In January, the U.S. Department of Education’ s (ED) Office of Postsecondary Education (OPE) released a new beta-version of the 2019-2020 Financial Aid Shopping Sheet that was first introduced in 2012. After soliciting feedback from schools and stakeholders on the template earlier this year, the Office of Postsecondary Education has released a finalized form template which incorporates improvements based on the recommendations and feedback they received.

According to the OPE announcement, the Financial Aid Shopping Sheet was redubbed the “College Financing Plan” to “more accurately reflect that loans may be a significant part of the student’s investment, and to emphasize to students that they are making a financial transaction when enrolling in an institution.”

The College Financing Plan looks very similar to the Financial Aid Shopping Sheet institutions have been using for many years, but some of the information has changed a bit. For example, the new form template includes additional information about interest rates on each loan as well as new information about need-based and merit based scholarships, on campus versus off campus housing, and even additional clarity on the difference between grants, which don’t have to be repaid and loans, which do. The form has also been decluttered and simplified to make it easier to read and understand. Section headings have also been restructured to better illustrate a rather simple formula its predecessor didn’t do so well; Total Cost of Attendance – Grants and Scholarships = Net Cost.

Schools that signed the Memorandum of Understanding (MOU) to comply with the Principles of Excellence (POE) in Executive Order 13607 will be required to begin using the new format for the 2020-2021 award year once it is released however ED has not provided clarification as to when, and whether or not schools currently using the FA Shopping sheet need to adopt the College Financing Plan.


I remember when the College Scorecard was first released. The most striking thing about the scorecard wasn’t the just the data it provided about institutions, but rather the data it didn’t. First off, it excluded thousands of institutions, particularly for-profit colleges and schools with primarily non-degree certificate programs. Graduation data for non-first-time and non-full-time students weren’t included either, since the Scorecard then, only looked at first-time-full-time students, and the only information available on student debt was an institutional, not programmatic.

Following an executive order signed by President Trump last year, U.S. Secretary of Education Betsy DeVos released an expanded College Scorecard last month. According to an ED press release, “the tool now includes information on 2,100 additional postsecondary education options”. To be clear, that’s 2100 institutions that are now being included in search options for students, parents and others to aid them in making informed choices about the schools and programs they are interested in attending.

In addition to the inclusion of these schools, the new College Scorecard includes information about graduation rates for non-first-time and non-full-time students, and the percentage of students who transferred or were still enrolled in school. Cost, graduation rates, student demographics and other data will now be updated at multiple times each year instead of once annually; making use of the data institutions report three times a year to the IPEDS data system.

The expanded College Scorecard data also includes information on student loan debt, broken down by field of study. According to the Press Release, Secretary DeVos had this to say; “For years, the College Scorecard provided undergraduate loan debt information at only the institution-level even though the amount borrowed to attend school can vary substantially depending on which program the borrower is enrolled.”

As of today, the information in the expanded scorecard is only preliminary data. The U.S. Department of Education decided to release this data while asking institutions to update their historical enrollment data from which these loan debt metrics are derived. Later this fall, the Scorecard will be updated to include any adjustments institutions submit this summer. The deadline for such corrections is July 10, 2019


2018 Election Day - Voter Registration Requirements Under the Higher Education Act - Consumer Information

Election Day is Tuesday, November 6th, 2018. Remember to vote and encourage your students to do the same! It’s not just a good idea, it’s the law.
Under the Higher Education Act, schools and colleges must make a good faith effort to distribute voter registration forms to students. Voter registration forms must be made widely available and be provided to each enrolled student for federal elections and state elections for governor or other State chief executive.
Since 2008 a provision included in the Higher Education Opportunity Act has allowed colleges to, electronically distribute the voter registration forms to enrolled students by providing an internet address where such a form can be downloaded. The information must be in an electronic message devoted exclusively to voter registration and distributed to each enrolled student to be considered in compliance with the distribution requirements.
Voter Registration requirements don’t apply to institutions in states that do not have a voter registration requirement or that allow voters to register at the time of voting. Thus. schools in some states such as Idaho, Minnesota, New Hampshire, North Dakota, Wisconsin, and Wyoming are exempt from this requirement. In every other state, schools must request voter registration forms from the state at least 120 days prior to the state’s deadline for registering to vote. If a school does not receive the forms within 60 days prior to the deadline for registering to vote in the state, it is not liable for failing to meet the requirement during that election year.

Is your institution complying with all relevant consumer information policies?


the Department issued new guidance for institutions about how it will assess a school’s compliance with Title IX

Title IX protects people from discrimination based on sex in education programs or activities at more than 7000 postsecondary institutions that receive Federal Financial Assistance. Last month, the U.S. Department of Education’s Office For Civil Rights announced they were withdrawing some Title IX policies and guidance issued under the Obama administration. The guidance that has been rescinded includes an April 4, 2011 Dear Colleague Letter on Sexual Violence and an OCR Q&A on Title IX and Sexual Violence from 2014. The Department also announced they will readdress the standards for Title IX through the negotiated rulemaking process later this year.

In the interim, the Department issued new guidance for institutions about how it will assess a school’s compliance with Title IX. A seven page document released by ED’s Office for Civil Rights, outlines a school’s responsibilities to address sexual misconduct.

The biggest change at issue is a change in the procedures a school should follow for resolving cases of reported sexual misconduct. Under the old guidance, schools were required to use the “preponderance of the evidence” standard when adjudicating and resolving allegations of student on student misconduct. Under the new guidance, findings of fact and conclusions should be reached by applying either a preponderance of the evidence standard or a clear and convincing evidence standard.

Some supporters of the move to rescind these rules have long called for a higher standard of proof to be used in cases of rape and sexual assault such as those used by criminal courts where the burden is proof for vicious crimes is “beyond a reasonable doubt”. Supporters of the new OCR guidance see this as an opportunity for individuals accused of committing these crimes to get due process.

Opponents and advocates of victims defended the preponderance of the evidence standard say that requiring colleges to judge a case based on the higher evidentiary standard of beyond a reasonable doubt is extremely difficult. Colleges are not courts after all and it’s important to remember that schools are conducting disciplinary hearings, not civil or criminal court cases.

So what else changed?

Under the interim guidance, schools have some new flexibility including the discretion to apply either the preponderance of the evidence standard or the clear and convincing standard. Although schools are not required to allow appeals, they may choose to allow appeals solely from the accused or both parties. Mediation is also now permissible if a school deems it appropriate, and both parties agree voluntarily.

The OCR also made several recommendations to schools including one that schools should provide written notice to the accused, including sufficient details and with adequate time to prepare a response before initiating any proceedings. The OCR also recommends that schools provide written notices of the outcome of disciplinary hearings to both parties, at the same time.

No date has been set for the upcoming comment and negotiation periods.


Higher Ed Executives Compliance Consultants

September 17 is Constitution Day.

Constitution Day commemorates the September 17, 1787 signing of the United States Constitution by the delegates of the Constitutional Convention.

Each Educational institution receiving Federal funding is required to hold an educational program for its students about the United States Constitution on September 17 of each year. Since it became a requirement in 2005, schools and colleges across the country have commemorated the day with a variety of educational programs, lectures and events to inform students about the constitution, their rights and their responsibilities as Americans.

Today, at the intersection of liberty and tyranny this programming is especially important on college campuses.

To aid in planning your Constitution Day activities we’ve created a list of five exceptional resources for schools:

  1. Get a Free copy of the U.S. Constitution from the National Archives website.
  2. Sign up for “Introduction to Key Constitutional Concepts and Supreme Court Cases,” an on-demand course that starts with the creation of the Constitution and wraps up with modern issues and how the Constitution is applied to them. The course includes 24 short videos, a study guide, and quizzes. University of Pennsylvania law professor Kermit Roosevelt is the lecturer.
  3. The Annenberg Classroom has a free brochure about teaching the Constitution which provides more than 60 additional resources from interactive games on the Constitution to downloadable books to engage your students.
  4. Check out the resources on The website contains educational materials, flyers, and other information to help you celebrate Constitution Day right.
  5. The Library of Congress American Memory site provides several special presentations including “The Making of the U.S. Constitution” which provides Transcription of the Introduction and the U.S. Constitution
    from the First Volume of the Annals of Congress.

How does your campus celebrate Constitution and Citizenship Day? Share your plans with us on Twitter @HigherEdPete