1. Consumer Information Jessica Finkel Office of Postsecondary Education U.S. Department of Education

2. Agenda Net Price Calculator (NPC) Textbook Information GE Disclosures Clery Act Changes Resources 2

3. Background IHEs must disclose certain information as part of Title IV participation Disclosures often require information from offices across an IHE, not just the financial aid office IHEs may face penalties for noncompliance 3

4. Net Price Calculator 4

5. Section 132(h) of the HEA states: “Each institution of higher education that receives Federal funds under title IV shall make publicly available on the institution’s website a net price calculator to help current and prospective students, families, and other consumers estimate a student’s individual net price at such institution of higher education.” 5

6. Net Price Calculator What is net price? – The average yearly price actually charged to first- time, full-time (FTFT) undergraduate students receiving student aid at the institution 6 Institution’s Cost of Attendance (average annual cost of tuition and fees, room and board, books, supplies, and transportation Total need- and merit-based Federal, State, and institutional grant aid awarded to FTFT students Number of FTFT students receiving such aid

7. Net Price Calculator What is required? – ED was required to develop a net price calculator template – Institutions had two years from release of template to post a NPC to their websites Required by 10/20/2011 May use ED’s template or an IHE-developed NPC Must include minimum data elements 7

8. Net Price Calculator Minimum required data elements 8 Input ElementsOutput Elements Student’s incomeEstimated total price of attendance Number of people in householdEstimated tuition and fees Dependency status (or factors that estimate dependency status) Estimated room and board Estimated books and supplies Estimated miscellaneous expenses (personal, transportation, etc.) Estimated total grant aid Estimated net price Percent of the cohort (FTFT) that received grant aid

9. Net Price Calculator Must include required disclaimers and link in NPC – Estimate is not final or binding on ED, the institution, or the State – Students must complete the FAFSA to be eligible for Title IV aid – Link to the FAFSA ED template has these built in 9

10. Net Price Calculator Who counts as a “first-time, full-time (FTFT) student? – First-time = a student who has no prior postsecondary experience attending any institution for the first time at the undergraduate level – Full-time = a student enrolled for 12+ semester credits, 12+ quarter credits, or 24+ contact hours/week each term 10

11. Net Price Calculator Who must have a NPC? – IHEs with any FTFT students – Foreign schools are exempt Approximating the student’s EFC – IHEs may use either Federal Methodology or Institutional Methodology 11

12. Net Price Calculator Where must the NPC be located? – Varies by institution – National Postsecondary Education Cooperative (NPEC) guidance on making disclosures easy to find http://nces.ed.gov/pubsearch/pubsinfo.asp?pubi d=2010831rev http://nces.ed.gov/pubsearch/pubsinfo.asp?pubi d=2010831rev 12

13. Net Price Calculator May schools rename the NPC? – Best bet for full compliance is to call it a “net price calculator” May schools include loans in the NPC? – Net price definition takes into account scholarships and grants – Calculation must not consider loans 13

14. Net Price Calculator When and how often must IHEs update the NPC? – They update on an annual basis, when new data become available to do so – COA and grant aid data are from the same year and represent actual, not projected data – ED releases updated versions of the template annually around January 14

15. Net Price Calculator How should IHEs account for VA and DOD benefits? – Not need- or merit-based grant/scholarship aid, so not subtracted from COA in calculating net price – IHEs may collect information that will provide more accurate cost estimates, but— Must provide HEA-required NPC first Must clearly ID whether/how these benefits were included 15

16. Net Price Calculator May IHEs use a 3 rd party’s (e.g., State, college system, private servicer) NPC? – NPC must be accessible via school’s “.edu” URL – Calculator must have all minimum elements – Institution-specific data – NOTE: may not direct users to ED’s website 16

17. Net Price Calculator Does ED use the NPC URLs reported to IPEDS? – YES. Important that the links work and are correct! Net Price Calculator Center College Scorecard College Navigator Zip file (available on NPC Information Center) 17

18. Textbook Information 18

19. Textbook Information Section 133 of the HEA requires institutions to disclose textbook information to— – Students – College bookstores Applies to each IHE receiving Federal financial assistance 19

20. Textbook Information Information for students – IHEs must disclose textbook info on the web- based schedule of courses used for pre- registration and registration purposes – Required info includes ISBN and retail price info of required and recommended textbooks and supplemental materials for each course – IHEs decide the format 20

21. Textbook Information Information for students – A: Includes ISBN and retail price info of required and recommended supplemental materials for each course – If not A, then B: If ISBN not available, IHEs must provide the author, title, publisher, and copyright date – If not B, then C: If IHE determines the disclosure is not practicable, they say “TBD” 21

22. Textbook Information Information for students – In addition to pricing information, IHEs must include a notice on their paper-based written course schedule that: Lets students know that information is available on the web-based course schedule Specifies the URL for the web-based course schedule 22

23. Textbook Information Information for college bookstores – College bookstore = a bookstore “operated by, or in a contractual relationship or otherwise affiliated with” the institution – Institutions must provide certain information to a college bookstore (see next slide) 23

24. Textbook Information Information for college bookstores – IHEs must tell their bookstores: Their course schedule for the upcoming academic period For each upcoming course/class: – The ISBN and retail price (or alternatives B or C, as needed) for each required or recommended textbook or supplemental materials – The number of students enrolled – The maximum student enrollment 24

25. Textbook Information Additional information – HEA encourages institutions to disseminate information to students about: Programs for renting or purchasing used textbooks Guaranteed buy-back programs Alternative content delivery programs Other cost-saving strategies 25

26. Gainful Employment (GE) 26

27. Status of GE Regulations Existing rules – On 6/30/2012, the U.S. District Court upheld the Department’s authority to regulate on GE but vacated most of the GE regulations – The Court left the GE disclosure requirements in place and they are still in effect 27

28. Status of GE Regulations Rule in Production – Negotiations held Fall 2013 – NPRM published March 25 – Comment period March 25 - May 27 – Final Rule development – Final Rule publication by November 1, 2014 – Effective date would be July 1, 2015 28

29. Which Programs are GE Programs? Under the HEA, Title IV eligible programs generally include: – Degree programs at public or nonprofit institutions – Programs that prepare students for “gainful employment in a recognized occupation” at any type of institution 29

30. Which Programs are GE Programs? At proprietary institutions, all programs are GE programs except for: – Bachelor’s degree programs in liberal arts offered since 2009 by a proprietary institution that has been regionally accredited since October 2007 – Preparatory coursework necessary for enrollment in an eligible program* 30

31. Which Programs are GE Programs? At public and nonprofit institutions, all programs are GE programs except for: – Degree programs – Programs ≥ 2 years designed for transfer to a bachelor’s degree program* – Preparatory coursework necessary for enrollment in an eligible program* 31

32. Which Programs are GE Programs? *If IHE awards a certificate or other non- degree credential (or a degree, at a proprietary institution), then it’s a GE program. This includes: – Teacher certification programs leading to an institutional certificate – ESL/ESOL programs 32

33. 33 Proprietary institutions start here

34. 34 Public/nonprofit institutions start here

35. Required Disclosures Occupations Normal time to complete program On-time graduation rate for completers Tuition and fees, books and supplies, room and board Placement rate for completers (as determined by State or Accreditor methodology) Median loan debt Other program information provided by the Secretary 35

36. Required Disclosures Occupations – IHEs 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/ – May use a representative sample if >10 possible occupations 36

37. Required Disclosures Normal Time – IHEs must specify how long they say it takes to complete the program Weeks, months, or years 100% of time it takes to complete, NOT 150% of the time for Student Right to Know 37

38. Required Disclosures On-Time Graduation Rate for Completers – IHEs specify the % of students who completed in the most recently completed award year within normal time 38 Step 1 Determine how many students completed in the most recently completed award year. Step 2 Determine the number of students in Step 1 who completed within normal time. Step 3 Divide the number in Step 2 by the number in Step 1. Then, multiply by 100.

39. Required Disclosures Example: On-Time Graduation Rate for Completers 39 Total number of students who completed in the 2012-2013 AY Number of students who completed within normal time

40. Required Disclosures On-Time Graduation Rate for Completers – Includes: Leaves of absence Time if a student withdrew and then returned Enrollment in other programs if the student did not complete the other program 40

41. Required Disclosures Educational Costs – Tuition & fees charged for completing the program within normal time – Typical costs for books & supplies (unless included in tuition and fees) – Costs for room & board, if applicable – Other expenses are optional, but IHEs must provide a link/access to program cost information under Student Right-to-Know 41

42. Required Disclosures Occupations Normal time to complete program On-time graduation rate for completers Tuition & fees, books & supplies, room & board Placement rate for completers (as determined by State or Accreditor methodology Median loan debt Other program information provided by the Secretary 42

43. Required Disclosures Placement Rate(s) – IHEs must disclose accrediting agency and/or State placement rates and methodologies – If not required by accrediting agency or State, then IHEs not currently required to disclose a placement rate – Once available, will have to use NCES’ methodology 43

44. Required Disclosures Median Loan Debt – IHEs must specify the median (not mean) loan debt incurred by students who completed the program – Three categories of debt  3 medians! Title IV, HEA program loans Private education loans Institutional financing plans 44

45. Required Disclosures Median Loan Debt – Title IV, HEA program loans Includes FFEL and Direct Loans (including GRAD Plus loans) Excludes Perkins Loans, Parent Plus Loans, and TEACH grants converted to Unsub Direct Loans Considers loans taken out over the course of the program, NOT just one year of it 45

46. Required Disclosures Median Loan Debt – Private education loans Defined as “non-title IV loans provided by private educational lenders expressly for postsecondary educational expenses” Considers loans taken out over the course of the program, NOT just one year of it 46

47. Required Disclosures Median Loan Debt – Institutional financing plans Includes any loan, extension of credit, payment plan, or other financing mechanism provided by the institution or a related party for attendance that is not otherwise reported as a private loan Includes any debt the student owes the school as of the day they completed the GE program 47

48. Required Disclosures Any other information the Secretary provided to the institution about the GE program – Currently, nothing to disclose under this provision – ED will provide information and guidance if/when a disclosure applies under this provision 48

49. Disclosure Template Released in November 2013 Deadline to update disclosures with 2012- 2013 information using the template was January 31, 2014 49

50. Disclosure Template The template is an application that creates a standardized Web page with the GE disclosure information The application: – Collects institutional data – Combines the institutional data with ED data – Creates a consumer-friendly Web page 50

51. 51 OPEID

52. 52 Program CIP Program Name Credential Level SOC code(s)

53. 53 Costs

54. 54 # of Completers Median Loan Debt

55. 55 Normal Time Number of On- Time Completers

56. 56

57. 57 Rate Accreditor Name Methodology

58. 58 Rate State Name Methodology

59. 59 Context

60. Disclosure Template 60

61. Disclosure Template Bulk Data File Option – Allows IHEs to upload the data to produce the HTML output file for more than one GE program at a time – To use this tool, IHEs must follow certain import specifications to set up the data file Sometimes requires IT department 61

62. Disclosure Template Planned Updates to Template – Add graduate certificate as a credential level – Add 8-digit SOC Codes from O*NET – Clarify instructions/improve skip logic when fewer than 10 completers – Add bulk upload for GE programs of significantly different lengths but same CIP code and award level 62

63. Disclosure Availability IHEs must include the Template in all promotional materials about the GE program – Promotional materials include invitations, ads, course catalogs, social media, etc. that mention or otherwise refer to a specific GE program – If not feasible to include the Template, IHEs include a live link or URL to it and clearly explain what is available at that Web page 63

64. Disclosure Availability IHEs post the Template on their Web page – The must prominently display direct links to the Template on: The GE program home page Other institutional Web pages about the GE program 64

65. Compliance Tips Who should IHEs include in the disclosures? – Students who completed the program in the most recently completed award year – Regular students If a high school student is a “regular student,” then include that student – They do not include students without SSNs 65

66. Compliance Tips If fewer than 10 students completed a GE program during the most recently completed award year: – IHEs do not disclose median loan debt amounts or the on-time graduation rate – IHEs follow their accreditor or State requirements for calculating/disclosing placement rates with “small numbers” 66

67. Compliance Tips If IHEs offer multiple programs with the same CIP Code and Credential Level, they may do separate disclosure templates if there is a significant difference in the: Published length of the program Tuition, fees, or other costs Placement rate calculations (e.g., offered in different States) 67 See GE Electronic Announcement #25!

68. GE Resources GE Information Page on IFAP http://ifap.ed.gov/GainfulEmploymentInfo http://ifap.ed.gov/GainfulEmploymentInfo – Federal Register Notices including Regulations – DCLs and Electronic Announcements – FAQs – Webinars and Presentations – Resources 68

69. Clery Act 69

70. Clery Act Updates Department is implementing changes to the Clery Act made by the Violence Against Women Reauthorization Act (VAWA) IHE expected to make a good faith effort to comply with the new requirements in the Annual Security Report due this fall 70

71. Resources Statute – HEA – Section 132(h) – NPC – Section 133 – textbook information – Section 485 – bulk of disclosures Regulations – www.ecfr.govwww.ecfr.gov – 34 CFR §668, Subpart D – 34 CFR Part 86 (DFSCA) FSA Handbook – Vol. 2, Chapters 6-8 71

72. Resources FSA Assessments on consumer info http://ifap.ed.gov/qahome/qaassessments/consum erinformation.html http://ifap.ed.gov/qahome/qaassessments/consum erinformation.html NPEC report and supplement – http://nces.ed.gov/pubsearch/pubsinfo.asp?pubi d=2010831rev (part 1) http://nces.ed.gov/pubsearch/pubsinfo.asp?pubi d=2010831rev – http://nces.ed.gov/pubsearch/pubsinfo.asp?pubi d=NPEC2012831 (supplement) http://nces.ed.gov/pubsearch/pubsinfo.asp?pubi d=NPEC2012831 72

73. Net Price Calculator Resources – NPC Information Center http://nces.ed.gov/ipeds/resource/net_price_calc ulator.asp http://nces.ed.gov/ipeds/resource/net_price_calc ulator.asp FAQs Quick start guides Bulk upload tools EFC tables Template source code 73

74. Net Price Calculator Resources – Help Desk: npc@inovas.net or 1-877-299-3593npc@inovas.net – GEN-13-07: http://ifap.ed.gov/dpcletters/GEN1307.html http://ifap.ed.gov/dpcletters/GEN1307.html 74

75. Textbook Information Resources – GEN-10-09 http://ifap.ed.gov/dpcletters/GEN1009FinalTextbo okGuidance.html http://ifap.ed.gov/dpcletters/GEN1009FinalTextbo okGuidance.html – GAO report (released June 6, 2013) http://www.gao.gov/products/GAO-13-368 http://www.gao.gov/products/GAO-13-368 75

76. GE Resources GE Disclosure Template http://www2.ed.gov/policy/highered/reg/hear ulemaking/2009/negreg-summerfall.html http://www2.ed.gov/policy/highered/reg/hear ulemaking/2009/negreg-summerfall.html – Requirement – Template application – Quick start guides – Bulk data file upload tool – Help desk: (855) 359-3697, gedt@inovas.net 76

77. Clery Act Resources Clery Act/VAWA rulemaking website http://www2.ed.gov/policy/highered/reg/hea rulemaking/2012/vawa.html http://www2.ed.gov/policy/highered/reg/hea rulemaking/2012/vawa.html May 29, 2013 electronic announcement http://ifap.ed.gov/eannouncements/052913I mplementofChangesMade2CleryActViolenceA gainstWomenReauthorizationAct2013.html http://ifap.ed.gov/eannouncements/052913I mplementofChangesMade2CleryActViolenceA gainstWomenReauthorizationAct2013.html 77

78. Clery Act Resources Handbook for Campus Safety and Security Reporting http://www2.ed.gov/admins/lead/safety/cam pus.html http://www2.ed.gov/admins/lead/safety/cam pus.html FSA Data Center (review compliance reports) https://studentaid.ed.gov/about/data- center/school/clery-act https://studentaid.ed.gov/about/data- center/school/clery-act 78

79. Thank you! 79 Jessica.Finkel@ed.gov 202-502-7647