Gainful Employment Disclosures

1. Session 26 Gainful Employment Disclosures Cynthia Hammond and Greg Martin | Nov-Dec. 2016 U.S. Department of Education 2016 FSA Training Conference for Financial Aid Professionals

2. Required Disclosures Performance on the debt-to-earnings (D/E) rates measure (if failing) Completion rate for students completing the program within normal time Tuition and fees charged students for completing the program within normal time Total costs for books and supplies, the cost of room and board Percentage of individuals who received a Title IV loan or private loan for enrollment in the program (includes non-Title IV students) Median loan debt incurred by students who completed the program Estimated monthly payment amount Median earnings for program graduates Placement rate for students completing the program Occupations (by names and SOC codes) that the program prepares students to enter Information related to state licensure requirements

3. Changes to Existing Disclosures • Completion Rate • Calculated by institutions, as under current requirements • Normal (100%) time to completion • Includes only Title IV students whose enrollment status was full-time when they first enrolled in the program • Template automatically determines applicable completion cohort based on program length

4. Completion Rate Calculation Step 1 Determine how many students whose enrollment status was full-time on the first day of the program during the cohort years specified by the template Step 2 Determine the number of students in Step 1 who completed within the period specified by the template

5. Changes to Existing Disclosures • Median Debt • Calculated by institutions • Based on same cohort used for completion rate • Single median for total debt, including federal, private, and institutional debt for Title IV students • Creates estimated monthly payment based on debt and interest rate

6. New Disclosures for 2017 • Performance on the debt-to-earnings (D/E) rates measure, if program fails • Notice of determination provided by the Department • Template must be updated within 30 days of receiving final determination

7. New Disclosures for 2017 • Median earnings for program graduates • Provided by the Department, based on Title IV graduates • If alternate earnings appeal submitted, must still disclose SSA earnings until appeal is resolved

8. New Disclosures for 2017 • Information related to state licensure requirements • Whether program meets state licensure requirements in • Any state in the institution’s metropolitan statistical area (MSA) • Any other states of which the institution is aware

9. Refresher On Other Items • Placement Rates • Required if your state authorizing agency or accreditor requires you to report a placement rate • If both require you to report a placement rate, you must provide both rates • Occupations • Should match the program CIP code based on the CIP-SOC crosswalk • If there is no match on the crosswalk, you may manually add a SOC code

10. Redesigned Disclosure Template • User-friendly interface • Designed to align with College Scorecard • Can be printed for hand-delivery • Auto-populates with warning message if program is failing

11. Redesigned Disclosure Template

12. Redesigned Disclosure Template

13. Redesigned Disclosure Template

14. Separate Templates • If you offer the program in multiple lengths, you are required to post a separate disclosure template for each length of the program • If you offer multiple programs with the same CIP Code and Credential Level, consider separate disclosure templates if there is a significant difference in the: • Tuition, fees, or other costs • Placement rate calculations (e.g., offered in different States)

15. Availability of Template • On any web page containing academic, cost, financial aid, or admissions information about a GE program, you must provide the disclosure template for your program or a prominent, readily accessible, clear, conspicuous, and direct link to the disclosure template for that program • The Secretary may require you to modify a web page if your link is not prominent, readily accessible, clear, conspicuous, and direct • 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, include a live link or URL to it and clearly explain what is available at that Web page

16. Student Warnings • Within 30 days of receiving a final determination for a failing program, you must provide a warning to currently enrolledandprospective students. • Warning must state: “This program has not passed standards established by the U.S. Department of Education. The Department based these standards on the amounts students borrow for enrollment in this program and their reported earnings. If in the future the program does not pass the standards, students who are then enrolled may not be able to use federal student grants or loans to pay for the program, and may have to find other ways, such as private loans, to pay for the program.”

17. Warning Enrolled Students • Warnings provided to enrolled students must: • Describe the academic and financial options available to students to continue their education in another program at the institution, including whether the students could transfer credits earned in the program to another program at the institution and which course credits would transfer, if the program loses eligibility for Title IV funds • Indicate whether or not the institution will (1) continue to provide instruction in the program to allow students to complete the program; and/or (2) refund the tuition, fees, and other required charges paid to the institution by, or on behalf of, students for enrollment in the program; and • Explain whether the students could transfer credits earned in the program to another institution.

18. Warning Enrolled Students (cont’d) You may deliver student warnings to enrolled students by: Hand-delivering the warning as a separate document to the student individually or as part of a group presentation; or Sending the warning to the student’s primary email address

19. Email Delivery to Enrolled Students • If you send the warning to the enrolled student by email, you must— • Ensure that the warning is the only substantive content in the email; • Receive electronic or other written acknowledgement from the student that the student has received the email; • Send the warning using a different address or method of delivery if you receive a response that the email could not be delivered; and • Maintain records of your efforts to provide the warnings required by this section.

20. Warning Prospective Students If your program is failing, you have several options for providing the warning to prospective students: Hand-delivering the warning as a separate document to the prospective student or third-party individually, or as part of a group presentation; Sending the warning to the primary email address used by the institution for communicating with the prospective student or third-party about the program; Providing the prospective student a copy of the disclosure template that includes the student warning required by this section; or Providing the warning orally to the student if the contact is by telephone.

21. Warning Prospective Students (cont’d) • Before you enroll, register, or enter into a financial commitment with a prospective student, you must provide the student warning. • You may not enroll, register, or enter into a financial commitment with the prospective student with respect to the program earlier than— • Three business days after you first provide the student warning to the prospective student; or • If more than 30 days have passed from the date you first provided the student warning, three business days after the institution provides another warning.

22. Email Delivery to Prospective Students • If you send the warning to a prospective student by email, you must: • Ensure that the warning is the only substantive content in the email; • Receive electronic or written acknowledgement that the prospective student has received the email; • Send the warning using a different address or method of delivery if the institution receives a response that the email could not be delivered; and • Maintain records of its efforts to provide the warning required under this section.

23. Deadlines • Department will provide notice of timing in future communications on IFAP • Institutions will be given at least 30 days to comply with disclosure requirements once all materials available • All warnings must be provided to students within 30 days of receiving notice of determination

24. GE Disclosure Resources • GE Disclosure Template http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/negreg-summerfall.html • Requirement • Template application • Quick start guides • Bulk data file upload tool * • Help desk: 855-359-3697, gedt@inovas.net

25. Questions