Transcript Presentation Title

MASFAA 2013
October 6th – 9th, 2013
Indianapolis, Indiana
Consumer Information
and Disclosures
Dana Kelly
Regional Director and Trainer
Nelnet Partner Solutions
What must be disclosed?
What Must Be Disclosed

General disclosures
◊
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Institutional information
Financial aid information
Family Educational Rights & Privacy Act (FERPA)
•
◊
34 CFR 99.7
Student Right-To-Know Act (educational
outcomes)
Retention, completion, graduation, and transfer-out
rates
• Placement and types of employment of graduates
• Types of graduate/professional programs in which
graduates from four-year programs enroll
•
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What Must Be Disclosed
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Athletic disclosures
◊
Equity in Athletics Disclosure Act (EADA)
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34 CFR 86.100
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Campus security (Cleary Act)
Drug and alcohol abuse prevention
Security and safety disclosures
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Hate crimes
Fire safety
Missing student notification policy
Emergency notification
Emergency response and evacuation
Campus Crime and Fire Safety
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Annual reports published and distributed
to students and employees by October 1
Distribution through publications and
mailings
◊ Direct
mailing via USPS, campus mail, or
email
◊ Publications provided to each individual
◊ Posting on the website
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What Must Be Disclosed


Vaccination policy
Student body diversity
◊ Schools
must disclose the percentage of
enrolled, full-time students in the following
categories:
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Male
Female
Pell Grant recipients
Self-identified members of a racial/ethnic group
Plans for improving academic programs
What Must Be Disclosed

Voter registration information
◊ Program
Participation Agreements (PPA)
◊ Schools must make a good faith effort to
distribute voter registration forms to students
and make voter registration forms widely
available
•
•
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Satisfied by sending an email with state’s voter
registration form or internet address to the form
Message exclusively about voter registration
What Must Be Disclosed

Textbook information
◊ Pricing
information posted on online course
schedule
◊ GEN-10-09

Copyright policies and sanctions
◊ Peer-to-peer
file sharing
◊ A sample statement and other copyright
requirements are included in GEN-10-08
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What Must Be Disclosed

Provisions for books and supplies for Pelleligible students
◊ Under
certain conditions, Pell-eligible students
must be able to obtain or purchase, by the
seventh day of a payment period, their
required books and supplies

Transfer of credit policies
◊ Disclosure
current transfer of credit policies
◊ Disclose school with which there is an
articulation agreement
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Program Integrity Final Rule
What Must Be Disclosed

FSA loan disclosures
◊ Financial
•
assistance information
Terms and conditions of FSA loans
◊ Student
loan information published by ED
◊ Entrance and exit loan counseling
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•
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www.studentloans.gov
Student loan publications available for order at
www.fsapubs.org
www.fsapubs.org
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What Must Be Disclosed

Private student loan disclosures
Preferred Lender Arrangements (PLA)
◊ Information on private loans
◊
Provide prospective borrower with TILA disclosures
• Inform borrowers of possible eligibility for FSA loans
and that FSA loan terms may be more favorable
•
Private loan disclosures must be presented in
manners distinct from FSA loan information
◊ Provide information needed for student to
complete the self-certification form
◊
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What Must Be Disclosed

Code of Conduct
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Schools must:
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Required under Program Participation Agreement
(PPA)
Develop a code
Publish prominently on institution’s website
Administer and enforce such code
Annually inform the institution’s officers,
employees, and agents of code requirements
Additional requirements for Preferred Lender
Arrangements (PLAs)
What Must Be Disclosed

Net price calculator
◊ Schools
must post a net price calculator on
their websites by October 29, 2011
•
•
ED’s template published October 29, 2009
http://nces.ed.gov/ipeds/resource/net_price_calcul
ator.asp
◊ May
use ED’s calculator, develop own, or
contract with a third party
◊ Include “at a minimum the same data
elements” found in ED’s template
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What Must Be Disclosed

Teacher preparation program report
◊ Required
for schools that prepare teachers for
initial state certification or licensure
◊ Report annually to state and public
◊ Refer to GEN-08-12 for specific reporting
requirements
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What Must Be Disclosed

Information on written arrangements to
provide educational programs must be
made available to enrolled and prospective
students
◊ Written
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arrangements:
Between eligible institutions
For study abroad
Between an eligible institution and an ineligible
institution
Program Integrity Final Rule
What Must Be Disclosed

Gainful employment information
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Program Integrity Regulations
Information webpage
◊
http://www.ifap.ed.gov/GainfulEmploymentInfo/i
ndex.html
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Regulations
Dear Colleague Letters and Electronic Announcements
FAQs
Available training
Additional resources
What Must Be Disclosed

Constitution and Citizenship Day
◊A
Constitution Day program must be
conducted on September 17
◊ Not in the Title IV regulations
◊ Additional information and resources
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http://www.archives.gov/fedemployees/constitution-day.html
http://memory.loc.gov/ammem/collections/contine
ntal/
http://www.archives.gov/exhibits/charters/charters
.html
How must it be disclosed?
How It Must Be Disclosed

Annual direct notice to all enrolled
students regarding the availability of
consumer information
◊ General
disclosures (presented on slide 3)
◊ FERPA
◊ Athletic
disclosures (if applicable)
◊ Annual security and fire safety reports
◊ Athletic program participation rates and
financial support data
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How It Must Be Disclosed

Annual direct notice must include a brief
description of consumer information and
how to access more details
◊ If
provided on a website, disclose exact
address for accessing the details
◊ Include a statement that the institution will
provide a paper copy of the information on
request
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How It Must Be Disclosed

Disclosure through websites
◊A
school may post information that must be
disclosed to the school websites
•
For enrolled students or current employees
−
•
For prospective students or employees
−
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Internet or an intranet website
Internet website
Frequently Missing Disclosures
Frequently Missing Disclosures
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Drug and Alcohol Abuse Prevention
FERPA Notification
Voter Registration
Satisfactory Academic Progress Policy
Frequently Missing Disclosures
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Drug and Alcohol Abuse Prevention
◊
Institutions must certify that they have
adopted/implemented a program to prevent drug
and alcohol abuse
As part of the program, institutions must distribute
certain information to students and employees annually
(34 CFR § 86.100)
• Must do a biennial review of the program to determine
effectiveness, needed changes, and whether
disciplinary sanctions are consistently enforced
• Must provide review results upon request
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Frequently Missing Disclosures
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Information to include:
Standards of conduct that clearly prohibit the
unlawful possession, use, or distribution of drugs and
alcohol
◊ Description of sanctions under state, local, and
Federal law
◊ Description of available drug or alcohol counseling,
treatment, or rehabilitation programs
◊ Description of health risks associated with the use of
illicit drugs and alcohol
◊ Clear statement that institution will impose sanctions
on students and employees for violations of the
standards of conduct and a description of sanctions
◊
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Frequently Missing Disclosures
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Annual FERPA Notification
◊ Must
inform students of their rights under
FERPA to:
Inspect and review education records
• Seek to amend education records
• Consent to disclosure of PII from his/her education
records, except as specified by law
• File a complaint with the Department if institution
doesn’t comply
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Frequently Missing Disclosures
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Annual FERPA Notification
◊ Must
specify procedures for exercising rights
◊ Must specify criteria for determining who
constitutes a school official and what
constitutes a legitimate educational interest
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Frequently Missing Disclosures

Voter Registration
◊ Institutions
must:
in nearly every state and D.C.
Make a good faith effort to distribute a mail voter
registration form to each student enrolled in a
degree/certificate program and physically in
attendance
• Make the voter registration form widely available
to students at the institution
• Request forms from the state 120 days prior to the
voting registration deadline
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Frequently Missing Disclosures

Voter Registration
◊ May
distribute the form electronically
◊ Institutions in ID, MN, NH, ND, WI, WY, and
the territories are exempt
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Frequently Missing Disclosures

SAP Policies
◊ Make
sure you have updated your SAP
policies to conform with the regulatory
changes that were effective July 1, 2011
◊ Make sure consumer disclosures for SAP
accurately reflect those policies
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What other resources are
available?
Resources
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FSA Assessments on consumer
information
National Postsecondary Education
Cooperative
Resources
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FSA Handbook – Volume 2, Chapters 6-8
Regulations – 34 § 668, Subpart D
GEN-08-12 (especially pages 95-102)
Email [email protected] with FERPA
questions
Resources
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Model FERPA notifications
SAP
◊ Final
program integrity regulations published
October 29, 2011
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Resources

Additional Campus Crime and Fire Safety
resource
◊ The
Handbook for Campus Safety and
Security Reporting
◊ Accompanying online tutorial
•
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Campus Safety and Security Reporting Training
Campus Security Website
http://www2.ed.gov/admins/lead/safety/campus.html#han
dbook
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Resources

Additional Campus Crime and Fire Safety
resources
◊ Campus
crime and fire safety statistics
◊ Crime statistics
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Consumer Information Disclosures
At-a-Glance
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Thank You!
Dana Kelly
National Trainer
Nelnet Loan Servicing
[email protected]
336-848-6441
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