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Risk Sharing and Accountability
Core Concern Colleges and universities do not have enough “skin in the game” leaving tax payers to foot the bill for defaulted loans. Replace cohort default rate with loan repayment rate Calculated by program of study Tighten rules on “earned aid” under R2T4 for withdrawn students, so schools bear more of the cost Require schools to repay ED for some portion of defaulted loans
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Return of Title IV Funds
Be Careful What You Ask for in Simplifying Return of Title IV Funds Aid earned by quarter of term School returns unearned aid based on total disbursed, regardless of credit balance refunds School may only recover 10% of amount returned from student If student completes at least one modular course in term, not treated as withdrawal
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In the Agencies
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Administration Still Staffing Up
Department of Education 4 confirmed 6 nominations pending 5 no nomination yet Undersecretary Assistant Secretary for Postsecondary Education
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Do Overs at ED Title IX Sexual assault Gainful employment Borrower defense to repayment Direct loan servicing
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State Authorization for Distance Education
Institution offering distance education must: Be authorized in each state in which it enrolls students if state requires authorization Document state process for resolving student complaints Provide disclosures for programs offered solely through distance education State reciprocity agreements (SARA) (but confusingly…) Effective July 1, 2018
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State Authorization for Foreign Locations
Additional location/branch campus outside U.S. Must be authorized by “appropriate government agency” in host country If at least half of an educational program is offered, it must be Approved by institution’s accrediting agency Reported to the state where the institution’s main campus is located Effective July 1, 2018
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myStudentAid Mobile App to Facilitate…
Choosing a school Understanding aid options Applying for aid Receiving aid Managing loan account Making payments on loans Resolving issues And more…
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myMoney Solicitation for pilot coming soon Integral “payment vehicle”
No fees to student or school Available to anyone who completes FAFSA Functions as bank account, including check writing capability Schools would load credit balances to account Funds could come from family or other sources as well Possible warnings, controls, rewards, etc.
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