Consumer Information Boot Camp - Amazon Web Servicesdocs.accet.org.s3.amazonaws.com/.../handouts/consumer_bootcam… · Presentation Outline General CI Strategy • CI Resources,

Consumer InformationBoot Camp

ACCET 2014 Annual Conference

November 4, 2014

Introduction

Thompson Coburn LLP• Full-service firm with 375+ attorneys

• Offices in Chicago, Los Angeles, St. Louis, Southern Illinois, andWashington, D.C.

Higher Education Practice• Counsel clients concerning federal, state, and accrediting agency laws and

standards, to include federal financial aid programs and consumer information.

• Represent institutions in litigation, as well as administrative proceedings beforestate licensing entities, accrediting agencies, and federal government.

• Assist clients with the postsecondary mergers and acquisitions, contract draftingand negotiation, policy creation and implementation, and compliance systemsdesign.

Introduction

Aaron D. Lacey

• Partner, Higher Education Practice

• Served four years as Senior Vice President of RegulatoryAffairs and Strategic Development for a multi-campus,postsecondary education company, with 24 campus locationsand online division.

• Prior to going in-house, served eight years in thepostsecondary education practice of prominent Washington,D.C. law firm.

Presentation Outline

General CI Strategy

• CI Resources, CI Systems, Housing CI, Tracking CI,Disclosing CI

Strategy for Select CI Disclosures

• Net Price Calculator, Annual Security Reports, Drug andAlcohol Prevention Information, Student-Right-to-Know,Voter Registration, FERPA, Gainful EmploymentDisclosures

General ConsumerInformation Strategy

CI Resources

IFAP Consumer Information Page• CI Disclosures at a Glance (31 Pages; last updated April

2014)

• 11 Training Activities (last updated 2012-2014)• Institutional and Financial Assistance Information, Drug and Alcohol

Prevention, Consumer Information for Student Athletes StudentRight-to-Know Act, Campus Security, FERPA, Safeguarding CustomerInformation, Fire Safety Reports and Student Housing,Misrepresentation, Loan Disclosures, Gainful Employment Disclosures

• http://ifap.ed.gov/qahome/qaassessments/consumerinformation.html

CI Resources

Higher Education Compliance Alliance

• Created by the National Association of College andUniversity Attorneys in partnership with thirty otherhigher education associations, provides centralizedrepository of information and resources forcompliance with federal laws and regulations.

• Includes Resources by Topic and Compliance Matrix

• http://www.higheredcompliance.org

CI Resources

Campus Legal Information Clearinghouse

• Collaborative effort between American Council onEducation and The Catholic University of America'sOffice of General Counsel.

• Resources by Topic

• http://counsel.cua.edu

CI Resources

REGucation: Higher Ed Law and Policy Blog

• Offers practical advice and insight to assistpostsecondary community to manage regulatoryenvironment.

• Covers universe of disclosure, reporting, and trainingrequirements associated with participation in thefederal student aid programs.

• http://thompsoncoburn.com/news-and-information/regucation.aspx

CI Systems

• Consumer information is an institutionalresponsibility; key data are controlled andproduced by a wide range of individuals withinthe organization.

• Create systems designed (1) to direct to yourattention information or correspondencerelating to your CI responsibilities and (2) tofacilitate coordination among campuses andadministrative verticals.

CI Systems

• Create Regulatory Correspondence Policy

• Requires that all substantive correspondenceto/from regulators be copied to thoseresponsible for CI

• Use CI flow charts

CI Systems

2013-2014 Gainful Employment Disclosure Template (GEDT) Flow Chart

Following, please find a listing of each data element that will be entered into the Gainful EmploymentDisclosure Template in order to generate the required GE Disclosures for each program at each campus, for the2012-2013 school year. Each data element is annotated to indicate the source of the required data. Unlessotherwise stated, the period under review is July 1, 2012, through June 30, 2013. We are producing GEDTtemplates only for Title IV eligible programs.

· 6-Digit OPEID Code. This data can be generated from CV in connection with the primary data pull.

· 8-Digit OPEID Code. This data can be generated from CV in connection with the primary data pull.

· CIP Code. This data can be generated from CV in connection with the primary data pull. We agreed thatwe would use the 6-digit CIP Code associated with the most recent version of each program.

· Approved Name for Program. This data can be generated from CV in connection with the primary datapull. We agreed that we would use the program name associated with the most recent version of eachprogram. Compliance will quality check the name against the approved program name listed on the ACCSCwebsite, prior to entering the data into the GEDT.

· Credential Level. This data can be generated from CV in connection with the primary data pull.

· SOC Codes and Accompanying Occupation Titles. This data can be selected for each program during thedata entry process.

· Tuition and Fees (for the entire program, assuming normal time completion). This data can begenerated from CV in connection with the primary data pull. We agreed that we would use the tuition andfees associated with the most recent version of each program. We also agreed that we would pull the tuition

CI Systems

• Automate Monitoring of ExternalResources

• My IFAP (Electronic Announcements, DCLs)

• NASFAA, NAICU, AACC, APSCU

• Inside Higher Education, Chronicle

• Create a Compliance Calendar

CI Systems

SCHOOL AGENCY SUMMARY OF FILING, RESPONSE, OR REVIEWDUE TO

COMPLIANCEDUE TO AGENCY STATUS STATUS COMMMENTS

School A City X Submit Business License Application to City X upon

receipt of sales tax identification number.

4/1/13

School B ACCSC Onsite visit for Paralegal will be scheduled between

4/1/13 & 7/31/13. (When possible, this entry should

be updated to the date set by ACCSC for the visit.)

4/1/13*

School C City Y Liquor License Renewals due to the City Y. 4/1/13 2/13-Fingerprinting required.

School B State of TN Corporate Annual Report due to Secretary of State in

Tennessee

4/1/2013*

School B TWC Update PS-005 4/1/2013*School A USDE IPEDS Spring Collection Closes. 4/10/13

School D NCCPE Audited Financial statements due to the Nebraska

Coordinating Commission for Postsecondary

Education (Nebraska State Grant program).

3/15/13 2/25- Fwd Financial Statements upon

reciept.

School X ACCSC Student Satisfaction Report due to the Accrediting

Commission of Career Schools and Colleges.

4/1/12 4/15/13

School A IBHE Annual Renewal Application due to the Illinois Board

of Higher Education.

4/15/13 2/22- Applications submitted after this

date are not guaranteed a response by

June 30, 2013.School A WIA Quarterly WIA State of Tennessee Report due to the

Tennessee Department of Labor and Workforce

Development, Division of Workforce Development.

4/16/2013*

All Schools IPEDS Spring IPEDS (Integrated Postsecondary Education

Data System) Data Collection closes (Fall Enrollment,

Graduation Rates & Finance) closes for Coordinator.

4/25/2013*

School B OSBCCS Agent Permit Renewals due to the Ohio State Board of

Career Colleges and Schools-Stambaugh & Meleg

4/27/2013*

School C ACCSC Change of Location On-Site Evaluation Visit 4/30/13 1/10 Form and fee due 2/10

School D City X City X Liquor License Expires. 4/31/2013* 9/11/11- Renewal application due to

the city 4/1.

* Indicates that this event has not yet been confirmed for the current year, but occurred in the prior year on this date.

Orange coloring denotes an on-site visit by agency personnel.

Purple coloring denotes an approval expiration.

APRIL

MAY

Housing CI

• Build a Resource Library• Compliance Calendar

• Official Correspondence

• Unofficial Correspondence

• Current and Past CI Disclosures

• Flow Charts and Evidence of CI Distribution

• Laws and Regulations

• Agency Guidance

• Agency Tutorials and Training

Disclosing CI

• Build a CI Website• Post everything! Well, almost everything...

• Holds all CI for all brands, unless prohibited,or bad for business

• Easier for students and regulators

• Easier for staff

• Facilitates Notice and Distribution

• Mitigates exposure to student litigation

Drafting CI

• If possible, makes notices and disclosureslocation, time, and brand neutral

• Include revision date• Consider including annual distribution date if

annual distribution required• Place on company or school letterhead• Include statement regarding consistency

between oral statements and written disclosure• Take advantage of opportunity to offer

explanatory comments

Strategies for SelectConsumer InformationDisclosures

Requirement: Must post net price calculator onwebsite and include prominent disclaimer:

• Stating estimate is not final, is not binding, andmay change;

• Stating that student must complete FAFSA to beeligible for FSA funds; and

• Providing link to USED FAFSA website.

February: Net Price Calculator


Timing: Must update NPC on an annual basis.USED releases updated versions of NPCtemplate in January annually (e.g., template for2013-14 data will be released in January 2015).Institutions using USED NPC template shouldupdate their NPC shortly thereafter.


Strategy: Use USED template; create CI flowchart; place link to NPC on CI Website.

Citation: 20 U.S.C. 1015a(a); 20 U.S.C. 1015a(h);DCL GEN 08-12, page 33.

Key Resource:http://nces.ed.gov/ipeds/resource/net_price_calculator.asp

March: Annual Security Reports

Requirement: Each year, must (1) distribute toall students and employees Annual SecurityReport, to include crime statistics for incidentsthat occur on campus (2) report crime statisticsto Department, and (3) if applicable, compileand distribute annual fire safety report.Prospective students and prospective employeesmust receive notice of report and receive reportupon request.


Timing: Updated ASR and crime statistics mustbe published by October 1. Gathering crimestatistics is most challenging piece, start early topermit time for agencies, campuses, andsecurity personnel to respond.


Strategy: Ensure agency letter is detailed; use USEDtemplates; keep copies of all correspondence; trackcorrespondence and completion of tasks; post ASRto CI Website and distribute notice to new studentsand employees and annually to all; ensure noticesatisfies specific requirements.

Citation: 34 CFR 668.41(a); 34 CFR 668.41(e); 34CFR 668.46; 34 CFR Part 668 Subpart D, Appendix A.

Key Resource:http://www2.ed.gov/admins/lead/safety/campus.html;http://clerycenter.org.

Lagniappe: VAWA

• In March 2013 Violence Against WomenReauthorization Act of 2013 (VAWA) amended CleryAct requiring schools (1) to compile statisticsconcerning sexual assault, domestic violence, datingviolence, and stalking; and (2) to adopt policies,procedures, and programs pertaining to these crimesin their ASR.

• Under VAWA, 2014 ASR should have included newpolicies, as well as new statistics for 2013 (best effort).New statistics for 2013 and 2014 will be reported in2015 ASR.

• New regulations issued October 20, 2014. Reviewcarefully - they go well beyond VAWA!

April: Drug & Alcohol Abuse Program

Requirement: Must institute drug and alcohol abuse program,consisting of at least two parts:1. Annually distribute in writing to each student and employee:

• Standards of conduct that clearly prohibit the unlawful possession, use, ordistribution of illicit drugs and alcohol by students and employees on theschool’s property or as part of any of the school’s activities

• Description of applicable legal sanctions under state, local, and federal law

• Description of health risks

• Description of available counseling, treatment, rehabilitation, or re-entryprograms

• Clear statement that school will impose sanctions for violation ofstandards of conduct and a description of sanctions

Students who enroll or employees who are hired after the annual distributionmust receive the information.


2. Conduct biennial review of school’s Drug and Alcohol Abuseprogram that:

• Determines the effectiveness of the program and implementsneeded changes

• Determines the number of drug and alcohol-related violationsand fatalities that occur on the school’s campus or as part ofthe school’s activities, and are presorted to campus officials

• Determines the number and type of sanctions that areimposed

• Ensures that sanctions are consistently enforced

Biennial review is available to public upon request.


Timing: Flexible, can be carried out at any pointduring year.

Strategy: Distribute annually to every studentand employee and supply to all new studentsand employees upon arrival; have students andemployees sign evidence of receipt; save annualdistribution notices and record results ofbiennial review; post info to CI Website; ensurepolicies match ASR.


Citation: 34 CFR 86

Key Resource:http://ifap.ed.gov/qahome/qaassessments/consumerinformation.html

Lagniappe: FSA Penalties for Drug Violations

Effective August 14, 2008, must provide to everystudent upon enrollment a separate, clear, andconspicuous written notice with information on theFSA Penalties for drug law violations detailed in 20U.S.C. 1091(r)(1). Also, to any student who has lostFA eligibility due to drug law violations, mustprovide separate, clear, conspicuous written noticeof the loss and advise of ways to regain eligibilityunder 20 U.S.C. 1091(r)(2). See 34 CFR 668.40; DCLGEN 08-12, pages 101 through 102.

Lagniappe: FSA Penalties for Drug Violations

Prepare separate, one-page notice withsignature block, provide with Drug and AlcoholAbuse Program disclosure; save annualdistribution notice; post info to CI Website.

May 1: Emergency System Test

Requirement: Must develop and test emergencyresponse and evacuation procedures on at leastan annual basis.

Timing: May 1 - because its May Day!

Strategy: Record evidence that test wasconducted; remember that this is not just acompliance exercise; consider third-partyproviders.

May 1: Emergency System Test

Citation: 34 CFR 668.46(g)(6).

Key Resources:http://www2.ed.gov/admins/lead/safety/campus.html;http://clerycenter.org.

June: Student-Right-to-Know

Requirement: Must annually make availablecompletion/graduation rate and, if applicable,transfer-out rate; must circulate detailed noticeof availability.

Timing: Annual notice can be made at any time,but must publish most recent SR2K data by July1 of each year; data reported annually in IPEDSGraduation Rate Survey (closed February 26 in2014).

June: Student-Right-to-Know

Strategy: Old model disclosure no longersufficient; leave time to produce disaggregateddata; make sure disclosure explains data; postdata to CI Website and circulate detailed notice;keep record of notice distribution.

Citation: 34 CFR 668.41(a) - (d); 34 CFR 668.45;34 CFR 668.8(b)(1)(ii)

Key Resource:http://ifap.ed.gov/qahome/qaassessments/consumerinformation.html

Lagniappe: Retention Rates

• Must make available the retention rate ofcertificate or degree seeking, first-time,undergraduate students; must circulate detailednotice of availability. 34 CFR 668.41(d)(3).

• Include with SR2K disclosure; Data reported inIPEDS Fall Enrollments Survey (closed April 23 in2014); will be available for easy inclusion.

• Make sure disclosure explains data; post data toCI Website and circulate detailed notice; keeprecord of notice distribution.

DEFUNCT SR2K disclosure

Student Right-to-Know RatesAs of July 1, 2010

______________________________________________________

Student Right-To-Know refers to a federally-mandated public disclosure ofan institution’s Completion/Graduation Rate and Transfer-Out Rate. Thisinformation is provided in compliance with the Higher Education Act of1965, as amended. This is a "cohort" study; that is, a group of students whoare first-time freshmen who are enrolled full-time and are degree-seeking isidentified in a fall term and their outcomes are measured over a period oftime.

The outcomes measured are Completion/Graduation (the total number ofstudents in the cohort who earn either a degree, a certificate, or whosuccessfully completed a two-year-equivalent transfer-preparatory program)and Transfer-Out (the total number of cohort non-completers who wereidentified as having enrolled in another institution).

Graduation (and transfer-out) rates do not include students who left theschool to serve in the armed forces, on official church missions, or in theforeign service of the federal government. Students who died or were totallyand permanently disabled are also excluded.

The completion/graduation rate at Sample College is 59%.

Sample modern SR2K disclosure

Student-Right-to-Know and Federal Retention Rate Disclosure

Our School Effective Date: July 1, 2014

Pursuant to the federal Student Right-to-Know Act, on an annual basis, our school determines and makes available an

overall graduation rate of certificate or degree-seeking, first-time, full-time, undergraduate students. In addition, ourschool also provides the Student-Right-to-Know graduation rate disaggregated by various sub-categories, as

determined and defined by the U.S. Department of Education.

The Student Right-to-Know graduation rate is based on a "cohort study,” meaning that a group or “cohort” of students is

identified and then monitored over a period of time. The current rates, set out below, are based on the group ofstudents who enrolled for the first-time, as full-time students, between September 1, 20XX and August 31, 20XX. The rate

represents the number of those students who earned their degree or certificate within 150% of the normal time requiredto complete their program. The rate does not include students who left school to serve in the armed forces, on official

church missions, or in the foreign service of the federal government. Students who died or were totally and permanently

disabled also are excluded.

It’s important to note that the Student Right-to-Know graduation rate is calculated at the school level. In other words,there is one rate for the entire school, not a rate for each specific program. Certain institutions also are required to

calculate and distribute graduation or completion rates for students receiving athletically related student aid, as well astransfer-out rates. These requirements, however, are not applicable to our school. The most recent, disaggregated

Student-Right-to-Know graduation rate for our school is set out in the following chart:

Student Category Number of Students Number Graduating

Within 150%

Graduation

Rate

Men

Women

Nonresident Alien

Hispanic/Latino

Sample modern SR2K disclosure

Sample Student-Right-to-Know and Federal Retention Rate Disclosure (Effective: Month XX, 2014)

Our School Page 1 of 1

Race and Ethnicity Unknown

Received Pell Grant

Received Subsidized Stafford Loan but no Pell Grant

Received No Subsidized Stafford Loan or Pell Grant

OVERALL

Our school also makes available each year a federal retention rate, which is the percentage of first-time, full-timestudents from the previous fall who are still enrolled, or successfully completed their program, the following year. Like the

Student-Right-to-Know graduation rate, this retention rate is based on a cohort study and calculated at the school level

(i.e., there is one rate for the entire school, not a rate for each specific program). The most recent federal retention rate

for our school is set out in the following chart:

Number of Students in Fall 2010 Number Still Enrolled or Completed as of Fall 2011 Retention Rate

Current and prospective students may request a paper copy of this disclosure from the Campus Director, or by [email protected]. This disclosure also is available on our school’s website at www.ourschool.edu/right2know.

The Student-Right-to-Know graduation rate for our school is based on data reported by the school in connection withthe National Center for Educational Statistics (NCES) Integrated Postsecondary Education Data System (IPEDS) 20XX-

20XX Graduation Rate Survey. The federal retention rate is based on data reported by the school in connection with theNCES, IPEDS 20XX-20XX Enrollment Survey.

“-“ Indicates that there were no students in this category, or that the student population for this category is too small to be disclosed withconfidence or confidentiality (i.e., 10 or fewer students).

August: Voter Registration Information

Requirement: Make good faith effort to distributevoter registration form (for federal elections andstate elections for governor or other State chiefexecutive) to every student. Will be considered incompliance if electronically distribute voterregistration form (can provide link where form canbe downloaded). Electronic message must bedevoted exclusively to voter registration.

Timing: Quarterly distribution best. But in theleast, must be sufficiently in advance of Novemberelections.

August: Voter Registration Information

Strategy: Provide quarterly notice to all students(and employees) via email with link to registrationform on state site; discuss importance of voting, setout state and federal election calendar; keep recordof distribution notice; post information to CIWebsite.

Citation: 20 USC 1094(a)(23) and DCL GEN 08-12.

Key Resource: U.S. Election Assistance Commission athttp://www.eac.gov/voter_resources/register_to_vote.aspx

November: Annual FERPA Notice

Requirement: Must annually provide notice to allstudents about:

• Right to review educational records, request amendment ofrecords, consent to disclosures or personally identifiableinformation, and file complaints with USED;

• Procedures for reviewing educational records and requestingamendment of records; and

• Policy regarding disclosures to school officials with legitimateeducational interest in educational records.

November: Annual FERPA Notice

Timing: Flexible, can be carried out at any pointduring year.

Strategy: Make sure all required elements included;use model forms; distribute via email and post to CIWebsite; keep record of notice distribution.

Citation: 34 CFR 668.41(c) and 34 CFR Part 99.

Key Resource: Family Policy Compliance Office athttp://www2.ed.gov/policy/gen/guid/fpco/index.html

Lagniappe: FERPA Directory Information

• To disclose directory information without priorconsent, must provide students notice ofdirectory information that include ( 1) types ofinformation school has designated as directoryinformation; and (2) student’s right to refuseuse of directory information; and (3) time periodstudent has for notifying school in writing. 34CFR 99.37.

• In addition to including with annual FERPAnotice, post directory information notice on CIWebsite and put it in your application foradmission.

December: Update GE Disclosure Templates

Requirement: For each GE program, must disclose in promotionalmaterials mentioning program and on school website:

• Department of Labor SOC Code(s) related to program CIP Code withlinks to O*NET occupational profiles;

• On-time graduation rate;

• Tuition and fees (normal time);

• Typical costs for books and supplies, and room and board, ifapplicable;

• Job placement rate (fed formula never developed, so only if youcalculate state/accreditor rates); and

• Median loan debt incurred by students who completed the program(separately by Title IV loans, private loans, and institutional debt).


Timing: Effective January 31, 2014, institutionsmust use Gainful Employment DisclosureTemplate (GEDT) to create webpage containingthe required disclosure information for each GEprogram. Institutions expected to update GEdisclosure information at least annually.


Strategy: Update cost and fee data in real-time tomitigate exposure to misrepresentation claims; forsame reason, consider updating on-time graduationrates and median loan info each year after June 30,and outcomes after annual report go in; otherwiseupdate everything in December; create CI flowchart.

Citation: 34 CFR 668.6(b)

Key Resource: IFAP GE Page:http://ifap.ed.gov/GainfulEmploymentInfo/

Lagniappe: GE Disclosure Changes

• New GE final rule arrived October 31, 2014.

• Effective July 1, 2015.

• Revised GE disclosure requirements arelocated at 34 C.F.R § 668.412


What information must be disclosed?

• At USED discretion. USED will conduct “consumertesting” to determine best disclosure mix. Periodicnotification through Federal Register.

• Practically speaking, disclosure mix will be reflectedin GE disclosure template (GEDT), and based on datareported by institution in prior year.


Potential disclosure information provided byinstitution:• Primary occupations (by name and SOC code)

that program prepares students to enter, alongwith links to occupational profiles on O*NET

• Program length (i.e., weeks, months, years)• Program clock or credit hours• Total cost of tuition and fees books, supplies, and

equipment (normal time)• Placement rate for the program (if required by

state or accreditor)


• Total number of individuals enrolled in theprogram during most recently completed awardyear

• Percentage of the individuals enrolled in theprogram during most recently completed awardyear that received a title IV loan or a private loan

• Whether the program is programmaticallyaccredited

• A link to USED College Navigator Web site


• Whether program satisfies educational prerequisitesfor professional licensure or certification in each Statewithin the institution’s MSA

• Whether program satisfies educational prerequisitesfor professional licensure or certification in any otherState for which institution has made a determinationregarding such requirements.

• For any other States, a statement that institution hasnot made a determination with respect to the licensureor certification requirements of those States.


Potential disclosure information generated by USED:

• Completion rates for full-time and less- than-full-timestudents

• Withdrawal rates

• Loan repayment rate for students who enteredrepayment during the two-year cohort period,including for all students, for students who completed,or for students who withdrew

• Median loan debt for students who completed duringmost recent award year, students who withdrew duringmost recent award year, or for both


• Mean or median earnings for students whocompleted during the applicable cohortperiod, students who withdrew during theapplicable cohort period, or for both

• Program cohort default rate

• Annual earnings rate


Disclosures on School Website

• Includes any page containing academic, cost,financial aid, or admissions information aboutprogram maintained by or on behalf ofinstitution

• Must provide GEDT or “prominent, readilyaccessible, clear, conspicuous, and direct link”to GEDT


Disclosure in marketing and promotional materials

• Includes all “promotional materials” madeavailable by or on behalf of institution toprospective students that identify program byname or otherwise promote the program

• Promotional materials include, but are notlimited to, an institution’s catalogs, invitations,flyers, billboards, and advertising on or throughradio, television, print media, the Internet, andsocial media


• Must include GEDT “in prominent manner”

• If space or airtime constraints, may includelink to GEDT, provided link is “prominent,readily accessible, clear, conspicuous, anddirect” and states ‘‘Important Informationabout the educational debt, earnings, andcompletion rates of students who attendedthis program’’


Pre-Enrollment Disclosure• Must provide GEDT before prospective student signs an

enrollment agreement, completes registration, ormakes a financial commitment.

• Disclosure may be made in-person (individually or aspart of a group presentation) or via email• If provided in-person, must obtain written confirmation of

receipt• If provided via email, must ensure GEDT is only substantive

content in email, obtain written confirmation of receipt,send using different address if institution receivesundelivered response, maintain records of efforts toprovide GEDT


When must disclosures be updated?

• Generally, must update GEDT information atleast annually with most recent data available

• Must update GEDT immediately to include anyrequired student warning (due to programfailing or being in the zone)


Additional Points of Interest• If institution offers program in more than one length,

must publish separate GEDT for each length

• If institution offers program in more than one locationor format (e.g., full-time, part-time, accelerated), itmay publish separate GEDT for each, if doing so wouldresult in clearer disclosures. In such cases, institutionmust disaggregate appropriate data by length of theprogram, location, or format (e.g., number of clockhours, enrollments, cost, placement rate).


• Certain data may not be included in GEDT ifbased on fewer than 10 students.

• Institutions will have opportunity to reviewand challenge disclosure informationgenerated by USED in advance of finalization.

• First set of expanded disclosures (for results ofAY 2014-15 and including disclosures based oninformation that USED must provide) “likely”required by January 2016.

Contact Information

Aaron D. Lacey

Partner, Higher Education Education Practice

Thompson Coburn LLP

[email protected]

314-552-6405

Conditions of Use/Disclaimer

• The purpose of this presentation is to provide newsand information on legal issues and all contentprovided is for informational purposes only and shouldnot be considered legal advice.

• The transmission of information from this presentationdoes not establish an attorney-client relationship withthe viewer. Participants should not act on theinformation contained in any of the materials orpresentation without first consulting retained legalcounsel.

• If you desire legal advice for a particular situation, youshould consult an attorney.

Consumer Information Boot Camp - Amazon Web Servicesdocs.accet.org.s3.amazonaws.com/.../handouts/consumer_bootcam… · Presentation Outline General CI Strategy • CI Resources,

Documents