Jeff Baker & Lynn Mahaffie| Dec. 2015

U.S. Department of Education

2015 FSA Training Conference for Financial Aid Professionals

Welcome & Federal UpdateGS1

Administration Priorities

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Administration Priorities President’s 2020 Goal: By 2020, America will once again have the highest proportion of college graduates in the world.Themes:Increasing accessMaking college more affordableImproving outcomes 3

Access

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Access: First Lady’s Reach Higher Initiative Exposing students to college/career

opportunities – encourage students to reach for the best college they can attend

Encouraging academic planning and summer learning

Understanding financial aid Supporting high school counselors

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Access: FAFSA Promoting FAFSA Completion FAFSA Simplification Early FAFSA Prior-Prior Year

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Access: Experimental Sites Second Chance Pell Pilot Program

Waivers to allow incarcerated individuals to receive Pell Grants for postsecondary education

Dual EnrollmentWaivers to allow students who are enrolled in high school to receive Pell Grants for enrollment in Title IV-eligible postsecondary programs

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Affordability

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Affordability: Front End Strategies

America’s College Promise Increase in Pell Grant funding First in the World (FITW) Competency-Based Learning Educational Quality Through Innovative

Partnerships (EQUIP)9

Affordability: America’s College Promise Proposal would make two years of college free

and universal Students would be able to secure an

associate’s degree or certificate, earn the first half of a bachelor’s degree, and gain skills needed in the workforce at no cost

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Affordability: Increases in Pell GrantMaximum Award

2008-2009 $4,7312015-2016 $5,775

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Affordability: First in the World Discretionary grant program designed to spur

innovation to drive down costs while maintaining quality

Program focuses on students most likely not to persist and graduate

Tests and evaluates practices for cost effectiveness, maintains quality, and facilitates replication

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Affordability: Experimental Sites Competency-Based Learning

Creates flexibility by allowing students to progress as they demonstrate mastery of content

Educational Quality Through Innovative Partnerships (EQUIP)Accelerates and evaluates partnerships with non-traditional providers

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Affordability: Back End Strategies

Student Aid Bill of Rights Income-Driven Repayment Plans

Pay As You Earn (PAYE) Revised Pay As You Earn (REPAYE)

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Affordability: Student Aid Bill of Rights

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Affordability: Pay As You Earn (PAYE) Caps payments for Federal Direct Student

Loans at 10 percent of discretionary income for eligible borrowers

Helps ensure that borrowers are able to manage their debt and avoid defaulting on their student loans

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Affordability: Pay As You Earn (PAYE) Provides relief on loan payments, especially in

a borrower’s early years of repayment Complements other repayment plans that help

borrowers manage their debt Conference Session #33

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Affordability: REPAYE Regulations Negotiations held February - April, 2015 -- consensus

reached on a Revised Pay As You Earn repayment plan (REPAYE) that extends the 10 percent income cap to all borrowers regardless of when they borrowed

Published final regulations October 30, 2015Early implementation in December 2015

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Affordability: Student Aid Bill of Rights Protects Social Security benefits of borrowers with

disabilities who may qualify for a loan discharge or other repayment options

Ensures that the debt collection process for defaulted Federal student loans is fair, transparent, and reasonable (compensation of collection agencies, guidance provided to collection agencies, ensuring accurate information provided)

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Outcomes

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Outcomes

College Scorecard Accreditation Executive Actions and Legislative

Proposals Gainful Employment Regulations

Consumer protections and informationDebt to earnings ratios

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Outcomes: College ScorecardInteractive tool – new data recently addedHighlights key indicators about institutions’ costs and valueHelps students and families decide where to enroll for postsecondary education Allows comparison of schools based on simple criteria

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Outcomes: College Scorecard Scorecard data include:

Costs Graduation Rates Loan Default Rates Loan Repayment Rates Average Amount Borrowed Employment Earnings

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Outcomes: Accreditation Executive actions and a legislative proposal

designed to: Increase transparency in the accreditation process Increase coordination within the Department and

among accreditors to improve institutional oversightEncourage greater attention to outcomes within

current accreditor review processes

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Regulatory Update

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Recent & Upcoming Regulatory Efforts Revised Pay As You Earn (REPAYE) Program Integrity and Improvement (Cash

Management) Teacher Preparation Borrower Defenses State Authorization

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Program Integrity and Improvement Final regulations published in October 2015 Effective July 1, 2016 Cash Management provisions ensure students:

Have convenient access to their Title IV, HEA program funds

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Program Integrity and ImprovementDo not incur unreasonable and uncommon financial account fees

Are not led to believe they must open a particular financial account to receive their Federal student aid

Conference Session #21

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Program Integrity and Improvement Other Program Integrity and Improvement

Provisions:Clarify how previously passed coursework is treated for Title IV eligibility purposes

Streamline the requirements for converting clock hours to credit hours

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Teacher Preparation Goal: To help ensure teacher preparation programs are preparing educators who are ready to succeed in the classroom Proposed regulations: Would focus Title II reporting on outcomes, including student achievement, employment, teacher and principal survey information, and tie outcomes to Title IV TEACH Grant eligibility

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Teacher Preparation

Negotiations held in 2012Consensus not reachedNPRM published on December 3, 2014Received nearly 5,000 commentsAnticipated publication of final regulations this month

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Borrower Defenses Two September 2015 public hearings in

Washington and San Francisco Federal Register Notice announcing negotiator

nominations and schedule of committee meetings published on October 20, 2015

Negotiator nominations were due November 19, 2015 - 33 nominations received32

Borrower Defenses Negotiations scheduled for:

Jan. 12-14, 2016 Feb. 17-19, 2016March 16-18, 2016

Anticipate publishing proposed rules this summer Anticipate publishing final rules by November 1,

201633

Borrower Defenses Negotiated Rulemaking Committee will consider:

Procedures for a borrower to establish defense to repayment

Criteria that will be used to identify acts or omissions of an institution that constitute defenses to repayment

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Borrower Defenses Negotiated Rulemaking Committee will consider:

Standards and procedures that ED will use to determine school liability for amounts based on borrower defenses

Effect of borrower defenses on institutional administrative capability assessments

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Violence Against Women Act (VAWA)

Signed by President on March 7, 2013Final rules published on October 20, 2014Regulations became effective July 1, 2015Conference Session #38

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Violence Against Women Act (VAWA)Requires institutions to:

Maintain statistics on dating violence, domestic violence, sexual assault, and stalking

Provide, and describe in annual security reports, prevention and awareness campaigns

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Violence Against Women Act (VAWA)Requires institutions to:

Provide a prompt, fair, and impartial disciplinary proceeding, and provide for requirements governing that proceeding

Provide information and support services to victims Department revising the Clery Handbook to reflect

VAWA regulations

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State Authorization Requirements Under regulations published October 29, 2010, in

order to receive Title IV funds, institutions are required to have State authorization, including:Approval to provide postsecondary education programs

A student complaint process Conference Session #20

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Prior – Prior and Early FAFSAConference Session #49

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Early FAFSA President’s Announcement –

FAFSA Start-Up on October 1 Use of Prior-Prior Income Data

Beginning with the 2017-2018 FAFSA October 1, 2016 2015 Tax Year

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Questions?

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Prior-Prior and Early FAFSA Issues

Outreach Professional Judgement Verification Conflicting information

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2016-2017 FAFSA/ISIRConference Session #GS2

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FAFSA – List of Schools Beginning with the 2016-2017 FAFSA the names

of the colleges listed by applicants on FAFSAs will not be included on ISIRs sent to institutions.

Will continue to be included on ISIRs provided to state grant agencies

Will be on SARs provided to FAFSA applicants.

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Paper FAFSAs More than 99 percent of FAFSAs are filed

electronically. Beginning with the 2016-2017 FAFSA we will no

longer print the FAFSA as a color packet. PDF FAFSA available on-line to be printed Call 1-800-4FEDAID to request a copy

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FFEL/Direct FY ‘12 Cohort Default Rates

Conference Sessions #15 and 16

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FY ‘12 Cohort Default RatesSchool Type

STATE FY 11’ CDR FY 12’ CDR

Public – Two Year 20.5% 19.1%Public – Four Year 8.9% 7.6%Non-Profit – Two Year 15.6% 16.1%Non-Profit – Four Year 7.0% 6.3%For-Profit – Two Year 20.0% 17.7%For-Profit – Four Year 18.6% 14.7%Foreign 3.8% 3.3%All Schools 13.7% 11.8%

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Perkins Loan Program

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CommunicationsDear Colleague Letter GEN-15-03Electronic AnnouncementsQuestions and Answers

Perkins Loan Program

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Program ended on September 30, 2015Schools may not make Federal Perkins Loans to

new borrowers after September 30, 2015.

Perkins Loan Program

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2015-2016 Awards – If prior to October 1, 2015, a school made the first disbursement of a Perkins Loan to a student for the 2015-2016 award year, the school may make any remaining disbursements of that 2015-2016 loan after September 30, 2015.

Perkins Loan Program

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Grandfathering Allows a school to make additional Perkins Loans to

certain students for up to five additional years (through September 30, 2020) to enable the students “to continue or complete courses of study”.

Loans can be made only if all of the following conditions are met:

Perkins Loan Program

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School made at least one Perkins Loan disbursement to the student on or before June 30, 2015. Results in 2015-2016 being a “gap” year.

Student is enrolled at the same school and in the same academic program as when the last Perkins Loan disbursement was received.

Need remains after Direct Subsidized loan is awarded

Perkins Loan Program

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Excess Liquid CapitalDCL GEN-15-19Attached Excel Work-Sheets

Calculate Excess Cash Calculate Federal/School Shares

Return Federal Funds by December 31, 2015

Perkins Loan Program

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ATB and Career Pathway Programs

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ATB and Career Pathway ProgramsAllows for Ability-to-Benefit (ATB) alternatives for students without a high school diploma, or equivalent (or home schooled) who are enrolled in an eligible “Career Pathway” “Program”.

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ATB and Career Pathway ProgramsATB –

Pass an ED approved ATB test State Process (none have ever been

submitted) Complete six credit hours (or equivalent)

Beginning July 1, 2015, reduced Pell Grant payment schedule

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Career Pathway Program Concurrently enrolls students in “connected adult

education” and an eligible Title IV programProvides “structured course sequences”Provides opportunities for accelerationOrganized to meet the needs of adults

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Career Pathway Program Aligned with the education and skill needs of the

regional economyProvides counseling and support servicesDeveloped in collaboration with business,

workforce development, and economic development.

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SequestrationSee DCL GEN-15-07

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Sequestration – Grants

TEACH Grant and Iraq-Afghanistan Service Grant awards reduced by 6.8% for FY 2016 (first disbursed between October 1, 2015 and September 30, 2016).

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Sequestration – Loan FeesSubsidized Loans and Unsubsidized Loans –1.068 percent for loans first disbursed on or

after October 1, 2015 and before October 1, 2016.

PLUS Loans (Parent and Grad Student) –4.272 percent for loans first disbursed on or

after October 1, 2015 and before October 1, 2016

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Correct and Timely Reporting

Conference Session #10

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Correct and Timely ReportingCOD –

Program informationNSLDS –

Enrollment, including academic program GE Reporting

CPS – Professional Judgement Results of V4 and V5 Verification

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Protecting Student Information

Conference Session #43

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Protecting Student Information Dear Colleague Letter GEN-15-18

Reminds institutions (and their third-party servicers) of their continuing obligations to protect data used in all aspects of the administration of the Title IV Federal student financial aid programs.

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Protecting Student InformationExpectation is that all institutions will assess and implement strong security policies and controls and undertake ongoing monitoring of the systems, databases and processes that support all aspects of the administration of the Federal student financial aid programs

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Protecting Student InformationThe SAIG Enrollment Agreement includes a provision that the institution – Must ensure that all Federal Student Aid applicant information is protected from access by or disclosure to unauthorized personnel.

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Protecting Student InformationThe SAIG Agreement includes a provision that in the event of an unauthorized disclosure or an actual or suspected breach of applicant information or other sensitive information (such as PII) the institution must immediately notify FSA at CPSSAIG@ed.gov.

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Protecting Student InformationUnder various Federal and state laws and other authorities, including the HEA; FERPA; the Privacy Act of 1974; the Gramm-Leach-Bliley Act; state data breach and privacy laws; institutions may be responsible for losses, fines and penalties (including criminal penalties) caused by data breaches.

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Protecting Student InformationWithin the SAIG Agreement and the PPA, institutions must comply with the Gramm-Leach-Bliley Act. Under Title V of the Gramm-Leach-Bliley Act, financial services organizations, including institutions of higher education, are required to ensure the security and confidentiality of customer records and information.

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Gainful EmploymentSee DCL GEN-15-12

Conference Sessions #30 and #31

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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 institution and leads to a degree; or

Prepare students for gainful employment in a recognized occupation.

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Which Programs are GE Programs? At public institutions and non-profit institutions, all

non-degree programs are GE Programs except for - Programs of at least two years in length that are designed to be fully transferable to a bachelor’s degree program, and

Preparatory coursework necessary for enrollment in an eligible program

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Which Programs are GE Programs? 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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Gainful Employment Final rules published on October 31, 2014 Rules became effective July 1, 2015 Published Dear Colleague Letter GEN-15-12

summarizing the rules

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Gainful Employment MeasureDebt-to-earnings (D/E) ratesAnnual Earnings D/E rateDiscretionary Income D/E ratePass: Annual D/E < = 8% or Discretionary D/E < = 20% Fail: Annual D/E > 12% and Discretionary > 30% Zone: Annual D/E > 8% and < = 12% or Discretionary D/E > 20% and

<= 30%

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Gainful Employment Results Program’s loses Title IV eligibility if:

D/E measures – Fails in two out of three years;

ORD/E measures - Fails or in the zone for four

consecutive years

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Important Dates

REPORTING

JUL 31, 2015 (For 2008/2009 to 2013/2014 Data)

OCT 01, 2015 (For 2014/2015 Data)

COMPLETERS LIST CHALLENGES DUE FROM

INSTITUTIONS

45 days

DRAFT DEBT-TO-EARININGS RATES TO

INSTITUTIONS

SUMMER 2016

DRAFT DEBT-TO-EARNINGS RATES CHALLENGES DUE

FROM INSTITUTIONS

45 Day Challenge Period

RELEASE FINAL DEBT-TO-EARNINGS RATES TO

INSTITUTIONS

WINTER 2016

COMPLETERS LIST FOR INSTITUTIONS

Winter 2015/2016

DISCLOSURES (UPDATES)

JANUARY 2016

DISCLOSURES (NEW REGULATORY

REQUIREMENTS)

JANUARY 2017

PROGRAMCERTIFICATIONS

DECEMBER 2015 & Ongoing

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GE Reporting Report all Title IV Students by July 31, 2015

Report 2008 – 2009 through 2013 – 2014 award years. Programs with Medical and Dental Residencies report 2007 – 2008 through 2013 – 2014 award years.

Report following award years by October 1.

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GE Corrections and Challenges Important information and data –

Completer Lists – Winter ‘16Draft D/E Rates w/Backup Data – Summer ‘16Final D/E Rates w/Backup Data – Winter ‘16

Regulatory timeframes for responses

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GE Corrections and Challenges Each Institution Must –

Establish SAIG Mailbox for GE FilesRegister for the Data Challenges and Appeals Solution(DCAS) using Participation Management

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GE Program Certifications December 31, 2015 – Transitional Certifications

Due Signed by institutions CEO Certifications renewed when institution

recertifies Program Participation Agreement (PPA)

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GE Program Certifications Each GE Program is:

Approved by accrediting agency and State. Is programmatically accredited if that is required

for that profession in the state. Graduates qualify to meet licensing or certification

exam requirements to work in the state, if any.

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Gainful Employment DisclosuresBeginning in 2017, in addition to program

information required disclosures could include: D/E rates Program cohort default rates Loan repayment rates Median loan debt Percent borrowing

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Gainful Employment DisclosuresBeginning in 2017, in addition to program

information required disclosures could include: Completion rates Withdrawal rates Placement rates

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Experimental Sites

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Experimental SitesCurrent –

Pell for short-term career programsPell for students with a bachelors degreeReduced Unsubsidized Loans

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Experimental Sites New –

FWS for High School TutorsPrior Learning AssessmentsCompetency Based EducationLimited Direct Assessment

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Experimental SitesComing –

Expanded Competency Based Education“Second Chance Pell” for incarcerated studentsDual Enrollment – High school and postsecondaryLoan Counseling

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Recent Dear Colleague Letters

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Recent Dear Colleague Letters GEN-15-18: Protecting Student Information GEN-15-15: Implementation of the VAWA Final Regulations GEN-15-12: Regulatory Requirements Related to Gainful Employment

Programs GEN-15-11: 16-17 FAFSA® Information to be Verified and Acceptable

Documentation

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Recent Dear Colleague Letters GEN-15-08: Citizenship and Immigration Status

Documentation GEN-15-06: Loan Counseling Requirements and

Flexibilities GEN-15-01: Third-Party Servicer Institutional

Requirements and Responsibilities

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Thank You

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