Kevin Piotrowski Massachusetts College of Pharmacy and Health Sciences Consumer Information Compliance, Evaluation and Communication

Consumer Information Information that you have the right to know as a consumer according to federal law.

Name Variations Student Consumer Information Public Disclosure Student Right to Know Federal Disclosure Notices Federal Compliance and Disclosures University Disclosure Statements Federal Compliance Statements, Disclosures

Legislation Higher Education Opportunity Act HEOA reauthorized the Higher Education Act of 1965 and established new institution-based disclosure requirements  Net price calculator  Codes of conduct  Textbook cost information  Private loan disclosures (self-certification form) Enacted August 14, 2008 Public Law Dear Colleague Letter GEN-08-12

Legislation Negotiated Rulemaking Non-loan disclosure issues negotiated Spring 2009  Campus Safety  Peer-to-peer file sharing  Educational outcomes information NPRM published August 21, 2009 Final rule published October 29, 2009 Final rules went into effect July 1, 2010

Recent Legislation Program Integrity Issues – School and Student disclosures  Written arrangements  Disbursement  Incentive compensation  Gainful employment  State authorization as a component of institutional eligibility  Definition of credit hour to determine program eligibility  High school diploma definition  Verification of information included on student aid application NPRM published June 18, 2010 Final rule published October 29, 2010 Final rules went into effect July 1, 2011 (Verification was July 1, 2012)

Main Focus Compliance Evaluation Communication

Compliance Law Regulations Sub-regulatory guidance Institutional policies and procedures

Institutional Disclosure Requirements  There are currently over 40 disclosure requirements associated with Title IV  There are over 200 data requirements embedded within the disclosures

Disclosures include: Notice of Availability of Institutional and Financial Aid Information Contact Information for Assistance in Obtaining Aid Information Student Financial Aid Information Notice of Federal Student Financial Aid Penalties for Drug Law Violations Privacy of Student Records – FERPA Consumer Information on College Navigator Facilities and Services Available to Students with Disabilities Student Body Diversity Price of Attendance Net Price Calculator

Disclosures include: Refund Policy, Requirements for Withdrawal and R2T4 Textbook Information Academic Program (Educational Programs, Instructional Facilities, and Faculty) Transfer of Credit Policies and Articulation Agreements Institutional and Program Accreditation and Approval Copyright Infringement Policies and Sanctions (including computer use and peer-to-peer file sharing) Teacher Preparation Program Report Drug and Alcohol Abuse Prevention Program Vaccination Policies

Disclosures include: Security Report – October 1 st each year Missing Person Notification Policy Fire Safety Report and Fire Log Information for Crime Victims about Disciplinary Hearings Retention Rate Completion/Graduation and Transfer-Out Rates (including disaggregated completion/graduation rates) Completion/Graduation and Transfer-Out Rates for Students Receiving Athletically Related Student Aid (including disaggregated completion/graduation rates) Placement in Employment

Disclosures include: Job Placement Rates Types of Graduate and Professional Education in which the Institution’s Graduates Enroll Intercollegiate Athletic Program Participation Rates and Financial Support Data Voter Registration Forms State Grant Assistance Student Loan Information Published by the Department of Education National Student Loan Data System Entrance Counseling for Student Borrowers Exit Counseling for Student Borrowers

Disclosures include: Private Education Loan Disclosures (Self-Certification Form) Code of Conduct for Education Loans Preferred Lender Lists Preferred Lender Arrangements (PLA) and Annual PLA Report Written arrangements Disbursement Incentive compensation Gainful employment State authorization as a component of institutional eligibility High school diploma definition Verification of information included on student aid application

Evaluation Development Implementation Communication Annual Assessment

Institutional Responsibility As is all statutory and regulatory compliance pertinent to Title IV; what varies is how each institution divides the responsibilities as part of administrative capability.

Evaluation Identify what information applies to your institution and what needs to be disclosed Recognize and know the individuals/groups/departments responsible for each disclosure and for annual review

Evaluate the Language Review and interpret regulatory language to address the ‘spirit’ of the law Always make a ‘good faith’ effort to comply with laws and regulations

Notice of Availability of Institutional and Financial Aid Information Each year a school must provide to enrolled students a notice containing a list of consumer information it must disseminate, and the procedures for obtaining the consumer information. Schools must provide this notice through a one-on-one distribution. – FSA Handbook, Vol. 2, Ch. 6

Notice of Federal Student Aid Penalties for Drug Law Violations Provide to each student upon enrollment, a separate, clear, and conspicuous written notice about the loss of eligibility as a result of a conviction under any federal or state law involving the possession or sale of illegal drugs while receiving Title IV funds. Individual notice, in a timely manner, to students who lost eligibility and how to regain eligibility.

Student Financial Aid Information Deferments required to be published for federal educational loans (information is on DL Disclosure) Under the terms and conditions that you receive Federal Student Loan assistance, you may obtain deferral of the repayment of principle and interest for:  Service under the Peace Corps Act  Service under the Domestic Volunteer Service Act of 1973  Comparable service as a volunteer for a tax-exempt organization of demonstrated effectiveness in the field of community service

Student Loan Information Student Loan information published by the Department of Education

Privacy of Student Records - FERPA Must be disclosed if receiving any types of funds from any Department of Education Program (includes student financial aid) One of the few disclosures that must be made directly to students and made available.

Information on College Navigator Data is published by the Department of Education which is reported by each institution to NCES in IPEDS Required to be made available on the institution’s website

Facilities and Services Available to Students with Disabilities Information made available to prospective and enrolled students about facilities and services available to students with disabilities, including students with intellectual disabilities.

Net Price Calculator Required to be published on website by October 29, 2011 Individual net price estimates must have prominent disclaimer that estimate is not final or binding Student must complete FAFSA to be eligible for and receive federal student funds Must include link to FAFSA May use Federal or Institutional methodology to approximate student’s EFC

Textbook Information Provisions are statutory and the Secretary has no regulatory authority. Statutory refers to laws passed by the state of federal government. Regulatory means a rule issued by some agency that the government has given authority to regulate an industry. Must be disclosed on the institution’s Internet course schedule: ISBN and retail price for required and recommended textbooks and supplemental materials for each course.

Copyright Infringement Summary of penalties for violation of federal copyright laws Unauthorized peer to peer file sharing: institution’s policy and disciplinary actions.

Teacher Preparation Program Report Each institution must provide a report annually to the state and to the general public in relation to: Goals Assurances Pass rates and scaled scores

Drug and Alcohol Abuse Prevention Program Annually distribute information in writing to each student and each employee Required to do biennial review of the institution’s program and upon request, make available to Department of Education and the public

Security Report – Cleary Act Additions include: Crime statistics for larceny-theft, intimidation, destruction/damage/vandalism of property as hate crimes Any other crime involving bodily injury Missing person notification Sex offenses – review data (registered sex offender link)

Completion/Graduation Rates Graduation rates must be disaggregated by: Gender Ethnicity Recipients of Federal Pell Grant Recipients of a Subsidized Stafford Loan who did not receive a Pell Grant Students who did not receive either a Pell Grant or a subsidized Stafford Loan

Voter Registration Forms This requirement does not apply to institutions in states that do not have a voter registration requirement or that allow voters to register at the time of voting

Preferred Lender Arrangement (PLA) and Preferred Lender List Covered Institution – Institution that receives any Federal funding Does not include private loans:  funded by institution’s own funds  funded by donor-directed contributions  Made under title VII or VIII of Public Service Act  Made under a State-funded financial aid program, if terms and conditions of the loan include a loan forgiveness option for public service

Entrance and Exit Counseling for Student Loan Borrowers In full compliance with the use of: Entrance counseling Exit counseling

Advanced Funds for Pell Grant Eligible Students to Obtain Books and Supplies Students do not have to opt-in to this process but an institution is required to have an opt-out process

Online Programs Online student who wants to file a complaint within the state in which s/he resides: notices

Satisfactory Academic Progress Pace GPA Maximum Timeframe Types of coursework used in calculation Appeals Warning, Probation, Academic Plan?

Added to Program Participation Agreement (PPA) Institutions must develop, publish, administer and enforce a code of conduct with respect to loans made under title IV, HEA loan programs in accordance with For any year an institution has a PLA, annually compile, maintain and make available to students, a list of private education loans the institution recommends

Added to Program Participation Agreement (PPA) Institutions must, upon request of an enrolled or admitted student applicant of a private education loan, provide the applicant with the self-certification form and the information needed to complete it Institutions must have developed and implemented written plans to effectively combat unauthorized distribution of copyrighted materials by users of their network and periodically review alternative legal sources and provide to students

Communication Basic Principle Who does the information need to be communicated to? What information needs to be communicated? Where does the information need to be communicated? When does the information need to be communicated? Why does the information need to be communicated? How does the information need to be communicated?

Institutional Responsibility As is all statutory and regulatory compliance pertinent to Title IV; what varies is how each institution divides the responsibilities as part of administrative capability.

Communication Information that must be provided to: Prospective students and families Current students and families Prospective and current students Prospective student athletes (parents, guidance counselors and coaches) Current and prospective employees College bookstore

Communication Information made available to: Prospective students and families Current students and families Current student athletes Prospective and current students Public

Communication Information that must be published on website Information that must be provided to current and prospective borrowers

Communication

Centralized Location Pros One location to update/review Ensures all requirements are addressed Accessible for all students Assists with demonstrating to administration / generating institutional responsibility Cons Need to keep information updated Ensure all requirements are addressed Still need to ensure that certain information is provided directly to specified individuals

Continuously Review Information FASFA EFC – Estimated Financial Contribution Financial need is calculated by adding your educational resources to the difference between the cost of attendance and your expected family contribution Contact your guarantor for repayment Financial aid will fund your education Updated information (interest rate for Subsidized loans)

More than 2900

Principles of Excellence As of September 25, 2012, more than 2900 institutions have agreed to the Executive Order signed by the President in April 2012 establishing Principles of Excellence for Educational Institutions Serving Service Members, Veterans, Spouses, and Other Family Members.Principles of Excellence for Educational Institutions Serving Service Members, Veterans, Spouses, and Other Family Members

316

Federal Shopping Sheet As of September 25, 2012, 316 institutions have agreed to adopt the Federal Shopping Sheet.

On the Horizon ACCEPT Act Attempt to crack down on aggressive recruiting process and expand penalties for misrepresented information Disclosure sheet for students and families created by Department of Education and Consumer Financial Protection Bureau Add to PPA about deceptive practices in relation to misleading consumers

ACCEPT Act Disclosure would include: COA Average net price and link to NPC Average net price for students receiving Title IV and broken down by family income Percent of students receiving aid CDR Average percentage of student borrowing federal loans Average federal student loan debt for graduates Transfer out rate Completion/graduation rate

Resources FSA Handbook; Volume 2/School Eligibility/ Chapter 6, Chapter 7 and Chapter 8 k&awardyear= NPEC: Information Required to Be Disclosed Under the Higher Education Act of

Resources Federal Register The Handbook for Campus Safety and Security Reporting National Center for Educational Statistics

Resources The Equity in Athletics Data Analysis Cutting Tool Higher Education Center for Alcohol, Drug Abuse, and Violence Prevention Constitution Day

Assessment Tools NASFAA Policies and Procedures Tools Assessing Regulatory Requirements Self Evaluation Guides Compiled Title IV Regulations regs/2012/Compiled_Title_IV_Regulations.aspx IFAP Quality Assurance Program

Contact Information Kevin Piotrowski Director, Student Financial Services Massachusetts College of Pharmacy and Health Sciences 179 Longwood Avenue Boston, MA