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Federal Update April 2016
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Administration Priorities
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Administration Priorities
President’s 2020 Goal: By 2020, America will once again have the highest proportion of college graduates in the world. Themes: Increasing access Making college more affordable Improving outcomes
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Access
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Access: First Lady’s Reach Higher Initiative
Exposing students to college/career opportunities – encourage students to reach for the best college they can attend Encouraging academic planning and summer learning Understanding financial aid Supporting high school counselors
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Access: FAFSA Promoting FAFSA Completion FAFSA Simplification
Early FAFSA Prior-Prior Year
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Access: Experimental Sites
Second Chance Pell Pilot Program Waivers to allow incarcerated individuals to receive Pell Grants for postsecondary education Dual Enrollment Waivers to allow students who are enrolled in high school to receive Pell Grants for enrollment in Title IV-eligible postsecondary programs
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Affordability
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Affordability: Front End Strategies
America’s College Promise Increase in Pell Grant funding First in the World (FITW) Competency-Based Learning Educational Quality Through Innovative Partnerships (EQUIP)
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Affordability: America’s College Promise
Proposal would make two years of college free and universal Students would be able to secure an associate’s degree or certificate, earn the first half of a bachelor’s degree, and gain skills needed in the workforce at no cost
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Affordability: First in the World
Discretionary grant program designed to spur innovation to drive down costs while maintaining quality Program focuses on students most likely not to persist and graduate Tests and evaluates practices for cost effectiveness, maintains quality, and facilitates replication
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Affordability: Experimental Sites
Competency-Based Learning Creates flexibility by allowing students to progress as they demonstrate mastery of content Educational Quality Through Innovative Partnerships (EQUIP) Accelerates and evaluates partnerships with non-traditional providers
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Affordability: Back End Strategies
Student Aid Bill of Rights Income-Driven Repayment Plans Pay As You Earn (PAYE) Revised Pay As You Earn (REPAYE)
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Affordability: Student Aid Bill of Rights
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Affordability: REPAYE Regulations
Negotiations held February - April, consensus reached on a Revised Pay As You Earn repayment plan (REPAYE) that extends the 10 percent income cap to all borrowers regardless of when they borrowed Published final regulations October 30, 2015 Early implementation in December 2015
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Affordability: Student Aid Bill of Rights
Protects Social Security benefits of borrowers with disabilities who may qualify for a loan discharge or other repayment options Ensures that the debt collection process for defaulted Federal student loans is fair, transparent, and reasonable (compensation of collection agencies, guidance provided to collection agencies, ensuring accurate information provided)
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Outcomes
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Outcomes College Scorecard
Accreditation Executive Actions and Legislative Proposals Gainful Employment Regulations Consumer protections and information Debt to earnings ratios
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Outcomes: College Scorecard
Interactive tool – new data recently added Highlights key indicators about institutions’ costs and value Helps students and families decide where to enroll for postsecondary education Allows comparison of schools based on simple criteria
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Outcomes: College Scorecard
Scorecard data include: Costs Graduation Rates Loan Default Rates Loan Repayment Rates Average Amount Borrowed Employment Earnings
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Outcomes: Accreditation
Executive actions and a legislative proposal designed to: Increase transparency in the accreditation process Increase coordination within the Department and among accreditors to improve institutional oversight Encourage greater attention to outcomes within current accreditor review processes
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FY 2017 Budget
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FY 2017 President’s Budget Pell Grant Program
Higher award amount for more than 12 credits per term Summer Pell for students who complete at least 24 credits in regular academic year
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Early FAFSA Prior – Prior
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Prior-Prior and Early FAFSA
Outreach Toolkit Posted to IFAP Professional Judgment More Expected Pell schedules and campus-based awards
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Prior-Prior and Early FAFSA
Verification Use of DRT Will Reduce Selection for Verification Documentation of income/taxes from can be used for Eliminating Tracking Group V6 (Low Income)
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Prior-Prior and Early FAFSA
Conflicting Information Occurrences reduced if DRT used for both and FOTW warnings if reporting income/taxes not equal to reported amounts
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Prior-Prior and Early FAFSA
Conflicting Information – The CPS Will – Perform an automatic review to determine if there might be conflicting information between the two FAFSAs Flag for institutional resolution only those ISIRs where the potential conflict, once resolved, would have a significant impact on the student’s EFC.
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Perkins Loan Program (DCL GEN-16-05)
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Perkins Loan Program Federal Perkins Loan Program Extension Act of 2015. Extends program through September 30, 2017 Eliminates the Perkins Loan five-year grandfathering provisions Places requirements on the eligibility for undergraduates to receive a loan
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Perkins Loan Program Federal Perkins Loan Program Extension Act of 2015. Effectively eliminates the eligibility for graduate students to receive Perkins Loans. Requires school disclosures Requires return of federal share of revolving fund after October 1, 2017
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Regulatory Update
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Borrower Defenses
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Borrower Defenses to Repayment
Negotiation sessions: Session 1: January 12-14, 2016 Session 2: February 17-19, 2016 Session 3: March 16-18, 2016 Expect to publish proposed rules this summer Expect to publish final rules by November 1, 2016
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Borrower Defenses to Repayment
Issues discussed Procedures for borrower to establish a defense to repayment Criteria to identify acts or omissions of an institution that constitute defenses to repayment Standards and procedures that ED will use to determine school liability from borrower defenses
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Direct Loan REPAYE Payment Plan
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REPAYE Regulations Negotiations held February - April, consensus reached on a Revised Pay As You Earn repayment plan (REPAYE) that extends the 10 percent income cap to all borrowers regardless of when they borrowed Published final regulations October 30, 2015 Implemented on December 17, 2015
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REPAYE Regulations Extends 10% of income repayment cap to all borrowers regardless of when they borrowed Repayment period = 20 years for undergraduate loans and 25 years if graduate loans included PAYE still available; not a replacement plan
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Program Integrity Cash Management
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Cash Management Regulations
October 30, 2015: Final regulations published July 1, 2016: Regulations effective Ensure that students receiving Title IV, HEA funds: Have convenient access to their funds Do not incur unreasonable financial account fees Are not led to believe they must open a particular financial account to receive their funds 40
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Debit Card Provisions: Who is covered?
Tier 1 (T1) Arrangement U.S. school with third-party servicer; and Servicer processes Title IV aid; and Aid disbursed to contracted account or; Information about contracted account is provided to student Tier 2 (T2) Arrangement U.S. school that has a contract with provider; and Provider is not a third-party servicer; and One or more Title IV credit balance recipient; and Product is marketed to students through school communication, student IDs, or cobranded cards
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Debit Card Provisions: Overview
All T1 and T2 Student choice menu No automatic opening of accounts Privacy restrictions Contract disclosure All T1 ATM network Fee restrictions Contracts negotiated in best interest of students Average student cost disclosure T2 (more than de minimis) Fee-free ATM
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Correct and Timely Reporting
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Correct and Timely Reporting
COD – Program information NSLDS – Enrollment, including academic program GE Reporting CPS – Professional Judgement Results of V4 and V5 Verification
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Protecting Student Information
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Protecting Student Information
Under various Federal and state laws and other authorities, including the HEA; FERPA; the Privacy Act of 1974; the Gramm-Leach-Bliley Act; state data breach and privacy laws; institutions may be responsible for losses, fines and penalties (including criminal penalties) caused by data breaches.
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Protecting Student Information
Dear Colleague Letter GEN-15-18 Reminds institutions (and their third-party servicers) of their continuing obligations to protect data used in all aspects of the administration of the Title IV Federal student financial aid programs.
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Protecting Student Information
The SAIG Enrollment Agreement includes a provision that the institution – Must ensure that all Federal Student Aid applicant information is protected from access by or disclosure to unauthorized personnel.
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Gainful Employment See DCL GEN-15-12
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The HEA provides that to be Title IV eligible an educational program must:
Be offered by a public or non-profit institution and leads to a degree; or Prepare students for gainful employment in a recognized occupation.
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Which Programs are GE Programs?
At public institutions and non-profit institutions, all non-degree programs are GE Programs except - Programs of at least two years in length that are designed to be fully transferable to a bachelor’s degree program, and Preparatory coursework necessary for enrollment in an eligible program
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GE Program Certifications
Each GE Program is: Approved by accrediting agency and State. Is programmatically accredited if that is required for that profession in the state. Graduates qualify to meet licensing or certification exam requirements to work in the state, if any.
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Gainful Employment Disclosures
Beginning in 2017, in addition to program information required disclosures could include: D/E rates Program cohort default rates Loan repayment rates Median loan debt Percent borrowing
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Gainful Employment Disclosures
Beginning in 2017, in addition to program information required disclosures could include: Completion rates Withdrawal rates Placement rates
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Experimental Sites
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Experimental Sites Current – Pell for short-term career programs
Pell for students with a bachelors degree Reduced Unsubsidized Loans
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Experimental Sites New – FWS for High School Tutors
Prior Learning Assessments Competency Based Education Limited Direct Assessment
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Experimental Sites Coming – Expanded Competency Based Education
“Second Chance Pell” for incarcerated students Dual Enrollment – High school and postsecondary Loan Counseling
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Thank You
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