Gainful Employment Disclosure Requirements, Correcting Data and Adding Programs

Gainful Employment Disclosure Requirements, Correcting Data and

Adding Programs

Susan Bowder

Cynthia Hammond

U.S. Department of Education

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What We Will Cover

Status of GE Regulations Disclosure Updating Information

What is new in Fall 2012 Correcting previously reported data

Adding New Programs

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STATUS OF GAINFUL EMPLOYMENT REGULATIONS

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On June 30, 2012, a U.S. District Court vacated most of the gainful employment regulations

Court’s decision was based on ED’s rationale for setting the Repayment Rate failure threshold

Because of the interrelationship of the gainful employment requirements, the Court vacated most of the gainful employment regulations – GE Metrics, GE Reporting, Adding New GE Programs

Court left in place GE Disclosure requirements

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U.S. District Court Decision

Disclosure

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Disclosure Requirements: Occupations Normal Time to complete the program On-time graduation rate for completers Total cost of the program - tuition and fees,

books and supplies, room and board Placement rate for completers Median loan debt

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Disclosure Template Similar to the template used for the Net

Price Calculator (NPC) Allows institutions to enter their own data,

combines it with ED data, and displays in consistent consumer-friendly webpage

Difference: NPC template was optional; GE template is required

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Institution enters data into the online form: Program length Related SOCs Total tuition and required fees for the entire program Total estimated costs for books and supplies Room and board (if applicable) On-time graduation rate for completers Job placement rate

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After entering all the data for the program, hit submit

ZIP file produced with html page to be put on your institution’s website

Note: file upload option will be available so you don’t have to enter all data for all programs on screen manually – produces ZIP files for all programs at once

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Timing for Disclosure Template

Template availability Electronic Announcement Deadline to use template for Award Year 2011-12

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Disclosure Tips:If no SSN, do not include that student in disclosure calculationsIf the number of students who completed a GE Program during the award year was less than 10, the school should not disclose to the public:

Median debt amounts On-time completion rate

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More Tips: Promotional Materials Invitation, advertisement, or solicitation

mentions or otherwise refers to a specific GE Program or Programs

Institution 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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On-Time Completion Number of students who completed in most

recently completed award year Number of those students that completed

within normal time Includes leave of absence Includes time if a student withdrew and

returned Includes enrollment in other programs if the

student did not complete the other program13

Electronic Announcement #25 Length of the Programs – Is there is a

significant difference in the published length of the programs?

Tuition and Fees – Is there is 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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Updating Previously Reported

Information

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Reporting and Updating Information Court vacated the gainful employment

reporting requirements in 34 CFR 668.6(a) Institutions are not required to submit gainful

employment reports for the just ended 2011-2012 award year

Institutions may update previously reported gainful employment information if they choose to do so

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NSLDS Enhancements for Corrections to Prior Year Data Mass Update Capability Improved Submittal Template

Elimination of some reporting fields

Note: All reporting file formats and templates used last year will continue to be accepted if an institution chooses to make corrections.

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Mass Update Capability Update/Change/Correct/Deactivate multiple

records simultaneously Including CIP Code and Credential Level

Improved Submittal Template Record limit increased from 50 to 250 records Errors can be corrected on the actual template

and resubmitted Will be available via FSADownload.ed.gov

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Example of Mass Update Screen

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Can No Longer Be Corrected: GE Program Indicator FFEL or Direct Loans Enrolled in Another Program CIP of Other Program Credential Level of Other Program Program Name of Other Program GE Program Indicator of Other Program OPEID of Other Program Institution Name of Other Program

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GE User Guide Updated GE User Guide to be released

Updated file layout Details regarding new online

functionality New Submittal template instructions

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Reminder

Violation of Privacy Act data Files sent via e-mail without password

protection

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Adding Programs

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Eligibility DocumentsAccess all documents at eligcert.ed.govElectronic Application for Approval to Participate in the Federal Student Financial Aid Programs (E-App)Program Participation Agreement (PPA)Eligibility and Certification Approval Report (ECAR)

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Eligibility References Code of Federal Regulations (CFR)

668.8 – Eligible Program 668.14 – Program Participation Agreement (PPA) 600.2 – Definitions 600.10 – Extent of Eligibility 600.20 – Application Procedures

Federal Student Aid Handbook, Volume 2, Chapter 5

Adding Programs ECAR lists the eligible program levels ECAR lists the eligible Gainful Employment

(GE) programs approved or acknowledged by ED

Eligibility does not automatically include new programs In some cases, the school may make a

self-determination of program eligibility In some cases, the school must seek ED

approval of a new program

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Adding Programs – School Self-Determination of Eligibility

There are two cases in which a school may determine program eligibility without prior ED approval

1. The added program leads to an associate, bachelor’s, professional, or graduate degree and the school has already been approved to offer programs at that level,* or

*If not approved for that level or higher, school would request an Increased Level of Offering

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Adding Programs – School Self-Determination of Eligibility

2. A fully certified school adds a program that is at least a 10-week (of instructional time)

program of at least 8 semester hours, 12 quarter hours, or 600 clock hours

AND

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Adding Programs – School Self-Determination of Eligibility

Prepares students for gainful employment in the same or related recognized occupation as an educational program that the Department already has designated as an eligible program at the school “Recognized Occupation” as defined in 34

CFR 600.2, dated October 29, 2010

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Adding Programs – School Self-Determination of Eligibility

If a school makes such a determinationIt must have received the required state and accrediting agency approvals before making the decisionIt must include the “self-certified” program on the next recertification e-app, or may report the program soonerIt is liable for FSA funds disbursed if self-determination is found to be incorrect

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Adding Programs - ED Approval Required

ED approval is required for addition of: Any program under 600 clock hours,

regardless of school’s eligibility (short term)

GE program added by a provisionally certified school (per PPA)

Non-degree program at fully certified school in a program of study different or unrelated to already eligible programs

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Adding Programs - ED Approval Required

A Direct Assessment Program A Comprehensive Transition and

Postsecondary (CTP) Program

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Adding Programs - Limitations Schools subject to the 2-year rule, during initial

period of participation ED will not approve new programs unless

institution demonstrates a program has been offered for at least two years

Provisionally certified schools with a growth restriction condition ED will not approve new programs until the

issue that lead to the restriction has been resolved

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Adding Programs – Submitting Changes

Use E-App to submit changes and updates www.eligcert.ed.gov

In Section A, Question 1, select “Update Information” box

Select the specific updates from the pick list; if “Degree Program” or “Nondegree/Vocational Program” is selected, application will display only the required questions

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Adding Programs – Submitting Changes

Complete the appropriate questions, and Section L, of the E-App

Mail the signature page (Section L) and the supporting documents listed in Section M to the address indicated

Adding Programs – Process if Approval Required

ED will review the new program ED will evaluate institution’s

administrative and financial capability If approved, a revised ECAR and

Approval Letter is issued Institution may disburse funds after

receiving Approval Letter

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Adding Programs – Process if Approval Required

If not approved, Denial Letter is issued and institution may request reconsideration

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Adding Programs – Process if Approval Not Required ED will review the new program and add

the program to the institution’s ECAR if program meets eligibility requirements

ED will provide written notification when review is complete

Institution may disburse funds prior to receiving ED notification

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Adding Programs – Process if Approval Not Required If program does not meet eligibility

requirements, ED will deny eligibility Institution is liable for FSA funds if

program does not meet program eligibility requirements in 34 CFR 668.8

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Adding Programs – ED Review of Programs

Accreditor and state approval matches E-App (name and program length)

CIP Code consistent with name of program Leads to a recognized occupation (SOC code) Meets minimum weeks and clock/credit hours Meets clock to credit conversion where

required

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Adding Programs – ED Review of Programs

Meets placement and completion rates, and has been in existence for 1 year, if short term (less than 600 hours)

Does not exceed by more than 50% the minimum number of clock hours established by the state for training in the occupation for which the program prepares students

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Adding Programs – ED Review of Programs

Program meets special requirements if Comprehensive Transition and Postsecondary (CTP) Program

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Adding Programs – ED Response Sent via E-mail

E-mail instructs institution to go to the PPA/ECAR page of the E-App website to view Approval Letter

Institution prints and reviews copy of Approval Letter and ECAR

E-mail also provides contact information for questions about the action

Resources

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Information on GE on IFAP:

http://ifap.ed.gov/GainfulEmploymentInfo Regulations Dear Colleague Letters and Electronic

Announcements Frequently Asked Questions Training Resources

Resources

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