Gainful Employment Disclosures & Template Demonstration

1. Session # 27 Gainful Employment Disclosures & Template Demonstration Jessica Finkel and Cynthia Hammond | Dec. 2013 U.S. Department of Education 2013 FSA Training Conference for Financial Aid Professionals

2. Today’s Agenda • Status of Gainful Employment (GE) Regulations • Which Programs are GE Programs • Required Disclosures • Disclosure Availability • Disclosure Template • Compliance Tips • GE Resources

3. Status of GE Regulations • Existing rules • On 6/30/2012, the U.S. District Court upheld the Department’s authority to regulate on gainful employment but vacated most of the GE regulations • The Court left in place the GE disclosure requirements

4. Status of GE Regulations • Rule in production • ED held negotiations to draft a new gainful employment rule in fall 2013 • NPRM currently in development • Final Rule to be published by November 1, 2014 • Bottom line: • The original disclosure requirements are still in effect • Any future changes to the disclosures would be effective in July 2015

5. Which Programs are GE Programs • The HEA provides that to be Title IV eligible an educational program must be offered by: • A public or non-profit postsecondary educational institution, if the program leads to a degree; or • Any institution, if the program prepares students for “gainful employment in a recognized occupation” • Generally, all non-degree programs must lead to gainful employment • Generally, most programs at for-profit institutions must lead to gainful employment

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

7. Which Programs are GE Programs • At public institutions and not-for-profit institutions, all programs are GE Programs except for – • Programs that lead to a degree • Programs of at least two years in length that are designed to be fully transferable to a bachelor’s degree program • Preparatory coursework necessary for enrollment in an eligible program

8. Which Programs are GE Programs • GE Programs include – • Teacher certification programs leading to a certificate awarded by the institution • ESL programs

9. Which Programs are GE Programs • GE Programs do not include – • Teacher certification coursework that does not lead to a certificate awarded by the institution • Preparatory coursework necessary for enrollment in an eligible program (loans only) • At public and private non-profit institutions, programs of at least two academic years that are designed to be fully transferrable to a bachelor’s degree program and do not lead to a credential awarded by the institution

10. Required Disclosures • Outlined at 34 CFR §668.6(b)(1) • Disclosures must be made for each GE program • Disclosure items: • Occupations • Normal time to complete program • On-time graduation rate for completers • Tuition and fees, book and supplies, room and board • Placement rate for completers (as determined by State or Accreditor methodology) • Median loan debt • Any other information the Secretary provided to the institution about that program

11. Required Disclosures • Occupations – 34 CFR 668.6(b)(1)(i) • Must 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/) • Use a representative sample if >10 possible occupations • See GE Electronic Announcement #25

12. Required Disclosures • Normal Time • Defined in regulation at 34 CFR 668.41(a) • In weeks, months, or years • Not 150% of normal time

13. Required Disclosures • On-time graduation rate for completers – 34 CFR 668.6(b)(1)(ii)

14. Required Disclosures • Example: On-time completion rate if 200 students completed in most recent award year Number of students who completed within normal time Total number of students who completed in the 2012-2013 AY

15. Required Disclosures • On-time graduation rate for completers includes: • Leave of absence • Time if a student withdrew and then returned • Enrollment in other programs if the student did not complete the other program

16. Required Disclosures • Educational costs – 34 CFR 668.6(b)(1)(iii) • Tuition and fees charged for completing the program within normal time • Typical costs for books and supplies • Unless included in tuition and fees • Room and board, if applicable • Other expenses (such as living expenses or transportation) are optional • But must link to/provide access to program cost information under 34 CFR 668.43

17. Required Disclosures • Placement rates – 34 CFR 668.6(b)(1)(iv) • For students who complete the program • To be determined using NCES methodology, once available. Until then: • Disclose/use accrediting agency and/or state rates or methodologies or • If not required by an accrediting agency or state, then placement rate disclosure not required until NCES methodology is available

18. Required Disclosures • Median loan debt – 34 CFR 668.6(b)(1)(v) • Median (not mean) incurred by students who completed the program • Must separate median loan debt • Title IV, HEA program loans • Private education loans • Institutional financing plans

19. Required Disclosures • Median loan debt categories: • Title IV Debt - FFEL and Direct Loans do not include Perkins or Parent PLUS • Private Loan Debt - Examples include, but are not limited to loans made expressly for educational expenses by: • Financial institutions or credit unions • Institutions of higher education or their affiliates • States and localities • Institutional Debt - the amount owed as of the day the student completed from the GE Program

20. Required Disclosures • Any other information the Secretary provided to the institution about that program • Disclosures updated by January 31, 2014 will not have anything new • We will provide information and guidance if and when we require additional disclosures under this provision

21. Disclosure Availability • Requirements outlined in 34 CFR 668.6(b)(2) • Disclosures must be in promotional materials made available to prospective students • Promotional materials include invitations, advertisements, or solicitations that mention or otherwise refer to a specific GE Program or Programs • Includes course catalogs and social media • May display the URL or provide a live link to the webpage where the required information is located, with a clear explanation of the information that is available at that webpage

22. Disclosure Availability • Disclosures must be posted on institution’s website • Prominent on program home page of relevant GE program • Accessible via direct, prominent link from other institutional webpages about the program • Prepared in an open format that can be easily searched by common web search applications • Institutions must use template

23. Disclosure Template • Released November 2013! • Institutions must update their disclosures with the most recent information using the template by January 31, 2014

24. Disclosure Template • What is the template? • An application that creates a standardized webpage with the gainful employment disclosure information • The application: • Collects data from an institution • Combines the institutional data with ED data • Creates a consistent, consumer-friendly webpage • Similar to Net Price Calculator template, but GE template is required

25. Disclosure Template • How did we develop the template? • Reviewed regulatory requirements • Developed mock screens • Held focus groups with students for feedback on the output webpage • Held focus groups with institutional representatives on data entry form for template • Published a notice of proposed form in the Federal Register for public comment • Developed the final online form and tool • Tested the template • Released the template November 2013

26. Disclosure Template For each GE program-- • Step 1 - Institution enters information on the program into an online form: • OPEID • CIP Code • Name of Program • Credential Level • SOC code

27. Disclosure Template OPEID

28. Disclosure Template Program CIP Program Name Credential Level SOC code(s)

29. Disclosure Template • Step 2 - Institution enters cost data into the online form: • Total tuition and required fees for the entire program • Total estimated costs for books and supplies • Room and board (if applicable)

30. Disclosure Template Costs

31. Disclosure Template • Step 3 - Institution enters additional data into the online form: • Median loan debt • On-time graduation rate for completers • Normal Time

32. Disclosure Template # of Completers Median Loan Debt

33. Disclosure Template Normal Time Number of On-Time Completers

34. Disclosure Template • Step 4 - Institution enters job placement information into the online form: • Calculated rate • Entity requiring the rate • Methodology

35. Disclosure Template

36. Disclosure Template Rate Accreditor Name Methodology

37. Disclosure Template Rate State Name Methodology

38. Disclosure Template • Step 5 - After entering all the data for the program, institution selects “Create Disclosure Template” • Application produces a ZIP file with html page that will be hosted on the institution’s website for that program • Note: file upload option allows institutions to produce html pages for all programs at once – you don’t have to enter all data for each program manually!

39. Disclosure Template

40. Compliance Tips • Who should I include in my calculations? • Students who completed the program in the most recently completed award year • Regular Students • If a high school student is a “regular student,” then you should include that student • If no SSN, do not include that student in disclosure calculations

41. Compliance Tips • If fewer than 10 students completed a GE program during the award year, do not disclose: • Median debt amounts • On-time completion rate

42. Compliance Tips • Regardless of the number of students who were enrolled in or completed the program (i.e., even if <10), disclose: • The occupations (by names and SOC codes) that the program prepares completers to enter • Normal time to complete the program • Tuition/fees charged to complete the program in normal time • Placement rates, if doing so aligns with the requirements of the accreditor or state on “small numbers”

43. Compliance Tips • Electronic Announcement #25 - Disclosures by Educational Program • Length of Programs • Is there a significant difference in the published length of the programs? • Tuition and Fees • Is there a significant difference in the tuition, fees, or other costs for the programs? • Programs Offered in Different States • Are programs offered in different states that require different placement rate calculations and different minimum requirements?

44. GE Resources • GE Information Page on IFAP - http://ifap.ed.gov/GainfulEmploymentInfo • Regulations • Dear Colleague Letters and Electronic Announcements • FAQs • Training • Resources

45. GE Resources

46. GE Resources • If you still have questions after reviewing the Dear Colleague Letter, Electronic Announcements, and FAQs, send your questions to GE-Questions@ed.gov

47. Contact Information • Jessica Finkel, Office of Postsecondary Education • Phone: 202-502-7647 • E-mail: Jessica.Finkel@ed.gov • Cynthia Hammond, Federal Student Aid • Phone: 202-377-4236 • E-mail: Cynthia.Hammond@ed.gov