Transcript Slide 1
NYSFAAA STATE WIDE TRAINING
10/5/11
GAINFUL EMPLOYMENT
‘ROUND TABLE’
TODAY’S GOALS
Now that the first two Gainful Employment
deadlines have passed, we want to make
sure everyone:
Has done everything they need to
Knows what to do next
Understand the potential ramifications of the
Gainful Employment Regulations.
THIS IS AN OPEN FORUM WEBINAR
DO NOT hold your questions for the end.Your
questions are the second most important aspect
of today’s session.
The most important portion of today’s session is
to hear the answers to everyone’s questions.
We want everyone to participate as we are ALL
BIRDS OF A FEATHER – aka – IN THE SAME
BOAT.
RULES OF ENGAGEMENT
Everyone’s phone will be muted except for your
State Wide Training Co-Chairs (Vera and Beth).
If you have a question, comment or response:
You can type it in the comments box – choose the
‘staff’ tab. Vera or Beth will jump in and pose the
question/comment.
You can type in that you have a question, comment
or response to a question. Vera or Beth will tell me
that John Smith has a Q, C or Response. I will then
un-mute John and put him back on mute when
complete.
RULES OF ENGAGEMENT
If your co-chairs believe that we need to move on
they may ask everyone to hold questions to the end.
If there are any questions that relate to compliance –
no one should guess what the answer is. That would
be very dangerous.Your co-chairs will note the
question and submit it to [email protected].
When they get a response they will share them on
NYSFAAA-L.
We are scheduled to end at noon. However, we
have arranged to go as late as 12:30 if necessary.
RULES OF ENGAGEMENT
Our plan is to record this webinar and make it
available on the NYSFAAA website and/or utube.
Once it has been posted to the web we will let
everyone know via NYSFAAA-L.
WARNING: By virtue of your asking or responding
to a questions (or any other verbal comment) you are
giving NYSFAAA permission to record you and make
it public.
FURTHER WARNING: Do not say something you
might regret.
AGENDA
Summary/Discussion
GE Disclosures
GE Reporting
GE New Programs
Impact on PPAs – are you in
compliance?
GE Metrics
ALL INFO GE
ON IFAP
GE DISCLOSURES
July 1st deadline required disclosures
The name and U.S. Department of Labor's Standard
Occupational Classification (SOC) code of the
occupations that the program prepares students to
enter, along with links to occupational profiles on
the U.S. Department of Labor's O*NET Web site or
its successor site.
The on-time graduation rate for students
completing the program.
GE DISCLOSURES
The tuition and fees the institution charges a student
for completing the program within normal time.
The typical costs for books and supplies (unless
those costs are included as part of tuition and fees),
and the cost of room and board, if applicable.
The job placement rate for students completing the
program.
GE DISCLOSURES
The median loan debt incurred by students who
completed the program (separately by Title IV loans
and by other educational debt to include both
private educational loans and institutional financing)
as provided by the Secretary.
Other information the Secretary provided to the
institution about the program.
GE DISCLOSURES
July 1st deadline
(Current) Impact if you are not in
compliance
Are you in compliance? Many
institutions think they are but they
are not.
DOE Position on the deadline
GE DISCLOSURES
Let’s share experiences
SAMPLE COMPLIANT DISCLOSURE
GE REPORTING
Why?
Who?
When?
DOE position on the deadline?
What if I cannot/did not?
GE REPORTING
Circumstances that Require Submission of Missing or
Incomplete Explanations (see Gainful Employment
Electronic Announcement #18 on August 9, 2011)
The institution has no GE Programs.
The GE Program was Title IV eligible in the 2010-2011
award year, but was not Title IV eligible in one or more
of the award years between 2006-2007 and 2010-2011.
GE REPORTING
Circumstances...
The institution is a foreign school and will not be reporting
for a GE Program because there were fewer than 10
students enrolled in the program in the relevant award
year. Note: Domestic institutions must report for all GE
Programs, regardless of the number of students who were
enrolled..
The institution is unable to report for one or more of the
required award years (2006-2007 through 2010-2011).
The institution is unable to report for one or more of its
GE Programs.
GE REPORTING
Circumstances..
The institution is unable to report all of the
information required for each student who was
enrolled in a GE Program in the required award
years (2006-2007 through 2010-2011).
Any other circumstance where the institution is
unable to meet the regulatory reporting
requirements by the established timelines for
reporting.
GE REPORTING
The required explanation(s) of missing or
incomplete GE Program information must be
submitted by an institution in an e-mail sent to
[email protected].
Subject Line of e-mail - include the first 6 digits of the your
OPEID and the institution’s name.
Body of e-mail –provide the name, phone number, and e-
mail address of a contact person at the institution. This is the
person they will contact if we have any questions on the
missing or incomplete data explanation provided.
Then add the explanation
GE REPORTING
SUMMARY OF DATA ELEMENTS
GE REPORTING
NSLDS RECORD LAY OUT
GE REPORTING
Let’s share experiences
GE New Programs
THINGS MIGHT BE CHANGING
On September 27, 2011, DOE published in the
Federal Register a Notice of Proposed Rulemaking
(NRPM) that proposes changes to the regulations to
streamline the application and approval process for
new educational programs
Opinion.
Don’t forget the calendar – early implementation?
For now you must abide by the current regulations!
GE New Programs
GE New Programs
GE New Programs
GE New Programs
GE New Programs
E-App, PPA, ecar
Let’s share experiences
GE Metrics
Two Standards – Three Measures
Repayment Rate –
A percentage of the loan amounts that a GE Program’s
former students are repaying (weighted for loan
balance).
Debt to Earnings Ratio –
For the GE Program’s completers, the average
educational loan annual repayment amount as a
proportion of the average borrowers’ annual income.
30
GE Metrics
repayment
Rate
Loan repayment rate for a program calculated annually using the
following ratio:
OOPB of LPF plus OOPB of PML
OOPB
OOPB = Original Outstanding Principal Balance
LPF = Loans Paid in Full
PML = Payments-Made Loans
GE Metrics
debt to incomernings
Earnings Rate
Average Annual Loan Payment Amount
Mean or Median Annual Earnings
Discretionary Income Rate
Average Annual Loan Payment Amount
Mean or Median Annual Earnings less 1.5 X poverty guideline
DGE Metrics
to-Earnings -Earnings
Calculating of the annual loan payment
Uses the program's median loan debt,
Amortized at 6.8% over –
10 years for a certificate or AA program,
15 years for a baccalaureate program, or
20 years for a graduate program
PnGE Metrics
A program must pass at least one of the three rates to be a Gainful
Employment Program eligible for Title IV participation.
Repayment rate of at least 35%.
Debt-to-Earnings rate of less than
12% of total earnings, or
30% of discretionary income.
GE Metrics
Loss of TIV Eligibility
Failing ALL 3 metrics for three FYs in a four
year period
Earliest year for eligibility loss is FY 2015: if
ALL 3 Metrics failed for FYs 2014, 2013, 2012
Must wait 3 years before re-applying for
program eligibility
PeGE Metrics
e Requirements
A program is a failing program for a year if it does not meet ANY of
the minimum standards.
After one year’s failure institution must —
Disclose to students and prospective students the
amount by which the program did not meet the
minimum standards and any plans for improvement;
Establish a three‐day waiting period before students
can enroll.
GE Metrics
oFY 2012 Debt Measures – to be released early 2013
oFY 2011 Debt Measures – to be released early 2012 *
*for information purposes only (Per info at NASFAA Conference we can
expect this June 2012)
GE Metrics
Let’s share thoughts and strategies