards the student’s enrollment status. 20

Program Integrity Regs-Part 1 GAINFUL EMPLOYMENT NPRM published on July 26, 2010. Final regulations for some provisions published on October 29, 2010. Effective July 1, 2011 More final regulations scheduled to be published in January. Effective July 1, 2012 The Department published NPRM on “Gainful Employment” on July 26, 2010. Final regulations for the provisions with an effective date of July 1, 2011 was published October 29, 2010. For regulations with an effective date of July 1, 2012, the final regulations were scheduled for publishing in January. 58

Program Integrity Regs – Part 1 Protecting consumers. Gainful Employment (GE): Programs at for-profit institutions and occupationally specific training at other institutions must lead to gainful employment in a recognized occupation. Currently there is no standard to measure “gainful employment”. These rules will establish such a standard. The Department, in protecting Consumers in the area of Gainful Employment, requires that Programs at for-profit Institutions and occupationally specific training at other Institutions must lead to gainful employment in a recognized occupation. Since there are currently no standards to measure “Gainful Employment”, these rules will establish such standard. Data collected from public comments, studies, reports and the media suggests the need to regulate in this area. 58

Program Integrity Regs – Part 1 Protecting consumers. Gainful Employment (GE): Public comment received along with a number of studies, reports, and media reports point to the need to regulate in this area. Data collected from public comments, studies, reports and the media suggests the need to regulate in this area.

GE –Covered Programs Proprietary Institution of Higher Education and Postsecondary Vocational Institution All programs must prepare students for gainful employment in a recognized occupation Exceptions Program leading to baccalaureate degree in liberal arts (proprietary institution) Comprehensive transition program for students with intellectual disabilities (vocational institutions) Under this regulation, all programs at Proprietary Institutions of Higher Education and Postsecondary Vocational Institutions must prepare students for “Gainful Employment” in a recognized occupation, with the exception of: Programs leading to baccalaureate degrees in liberal arts (Proprietary Institutions), and Comprehensive Transition programs for students with intellectual disabilities (Vocational Institutions). 60

GE –Covered Programs Public/Private Non-profit Institution of Higher Education Non-degree/certificate programs must prepare students for gainful employment in a recognized occupation Two exceptions Transfer program Comprehensive transition program for students with intellectual disabilities The requirement to prepare students for Gainful Employment include Public & Private Non-Profit Institutions of Higher Education, with Non-Degree and Certificate Programs, with the following Exceptions: Transfer Programs and Comprehensive Transition Programs for students with intellectual disabilities. 60

Program Integrity Regs – Part 1 Reporting Institutions with “gainful employment” programs must report to ED information on students enrolled in gainful employment programs. Student Identifiers Enrollment Status Non-Title IV educational debt Effective July 1, 2011 ED requires Institutions with “Gainful Employment” programs to report information to the Department on students enrolled in these programs to include; Student Identifiers, Enrollment Status, and Non-Title IV educational debt, effective July 1, 2011. 26

Program Integrity Regs – Part 1 Disclosures Institutions with “gainful employment” programs must provide prospective students with each eligible program's graduation and job placement rates, and provide the Department with information that will allow for the determination of student debt levels and incomes after program completion. On your website Effective July 1, 2011 Institutions with “Gainful Employment” programs must disclose to prospective students, graduation and job placement rates, and provide the Department with information to determine student debt levels and incomes after program completion, for each eligible program. 27

Program Integrity Regs – Part 2 Additional Gainful Employment Programs Institutions seeking to add a “gainful employment” program must obtain approval from ED. Must document an employment need in their community for graduates of the program. Effective July 1, 2011 These Regulations address Additional “Gainful Employment” Program rules. Effective July 2011, prior to adding a “GE” Program, Institutions must gain the approval from ED, and document an employment-need in their community for graduates of the proposed program. 28

Program Integrity Regs – Part 3 Gainful Employment Metrics Effective July 1, 2012 Defines “gainful” to be when a substantial number of the program’s students – Are repaying their Title IV loans (Repayment Rate) Have a reasonable debt burden (Debt to Earnings Ratio). “Gainful Employment” Metrics. The Final Rule was expected to be released January 2011, with an effective date of July 1, 2012. In these Regulations, the Department defines “Gainful” to be when a substantial number of the program’s students – Are repaying their Title IV Loans (Repayment Rate) and have a reasonable debt burden (Debt to Earnings Ratio). 29

Gainful Employment Metrics Repayment Rate The percentage of the outstanding principal balance of the federal loans taken by the academic program’s former students who entered repayment in the previous four years that has been repaid. The Repayment Rate is “The percentage of the outstanding principal balance of the federal loans taken by the academic program’s former students who entered repayment in the previous four years that has been repaid”. 63

Gainful Employment Metrics Debt to Earnings Ratio For the academic program’s completers, the average educational loan payments (federal, private, and institutional financing plans) as a proportion of the borrower’s income (either discretionary income or average annual earnings). Loan payment amount based on a 10- year amortization schedule at 6.8 percent. The Debt to Earnings Ratio is “For the academic program’s completers, the average educational loan payments (federal, private, and institutional financing plans) as a proportion of the borrower’s income (either discretionary income or average annual earnings). Loan payment amount based on a 10-year amortization schedule at 6.8%.

John Gritts John.Gritts@ed.gov 303-844-3148 AIHEC John Gritts John.Gritts@ed.gov 303-844-3148

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