New Directors Seminar Compliance

1. New Directors SeminarCompliance Private Licensed Schools

2. Sign In • Sign in if you haven’t already done so

3. Logistics • Snacks • Restrooms • Organization and schedule

4. New Division Name • Division of Occupational Training Schools • Applies to PDE Division only • Board is still the Board of Private Licensed Schools • Schools are still called Private Licensed Schools

5. Contents • Foundations – Statute, Regs, and Memos • Board organization • Electronic sites • Secure Website Access • Annual Statistical Report • Board Approvals Required • Notifications Required • License Renewal

6. Contents Continued • Contents of PDE Website • Program Changes • Site Visits • Advertising • Admissions Representatives • Student Records - transcripts • Records Repository

7. Contents Continued • Complaints • Enforcement Action • Possible Sanctions • Common Pitfalls • Rigid Deadlines • Closing Procedures • Questions and Answers

8. Today’s PowerPoints are on the Web • Public Website: http://www.education.state.pa.us

9. Board of Private Licensed Schools • 15 members • 14 appointed by Secretary of Education • 1 ex officio representative of Attorney General • 4 year terms • Term limits of 2 consecutive terms

10. Board’s Standing Committees • Executive Committee • Financial Review Committee • Review and Recommendation Panel • Curriculum Committee • Hearing Panels

11. Legal Authority • Statute • Regulations • Board Policy Memos

12. Board Policy Memos • Numbered memos that explain the regulations or create policy not addressed in the regulations. • Violation of the memos can result in enforcement action.

13. Board Policy Memos Memo #38 – Establishes Cure Period • Provides for a 10 day cure period (business days) for schools to provide any needed revisions for their program applications. Memo #52 - Scholarships • Must be a minimum of 25% of tuition cost • Cannot be used as a discount, premium, or special endorsement. Memo #65 – Limits Program Applications • Limits the number of new program applications to three per Board meeting.

14. Staff • The Pennsylvania Department of Education staffs the Board • Each school assigned to a staff member • Current staff • John Galganovicz • Robert Kline • Ed Rech • All Staff at (717)783-8228

15. Questions? • Any questions specific to the Board, its authority or organization?

16. Internet Resources • PDE Website: http://www.education.state.pa.us • Secure Website – via login • Financial forms and instructions: ftp://ftp.state.pa.us/pub/PDE_PUBLIC/PLSFinancial

17. Accessing Secure Website Steps: • Obtain user name and password for EdHub – do this on-line at http://www.education.state.pa.us • Director sends e-mail to RA-edhubadmin@state.pa.us to request access to PLS software • Receive confirmation that account is ready • Go to EdHub and log on • Access PLS Application

18. Annual Statistical Report • MUST be submitted between July 1 and September 30 each year. • Submitted electronically • Failure to submit is a violation punishable by a fine of at least $500 or revocation.

19. PDE-3808 • School program profile • Know how to access • Confirm accuracy • Used by accreditation, vet ed, other funding sources

20. Questions • Questions on web resources, PDE-3808 or annual report?

21. Board Approvals Required • Relocation • Expansion • Remote Location • New Branch • All Require site visit ($500 fee), certificate of occupancy, bond rider • Scholarship (requires FRC approval) • Change of Ownership (requires FRC approval) • Name Change or Alternate Name

22. Notifications Required • Change in Director – PDE-340 • Change in Acting Director – PDE-340 • Program Changes – PDE 3744

25. Reportable Events • Material change in financial condition • Lapse in surety • School files for bankruptcy • Building code violation • Environmental hazard • Title IV audit

26. How to Report • Send letter to the Division • No form provided

27. Additional Information Needed • Change in e-mail account • Change in phone number

28. Questions • Any questions regarding issues that need Board approval, issues that require staff approval or reportable events?

29. License Renewal • First is due one year from first licensure • Subsequent due every two years • MUST be renewed prior to expiration • Reminder will be sent, but school is responsible • Renewal form PDE-3123

31. Components of Renewal App • Form PDE-3123 with signature • Fee ($500 - $4,400) • Financial Statement (PDE-2006 or audited) • Evidence of surety • Ethics statement • Records Repository • Enrollment Agreement • Catalog • Changes to PDE-3808 • Confirmations

32. Questions • Questions on renewals?

33. Program Changes • Submitted on PDE-3744 • Must be less than 25% change in clock hours • Cannot be a substantive change to objectives • Approval required PRIOR to implementation • Also required for tuition changes

34. Delivery Method • A change in delivery method of less than 25% of the program can be reported as a program change. • Note: Approval is required PRIOR to implementation • A change in delivery method for more than 25% of the program requires a new program application.

37. Questions • Questions on Program Changes?

38. Advertising • No blind advertising • No advertising in the help wanted • No salaries • No misrepresentation • No superlatives • No implication of college or university • Must use approved school name • No advertising unapproved programs

39. Advertising Con’t • No guarantee of employment • No guarantee of admission to another institution • No guarantee of credit transfer • No bait and switch • No premiums • No discounts • No demeaning of another school

40. Questions • Questions on advertising?

41. Site Visits • Expansion of instructional space • Remote location • Branch location • Relocation • All requested in writing by school - $500 fee • All require Certificate of Occupancy • Bond rider • All require Board approval • Compliance Visit • Scheduled by staff, no fee

42. Compliance Visit • Once every 3 years for unaccredited schools • Once every 4 years for accredited schools • Tour school, talk with students and staff, check facilities, certificate of occupancy, capacity, equipment, director and faculty credentials, program approvals, license posted, advertising, scholarships, catalog, enrollment agreement, student records.

43. Student Record Check • Current students • Enrollment agreement, proof of admission criteria, transcript, account information • Graduates • Transcript with all 7 components • Withdrawals • Transcript with all 7 components • Refunded correctly • Last date of attendance, % of program, refund date, refund amount,

44. Questions • Questions about site visits, including compliance visits?

45. Student Refunds and Withdrawal Policies • Calculated in accordance with 22 PA Code 73.134 • Determined by the percentage of the program completed • Refund amount and date of refund should be in the student file for all those who have withdrawn.

46. Refunds + 6 weeks • Up to 5 days after signing but before classes – 100% (including reg fee) • After 5 days and before classes 100% minus reg fee • During first 7 days – 75% • Within 25% - 55% • Within 50% - 30% • After 50% - no refund

47. Refunds < 6 weeks • Up to 5 days after signing but before classes – 100% (including reg fee) • After 5 days and before classes 100% minus reg fee • Up to 10% – 90% • Within 25% - 55% • Within 50% - 30% • After 50% - no refund

48. Refunds Distance Ed • Up to 5 days after signing but before sending in first lesson – 100% (including reg fee) • After 5 days after signing but before sending in first lesson 100% minus reg fee • Completed up to 10% of lessons – 90% • Completed up to 25% of lessons- 75% • Completed up to 50% of lessons - 50% • After 50% - no refund

49. Refunds • Students cannot be required to request withdrawal in writing. • If a student stops attending, a refund is due if they completed less than 50%

50. Refunds • Refunds must be calculated based on the last date of recorded attendance • If the school takes attendance, use recorded date • If the school does not take attendance, use the last written evidence of attendance –a homework assignment, quiz or test.