1. S ESSION T ITLE I T ’ S T IME TO L IGHT THE L IGHTS 2016 ILASFAA A NNUAL C ONFERENCE A PRIL 6 – 8, 2016, H ILTON, L ISLE, IL Consumer Reporting Requirements 2016 ILASFAA A NNUAL C ONFERENCE A PRIL 6 – 8, 2016, H ILTON, L ISLE, IL

2. Consumer Reporting Requirements It is a Campus Wide Endeavor and an Institutional Responsibility (FAA should not be flying solo)

3. The Goal of this Session Identify where to find the regulations Help you identify key stakeholders on your campus and who needs to be involved Discuss how to compile your campus team Discuss ideas on how to provide documentation, resources and training to team Discuss ideas to plan the implementation, review and updates of policy, procedure and/or written materials

4. Consumer information HEA Sec. 485(f); 20 USC 1092 Regulations: 34 CFR 668.41–49 Notice to enrolled students: 34 CFR 668.41(c) Web dissemination: 34 CFR 668.41(b), (c)(2), (e)(2) through (4), and (g)(1)(ii) Availability of school staff: 34 CFR 668.44

5. General disclosures General disclosures: 34 CFR 668.41(d) Financial assistance: 34 CFR 668.42 Institutional information: 34 CFR 668.43 Completion/graduation rates: 34 CFR 668.45 Definitions: 34 CFR 668.41(a) and 668.47(b

6. IFAP Resource Web Page: http://www.ifap.ed.gov/qahome/fsaassessment. html FSA Assessments http://www.ifap.ed.gov/qahome/fsaassessment. html Schools Student Eligibility Satisfactory Academic Progress Verification A Guide to Creating a Policies and Procedures Manual Automation Consumer Information Default Prevention & Management Fiscal Management Institutional Eligibility Return of Title IV Funds

7. Where to find the Reg

8. Additional Links: 2015-2016 FSA Handbook, School Eligibility & Operations, Chapter 6;2015-2016 FSA Handbook, School Eligibility & Operations, Chapter 6 2015-2016 FSA Handbook, School Eligibility & Operations, Chapter 7; Campus Security ResourcesCampus Security Resources; Online Training Module, Consumer Information – DCL ANN-14-15Online Training Module, Consumer Information – DCL ANN-14-15; DCL GEN-14-13 (Changes to the Clery Act by the Violence Against Women Reauthorization Act of 2013); DCL GEN-15-15 Implementation of the VAWA Final RegulationsDCL GEN-14-13 (Changes to the Clery Act by the Violence Against Women Reauthorization Act of 2013)DCL GEN-15-15 Implementation of the VAWA Final Regulations

9. Review and Plan The eleven activities listed for review should help you in deciding who else on campus needs to be involved in assuring your campus is in compliance. You will see that a variety of staff will be needed to design, disclose, disseminate, review and update information on at least an annual basis. You, as an FAA, should emphasize to the Campus stakeholders that this is not an “FA Reg” it is school compliance issue and requires campus participation

10. What if we do not comply? Civil penalty In addition to limiting, suspending, or terminating the participation of any school that fails to comply with the consumer information requirements, the Department may impose civil fines of up to $27,500 for each violation. Civil penalty,Sec. 487(c)(3)(B) of the HEA

11. Key to Compliance Publications that are “easily” available to students (prospective and current), staff and the community at large Publications that are accurate and reflect current data, policies and procedures Campus wide “knowledge” of Consumer Information regulations and where data can be found Identify responsible parties who must provide data and “publish” data annually

12. Where to find it in the FSA handbook

14. Ch 6 in the 2012/13 FSA Handbook

15. CHAPTER 6 HIGHLIGHTS Availability of information General student disclosures Disclosures and gainful employment Campus crime and safety information Information about athletics Textbook information Loan counseling Drug & alcohol abuse prevention Misrepresentation Information about private loans Provide Chapter 6 to Your Consumer Reporting Team

16. Resource Concerning “Best Practice” for Dissemination Suggestions for disseminating HEA-required information The National Postsecondary Education Cooperative (NPEC) has issued a publication entitled Information Required to Be Disclosed Under the Higher Education Act of 1965: Suggestions for Dissemination. (NPEC 2010-831), prepared by Carol Fuller and Carlo Salerno, Coffey Consulting. This publication is available at: http://nces.ed.gov Note: NPEC was established by the National Center for Education Statistics (NCES) in 1995 as a voluntary organization comprising federal agencies, postsecondary schools, associations, and others with an interest in postsecondary education data collection. The information and opinions in NPEC publications do not necessarily represent the policy or views of the U.S. Department of Education or NCES.

17. Team Members/Resources Your President/Chancellor/CEO(the Headcheese) Your Student Services Administrators Campus Security/Local Police/Housing Office School Health Department/Nurse Human Resources Business Office staff (Bursars/Cashier) IT/Accountability Office (for Data, Data Integrity and Safety issues, Web Postings) Library and Graphic/Printing Dept. Staff Athletic Directors/Staff Registrar/Academic Counseling Staff Financial Aid Administrators/Staff Student Government/Faculty lead Recruiting/Marketing Administrators/Staff Bookstore Administrators/Faculty/Deans

18. Why these People? All have a role to play in getting the data compiled, ensuring it is available for review and that it is accurate and kept current. Compliance is a school responsibility. You play a lead role (and have the biggest headache) to ensure they all do what is needed in a timely manner and that your school is in compliance. This does not mean you have the responsibility of compiling the data, fact checking the data and dissemination of reports.

19. What if they do not want to be a Team member or do not see their “role”? Be sure you are providing information that explains the regulation and what must be disclosed. Emphasis pertinent sections to those responsible for that function. Try not to overwhelm but do be sure they have the “Big Picture” Provide the data of how many students receive Title IV aid and the dollars involved and then emphasis the consequences for all if these resources would end due to noncompliance If all else fails report to your supervisor “issues” you have and that you need assistance

20. Helpful Hints Use your Web pages to disseminate reporting requirements. Review as if you are a “new” student. Can you find the data? Have a “Master Calendar” that all Team members can access (Google Calendar and Documents is handy) and provide reminders when data needs updated and/or deadlines for Fed Reporting Subscribe to IFAP to remain current on Consumer Reporting issues and forward pertinent data to Team members Use the CR Activity Pages to “grade” your progress and compliance, review annually

21. Campus “Buy In” You, in a lead role, must portray a positive attitude about the Reg. Consumers do have a right to know what they are (or may be) “purchasing”. We should be accountable to the student for safety issues, honest disclosers of programs, degree completions and career opportunities as well as an accurate picture of the price for their education at our school and overall the way we do “business”. With a positive attitude that our campus has nothing to hide, and that we are high quality and our data supports this disclosing this information to our “customers” should be welcomed.

22. Also a Part of Consumer Information The Shopping Sheet DoE Rational: Students should not have to wait until graduation to find out the size of their monthly loan payment, Families should have a clear and comparable instrument to “shop”. (Ad Lib from Ed. Sec. Arne Duncan at http://www2.ed.gov/policy/highered/guid/secletter/120724.htmlhttp://www2.ed.gov/policy/highered/guid/secletter/120724.html) Current info: Schools are encouraged to have in place by the 2013/14 Award Year (as early as March 2013 for some schools?) See GEN-12-12 and GEN 12-17 Implementation by this date supports Exec Order 13607 for Federal Veteran’s Ed Benefits

25. Net Price Calculator Signed into law on August 14, 2008Higher Education Opportunity Act (HEOA) Requirement All institutions must have a net price calculator posted on their websites by October 29, 2011 An institution may either use the Department’s Net Price Calculator template or it may develop its own but institutionally developed calculators must include “at a minimum the same data elements” found in the Department’s Net Price Calculator template Purpose “to help current and prospective students, families, and other consumers estimate the individual net price of an institution of higher education for a student. The calculator shall be developed in a manner that enables current and prospective students, families, and consumers to determine an estimate of a current or prospective student’s individual net price at a particular institution.” - P.L. 110-315, sec. 132 (h) (1).

26. Comments? Thank you. Janet Ingargiola, Director Student Financial Aid and Veteran’s Educational Benefits Danville Area Community College 2000 E. Main Street, Danville, Il 61832 Jingarg@dacc.ed u