1. Disclosure Requirements and Consumer Information David Racculia PHEAA Compliance Services 1

2.  Why Regulate Consumer Information?  Provides consistency and uniformity to the information made available by institutions of higher education  Helps prospective students effectively compare these institutions  Informs students and families of their rights under the law 2

3.  Higher Education Act of 1965 (HEA)  Higher Education Opportunity Act of 2008 (HEOA) 3

4.  Requirements come in two basic types:  Disclosure Requirements Information that a school must distribute or make available to others  Reporting Requirements Information that must be provided to the U.S. Department of Education or other agencies 4

5.  Evaluate  Coordinate  Monitor 5

6. So what is required anyway? 6

7. NameRecipientMethodFrequency A Notice of Institutional and Financial Aid Information Enrolled studentsWritten noticeAnnually Contact Information for Individuals Who Can Assist in Obtaining Institutional or Financial Aid Data Prospective and enrolled students Publications, mailings, or electronic media Ensure availability Financial Aid Information Prospective and enrolled students Publications, mailings, or electronic media Ensure availability Notice of Federal Financial Aid Penalties for Drug Law Violations Each student upon enrollment Via conspicuous written notice Upon enrollment 7

8. NameRecipientMethodFrequency Family Educational Rights and Privacy Act (FERPA) All enrolled students A written or electronic method most likely to inform students of their rights Annually Certain Consumer Information for College Navigator Website Prospective and enrolled students and the general public Disclosure information must be posted on the Institution’s website ---- The institution’s web address (URL) as reported through IPEDS Ensure availability 8

9. NameRecipientMethodFrequency Diversity of the Student Body Prospective and enrolled students Publications, mailings, or electronic media Ensure availability Cost of Attendance Prospective and enrolled students Publications, mailings, or electronic media Ensure availability Net Price Calculator Prospective and enrolled students, and the general public Posted on the Institution’s website Must be posted to the institution’s website by October 29, 2011 Policies Regarding Withdrawal, Institutional Refund, and the Return of Title IV Funds Prospective and enrolled students Publications, mailings, or electronic media Ensure availability 9

10. NameRecipientMethodFrequency Textbook Information Currently enrolled students ---- Affiliated college bookstores For students – via the institution’s Internet or written course schedule as appropriate ---- Written notice to college bookstores For students: updated with internet or written course schedule as appropriate ---- College bookstores: as soon as practicable once changes occur and upon the request of the bookstore Description of Academic Programs Prospective and enrolled students Publications, mailings, or electronic media Ensure availability 10

11. NameRecipientMethodFrequency Accreditation, Approval, or Licensure for the Institution and its Programs Prospective and enrolled students Publications, mailings, or electronic media Ensure availability Policies and Sanctions Regarding Copyright Infringement (Including Computer Use and File Sharing) Prospective and enrolled students Publications, mailings, or electronic media Annually Teacher Preparation Program Report - State governments - Prospective and enrolled students and the general public To the state via the method required by that state, and to the general public via the institution’s website Annually by April of each year 11

12. NameRecipientMethodFrequency Policies Regarding Transfer of Credit and Articulation Agreements Prospective and enrolled students and the general public Publications, mailings, or electronic media Ensure availability Drug and Alcohol Abuse Prevention Program Enrolled students and employees Written publications that are sent directly to each student and employee Annually Annual Security Report (Emergency Response and Evacuation Procedures, Timely Warnings, and Crime Log) All currently enrolled students and all employees by Oct. 1 of each year ---- To any prospective student or employee upon request Publications, mailings, or electronic media Annually (by October 1) 12

13. NameRecipientMethodFrequency Vaccinations Policy Prospective and enrolled students Publications, mailings, or electronic media Ensure availability Fire Safety Report and Fire Log All currently enrolled students and employees by Oct. 1 of each year ---- To any prospective student or employee upon request Publications, mailings, or electronic media ---- May be included within the Annual Security Report Annually (by October 1) Information for Crime Victims about Disciplinary Proceedings The alleged victim of any crime of violence or a nonforcible sex offense (or next of kin if deceased) In writing Upon written request of the victim (or next of kin if deceased) 13

14. NameRecipientMethodFrequency Retention Rates Prospective and enrolled students Publications, mailings, or electronic media Ensure availability Completion, Graduation, and Transfer-out Rates Prospective and enrolled students Publications, mailings, or electronic media Annually (by July 1) Completion, Graduation, and Transfer-out Rates for Students Receiving Athletically Related Student Aid Prospective and enrolled students receiving athletically related student aid Publications, mailings, or electronic media Annually (by July 1) Placement in Employment Prospective and enrolled students Publications, mailings, or electronic media Ensure availability 14

15. NameRecipientMethodFrequency Job Placement Rates Prospective students Written notice At or before the time the prospective student applies for enrollment Types of Graduate and Professional Education in which the Institution's Graduates Enroll Prospective and enrolled students Publications, mailings, or electronic media Ensure availability Intercollegiate Athletic Program Participation Rates and Financial Support Data Prospective and enrolled students attending a co-educational institution that has an intercollegiate athletic program Publications, mailings, or electronic media Annually (by October 15) 15

16. NameRecipientMethodFrequency Voter Registration Forms Each student enrolled in a degree or certificate program and physically in attendance at the institution Direct distribution of voter registration form --OR-- An electronic message that includes either an electronic copy of the form, or the web address (URL) where the form can be found Annually (Within 120 days of the deadline for voter registration in that state) Student Loan Information Published by the U.S. Department of Education All prospective student borrowers Publications, mailings, or electronic media Ensure availability 16

17. NameRecipientMethodFrequency State Grant Aid All enrolled student borrowers Publications, mailings, or electronic media Annually (in sufficient time for the student to meet any applicable State Grant application deadline) Information Regarding the National Student Loan Data System (NSLDS) Prospective borrowers, borrowers, and parent borrowers Written notification At or before the origination of the loan 17

18. NameRecipientMethodFrequency Entrance Counseling for Student Loan Borrowers All student borrowers Conducted in person, by audiovisual presentation, or by interactive electronic means Before the first disbursement of a loan is made for a first time student borrower Exit Counseling for Student Loan Borrowers All student borrowers Conducted in person, by audiovisual presentation, or by interactive electronic means Before a student borrower leaves school 18

19. NameRecipientMethodFrequency Code of Conduct for Education Loans Employees with responsibilities related to education loans Prominently published on the institution’s website ---- Written or electronic notification to employees with education loan responsibilities Ensure availability ---- Annually notify - in writing – those employees with education loan responsibilities Private Education Loan Disclosures (Including Self- Certification Form) Prospective private education loan borrowers Publications, mailings, or electronic media Ensure availability ---- Provide a self certification form at the borrower’s request for a private education loan 19

20. NameRecipientMethodFrequency Preferred Lender Lists All enrolled students and their families Publications, mailings, or electronic media issued by the Institution (or an institution affiliated organization) Annually Preferred Lender Arrangements Prospective or current students and their families On the institution’s (or institution affiliated organization’s) website, and in all publications, mailings, or electronic messages, that describe or discuss private education loans Ensure availability 20

21. NameRecipientMethodFrequency Gainful Employment Programs All prospective and enrolled students Information must be posted on the Institution’s website and included in any promotional materials ---- Reporting requirements suspended Annually Misrepresentation Prospective and enrolled students and the general public information must be posted on the Institution’s website Ensure availability 21

22. Compliance is a group effort…  Identify and recruit the right players  Establish an implementation strategy  Ensure administrative buy-in  Establish a monitoring plan 22

23.  Think readability and accessibility  When possible, consider online publication 23

24.  When considering on-line publication :  Focus on communication as well as compliance  Consider a single portal page for all consumer information  Adopt a “3-click” approach 24

25.  Consider consumer friendly language; avoid technical jargon whenever possible  Establish common sense content titles National Postsecondary Education Cooperative: Information Required to be Disclosed under the Higher Education Act of 1965: Suggestions for Dissemination. (2009) 25

26.  Higher Education Act of 1965 as amended (http://www.gpo.gov/fdsys/)http://www.gpo.gov/fdsys/  Higher Education Opportunity Act of 2008 (HEOA)  Dear Colleague Letter (DCL) GEN-08-12 summarizes the HEOA (http://www.ifap.ed.gov/dpcletters/GEN0812FP0810.html)http://www.ifap.ed.gov/dpcletters/GEN0812FP0810.html  Volume 2 of the Federal Student Aid Handbook (http://ifap.ed.gov/fsahandbook/1314FSAHbkVol2.html)http://ifap.ed.gov/fsahandbook/1314FSAHbkVol2.html  Code of Federal Regulations (http://www.gpo.gov/fdsys/)http://www.gpo.gov/fdsys/  Handbook for Campus Safety and Security Reporting (http://www.ed.gov/admins/lead/safety/handbook.pdf)http://www.ed.gov/admins/lead/safety/handbook.pdf  National Postsecondary Education Cooperative: Information Required to Be Disclosed Under the Higher Education Act of 1965: Suggestions for Dissemination (2009) (http://nces.ed.gov)http://nces.ed.gov 26

27.  FSA Assessment Module for Consumer Information (http://www.ifap.ed.gov/qahome/qaassessments/consumerinformation. html)http://www.ifap.ed.gov/qahome/qaassessments/consumerinformation. html  IFAP Gainful Employment Information Page (http://ifap.ed.gov/GainfulEmploymentInfo/index.html)http://ifap.ed.gov/GainfulEmploymentInfo/index.html  Gainful Employment Operations Manual (rev. 5/23/2012) (http://www.ifap.ed.gov/GainfulEmploymentOperationsManual/GainfulE mploymentOperationsManual.html)http://www.ifap.ed.gov/GainfulEmploymentOperationsManual/GainfulE mploymentOperationsManual.html 27

28. For Policy Assistance… David Racculia Tarah Seroskie (Compliance Specialists) » E-mail – CMPolicy@aesSuccess.orgCMPolicy@aesSuccess.org » Phone – (717) 720-3460 28

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