Consumer Information & Disclosures Presentation To | Webinar Wednesday

What must be disclosed?

What must be disclosed General disclosures –Institutional information –Financial aid information –Family Educational Rights & Privacy Act (FERPA) 34 CFR 99.7 –Student-Right-To-Know Act (educational outcomes) Retention, completion, graduation, and transfer out rates Placement and types of employment of graduates Types of graduate/professional programs in which graduates from 4-year programs enroll

What must be disclosed Athletic disclosures –Equity In Athletics Disclosure Act (EADA) Drug and alcohol abuse prevention –34 CFR Security and safety disclosures –Campus security (Cleary Act) Hate crimes –Fire safety –Missing student notification policy –Emergency notification –Emergency response and evacuation

Campus crime and fire safety Annual reports published and distributed to students and employees by October 1 Distribution through publications and mailings –Direct mailing via USPS, campus mail or –Publications provided to each individual –Posting on the website

What must be disclosed Vaccination policy Student body diversity –Schools must disclose the percentage of enrolled, full-time students in the following categories : Male Female Pell Grant recipients Self-identified members of a racial/ethnic group Plans for improving academic programs

What must be disclosed Voter registration information –Program Participation Agreements (PPA) –Schools must make a good faith effort to distribute voter registration forms to students and make voter registration forms widely available Satisfied by sending an with state’s voter registration form or Internet address to the form Message exclusively about voter registration

What must be disclosed Textbook information –Pricing information posted on online course schedule –GEN Copyright policies and sanctions –Peer-to-peer file sharing –A sample statement and other copyright requirements are included in GEN-10-08

What must be disclosed Provisions for books and supplies for Pell eligible students –Under certain conditions, Pell eligible students must be able to obtain or purchase, by the 7 th day of a payment period, their required books and supplies Transfer of credit policies –Disclose current transfer of credit policies –Disclose school with which there is an articulation agreement Program Integrity Final Rule

What must be disclosed FSA loan disclosures –Financial assistance information Terms and conditions of FSA loans –Student loan information published by ED –Entrance and exit loan counseling Student loan publications available for order at

What must be disclosed Private student loan disclosures –Preferred Lender Arrangements (PLA) –Information on private loans: Provide prospective borrower with TILA disclosures Inform borrowers of possible eligibility for FSA loans and that FSA loan terms may be more favorable –Private loan disclosures must be presented in manner distinct from FSA loan information –Provide information needed for student to complete the self-certification form

What must be disclosed Code of Conduct –Required under Program Participation Agreement (PPA) Schools must : –Develop a code –Publish prominently on institution’s website –Administer and enforce such code –Annually inform the institution’s officers, employees, and agents of code requirements Additional requirements for Preferred Lender Arrangements (PLAs)

What must be disclosed Net price calculator –Schools must post a net price calculator on their websites by October 29, 2011 ED’s template published October 29, culator.asphttp://nces.ed.gov/ipeds/resource/net_price_cal culator.asp –May use ED’s calculator, develop own, or contract with a third party –Include “at a minimum the same data elements” found in ED’s template

What must be disclosed Teacher preparation program report –Required for schools that prepare teachers for initial state certification or licensure –Report annually to state and public –Refer to GEN for specific reporting requirements

What must be disclosed Information on written arrangements to provide educational programs must be made available to enrolled and prospective students –Written arrangements: Between eligible institutions, For study-abroad, and Between an eligible institution and an ineligible institution Program Integrity Final Rule

What must be disclosed Gainful employment information –Program Integrity Regulations Information webpage – Regulations Dear Colleague Letters and Electronic Announcements FAQs Available training Additional resources

What must be disclosed Constitution and Citizenship Day –A Constitution Day program must be conducted on September 17 –Not in the Title IV regulations –Additional information and resources

How must it be disclosed?

How it must be disclosed Annual direct notice to all enrolled students regarding the availability of consumer information –General disclosures (presented on slide 3) –FERPA –Athletic disclosures (if applicable) –Annual security and fire safety reports –Athletic program participation rates and financial support data

How it must be disclosed Annual direct notice must include a brief description of consumer information and how to access more details –If provided on a website, disclose exact address for accessing the details, and –Include a statement that the institution will provide a paper copy of the information on request

How it must be disclosed Disclosure through websites –A school may post information that must be disclosed to the school websites For enrolled students or current employees –Internet or an intranet website For prospective students or employees –Internet website

Who should disseminate?

Who should disseminate Each school must have at least one individual who is available full-time to disseminate consumer information –May have multiple employees designated to meet full-time availability requirement ED may waive the requirement if enrollment is too small to necessitate full-time availability

What are the related program review findings?

Program review findings Consumer information requirements not met –Policies not developed –Policies not provided to students Examples: –SAP –R2T4 –New HEOA consumer information requirements not implemented

Program review findings Crime awareness requirements not met –Policies did not contain all required elements –Inadequate distribution of statistics and policies –Failure to report statistics on website or crimes reported in wrong category

Program review findings Misrepresentation in school publications –False information and unsubstantiated claims –Incorrect information about: Educational programs, and Transferability of credits

Penalties for misrepresentation FSA eligibility may be: –Limited –Suspended, or –Terminated Civil fines may be imposed –Up to $25,000 per violation or misrepresentation

What other resources are available?

Available resources Federal Student Aid Handbook –Volume 2: School Eligibility and Operation Chapter 6: Providing Consumer Information Chapter 8: Campus Safety, Reports & Other Requirements –Information on safety report contents –Sample statement of report availability »For combined security and fire report

Available resources 2011 FSA Conference Presentations –Student Loan Consumerism –Partnering for Compliance and Consumer Protection Available at: – onference.htmlhttp://ifap.ed.gov/presentations/2010FSAC onference.html

Available resources Additional Campus Crime and Fire Safety resource – The Handbook for Campus Safety and Security Reporting –Accompanying online tutorial Campus Safety and Security Reporting Training

34 Campus security website

Available resources Additional Campus Crime and Fire Safety resources –Campus crime and fire safety statistics –Crime statistics

Available resources FERPA resources –Family Policy Compliance Office (FPCO) webpage Regulations Sample notification – a/ps-officials.htmlhttp://www2.ed.gov/policy/gen/guid/fpco/ferp a/ps-officials.html –MSWord version available –Consumer Information Assessment Module Activity 6

38 Available resources Information Required to be Disclosed Under the Higher Education Act of 1965 Available at:

Available resources FSA Assessment Modules –Designed to assist schools in evaluating financial aid policies, processes and procedures

FSA Assessment Modules

Consumer Information Disclosures At-A-Glance

Our Own Disclosure! Nelnet is glad help schools access all the information needed to make their jobs easier and to best help students. We cannot offer opinion or interpretation of FSA policies in all circumstances. If you have specific questions about the your programs and procedures, please contact FSA directly.

Questions? Dana Kelly Regional Director and Trainer