Transcript Document

GAINFUL EMPLOYMENT
TOM DALTON
EXCELSIOR COLLEGE
AND
HOWARD LESLIE
BERKELEY COLLEGE
NPRM
• Published in the Federal Register on
March 25, 2014 – Vol. 79
• Comments were due on or before
May 27, 2014
• Final regulations expected by
November 1, 2014 (AKA – any second)
Metrics
Annual debt-to-earnings
Discretionary debt-to-earnings
Program cohort default rate
Students
Completers
Completers & non-completers
Categories & thresholds
Pass: aDTE≤8% OR dDTE≤20%
Pass: pCDR<30%
Zone:
• Not passing AND
• 8%<aDTE≤12% OR 20%<dDTE≤30%
Fail: pCDR≥30%
Fail: aDTE>12% AND dDTE>30%
Ineligibility rules
(metrics operate
independently of each
other)
A program becomes T4 ineligible for 3yrs if:
• It fails in any 2 out of 3yrs, OR
• Does not pass in any 1 out of 4yrs (time for
zone programs to improve before
ineligibility)
A program becomes T4 ineligible for 3yrs if:
• The 3 year default rate of 3 consecutive
cohorts of students is greater than or equal
to 30%
Restrictions
• Debt warnings to students if program could
become ineligible at the end of the year
(applies to zone & failing programs)
• Tell students they may not be eligible for
federal aid because their program is failing
standards established by the US Department
of Ed
• Debt warnings to students if program could
become ineligible at the end of the year
• Tell students they may not be eligible for
federal aid because their program is
failing standards established by the US
Department of Ed
Certification
Most senior officials must certify:
• Program has accreditation or state recognition on its own or thru the institution
• Program has necessary programmatic accreditation if required by federal government or other
governmental entity in the state and Metropolitan Statistical Area
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Annual D/E and Discretionary D/E
Completers
Pass: aDTE≤8%
OR
Zone: 8%<aDTE≤12% OR
Fail: aDTE>12%
AND
dDTE≤20%
20%<dDTE≤30%
dDTE>30%
A program becomes T4 ineligible for 3yrs if:
• It fails in any 2 out of 3yrs, OR
• Does not pass in any 1 out of 4yrs (time for zone
programs to improve before ineligibility)
• f
Transition period
• For programs failing or in the zone use the lowest of the
following:
• Calculate debt for 2010-2011 award year
completers and use 2014 annual earnings
• Calculate debt for 2013-2014 award year
completers and use 2014 annual earnings
• Compare the 2 and use the lower of the draft D/E or
the transitional D/E
• Theory is you can lower tuition thereby lowering debt
pCDR
Completers & Non-Completers
• Pass:
pCDR<30%
• Fail:
pCDR≥30%
A program becomes T4 ineligible for 3yrs
if:
• The 3 year default rate of 3
consecutive cohorts of students is
greater than or equal to 30%
Restrictions & Certifications
Restrictions
• Warnings must be provided to students in zone/failing
programs
• Tell students they may not be eligible for aid because their
program is failing USDE standards
Certifications
• Most senior officials must certify:
• GE program has accreditation or state recognition on its
own or thru the institution
• GE program has necessary programmatic accreditation
if required by federal government or other governmental
entity in the state and Metropolitan Statistical Area
Disclosures DISCLOSURES
Template to be provided by USDE; updated annually;
included in all promotional materials
Occupation
Placement rate (if required by state or
accreditor)
Total costs for completing program on
time
Repayment rate (borrower-based)
calculated by the Secretary
Program length, clock or credit hours,
total enrollment, % of enrollees who
incurred debt
Median earnings/annual earnings and
median loan debt calculated by the
Secretary
Completion rate (for full and part-time
students)
Whether licensure requirements are met (if
applicable) in state where institution is
located and other state’s in MSA
Withdrawal rate (within normal time of
program)
Whether program holds appropriate
programmatic accreditation (if required)
Timing
-- Not Crystal
TIMING
– NOTClear
CRYSTAL CLEAR
• D/E
• Department example
• D/E issued for the 2014-2015 award year
• 2-year student cohort is 2010-2011/2011-2012 (2012 cohort)
• Earnings are 2014 calendar year – obtained by the Department in
early 2016
• Rates issued 2016
• D/E issued for the 2015-2016 award year
• 2-year student cohort is 2011-2012/2012-2013 (2013 cohort)
• Earnings are 2015 calendar year – obtained by the Department in
early 2017
• Rates issued 2017
• Fail 2 out of 3 consecutive years
• Ineligible (is it for the 2017 or 2018 award year in above example???)
• Ineligible for 3 years
Timing -- Not CrystalEAR
Clear
• pCDR
• Of borrowers entering repayment 3 fiscal years prior
to year of calculation; percentage who default by
end of subsequent 2 fiscal years
• Department example
• 2016 pCDR
• Borrowers who entered repayment in fiscal year
2013, percentage who defaulted by end of
fiscal year 2015
• Fail 3 consecutive years
• Ineligible for 3 years
IMPROVEMENTS
FROM
PREVIOUS
Significant
Changes from
Previous
Draft
DRAFT
• N size is 30
• Loan amortization is:
• 10 years for certificate and associate degree programs
• 15 years for bachelor’s and master’s degree programs
• 20 years for doctoral and first professional programs
Major Variations from 2011 Final Regulation
• Passing annual debt to earnings is set at 8%; 20% for
discretionary; zones set between 8%-12% and 20%30%. Previous rule set passing at 12% & 30% with no
zones.
• Programs must pass one of the debt-to-earnings
metrics and the cohort default rate metric; previous
rule provided for debt-to-earnings and loan
repayment to work as alternatives.
• Only Title IV recipients will be included in the debtto-earnings calculation; previous rule included all
students.
Gainful Employment
Informational Data Analysis for Private NonProfit Colleges
2014 NPRM (Full)
2014 NPRM (DEE only)
metrics: annual DTE*, discretionary DTE*
Pass: aDTE≤8% or dDTE≤20%
Zone: 8%<aDTE≤12% or 20%<dDTE≤30%
Fail: aDTE>12% and dDTE>30%
min program size: 30
amortization: 10/10/15/20
Interest rate 5.4%
metrics: annual DTE*, discretionary DTE*
Pass: aDTE≤8% or dDTE≤20%
Zone: 8%<aDTE≤12% or 20%<dDTE≤30%
Fail: aDTE>12% and dDTE>30%
min program size: 30
amortization: 10/10/15/20
Interest rate 5.4%
metric: program cohort default rate**
Pass: pCDR<30%
Fail: pCDR≥30%
min program size: 30
Total
253
262
345
Pass
244
(97% programs)
236
(90% of programs)
312
(90% of programs)
Zone
6
(2% of programs)
----------
4
(1% of programs)
Fail
3
(1% of programs)
26
(10% of programs)
29
(9% of programs)
2014 NPRM (pCDR only)
metric: program cohort default rate**
Pass: pCDR<30%
Fail: pCDR≥30%
min program size: 30
*Analysis based on Title IV aided (Stafford loan, GradPlus loan, or Pell grant) students who completed a GE program between October 1, 2007 and September 30, 2009 and whose
mean and median earnings by program were retrieved from the SSA for the 2011 calendar year (08/09 DTE Cohort).
**Analysis based on Title IV aided (Stafford loan or GradPlus loan) students who attended a GE program and entered repayment on their loans between October 1, 2008 and
September 30, 2009 (09 pCDR Cohort). For programs with less than 30 students in the 09 pCDR cohort, analysis also includes students who attended the program and entered
repayment between October 1, 2006 and September 30, 2008.
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Gainful Employment
Informational Data Analysis for Public Colleges
2014 NPRM (Full)
2014 NPRM (DEE only)
metrics: annual DTE*, discretionary DTE*
Pass: aDTE≤8% or dDTE≤20%
Zone: 8%<aDTE≤12% or 20%<dDTE≤30%
Fail: aDTE>12% and dDTE>30%
min program size: 30
amortization: 10/10/15/20
Interest rate 5.4%
metrics: annual DTE*, discretionary DTE*
Pass: aDTE≤8% or dDTE≤20%
Zone: 8%<aDTE≤12% or 20%<dDTE≤30%
Fail: aDTE>12% and dDTE>30%
min program size: 30
amortization: 10/10/15/20
Interest rate 5.4%
metric: program cohort default rate**
Pass: pCDR<30%
Fail: pCDR≥30%
min program size: 30
Total
1093
902
1507
Pass
1090
(99% programs)
850
(94% of programs)
1453
(96% of programs)
Zone
2
(less than 1% of programs)
----------
1
(less than 1% of programs)
Fail
1
(less than 1% of programs)
52
(6% of programs)
53
(4% of programs)
2014 NPRM (pCDR only)
metric: program cohort default rate**
Pass: pCDR<30%
Fail: pCDR≥30%
min program size: 30
*Analysis based on Title IV aided (Stafford loan, GradPlus loan, or Pell grant) students who completed a GE program between October 1, 2007 and September 30, 2009 and whose
mean and median earnings by program were retrieved from the SSA for the 2011 calendar year (08/09 DTE Cohort).
**Analysis based on Title IV aided (Stafford loan or GradPlus loan) students who attended a GE program and entered repayment on their loans between October 1, 2008 and
September 30, 2009 (09 pCDR Cohort). For programs with less than 30 students in the 09 pCDR cohort, analysis also includes students who attended the program and entered
repayment between October 1, 2006 and September 30, 2008.
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Gainful Employment
Informational Data Analysis for Private Sector Colleges
2014 NPRM (Full)
2014 NPRM (DEE only)
metrics: annual DTE*, discretionary DTE*
Pass: aDTE≤8% or dDTE≤20%
Zone: 8%<aDTE≤12% or 20%<dDTE≤30%
Fail: aDTE>12% and dDTE>30%
min program size: 30
amortization: 10/10/15/20
Interest rate 5.4%
metrics: annual DTE*, discretionary DTE*
Pass: aDTE≤8% or dDTE≤20%
Zone: 8%<aDTE≤12% or 20%<dDTE≤30%
Fail: aDTE>12% and dDTE>30%
min program size: 30
amortization: 10/10/15/20
Interest rate 5.4%
metric: program cohort default rate**
Pass: pCDR<30%
Fail: pCDR≥30%
min program size: 30
Total
4193
5651
6082
Pass
2850
4786
4204
(68% of programs)
(85% of programs)
(69% of programs)
875
----------
660
Zone
Fail
(21% of programs)
2014 NPRM (pCDR only)
metric: program cohort default rate**
Pass: pCDR<30%
Fail: pCDR≥30%
min program size: 30
(11% of programs)
468
865
1218
(11% of programs)
(15% of programs)
(20% of programs)
*Analysis based on Title IV aided (Stafford loan, GradPlus loan, or Pell grant) students who completed a GE program between October 1, 2007 and September 30, 2009 and whose
mean and median earnings by program were retrieved from the SSA for the 2011 calendar year (08/09 DTE Cohort).
**Analysis based on Title IV aided (Stafford loan or GradPlus loan) students who attended a GE program and entered repayment on their loans between October 1, 2008 and
September 30, 2009 (09 pCDR Cohort). For programs with less than 30 students in the 09 pCDR cohort, analysis also includes students who attended the program and entered
repayment between October 1, 2006 and September 30, 2008.
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FINAL REGS?