1. Jessica Finkel and Cynthia Hammond | Dec. 2013 U.S. Department of Education 2013 FSA Training Conference for Financial Aid Professionals Gainful Employment Disclosures & Template Demonstration Session # 27

2. Today’s Agenda Status of Gainful Employment (GE) Regulations Which Programs are GE Programs Required Disclosures Disclosure Availability Disclosure Template Compliance Tips GE Resources 2

3. Status of GE Regulations Existing rules On 6/30/2012, the U.S. District Court upheld the Department’s authority to regulate on gainful employment but vacated most of the GE regulations The Court left in place the GE disclosure requirements 3

4. Status of GE Regulations Rule in production ED held negotiations to draft a new gainful employment rule in fall 2013 NPRM currently in development Final Rule to be published by November 1, 2014 Bottom line: The original disclosure requirements are still in effect Any future changes to the disclosures would be effective in July 2015 4

5. The HEA provides that to be Title IV eligible an educational program must be offered by: A public or non-profit postsecondary educational institution, if the program leads to a degree; or Any institution, if the program prepares students for “gainful employment in a recognized occupation” Which Programs are GE Programs 5 Generally, all non-degree programs must lead to gainful employment Generally, most programs at for-profit institutions must lead to gainful employment

6. Which Programs are GE Programs At proprietary institutions, all programs are GE Programs except for – Preparatory coursework necessary for enrollment in an eligible program Bachelor’s degree programs in liberal arts offered since January 2009 that are offered by a proprietary institution that has been regionally accredited since October 2007 6

7. Which Programs are GE Programs At public institutions and not-for-profit institutions, all programs are GE Programs except for – Programs that lead to a degree Programs of at least two years in length that are designed to be fully transferable to a bachelor’s degree program Preparatory coursework necessary for enrollment in an eligible program 7

8. Which Programs are GE Programs GE Programs include – Teacher certification programs leading to a certificate awarded by the institution ESL programs 8

9. Which Programs are GE Programs GE Programs do not include – Teacher certification coursework that does not lead to a certificate awarded by the institution Preparatory coursework necessary for enrollment in an eligible program (loans only) At public and private non-profit institutions, programs of at least two academic years that are designed to be fully transferrable to a bachelor’s degree program and do not lead to a credential awarded by the institution 9

10. Required Disclosures Outlined at 34 CFR §668.6(b)(1) Disclosures must be made for each GE program Disclosure items: Occupations Normal time to complete program On-time graduation rate for completers Tuition and fees, book and supplies, room and board Placement rate for completers (as determined by State or Accreditor methodology) Median loan debt Any other information the Secretary provided to the institution about that program 10

11. Required Disclosures Occupations – 34 CFR 668.6(b)(1)(i) Must list occupations by name and SOC codes that the GE program prepares students to enter Must link to occupational profiles on O*NET (http://online.onetcenter.org/crosswalk/)http://online.onetcenter.org/crosswalk/ Use a representative sample if >10 possible occupations See GE Electronic Announcement #25 11

12. Required Disclosures Normal Time Defined in regulation at 34 CFR 668.41(a) In weeks, months, or years Not 150% of normal time 12

13. BOX 1 Determine the number of students who completed the program in the most recently completed award year. BOX 2 Determine the number of the students in Box 1 that completed within normal time (668.41(a)) BOX 3 Divide: Box 2/Box 1 and multiply by 100 = On-time Graduation Rate Required Disclosures On-time graduation rate for completers – 34 CFR 668.6(b)(1)(ii) 13

14. Required Disclosures Example: On-time completion rate if 200 students completed in most recent award year 14 Total number of students who completed in the 2012-2013 AY Number of students who completed within normal time

15. Required Disclosures On-time graduation rate for completers includes: Leave of absence Time if a student withdrew and then returned Enrollment in other programs if the student did not complete the other program 15

16. Required Disclosures Educational costs – 34 CFR 668.6(b)(1)(iii) Tuition and fees charged for completing the program within normal time Typical costs for books and supplies Unless included in tuition and fees Room and board, if applicable Other expenses (such as living expenses or transportation) are optional But must link to/provide access to program cost information under 34 CFR 668.43 16

17. Required Disclosures Placement rates – 34 CFR 668.6(b)(1)(iv) For students who complete the program To be determined using NCES methodology, once available. Until then: Disclose/use accrediting agency and/or state rates or methodologies or If not required by an accrediting agency or state, then placement rate disclosure not required until NCES methodology is available 17

18. Required Disclosures Median loan debt – 34 CFR 668.6(b)(1)(v) Median (not mean) incurred by students who completed the program Must separate median loan debt Title IV, HEA program loans Private education loans Institutional financing plans 18

19. Required Disclosures Median loan debt categories: Title IV Debt - FFEL and Direct Loans do not include Perkins or Parent PLUS Private Loan Debt - Examples include, but are not limited to loans made expressly for educational expenses by: Financial institutions or credit unions Institutions of higher education or their affiliates States and localities Institutional Debt - the amount owed as of the day the student completed from the GE Program 19

20. Required Disclosures Any other information the Secretary provided to the institution about that program Disclosures updated by January 31, 2014 will not have anything new We will provide information and guidance if and when we require additional disclosures under this provision 20

21. Disclosure Availability Requirements outlined in 34 CFR 668.6(b)(2) Disclosures must be in promotional materials made available to prospective students Promotional materials include invitations, advertisements, or solicitations that mention or otherwise refer to a specific GE Program or Programs Includes course catalogs and social media May display the URL or provide a live link to the webpage where the required information is located, with a clear explanation of the information that is available at that webpage 21

22. Disclosure Availability Disclosures must be posted on institution’s website Prominent on program home page of relevant GE program Accessible via direct, prominent link from other institutional webpages about the program Prepared in an open format that can be easily searched by common web search applications Institutions must use template 22

23. Disclosure Template Released November 2013! Institutions must update their disclosures with the most recent information using the template by January 31, 2014

24. Disclosure Template What is the template? An application that creates a standardized webpage with the gainful employment disclosure information The application: 1. Collects data from an institution 2. Combines the institutional data with ED data 3. Creates a consistent, consumer-friendly webpage Similar to Net Price Calculator template, but GE template is required

25. Disclosure Template How did we develop the template? Reviewed regulatory requirements Developed mock screens Held focus groups with students for feedback on the output webpage Held focus groups with institutional representatives on data entry form for template Published a notice of proposed form in the Federal Register for public comment Developed the final online form and tool Tested the template Released the template November 2013 25

26. Disclosure Template For each GE program-- Step 1 - Institution enters information on the program into an online form: OPEID CIP Code Name of Program Credential Level SOC code 26

27. Disclosure Template OPEID 27

28. Disclosure Template Program CIP Program Name Credential Level SOC code(s) 28

29. Disclosure Template Step 2 - Institution enters cost data into the online form: Total tuition and required fees for the entire program Total estimated costs for books and supplies Room and board (if applicable) 29

30. Disclosure Template Costs 30

31. Disclosure Template Step 3 - Institution enters additional data into the online form: Median loan debt On-time graduation rate for completers Normal Time 31

32. Disclosure Template # of Completers Median Loan Debt 32

33. Disclosure Template Normal Time Number of On- Time Completers 33

34. Disclosure Template Step 4 - Institution enters job placement information into the online form: Calculated rate Entity requiring the rate Methodology 34

35. Disclosure Template 35

36. Methodology Rate Accreditor Name Disclosure Template 36

37. Methodology Rate State Name Disclosure Template 37

38. Disclosure Template Step 5 - After entering all the data for the program, institution selects “Create Disclosure Template” Application produces a ZIP file with html page that will be hosted on the institution’s website for that program Note: file upload option allows institutions to produce html pages for all programs at once – you don’t have to enter all data for each program manually! 38

39. Disclosure Template 39

40. Compliance Tips Who should I include in my calculations? Students who completed the program in the most recently completed award year Regular Students If a high school student is a “regular student,” then you should include that student If no SSN, do not include that student in disclosure calculations 40

41. Compliance Tips If fewer than 10 students completed a GE program during the award year, do not disclose: Median debt amounts On-time completion rate 41

42. Compliance Tips Regardless of the number of students who were enrolled in or completed the program (i.e., even if <10), disclose: The occupations (by names and SOC codes) that the program prepares completers to enter Normal time to complete the program Tuition/fees charged to complete the program in normal time Placement rates, if doing so aligns with the requirements of the accreditor or state on “small numbers” 42

43. Compliance Tips Electronic Announcement #25 - Disclosures by Educational Program Length of Programs Is there a significant difference in the published length of the programs? Tuition and Fees Is there a significant difference in the tuition, fees, or other costs for the programs? Programs Offered in Different States Are programs offered in different states that require different placement rate calculations and different minimum requirements? 43

44. GE Resources GE Information Page on IFAP - http://ifap.ed.gov/GainfulEmploymentInfo http://ifap.ed.gov/GainfulEmploymentInfo Regulations Dear Colleague Letters and Electronic Announcements FAQs Training Resources 44

45. GE Resources 45

46. GE Resources If you still have questions after reviewing the Dear Colleague Letter, Electronic Announcements, and FAQs, send your questions to GE-Questions@ed.govGE-Questions@ed.gov 46

47. Contact Information Jessica Finkel, Office of Postsecondary Education Phone: 202-502-7647 E-mail: Jessica.Finkel@ed.govJessica.Finkel@ed.gov Cynthia Hammond, Federal Student Aid Phone: 202-377-4236 E-mail: Cynthia.Hammond@ed.govCynthia.Hammond@ed.gov 47