Gainful Employment One School’s Journey National American University 10/15/2016

National American University For-Profit Institution 31 Campuses Majority Non-Traditional Students Diplomas Associates Bachelors Masters Doctorates All programs, All students must be reported Except if Not Federal Financial Aid Recipient National American University 10/15/2016

34 Campuses-The Initial numbers July 31, 2015 Initial reporting 94,929 unduplicated students for award years 2008/09 through 2013/14 124 files (each campus/award year combination had to be separate, some campuses opened later than 2008/09) 349 Error records corrected directly in NSLDS within 10 days of receiving the corrections file October 1, 2015 Data for 2014/15 students 15, 929 unduplicated students for award year 2014/15 51 Error records corrected directly in NSLDS within 10 days of receiving the corrections file October 1, 2016 Data for 2015/16 students 13, 821 unduplicated students for award year 2015/16 59 Error records corrected directly in NSLDS within 10 days of receiving the corrections file National American University 10/15/2016

Debt to Earnings Calculation Annual Earnings Rate Annual Loan Repayment divided by Mean or Median Annual Earnings (whichever is higher) Discretionary Income Rate Mean or Median Annual Earnings (whichever is higher) minus 150% of HHS Poverty Guideline National American University 10/15/2016

What can we review for correctness? Debt Amount for Calculation limited to: Total tuition and fees, books and supplies and equipment OR Total debt attributable to the program (Federal student Loans, Private Education Loans and Institutional Debt) Whichever is less Annual Loan Repayment Length for the above debt depends on degree level Annual Earnings Based on individual students submitted to Social Security Administration Mean and Median calculated based on 2 calendar years preceding the year in which the rates are calculated 2015-16 Discretionary Earnings 150% of $11,770 = $17,655 Calculation Exclusions Military, permanent disability discharge, enrolled in another program during the years the mean and median were calculated, completed a higher degree at same school, deceased National American University 10/15/2016

Completers List Received July 28, 2016 Department of Education combined all campuses into one Completers File 43 Programs 2123 Students Discovered many students were not reported due to: Enrolled in the BS degree but had completed the AAS degree requirements during this time and graduated with the AAS degree Called GE about this and were told that if the student was not in attendance in the graduated degree at the time of graduation they could not be reported National American University 10/15/2016

Who do we Review? 2123 Students! Only 2 people work GE-Only 45 days Review only Programs w/small numbers? Review only Students w/amounts of tuition and fees higher than average? 29 Programs w/less than 30 completers even with 4 year cohort 3 Programs w/ 30-40 completers 4 Programs w/ 41-50 completes 2 Programs w/ 51-70 completers 5 Programs w/ more than 70 completers 5 Diploma students 70 Associates students 139 Bachelors students 0 Master 0 Doctorate National American University 10/15/2016

What we Reviewed 45 Days to submit cases (Challenges) to the Completers list information More time/people we could have reviewed more students Total amount of student’s tuition and fees, books and supplies and equipment Student’s enrollment begin and graduation dates Did not review students in programs with less than 30 completers even on a 4 year cohort 139 Students reviewed 95 submitted cases Had to not only submit the case but also had to correct the NSLDS data directly in NSLDS GE reporting Only 1 case not approved (Student was not in initial reporting) National American University 10/15/2016

What did you Review? How did it turn out? National American University 10/15/2016

SSA Earnings File and Draft Debt to Earnings Rates Received October 10, 2016 43 Programs 13 Programs no Earnings Data-Less than 30 completers 16 Programs used a 4 year cohort My preliminary guess at the Debt to Earnings rates using our average graduated student debt level by degree type turned out to be completely wrong We now have to work on corrections for the debt measures (received 10/19/16) Review each student’s individual underlying loans Loan period start and end dates Loans prior to starting SULA tracking did not have a reduced loan period if the student withdrew Loan amounts minus refunds and cancels National American University 10/15/2016

Deadline Complications!! Week of September 12-NAU’s Independent Audit of all campuses September 30-FISAP October 1-Early FAFSA New forms, processes and software setup to complete for this October 1-Yearly Gainful Employment Data 10 days after file received-Gainful Employment Data Corrections This year also reviewed all 1398 Graduates for the year to ensure they were reported October 17-During the week the draft Debt to Earnings measures sent Starts the 45 day challenge period October 19-IPEDs Fall Collection for Keyholders November 2-IPEDs Fall Collection for Coordinators What Else? National American University 10/15/2016