ACCET Conference 2015 Federal Updates for Vocational Institutions

Presenters Steve Gunderson, President /CEO APSCU Sally Samuels, Director of Compliance FAME 2

LOGO Sec (b)(1 )(ii), pg Notice and Authorizations Requires all credit balances for students/parents to be paid prior to requesting funds 5/18/15 NPRM-Possible Impact Proposed change makes no distinction between HCM1 & HCM 2 Issue-cash flow problem for all schools 3

The proposed Reg would eliminate requiring a program that could be credit hour per the state & accrediting agency to have to be clock hour Also eliminates the requirement that the hours associated with the credits must be completed Impact-better for our schools & students Clock to Credit Conversion (669.8 (k)(1) 4

Repeat Course Work The change would allow a student in an integrated curriculum (such as Nursing) to repeat a passed course, only once, when repeating a failed course in the same term Positive impact on SAP for all institutions with integrated programs 5

Third Party Servicers Validate student eligibility before initial disbursement of Title IV funds Validate student’s eligibility before receiving each subsequent disbursement SAP Attendance Perform R2T4 refund calculations Impact-Requires more monitoring by 3 rd party servicers 6

Reinstates ATB as alternative Student must be enrolled in an eligible career pathway program, 225 hours or 6 credit Transitions the student from an adult ED program to post secondary education and training, to employment Career Pathways (CPP) Must be a separate program 7

CPP (cont) 8

LOGO Consumer Information Issues 9

Missing GE information or links on program information page; catalog, student handbooks, flyers Program length includes break time or allowable absent hour time Not using required template/ information not updated Institutional debt as of LDA not included GE Disclosures 10

Institutions use a different measurement that a payment period (end of mod not midpoint of AY) Drop/ re-enroll handled incorrectly especially for clock hour/credit hour programs Policy worded incorrectly, financial aid warning & probation Satisfactory Academic Progress 11

Incorrect scheduled days or clock hours used Title IV funds received after LDA must be funds that could have been disbursed Unofficial withdrawals- attendance taking institutions must use a DOD of no more than 14 days after LDA Incorrect rounding, calculate to 4 decimals, round down to 3 decimals Return of Title IV Funds 12

Step 5- incorrect; if charging by a longer period than used for the R2T4 calculation; use the larger of Title IV received or prorated institutional cost in L Credit balances must be returned within 14 days of the date the R2T4 calculation is completed Returns are due 45 days from the DOD unless the state or accrediting agency requires a shorter time frame Return of Title IV Funds 13

Prepared for ACCET Conference October 27, 2015 Steve Gunderson President and CEO APSCU Federal Updates for Vocational Institutions

HEA Reauthorization 15 Our GOAL in this Congress!

“Defense to Repayment” Negotiated Rulemaking – Begins January 2016 Another Negotiated Rulemaking??? Higher Education community & Congress feel this should be addressed in HEA Reauthorization! 16 Another example of regulatory overreach

The Agenda is Full 17

The current Debt Ceiling is set at $ trillion Debt Ceiling Current Speaker John Boehner (R-OH) will try to move a debt ceiling bill before he retires from Congress 18 The United States Debt Ceiling must be increased by November 5, 2015

CR until December 11 th Goal: Omnibus Appropriations bill for rest of FY16 Our language: Delay GE and other rules until Reauthorization! Omnibus Funding Bill 19

HEA Roadblock 20 NCLB: Standing in the Way!

HEA Reauthorization 21

Key Issues 22 APSCU GE Market/ Ads Outcomes90/10

Simplicity (The same for everyone! One grant, one loan?) Accountability (Appropriate protections applied to all institutions!) Transparency (User Friendly!) APSCU Priorities: SAT! 23

Common Metrics for all! Replace Burdensome Regulations! Risk-based metrics! APSCU Priorities: Fairness! 24

APSCU Priorities: Student Aid 25

Simplify repayment options! Constant annual loan limits! Give Institutions authority to limit loans to education costs! APSCU Priorities: Student Loans 26

HEA Reauthorization 27 Senator Alexander at our Workforce Symposium:  Simplified Financial Aid Application  Restore Year-round Pell  One Grant/ One Loan  Remove the Regulations! (all 59!)  Accreditation for the Future  Discourage Over-borrowing  “Skin-in-the-Game”

Accreditation Concepts & Proposals Consumer Information & Transparency “Skin-in-the-Game” Senator Alexander Releases 3 White Papers 28

29 The Road Ahead!  Committees Report  Hill Day: March 15/16, 2016  House & Senate Consideration  Conference Report  “Happy New Year!”