Byron Scott | Dec U.S. Department of Education 2013 FSA Training Conference for Financial Aid Professionals Foreign School Consumer Information Session 45

Notice to Enrolled Students Schools must annually distribute a notice of the availability of all consumer information to all enrolled students Must be provided to an individual on a one-to-one basis through mailing or publication is acceptable Posting on website does not constitute a notice Must list and briefly describe the information and inform how to obtain the information For information disclosed on a school’s website, the notice must include the exact electronic address and a statement that the school will provide a paper copy on request Notice must also include information about student rights under FERPA 2

Definition of Notice From 34 CFR (a) “Notice means a notification of the availability of information an institution is required by this subpart to disclose, provided to an individual on a one-to-one basis through an appropriate mailing or publication, including direct mailing through the U.S. Postal Service, campus mail, or electronic mail. Posting on an internet website, or an intranet website does not constitute a notice.” 3

Availability of Employees Schools must designate an employee (or employees) who are available on a full-time basis to assist current and prospective students in obtaining required information Requirement for full-time employee may be waived by Department if total enrollment or number of students receiving Title IV is too small to justify a full-time employee 4

Student Financial Aid Information Schools must make available to students information about All federal, state, local, private and institutional financial student assistance programs available to students who enroll at the school Includes need-based and non-need based programs For each financial aid program, schools must disclose Procedures and forms for students to apply Student eligibility requirements Criteria for selecting recipients from the group of eligible applicants Criteria for determining the amount of a student’s award 5

Student Rights and Responsibilities Schools must describe the rights and responsibilities of students receiving federal student aid Criteria for continued eligibility in each program SAP standards and criteria by which a student who fails to maintain SAP may re-establish eligibility Frequency and method by which financial assistance disbursements will be made to students General conditions and terms applicable to any employment provided as part of the financial assistance package Terms and conditions of any loans Sample repayment schedule for sample loans Necessity of repaying loans Exit counseling information the school provides and collects 6

Student Financial Aid Information Schools must make available to students information about: Loan terms including sample repayment schedule and necessity for repaying loan Statement about enrolling in study abroad and its impact on applying for financial aid Exit counseling information the school provides and collects Student loan information published by the Department 7

Cost of Attendance Disclosure Schools must make available information about the cost of attending the school including: Tuition and fees Books and supplies Room and board Transportation Additional costs for a program in which a student is enrolled or expresses a specific interest 8

Refund and R2T4 Disclosures Schools must make available information about: Any refund policies applicable to the school Requirements and procedures for official withdrawing from the school Summary of R2T4 requirements 9

Academic Program Disclosure Schools must make available information about: Current degree and other educational and training programs Instructional, laboratory, and other physical plant facilities that relate to the academic program Faculty and other instructional personnel Names of accrediting agencies and governmental bodies that approve, accredit or license the school Include procedures for obtaining or reviewing documents describing accreditation, approval or licensing Any plans by the school for improving the academic program (upon determination by the school that such a plan exists) 10

Graduation/Completion Rate Each year schools must make available to prospective and current student the completion or graduation rate of certificate or degree-seeking first-time full-time undergraduates Make available by July 1 for the cohort that has had 150% of normal time for completion by August 31 of prior year For schools that offer most programs based on semesters, trimesters or quarters, cohort is based on students who enter the fall term of each year Include first-time undergraduates enrolled as of October 15, the end of the school’s drop-add period, or other official reporting date as defined in (a) Students are counted as a completer or graduate if they earn the degree or certificate within 150% of normal time for the program See 34 CFR

Completion/Graduation Rates Must be disaggregated by: Gender Major racial/ethnic subgroups Recipients of Federal Pell Grant, FFEL/DL (Other than unsubsidized Stafford loan) Recipients of neither Pell Grant nor FFEL/DL (Other than unsubsidized Stafford loan) Not required if number would not yield statistically reliable information or would reveal personally identifiable information 12

Placement Rates Required disclosures Placement and types of employment obtained by graduates of the institution’s degree or certificate programs Include any placement rates calculated by institution Identify source of information provided, including timeframes and methodology Schools that advertise job placement rates as a means of recruiting students must make available to prospective students at or before they enroll Employment and graduation statistics Any other information necessary to substantiate the truthfulness of the advertisements 13

Graduate/Professional Information Schools must make available information regarding the types of graduate and professional education in which graduates of the institution’s four-year degree programs enroll Identify the source of the information, and any timeframes and methodology associated with the information 14

Additional Information to be Disclosed Institutional policies regarding vaccines Services and facilities for students with disabilities, including intellectual disabilities Terms and conditions under which students receive Federal Direct Loans Transfer of credit policies Any established criteria the school uses regarding the transfer of credit from another school A list of schools with which the school has established an articulation agreement 15

Educational Records and Privacy Schools must provide a notice annually to enrolled students of Right to review educational records Procedures for reviewing records Information regarding disclosure of “directory” information Information required to be disclosed under Family Educational Rights and Privacy Act (FERPA) See 34 C.F.R Part 99 16

Copyright Infringement Schools must make readily available to current and prospective students the school’s policies and sanctions related to copyright infringement Disclosure must include Statement that explicitly informs students that unauthorized distribution of copyrighted material, including unauthorized peer-to- peer file sharing, may subject them to civil or criminal liabilities Summary of penalties for violating national copyright law Description of the institution’s policies on unauthorized peer-to-peer file sharing, including disciplinary actions 17

Textbook Information Disclosure Provisions are established by law and the Secretary has no regulatory authority Effective July 1, 2010 Applies to each institution receiving federal financial assistance 18

Textbook Information in Course Schedules For each course listed in the school’s online course schedule, must disclose: International Standard Book Number (ISBN) Retail price for each textbook Indication that required information is unavailable if it is yet to be determined with designation “to be determined” Include a notice on written course schedule that textbook information is on the internet course schedule, and include web address 19

Textbook Information for College Bookstores Schools must provide to college bookstore operated by or in contractual relationship or otherwise affiliated with school The course schedule for the subsequent academic period For each course/class for the following academic period The ISBN and price for material for the class The number of students enrolled The maximum student enrollment 20

Education Loans Code of Conduct Title IV Loan Code of Conduct required for all schools participating in Federal Direct Loans Must publish code of conduct prominently on institution’s website Must administer and enforce such code Must require that all of the institution’s officers, employees, and agents with responsibilities with respect to such loans be annually informed of the provisions of the code of conduct See 34 CFR for requirements 21

Private Education Loans Disclosures Must be distinct from information related to Title IV loans Disclosures must include Any information required under Truth in Lending Act Notice that may qualify for loans or other assistance under Title IV Notice that terms/conditions of Title IV loans may be more favorable than private education loans 22

Private Education Loans Schools may inform students of all private loan lenders that are willing to make loans to its students If this is fewer than three lenders, this is not considered a preferred lender list if all lenders that do work with the school are listed School must make it clear it is not endorsing the lenders and the borrowers may choose any lender 23

Drug-Related Offenses At enrollment, school must provide student with separate, clear and conspicuous notice regarding penalty for federal or state convictions of drug-related offenses while receiving Title IV assistance If a student loses eligibility for this reason, school must notify student of loss of eligibility and ways to regain eligibility 24

Drug Prevention Program Institutions must adopt and implement a drug prevention program to prevent the unlawful possession, use or distribution of illicit drugs and alcohol by all students and employees on school premises or as part of any of its activities Accessible to any student, employee or officer See 34 CFR Subpart 86 Certification of compliance included in signed Program Participation Agreement 25

Drug Prevention Program Description of legal sanctions for unlawful possession or distribution of illegal drugs and alcohol Description of the health risks associated with the use of illicit drugs and abuse of alcohol Description of any drug or alcohol counseling, treatment, rehabilitation or re-entry programs that are available to students and employees Clear statement that the school will impose disciplinary sanctions on students and employees (consistent with law) for violation of the standards of conduct 26

Review of Plan Effectiveness Schools must review drug prevention plans biennially Determine the effectiveness of the plan Determine the number of drug and alcohol violations and fatalities that occur on campus and are reported to campus officials Ensure disciplinary sanctions are consistently enforced, including the number and type of sanctions imposed 27

Drug Prevention Program Written information must be distributed to all employees and to each student taking one or more classes for any kind of academic credit Institutions must retain records including the annual notification document for three years after the fiscal year in which the record was created 28

Missing Student Notification Required of institutions that maintain an on-campus student housing facility Must have a policy regarding missing student notification procedures for student who reside in on-campus student housing facilities 29

Campus Definition From 34 CFR “(1) Any building or property owned or controlled by an institution within the same reasonably contiguous geographic area and used by the institution in direct support of, or in a manner related to, the institution’s educational purposes, including residence halls; and “(2)Any building or property that is within or reasonably contiguous to the area identified in (1) that is owned by the institution but is controlled by another person, is frequently used by students, and supports institutional purposes (such as food or other retail vendor).” 30

Missing Student Notification Titles of persons or organizations to which individuals should report that a student has been missing for 24 hours Requires that any missing student reports be immediately referred to campus police or local law enforcement Option for each student to identify a contact to be notified within 24 hours of determination by local law enforcement that student is missing 31

Missing Student Notification Required actions, within 24 hours of the determination that the student is missing Immediate referral of missing student report to authorities Notification of their parent or guardian, for students under 18 who are not emancipated Initiation of emergency contact procedures 32

Gainful Employment - Disclosures The Court left in place regulations at 34 CFR 668.6(b) requiring institutions to disclose certain information about each of their GE programs Regulations effective July 1, 2011 Institutions were required to update their GE program disclosures with information no later than January 31, 2013 See GE Electronic Announcement #42 posted to IFAP on November 23,

GE Program Disclosures Disclosure information must be on each GE program’s website home page and must Be simple and meaningful Contain direct links to any other webpage with general, academic or admission information about the program Be in an open format that can be retrieved, downloaded, indexed and searched by commonly-used web search applications Information must be disclosed for each and every GE program 34

GE Program Disclosures Same CIP code and credential level Guidance updated by GE Electronic Announcement #25 on September 28, 2011 Consider if separate disclosures will more accurately reflect program characteristics Factors to consider for separate disclosure Length of program Tuition and fees or other costs Offered in different states with different placement rate calculations, or different minimum requirements 35

GE Program Disclosures Disclose for each GE program Occupations (by name and SOC code) that program prepares students to enter, including links to O*NET occupational profiles Program costs Tuition and fees for completing program in normal time Typical costs for books and supplies Costs for room and board if applicable On-time completion rate 36

On-time Completion Rate Numerator is number of students in the award year who completed within normal time For clock-hour programs, normal time is the length of the program in days or weeks published in the catalog or other promotional materials. Denominator is all students who completed the program in the award year Leaves of absence are included when determining if a student completed within normal time 37

Job Placement Rates Disclose for each GE program Job placement rates for students completing the program Until release of ED formula for calculation, use formula that institutional accreditor or program accreditor or state requires Must be disclosed on a program-level basis, even if formula is for institutional level placement rates ED formula not yet developed See GE EA #31, December 22,

Median Loan Debt Disclose for each GE Program Median loan debt (Title IV and private loans separated) incurred by students who complete the program as provided by the Department Use school calculations of median debt until ED provides the information Report amount borrowed for Title IV and private loan debt Report amount owed under institutional financing plans 39

GE Program Disclosure Limitations If the number of students who completed a GE program in an award year is less than 10, do not disclose to public Median debt amounts (all types) On-time completion rate Must still disclose occupations for which the program prepares students, tuition and fees for normal time completion, and placement rates 40

Athletic Program Disclosures Equity in Athletics Disclosure Act (EADA) Applies to co-educational institutions that have intercollegiate athletic programs Current and prospective students must be provided a notice of their right to request such information If information is on a website, the notice must provide the exact electronic address, a brief description of the report, and a statement that the school will provide a paper copy Schools must prepare a report containing detailed information by October 15 each year 41

Annual Athletic Report The number of male and female full-time undergraduates enrolled Unduplicated head count of participants on at least one varsity team, by gender List of the varsity teams that competed in intercollegiate athletic competition, and for each team Total number of participants, number of participants who were on another varsity team, and the number of other varsity teams on which they participated Total operating expenses for each team Whether the head coach was male or female, full-time or part-time, and whether the coach was a full or part-time employee of the school 42

Annual Athletic Report Information for each varsity team (continued) Number of male and female assistant coaches, and the number of the them assigned to the team on a full or part-time basis Number of part-time assistant coaches who were full-time and part- time employees of the school Total amount and ratio of athletically-related student aid awarded to male athletes compare to female athletes Total annual revenues for men’s or women’s sports Separated by gender, and football (American) and basketball Total expenses for intercollegiate athletic activities Separated by gender, and football (American) and basketball 43

Athletic Program Definitions Intercollegiate athletic program Is a collegiate athletic program formally sponsored and managed by a school’s athletic department that involves student athletes formally competing against other school’s teams or athletes It does not include athletic contests between informal or “club” teams sponsored by student government or student activities offices Varsity team A varsity team is designated by its school or athletic association as a varsity team; or Primarily competes against other teams that are designated or defined by their schools or athletic associations as varsity teams 44

Resources Foreign School Assessments Consumer Information Consumer Information Disclosures At-A-Glance 34 CFR Subpart D FSA Handbook, Volume 2, Chapter 6 Program Participation Agreement 45

QUESTIONS? 46

Contact Information Foreign Schools Participation Division Phone: Fax: Byron Scott, Training Officer Phone;