MOST FREQUENTLY CITED PROGRAM REVIEW FINDINGS

A financial aid consultant can help your college identify risks and prevent program review findings

What are the most frequently reported program review findings according to ED?

ED recently released an updated program review guide packed with lot’s of great info to help schools and colleges understand the in’s and out’s of a program review. The new guide covers everything from general program review processes to procedures and guidelines for following up. According to the guide, these are the most frequently cited program review findings. 

These are the top ten most frequently cited program review findings at colleges and universities.

  • Crime Awareness Requirements Not Met
  • Verification Violations
  • Return to Title IV Calculation Errors
  • Student Credit Balance Deficiencies
  • Drug Abuse Prevention Requirements Not Met
  • Student Status – Inaccurate/Untimely Reporting
  • Entrance/Exit Counseling Deficiencies
  • Consumer Information Requirements Not Met
  • SAP Policy Not Adequately Developed and/or Monitored
  • Inaccurate Record keeping

How does your institution assess it’s risk and preparedness for audits and program reviews?

To learn more about how your institution can adjust its processes and reporting to minimize its risk of these federal student aid compliance issues, please contact us.


Get your 2018-2019 IRS Tax Return Transcript Matrix for ISIR Verification here!

REPORT ON BEST PRACTICES FOR FINANCIAL LITERACY AND EDUCATION

In a recent electronic announcement, Federal Student Aid announced that a new report on Financial Literacy Best Practices has been released. The report dubbed Best Practices for Financial Literacy and Education at Institutions of Higher Education is the result U.S. Financial Literacy and Education Commission. According to the Electronic Announcement, the report provides general best practices for financial education programs. Specifically, the report makes recommendations in the following areas:

  • Providing clear, timely and customized information to inform student borrowing;
  • Effectively engaging students in financial literacy and education;
  • Targeting different student populations by use of national, institutional and individual data;
  • Communicating the importance of graduation and major on repayment of student loans; and
  • Preparing students to meet financial obligations upon graduation.

This is useful information for helping student access information to make college affordable.

2019-2020 IPEDS REGISTRATION AND DATA COLLECTION SCHEDULE

Registration for the 2019-2020 IPEDS Data Collection Schedule opens in August. Reporting to IPEDS is mandatory thus; all institutions are required to register for the 2019-2020 data collection cycle. UserIDs and passwords for 2019-2020 will be distributed to all institutions on August 7. Those with designated keyholders will receive information via email. All institutions for which there is no designated keyholder will receive a letter directed to the CEO containing registration information. To register, visit the IPEDS website at: https://nces.ed.gov/ipeds/report-your-data

During the Registration Period, institutions are encouraged but not required to complete Report Mapping, Institution Identification, and IC Header. Report Mapping (if applicable) and Institution Identification must be completed, and IC Header must be locked before the Fall surveys can be started. Report Mapping and IC Header are available until the end of the Fall collection. Institution Identification is available through Spring.
On August 28, NCES will review the registration status of each institution. If an institution has not registered as of this date, a letter will be sent to the CEO requesting appointment of a new keyholder.

If you are responsible for reporting IPEDS data at your school, here are some other important dates to mark on your calendar.

  • September 4, 2019 – Fall Collection Opens – Institutional Characteristics; Completions; 12-month Enrollment
  • December 11, 2019 – Winter Collection Opens – Student Financial Aid; Graduation Rates; 200% Graduation Rates; Admissions; Outcome Measures
  • December 11, 2019 – Spring Collection Opens – Fall Enrollment; Finance; Human Resources; Academic Libraries

STATE AUTHORIZATION PING PONG NEARS RESOLUTION 

STATE AUTHORIZATION PING PONG NEARS RESOLUTION 
As we reported in May, the U.S. Department of Education was ordered by a U.S. District Court in California to implement the 2016 State Authorization Regulations. Although the original effective date of the regulations was July 1, 2018, the Department delayed them until July 1, 2020 and began the process of negotiating and writing new regulations which are still expected to be released later this year. The lawsuit brought by student and consumer advocates and the National Education Association, a teacher’s union, sought to force the Department of Education to implement the 2016 regulations and on May 26, 2019 the courts sided with the NEA. As a result, the court ordered the Department to implement the rules right away.

The 2016 state authorization amendments required institutions to obtain approval from each state in which they enroll students via online, distance education, and/or correspondence programs, or participate in a state authorization reciprocity agreement that includes the states they’re enrolling students in. States were required to have a means for students to lodge complaints and as of last year every state except California (and a few U.S. Territories) have either established a complaint process and process for approving out of state entities or joined a reciprocity agreement like NC-SARA.

Recognizing the effect this would have, the court allowed the Department time to consider how to implement the rules, since many schools and colleges have been enrolling Californians with the understanding that the State Authorization regulations had been delayed. On July 22, 2019 the Department released an electronic announcement explaining that the State Authorization rules were put into effect retroactively on May 26, 2016, causing a scramble in the distance education world. Reports of as many as 80,000 to more than 100,000 students enrolled in distance education programs all around the country were suddenly in jeopardy of losing access to their federal financial aid. As an attachment to the electronic announcement the Department provided some information about states’ complaint processes and pointed out that California didn’t have one for its private non-profit and public institutions. California’s Bureau of Private Postsecondary Education handles complaints for out-of-state for-profit institutions.     

California acted quickly to establish a complaint process for these schools, and authorized BPPE through the California Department of Consumer Affairs to begin handling complaints beginning on July 29, 2019. In a statement, the DCA said they expect that the ED will find the proposed process satisfactory, so that California is following federal rules, affected colleges can inform their students of the process, and students will not lose Title IV federal financial aid funding.

Although the Department hasn’t historically approved or denied individual state complaint processes, the U.S. Department of Education and California Regulators appear to be coordinating closely to avoid any missteps that could prolong or further deny federal aid to students receiving distance education because their institutions cannot meet the complaint process requirement due to problems with state procedures. The nation’s college students wait for the Department’s decision. Considering the potential to disrupt the education of thousands of online students affected. a conclusion to this issue needs to be carried out swiftly.

According to WCET, 4-6 states and territories may still be out of compliance after noting that some complaint procedures in some states were unclear and may not meet the federal requirements. So far, they have not released the names of the states or territories in question.  Education Secretary Betsy DeVos has also called for NEA to drop its lawsuit which although unlikely to happen could also resolve this issue by allowing the Department to continue their original plan to delay the regulations until such time as new rules are carried out or states comply.

UPDATED – QUESTIONS REMAIN ON RECENT COLLEGE CYBERSECURITY VULNERABILITIES

On July 17, the U.S. Department of Education’s Office of Federal Student Aid issued an Electronic Announcement regarding what they deemed an “active and ongoing exploitation” of a known vulnerability potential in some versions of Ellucian’s Banner software. According to FSA’s “Technology Security Alert, the vulnerability affects Ellucian Web Tailor versions 8.8.3, 8.8.4, and 8.9 and Banner Enterprise Identity Services versions 8.3, 8.3.1, 8.3.2, and 8.4. Pointing to advisory bulletin by the National Institute of Standards and Technology (NIST), FSA reported that hackers may be able to breach the system through an institutional account and could then potentially use that access to set up “thousands of student fake student accounts”. The Department says that 62 colleges or universities have been identified which may be affected. Federal Student Aid’s Cyber Incident Team is working with institutions to identify if systems were impacted and to facilitate the necessary fixes. FSA asked institutions using Ellucian Banner to do the following:

  1. review the vulnerability details as provided in NIST advisory CVE-2019-8978;
  2. contact Ellucian to receive information needed to patch or upgrade affected systems; and
  3. respond immediately to the Department via email to both FSASchoolCyberSafety@ed.gov and CPSSAIG@ed.gov.
  • Include the following information in your email:
  • Institution’s Name
  • Information Technology (IT) Contact at Institution (Name, Email Address, Phone Number)

Ellucian has since pushed back on ED’s characterization of the nature of breach and its impact, stating that Banner’s potential software vulnerabilities, which were brought to light by both Ellucian and the National Institute of Standards and Technology in May, are unrelated to some of the other cybersecurity concerns outlined by ED. Ellucian said neither they nor ED have reason to suspect that a breach occurred as a result of the Banner software vulnerability. Schools using the impacted software should implement the system patch issued by Ellucian in May, if they have not already done so.

This is the second summer in a row that ED released a Technology Security Alert. In August of 2018, FSA released a warning about a malicious phishing campaign aimed at student email accounts. Officials cautioned that cybercriminals could change student account information including information such as direct deposit banking information which could be used to funnel student refunds and aid distributions into accounts controlled by the attackers. FSA offered this guidance to institutions:

How to protect IHEs: FSA strongly encourages IHEs to strengthen their cybersecurity posture through the use of two-factor or multi-factor authentication processes. These types of authentication rely on a combination of factors, for example, username and password combined with a PIN or security questions or access through a secure, designated device.

If you believe your institution has fallen victim to an attack, report the incident immediately to cpssaig@ed.gov and FSASchoolCyberSafety@ed.gov. Include the following:

  • Name of the institution
  • Date the incident occurred (if known)
  • Date the incident was discovered
  • Copy of the phishing email (if available)
  • Extent of the impact (number of students)
  • Remediation status (what has been done since discovery)
  • Institution point of contact

Suggested remediation steps if an institution falls victim to the attack:

  • Temporarily freeze refund requests until the scope of the incident can be known. Note, refunds must still be provided within regulatory guidelines which may require a change in how impacted IHEs issue refunds, e.g. issue paper checks.
  • Temporarily disable changes to direct deposits for refunds.
  • Block IP addresses observed in institution logs related to the attack.
  • Disable campus credentials or passwords for potentially affected students and require password resets.
  • Perform additional forensic analysis on server and application logs from recent weeks.
  • Notify all students, warning them of active phishing attempts and encourage them to be vigilant and careful about using links and entering personally identifiable information into websites.

UPDATED – On Tuesday August 6, the Department of Education released an updated Technology Security Alert regarding the vulnerability in Banner Web Tailor and Banner Enterprise Identity Services.

The Department dialed back their claims that Banner products were affected and instead point to vulnerabilities in “third-party software” being used as “front-end access points to the Ellucian Banner System and similar administrative tools”. The Department also confirmed what Ellucian has been saying all along – “To date, based on reports from targeted institutions, we have not found any instances where the Ellucian Banner System vulnerability has been exploited or is related to the issues described in the original alert.”

In an emailed statement from Ali Robinson, an Ellucian spokesperson, he said

“Research by the Department has found:

  • no instances where the known Banner vulnerability has been exploited or where it is related to the issues described in the original alert.
  • an industry-wide issue in which attackers use automation tools to submit fraudulent admission applications in order to obtain new student accounts.

Additionally, I should note that, Ellucian has conducted its own research and monitoring that has produced no evidence of any attempt to attack the known Banner vulnerability.”

The Department is advising institutions to  review any third-party front-end applications to ensure that they are not introducing unpatched vulnerabilities, or increasing the risk of potential future issues through automation attacks. The Department reccommends that insitutions implement human validation checks as part of their front-end portal submission process.

 

DOES YOUR SAP POLICY MAKE THE GRADE?

I’ve been spending a lot of time reading the latest batch of Final Program Review Determination letters released by ED last month. One thing is for sure, some people still don’t understand Satisfactory Academic Progress, otherwise known as SAP. So, this month I’m writing about SAP. After all, I wouldn’t want you to have problems like these schools did.

Whether it’s deficient policies or schools simply failing to administer their own policies correctly, SAP findings continue to be a top program review finding year after year. According to the Department, each year they’ve issued findings and liabilities to dozens of schools and colleges because of SAP issues. It’s problematic because since SAP is directly connected to students’ aid eligibility. Incorrect determinations of SAP and aid eligibility, whether by policy, or by inadequate monitoring, results in ineligible disbursements. Get busted for ineligible disbursements and you’ll literally pay for it. Liabilities related to SAP in Fiscal Year 2017 ranged from $25,000 on the low end (small proprietary school) to as much as $5.6MM (mid-sized public college).

In 2011, a package of rules known as the Program Integrity Regulations went into effect. The new regulations required schools to develop, publish, and apply reasonable standards for measuring whether a student is maintaining SAP in his or her educational program. These regulations created new minimum standards institutions must use when monitoring Satisfactory Academic Progress including specific qualitative and quantitative requirements which include requirements to define pace or progression and maximum timeframe. ED gives schools flexibility in choosing the frequency of evaluations and even in choosing whether to implement provisions for financial aid warning, probation, and appeals but these topics and others, need to be addressed by your school’s policies.

Unfortunately, some colleges haven’t fully implemented these requirements going on eight years after they took effect. It’s no surprise however that ED ranks “Failure to comply with the Program Integrity Regulations that went into effect on July 1, 2011” as one of the most common SAP findings from recent program reviews.

This finding can stand on its own as a common problem, but, it’s also an overarching finding which encompasses myriad underlying SAP issues. Knowledge is power, so here are some common pitfalls to avoid and some tips for making sure your Satisfactory Academic Progress policies and procedures are compliant.

  1. Failure to develop a policy that meets the minimum Title IV requirements.

The 2011 SAP regs, require institutions to incorporate several new elements into their SAP policy. In addition to specific qualitative and quantitative requirements, requirements to define pace and maximum timeframe, and provisions for financial aid warning, probation, and appeals, an institution’s SAP policy must describe how a student’s GPA and pace of completion are affected by incompletes, withdrawals, course repetitions and transfer credits. If your policy is missing any of these elements, it might not meet the minimum Title IV requirements leading to other administrative capability issues.

The SAP policy at the college that was assessed liabilities of $5.6MM didn’t comply with the 2011 SAP requirements. As a result, the school disbursed Title IV aid to students who had failed to make SAP under ED’s current standards, students who should have been deemed ineligible for further Title IV aid due to failing to make SAP. Not all SAP issues are as egregious or costly though.

  1. Applying a different policy than the official written SAP policy.

Prior to 2011 SAP requirements were less prescriptive and there were fewer limits on aid eligibility for students who failed to make the grade. Back then, SAP, although required for aid eligibility was viewed largely as an academic measurement and thus often the responsibility of a Dean or Department Chair to develop an institution’s academic policy and to monitor student progress. Even at schools that have updated SAP policies, old policies linger in some form and it’s important to make sure you follow your official SAP policy for Title IV purposes.

668.32 states that students are expected to maintain satisfactory academic progress in their course of study according to the institution’s published standards of satisfactory academic progress.

Yes, you have to publish your SAP policy.

Yes, you have to use the one that’s published.

No, your academic policy from 1998 won’t (likely) cut the mustard here.

Now that doesn’t mean that your school can’t have another policy; for instance, something like a policy on academic standing. It’s not uncommon for colleges to have such policies since they largely don’t impact aid eligibility and are typically applied to all students including those students who are not receiving aid. The key here is that your Title IV SAP policy must be at least “as strict or stricter than other school policies”.

Having a SAP policy “as strict or stricter than other school policies” refers to the actual measurements used to monitor qualitative and quantitative standards like GPA and pace of progression. That’s why it’s important to ensure that academic policies if they exist, aren’t confused with your Title IV SAP policies. Make sure you publish your official Title IV SAP policy and follow that one. Also, if your school publishes different SAP policies for different programs or categories, you must be sure to apply the correct policy consistently to students in that category or program.

  1. Misalignment of pace of progression and maximum timeframe.

The 2011 regulations capped financial aid eligibility for undergraduate programs at 150% of the published program length in credit hours. Graduate programs are generally free to define maximum timeframe based on the length of the program. And for clock hour schools, max time frame is expressed in weeks. It’s important that your policy specifies the pace at which students are expected to progress toward program completion. The maximum timeframe is used to determine the pace of completion.

Consider the standard example for aligning pace with maximum timeframe, a four-year degree program which requires 120 credits for completion. 120 x 150% = 180 attempted credits. This is your maximum timeframe. To calculate Pace, divide 120 by 180. 120/180 = 66.67% pace requirement (rounding is permissible, and this is commonly rounded to 67%).

Let’s say for the sake of argument that your institution requires more academic rigor, thus requiring stricter SAP standards than the minimum standards required by ED. That’s okay, but you must still define both pace and maximum time frame and make sure that the two are properly aligned to one another.

As your pace requirement increases above 67%, your maximum timeframe decreases from 150%.

Let’s say that your policy requires students to make 85% pace toward completion, the maximum timeframe must be something less than 150% of your published program length.

To calculate maximum time frame, first divide 100% scheduled length by the required pace.

In this case, 120 credits is the 100% scheduled length for a bachelor’s / 85% pace = 141 credits maximum timeframe.

To test this, reverse your arithmetic and divide 120 Credits by the 141 maximum time frame and you’ll get 85% pace.  120/141 = 85% pace.

Try it with your own pace and max timeframe to see if they are aligned properly. If the math doesn’t work, you may have a problem that needs fixing.

  1. Failure to properly monitor and/or document satisfactory academic progress.

This one shouldn’t need explaining, but this issue is all too common. One school was cited for problematic transcripts which failed to list students’ course work in conjunction with each payment period. That made it extremely difficult to determine if students were making SAP. Although the school did use a SAP evaluation form, the form only included check marks indicating that qualitative and quantitative progress was checked, but the school didn’t provide any substantiating documentation of what students’ progress was, couldn’t correlate it with a transcript or proof that the evaluation was done at the end of the payment period. Although this finding was eventually closed, it highlights the concern. The school was required to revise their SAP policy and provide a  detailed narrative and supporting documentation to ED to prove students’ eligibility. Not fun!

In another program review, ED found that an online college simply wasn’t monitoring SAP and was letting students continue to receive aid despite having failed SAP. The college had no evidence that it ever put students on warning or subject students to loss of aid. It turns out, the college also failed to notify students of changes in aid eligibility. When all was said and done, ED found the college made over $700,000.00 in ineligible disbursements and hit them with a hefty liability.

In another case, ED found that one small school’s SAP policy didn’t require monitoring of its students’ progress at the correct intervals for its clock hour programs. Specifically, the institution’s policy did not monitor SAP at the end of a payment period as required. ED also found that it did not apply the Financial Aid Warning status or the Probationary status correctly because the application of these statuses additionally did not correspond to the end of a payment period.

Instead the institution’s policy assessed SAP at strange intervals of 13.5 weeks, 27 weeks, 40.5 weeks and 54 weeks when it should have monitored SAP based on the midpoint of its academic year and scheduled weeks; at the end of 450 scheduled clock hours and 18 weeks (*the school noted they used scheduled hours for SAP). As a result, the institution was required to do a full SAP file review for the two most recently completed award years, revise and update their policy and repay nearly $27,000 in ineligible disbursements to ED. For a small school, even small liabilities can break the bank. And that was just for their SAP problems…

Don’t make the same mistakes and missteps as these schools did. Do and you’re asking for trouble. Regardless of whether your school hasn’t had a program review in 20 years, or you’re PPA is up for recertification soon, take some time to look at your SAP policy and related procedures to ensure they make the grade.

ICYMY – ED TO SEND NSLDS ENROLLMENT REPORTING COMPLIANCE NOTIFICATION TO BIG OFFENDERS

NSLDS is gearing up to begin sending Enrollment Reporting Compliance Notifications in June 2019.  NSLDS Newsletter 64 provides some insight as to what’s to come for schools that fail to report enrollment status timely and properly. Here’s what is says:

Compliance Notifications will be sent to schools that are not reporting Program-Level enrollment information for a sufficient portion of their students. NSLDS tracks whether a school has reported Program-Level enrollment information for at least 90% of the students on its Enrollment Reporting Roster. 

When NSLDS determines that a school does not meet the 90% minimum threshold, the school will receive an initial warning notification from NSLDS, addressed to the school’s Financial Aid Administrator (FAA) and the Enrollment Reporting Contact, as provided on the ORG tab of the NSLDS Professional Access website.

If your school has not yet provided an Enrollment Reporting Contact for each of its locations, such as a representative from the Registrar’s Office, please do so as soon as possible. Note that this contact cannot be someone from a school’s third-party servicer.

Schools will receive a separate Enrollment Reporting Compliance Notification for each of its locations that are under the 90% threshold. 

If the school’s reporting performance does not improve, the school will receive a second warning notification addressed to the FAA and to the Enrollment Reporting Contact, with the school’s President or CEO copied.

If the school’s performance still does not improve after two warning notifications, it will receive a third notification that the school has been referred to Federal Student Aid’s Program Compliance office for consideration of possible sanctions.

This third notification will be addressed to the school’s President/CEO, with copies to the school’s FAA and Enrollment Reporting Contact.  The Program-Level reporting threshold is set at 90% to allow for instances in which a school may have a small percentage of students included on its NSLDS Enrollment Reporting Roster who are not enrolled in academic programs. While these students are not receiving aid at the reporting institution, they are enrolled in, for example, continuing education coursework.

FSA TO DELAY DISTRIBUTION OF ASSETS FOR FEDERAL PERKINS LOAN PROGRAM

At last year’s Federal Student Aid Conference, Department officials announced that institutions were not required to return the federal share of their Perkins Loan Fund because the Department was still exploring ways to reimburse institutions for their Federal Perkins Loan Service Cancellations. In a recent announcement FSA stated that institutions should not remove the institutional share from their Perkins Loan Fund and return it to their institution either.

FSA is instructing institutions to forgo reporting repayment of any federal share or institutional share in its next Fiscal Operations Report and Application to Participate (FISAP) due October 1, 2019. The amounts in both the “Repayment of Fund capital to federal government” in Part III, Section A, Line 28 and “Distribution of excess/liquid fund capital” in Part III, Section A, line 30.2 should be the same amounts as the institution reported on the FISAP submitted by October 1, 2018. Note: Institutions that have already returned the federal share of their Perkins Fund to the Department and removed their institutional share from the Perkins Fund for the 2018–19 Award Year should report these repayments on the FISAP.

FSA ID ENHANCEMENTS FOR NEXT GEN FINANCIAL SERVICES ENVIRONMENT

Last month the Department made additional enhancements to the FSA ID. The enhancements were made as part of the Next Generation (Next Gen) Financial Services Environment FSA has been implementing. The FSA ID is used by students, parents and borrowers to access websites like FAFSA.gov, StudentLoans.gov, NSLDS Student Access, StudentAid.gov, and the myStudentAid mobile app. The FSA ID is also required for access to the Application for Borrower Defense to Loan Repayment and the Federal Student Aid Feedback System.

According to a recent electronic announcement from FSA, the following enhancements were made on May 19th.

Require verified email address or mobile phone number. New FSA ID users will be required to provide either a verified email address or mobile phone number when creating an FSA ID account. Existing FSA ID users who do not already have a verified email address or mobile phone number will be prompted to provide one when logging in for the first time after implementation of this change. This enhancement ensures FSA ID users can manage their account more effectively and helps us stay in contact with FSA ID users as needed. As a reminder, a verified email address or mobile phone number can be used to log in, reset a password, retrieve a username, or unlock an FSA ID account.

Replace Create-Your-Own Challenge Questions with Pick-From-List Challenge Questions. FSA ID users must answer four challenge questions when creating an FSA ID account. The answers to the challenge questions may be required to verify the user’s identity and are an important security feature. Currently, FSA ID users select two challenge questions from a list of questions and create two challenge questions on their own. To streamline the process for users, we will remove the create-your-own option. Users will select all four required challenge questions from a list.

Add Editable Summary Page to the Create Account Process. Users will have the option to edit the summary information that is presented at the end of the process to create an FSA ID. If a user identifies an error, he or she may edit and save the information directly on the summary page, rather than having to go back to correct the information on a prior page.

IS YOUR PASSWORD ABOUT TO EXPIRE?

If you’re a “professional user” accessing Federal Student Aid Systems like COD, eCDR Appeals, FAA Access to CPS, NSLDS Professional Access or your school’s SAIG or Edconnect software, you already know that if you haven’t logged in for a while your access may have been disabled or deactivated. Beginning on June 16, 2019 Federal Student Aid will begin tracking the number of days a user is inactive in each of their systems. If a user doesn’t log into any particular system for 90 days, their access to that system will be deactivated. For example, if you’re a regular user of COD, NSLDS and FAA Access to CPS online, but rarely log in to FAA Access to CPS, only FAA Access to CPS will be deactivated if you don’t log in at least once every 90 days. If you get locked out, you’ll have to call the Access and Identity Management System (AIMS) customer service center listed for that system to have your access restored.

If you haven’t logged in for a year, your access will be permanently deactivated after 365 days of inactivity and you’ll have to have your institution’s Primary Destination Point Administrator re-enroll you. If you happen to be the Primary DPA and you somehow let your access lapse for that long…you’ll have to jump through some hoops to get access restored. But don’t worry…FSA has a new report especially for you. It’s a Monthly User Status Report. You can get it right through your Edconnect SAIG Mailbox, just look for the PDPAEAOP file. This monthly report will help you keep track of users at your school who are in danger of losing access. CHeck out this electronic announcement from Federal Student Aid for info.

2019 GAINFUL EMPLOYMENT TEMPLATE AND GE COMPLIANCE DEADLINES

The 2019 Gainful Employment Disclosure Template was released recently. Schools, colleges and universities with Gainful Employment programs are required under current law to provide information about their gainful employment programs on their website. According to an electronic announcement from Federal Student Aid, the 2019 GE Template is a simple MS Word document that school users can simply fill in and then post on the website for each respective GE program. Seems simple. Additionally, there are several new data elements that must be disclosed including:

  • Normal time to complete the program
  • Total program costs if completing the program within normal time (including tuition and fees plus books, supplies, and equipment; excluding room, board, or other expenses)
  • Median cumulative debt for Title IV students completing the program within normal time (including Federal, private, and institutional debt)
  • Licensure information for the program’s target occupation
  • URL for the College Scorecard
  • Warning language if required under 34 CFR 668.410.

Speaking of warning language, FSA notes that under the GE regulations, institutions must provide warnings for programs that could become ineligible for Title IV aid based on the next round of final D/E rates. Loss of eligibility results after receiving overall “fail” ratings in any two (2) out of three (3) consecutive award years for which rates are calculated or after receiving a combination of “fail” and “zone” ratings for four (4) consecutive award years for which rates were calculated. Warning requirements are suspended for programs with an alternate earnings appeal currently under consideration. Following the first year of D/E rates, warnings are required for programs with an overall “fail” rating for their 2014-2015 rates without a pending earnings appeal. Following the withdrawal or rejection of a program’s appeal, an institution has 30 days to revise its GE Disclosures to include the warning.

Although the Department of Education recently completed Negotiated Rulemaking and is expected to rescind these rules, institutions are required to comply with these requirements by July 1, 2019.

Beginning on July 1, 2019 institutions must be sure their templates are updated and that all promotional materials are updated with accurate and current GE disclosure info.  Additionally, institutions must begin providing a copy of the GE disclosures to prospective students before they commit to enrolling, registering or making a financial commitment to the institution. Schools have some leeway in determining how to provide these disclosures to prospective students.