TOM DALTON EXCELSIOR COLLEGE AND HOWARD LESLIE BERKELEY COLLEGE 1 GAINFUL EMPLOYMENT

NPRM Published in the Federal Register on March 25, 2014 – Vol. 79 Comments were due on or before May 27, 2014 Final regulations expected by November 1, 2014 (AKA – any second) 2

Metrics Annual debt-to-earnings Discretionary debt-to-earnings Program cohort default rate Students CompletersCompleters & non-completers Categories & thresholds Pass: aDTE≤8% OR dDTE≤20% Zone: Not passing AND 8%<aDTE≤12% OR 20%<dDTE≤30% Fail: aDTE>12% AND dDTE>30% Pass: pCDR<30% Fail: pCDR≥30% Ineligibility rules (metrics operate independently of each other) A program becomes T4 ineligible for 3yrs if: It fails in any 2 out of 3yrs, OR Does not pass in any 1 out of 4yrs (time for zone programs to improve before ineligibility) A program becomes T4 ineligible for 3yrs if: The 3 year default rate of 3 consecutive cohorts of students is greater than or equal to 30% Restrictions Debt warnings to students if program could become ineligible at the end of the year (applies to zone & failing programs) Tell students they may not be eligible for federal aid because their program is failing standards established by the US Department of Ed Debt warnings to students if program could become ineligible at the end of the year Tell students they may not be eligible for federal aid because their program is failing standards established by the US Department of Ed Certification Most senior officials must certify: Program has accreditation or state recognition on its own or thru the institution Program has necessary programmatic accreditation if required by federal government or other governmental entity in the state and Metropolitan Statistical Area 3

Pass: aDTE≤8% OR dDTE≤20% Zone: 8%<aDTE≤12% OR 20%<dDTE≤30% Fail: aDTE>12% AND dDTE>30% A program becomes T4 ineligible for 3yrs if: It fails in any 2 out of 3yrs, OR Does not pass in any 1 out of 4yrs (time for zone programs to improve before ineligibility) f 4 Annual D/E and Discretionary D/E Completers

For programs failing or in the zone use the lowest of the following: Calculate debt for award year completers and use 2014 annual earnings Calculate debt for award year completers and use 2014 annual earnings Compare the 2 and use the lower of the draft D/E or the transitional D/E Theory is you can lower tuition thereby lowering debt 5 Transition period

Pass: pCDR<30% Fail: pCDR≥30% A program becomes T4 ineligible for 3yrs if: The 3 year default rate of 3 consecutive cohorts of students is greater than or equal to 30% 6 pCDR Completers & Non-Completers

Restrictions Warnings must be provided to students in zone/failing programs Tell students they may not be eligible for aid because their program is failing USDE standards Certifications Most senior officials must certify: GE program has accreditation or state recognition on its own or thru the institution GE program has necessary programmatic accreditation if required by federal government or other governmental entity in the state and Metropolitan Statistical Area 7 Restrictions & Certifications

DISCLOSURES Template to be provided by USDE; updated annually; included in all promotional materials 8 OccupationPlacement rate (if required by state or accreditor) Total costs for completing program on time Repayment rate (borrower-based) calculated by the Secretary Program length, clock or credit hours, total enrollment, % of enrollees who incurred debt Median earnings/annual earnings and median loan debt calculated by the Secretary Completion rate (for full and part-time students) Whether licensure requirements are met (if applicable) in state where institution is located and other state’s in MSA Withdrawal rate (within normal time of program) Whether program holds appropriate programmatic accreditation (if required) Disclosures

TIMING – NOT CRYSTAL CLEAR D/E Department example D/E issued for the award year 2-year student cohort is / (2012 cohort) Earnings are 2014 calendar year – obtained by the Department in early 2016 Rates issued 2016 D/E issued for the award year 2-year student cohort is / (2013 cohort) Earnings are 2015 calendar year – obtained by the Department in early 2017 Rates issued 2017 Fail 2 out of 3 consecutive years Ineligible (is it for the 2017 or 2018 award year in above example???) Ineligible for 3 years 9 Timing -- Not Crystal Clear

EAR pCDR Of borrowers entering repayment 3 fiscal years prior to year of calculation; percentage who default by end of subsequent 2 fiscal years Department example 2016 pCDR Borrowers who entered repayment in fiscal year 2013, percentage who defaulted by end of fiscal year 2015 Fail 3 consecutive years Ineligible for 3 years 10 Timing -- Not Crystal Clear

IMPROVEMENTS FROM PREVIOUS DRAFT N size is 30 Loan amortization is: 10 years for certificate and associate degree programs 15 years for bachelor’s and master’s degree programs 20 years for doctoral and first professional programs 11 Significant Changes from Previous Draft

Passing annual debt to earnings is set at 8%; 20% for discretionary; zones set between 8%-12% and 20%- 30%. Previous rule set passing at 12% & 30% with no zones. Programs must pass one of the debt-to-earnings metrics and the cohort default rate metric; previous rule provided for debt-to-earnings and loan repayment to work as alternatives. Only Title IV recipients will be included in the debt- to-earnings calculation; previous rule included all students. 12 Major Variations from 2011 Final Regulation

2014 NPRM (DEE only) metrics: annual DTE*, discretionary DTE* Pass: aDTE≤8% or dDTE≤20% Zone: 8%<aDTE≤12% or 20%<dDTE≤30% Fail: aDTE>12% and dDTE>30% min program size: 30 amortization: 10/10/15/20 Interest rate 5.4% 2014 NPRM (pCDR only) metric: program cohort default rate** Pass: pCDR<30% Fail: pCDR≥30% min program size: NPRM (Full) metrics: annual DTE*, discretionary DTE* Pass: aDTE≤8% or dDTE≤20% Zone: 8%<aDTE≤12% or 20%<dDTE≤30% Fail: aDTE>12% and dDTE>30% min program size: 30 amortization: 10/10/15/20 Interest rate 5.4% metric: program cohort default rate** Pass: pCDR<30% Fail: pCDR≥30% min program size: 30 Total Pass 244 (97% programs) 236 (90% of programs) 312 (90% of programs) Zone 6 (2% of programs) (1% of programs) Fail 3 (1% of programs) 26 (10% of programs) 29 (9% of programs) * Analysis based on Title IV aided (Stafford loan, GradPlus loan, or Pell grant) students who completed a GE program between October 1, 2007 and September 30, 2009 and whose mean and median earnings by program were retrieved from the SSA for the 2011 calendar year (08/09 DTE Cohort). **Analysis based on Title IV aided (Stafford loan or GradPlus loan) students who attended a GE program and entered repayment on their loans between October 1, 2008 and September 30, 2009 (09 pCDR Cohort). For programs with less than 30 students in the 09 pCDR cohort, analysis also includes students who attended the program and entered repayment between October 1, 2006 and September 30, Gainful Employment Informational Data Analysis for Private NonProfit Colleges 13

2014 NPRM (DEE only) metrics: annual DTE*, discretionary DTE* Pass: aDTE≤8% or dDTE≤20% Zone: 8%<aDTE≤12% or 20%<dDTE≤30% Fail: aDTE>12% and dDTE>30% min program size: 30 amortization: 10/10/15/20 Interest rate 5.4% 2014 NPRM (pCDR only) metric: program cohort default rate** Pass: pCDR<30% Fail: pCDR≥30% min program size: NPRM (Full) metrics: annual DTE*, discretionary DTE* Pass: aDTE≤8% or dDTE≤20% Zone: 8%<aDTE≤12% or 20%<dDTE≤30% Fail: aDTE>12% and dDTE>30% min program size: 30 amortization: 10/10/15/20 Interest rate 5.4% metric: program cohort default rate** Pass: pCDR<30% Fail: pCDR≥30% min program size: 30 Total Pass 1090 (99% programs) 850 (94% of programs) 1453 (96% of programs) Zone 2 (less than 1% of programs) (less than 1% of programs) Fail 1 (less than 1% of programs) 52 (6% of programs) 53 (4% of programs) * Analysis based on Title IV aided (Stafford loan, GradPlus loan, or Pell grant) students who completed a GE program between October 1, 2007 and September 30, 2009 and whose mean and median earnings by program were retrieved from the SSA for the 2011 calendar year (08/09 DTE Cohort). **Analysis based on Title IV aided (Stafford loan or GradPlus loan) students who attended a GE program and entered repayment on their loans between October 1, 2008 and September 30, 2009 (09 pCDR Cohort). For programs with less than 30 students in the 09 pCDR cohort, analysis also includes students who attended the program and entered repayment between October 1, 2006 and September 30, Gainful Employment Informational Data Analysis for Public Colleges 14

2014 NPRM (DEE only) metrics: annual DTE*, discretionary DTE* Pass: aDTE≤8% or dDTE≤20% Zone: 8%<aDTE≤12% or 20%<dDTE≤30% Fail: aDTE>12% and dDTE>30% min program size: 30 amortization: 10/10/15/20 Interest rate 5.4% 2014 NPRM (pCDR only) metric: program cohort default rate** Pass: pCDR<30% Fail: pCDR≥30% min program size: NPRM (Full) metrics: annual DTE*, discretionary DTE* Pass: aDTE≤8% or dDTE≤20% Zone: 8%<aDTE≤12% or 20%<dDTE≤30% Fail: aDTE>12% and dDTE>30% min program size: 30 amortization: 10/10/15/20 Interest rate 5.4% metric: program cohort default rate** Pass: pCDR<30% Fail: pCDR≥30% min program size: 30 Total Pass 2850 (68% of programs) 4786 (85% of programs) 4204 (69% of programs) Zone 875 (21% of programs) (11% of programs) Fail 468 (11% of programs) 865 (15% of programs) 1218 (20% of programs) * Analysis based on Title IV aided (Stafford loan, GradPlus loan, or Pell grant) students who completed a GE program between October 1, 2007 and September 30, 2009 and whose mean and median earnings by program were retrieved from the SSA for the 2011 calendar year (08/09 DTE Cohort). **Analysis based on Title IV aided (Stafford loan or GradPlus loan) students who attended a GE program and entered repayment on their loans between October 1, 2008 and September 30, 2009 (09 pCDR Cohort). For programs with less than 30 students in the 09 pCDR cohort, analysis also includes students who attended the program and entered repayment between October 1, 2006 and September 30, Gainful Employment Informational Data Analysis for Private Sector Colleges 15

FINAL REGS?