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

Gainful Employment Disclosures & Template Demonstration

Session # 27

Today’s Agenda

• Status of Gainful Employment (GE) Regulations• Which Programs are GE Programs• Required Disclosures• Disclosure Availability• Disclosure Template • Compliance Tips• GE Resources

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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

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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

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• 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”

Which Programs are GE Programs

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Generally, all non-degree programs must lead to

gainful employment

Generally, most programs at for-profit

institutions must lead to gainful

employment


• 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

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• 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

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• GE Programs include –• Teacher certification programs leading to a certificate awarded by

the institution• ESL programs

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• 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

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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

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• 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

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

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

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• Example: On-time completion rate if 200 students completed in most recent award year

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200

150

Total number of students who completed in the 2012-2013 AY

Number of students who completed within normal time

0.75 200 ÷150

75% 100 × 75.0


• 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

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• 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

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• 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

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• 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

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• 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

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• 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

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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

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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

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Disclosure Template

• Released November 2013!• Institutions must update their disclosures with the most

recent information using the template by January 31, 2014

Disclosure Template

• What is the template?• An application that creates a standardized webpage with the gainful

employment disclosure information

• The application: 1.Collects data from an institution

2.Combines the institutional data with ED data

3.Creates a consistent, consumer-friendly webpage

• Similar to Net Price Calculator template, but GE template is required

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

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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

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Disclosure Template

OPEID

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Disclosure Template

Program CIP

Program Name

Credential Level

SOC code(s)

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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)

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Disclosure Template

Costs

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Disclosure Template

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

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Disclosure Template

# of Completers

Median Loan Debt

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Disclosure Template

Normal Time

Number of On-Time Completers

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Disclosure Template

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

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Disclosure Template

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Methodology

Rate

Accreditor Name

Disclosure Template

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Methodology

Rate

State Name

Disclosure Template

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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!

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Disclosure Template

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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

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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

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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”

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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?

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GE Resources

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

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GE Resources

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GE Resources

• If you still have questions after reviewing the Dear Colleague Letter, Electronic Announcements, and FAQs, send your questions to [email protected]

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Contact Information

• Jessica Finkel, Office of Postsecondary Education• Phone: 202-502-7647• E-mail: [email protected]

• Cynthia Hammond, Federal Student Aid• Phone: 202-377-4236• E-mail: [email protected]

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Gainful Employment Disclosures & Template Demonstration

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