Disclosure Requirements and Consumer Information

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Disclosure Requirements and Consumer InformationDavid RacculiaPHEAA Compliance Services

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LET’S GET STARTED! Why Regulate Consumer

Information? Provides consistency and uniformity

to the information made available by institutions of higher education

Helps prospective students effectively compare these institutions

Informs students and families of their rights under the law

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NAVIGATING THE JUNGLE

Higher Education Act of 1965 (HEA)

Higher Education Opportunity Act of 2008 (HEOA)

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NAVIGATING THE JUNGLE Requirements come in two

basic types: Disclosure Requirements

Information that a school must distribute or make available to others

Reporting RequirementsInformation that must be provided to the U.S. Department of Education or other agencies

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NAVIGATING THE JUNGLE

Evaluate

Coordinate

Monitor

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DISCLOSURES UNDER THE HEA

So what is required anyway?

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DISCLOSURES UNDER THE HEAName Recipient Method Frequency

A Notice of Institutional and

Financial Aid Information

Enrolled students Written notice Annually

Contact Information for Individuals Who

Can Assist in Obtaining

Institutional or Financial Aid Data

Prospective and enrolled

students

Publications, mailings, or electronic

media

Ensure availability

Financial Aid Information


students


media

Ensure availability

Notice of Federal Financial Aid

Penalties for Drug Law Violations

Each student upon

enrollment

Via conspicuous

written noticeUpon enrollment

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DISCLOSURES UNDER THE HEAName Recipient Method FrequencyFamily

Educational Rights and Privacy Act

(FERPA)

All enrolled students

A written or electronic

method most likely to inform

students of their rights

Annually

Certain Consumer

Information for College

Navigator Website


students and the general

public

Disclosure information

must be posted on the

Institution’s website

---- The institution’s

web address (URL) as reported

through IPEDS

Ensure availability

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Diversity of the Student Body

Prospective and enrolled students


media

Ensure availability

Cost of Attendance



media

Ensure availability

Net Price Calculator


students, and the

general public

Posted on the Institution’s

website

Must be posted to the

institution’s website by October 29,

2011Policies

Regarding Withdrawal, Institutional

Refund, and the Return of Title

IV Funds



media

Ensure availability

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Textbook Information

Currently enrolled students

----Affiliated college

bookstores

For students – via the

institution’s Internet or

written course schedule as appropriate

----Written notice

to college bookstores

For students: updated with

internet or written course schedule as appropriate

----College

bookstores: as soon as

practicable once changes occur and upon the request of the

bookstoreDescription of

Academic Programs



media

Ensure availability

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Accreditation, Approval, or Licensure for the Institution

and its Programs



media

Ensure availability

Policies and Sanctions Regarding Copyright

Infringement (Including

Computer Use and File Sharing)



mediaAnnually

Teacher Preparation

Program Report

- State governments - Prospective and enrolled students and the general

public

To the state via the method

required by that state, and to the general public

via the institution’s

website

Annually by April

of each year

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Policies Regarding Transfer of Credit and Articulation Agreements



public

Publications, mailings, or

electronic mediaEnsure

availability

Drug and Alcohol Abuse

Prevention Program

Enrolled students and employees

Written publications that are sent directly to each student and employee

Annually

Annual Security Report

(Emergency Response and

Evacuation Procedures,

Timely Warnings, and

Crime Log)

All currently enrolled

students and all employees by Oct. 1 of each

year ----

To any prospective student or

employee upon request


electronic mediaAnnually

(by October 1)

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Vaccinations Policy




availability

Fire Safety Report and Fire

Log

All currently enrolled

students and employees by Oct. 1 of each

year----

To any prospective student or

employee upon request


electronic media----

May be included within the

Annual Security Report

Annually (by October 1)

Information for Crime Victims

about Disciplinary Proceedings

The alleged victim of any

crime of violence or a

nonforcible sex offense (or next

of kin if deceased)

In writing

Upon written request of the victim (or next

of kin if deceased)

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Retention RatesProspective and

enrolled students



availabilityCompletion,

Graduation, and Transfer-out

Rates



electronic mediaAnnually (by July 1)

Completion, Graduation, and

Transfer-out Rates for Students Receiving

Athletically Related Student

Aid

Prospective and enrolled students receiving

athletically related student

aid


electronic mediaAnnually (by July 1)

Placement in Employment




availability

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Job Placement Rates

Prospective students Written notice

At or before the time the

prospective student applies for enrollment

Types of Graduate and Professional Education in

which the Institution's

Graduates Enroll




availability

Intercollegiate Athletic Program

Participation Rates and Financial

Support Data


attending a co-educational institution that

has an intercollegiate

athletic program


electronic mediaAnnually

(by October 15)

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Voter Registration

Forms

Each student enrolled in a

degree or certificate

program and physically in

attendance at the institution

Direct distribution of

voter registration

form--OR--

An electronic message that includes either an electronic copy of the

form, or the web address (URL)

where the form can be found

Annually (Within 120 days of the deadline for

voter registration in

that state)

Student Loan Information

Published by the U.S.

Department of Education

All prospective student

borrowers


media

Ensure availability

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DISCLOSURES UNDER THE HEA

Name Recipient Method Frequency

State Grant AidAll enrolled

student borrowers


media

Annually (in sufficient time for the

student to meet any applicable

State Grant application deadline)

Information Regarding the

National Student Loan Data System

(NSLDS)

Prospective borrowers,

borrowers, and parent

borrowers

Written notification

At or before the origination of

the loan

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Entrance Counseling for Student Loan

Borrowers

All student borrowers

Conducted in person, by audiovisual

presentation, or by interactive

electronic means

Before the first disbursement of a loan is made for a first time

student borrower

Exit Counseling for Student Loan

BorrowersAll student borrowers

Conducted in person, by audiovisual

presentation, or by interactive

electronic means

Before a student borrower leaves

school

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Code of Conduct for Education

Loans

Employees with responsibilities

related to education loans

Prominently published on

the institution’s website

---- Written or electronic

notification to employees with education loan responsibilities

Ensure availability

---- Annually notify

- in writing – those

employees with education loan responsibilities

Private Education Loan

Disclosures (Including Self-

Certification Form)

Prospective private

education loan borrowers


media

Ensure availability

----Provide a self certification form at the borrower’s

request for a private

education loan

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Preferred Lender Lists

All enrolled students and their families


electronic media issued by the

Institution (or an institution affiliated

organization)

Annually

Preferred Lender

Arrangements

Prospective or current students

and their families

On the institution’s (or

institution affiliated

organization’s) website, and in all publications,

mailings, or electronic

messages, that describe or

discuss private education loans

Ensure availability

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Gainful Employment

Programs

All prospective and enrolled

students

Information must be posted

on the Institution’s website and

included in any promotional

materials----

Reporting requirements

suspended

Annually

Misrepresentation



public

information must be posted

on the Institution’s

website

Ensure availability

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ORGANIZE YOUR TEAMCompliance is a group effort…

Identify and recruit the right players

Establish an implementation strategy

Ensure administrative buy-in Establish a monitoring plan

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A NOTE ON PUBLICATION

Think readability and accessibility

When possible, consider online publication

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ONLINE PUBLICATION TIPS When considering on-line

publication : Focus on communication as well

as compliance Consider a single portal page for

all consumer information Adopt a “3-click” approach

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ONLINE PUBLICATION TIPS

Consider consumer friendly language; avoid technical jargon whenever possible

Establish common sense content titles

National Postsecondary Education Cooperative: Information Required to be Disclosed under the Higher Education Act of 1965: Suggestions for Dissemination. (2009)

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RESOURCES Higher Education Act of 1965 as amended (

http://www.gpo.gov/fdsys/)

Higher Education Opportunity Act of 2008 (HEOA) Dear Colleague Letter (DCL) GEN-08-12 summarizes the HEOA (

http://www.ifap.ed.gov/dpcletters/GEN0812FP0810.html)

Volume 2 of the Federal Student Aid Handbook (http://ifap.ed.gov/fsahandbook/1314FSAHbkVol2.html)

Code of Federal Regulations (http://www.gpo.gov/fdsys/)

Handbook for Campus Safety and Security Reporting (http://www.ed.gov/admins/lead/safety/handbook.pdf)

National Postsecondary Education Cooperative: Information Required to Be Disclosed Under the Higher Education Act of 1965: Suggestions for Dissemination (2009) (http://nces.ed.gov)

http://www.gpo.gov/fdsys/


http://www.ifap.ed.gov/dpcletters/GEN0812FP0810.html

http://www.ifap.ed.gov/dpcletters/GEN0812FP0810.html

http://ifap.ed.gov/fsahandbook/1314FSAHbkVol2.html

http://ifap.ed.gov/fsahandbook/1314FSAHbkVol2.html


http://www.ed.gov/admins/lead/safety/handbook.pdf

http://www.ed.gov/admins/lead/safety/handbook.pdf

http://nces.ed.gov/

http://nces.ed.gov/

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RESOURCES FSA Assessment Module for Consumer Information (

http://www.ifap.ed.gov/qahome/qaassessments/consumerinformation.html)

IFAP Gainful Employment Information Page (http://ifap.ed.gov/GainfulEmploymentInfo/index.html)

Gainful Employment Operations Manual (rev. 5/23/2012) (http://www.ifap.ed.gov/GainfulEmploymentOperationsManual/GainfulEmploymentOperationsManual.html)

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

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

http://ifap.ed.gov/GainfulEmploymentInfo/index.html

http://www.ifap.ed.gov/GainfulEmploymentOperationsManual/GainfulEmploymentOperationsManual.html




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RESOURCESFor Policy Assistance…

David Racculia Tarah Seroskie(Compliance Specialists)

» E-mail – [email protected]

» Phone – (717) 720-3460

mailto:[email protected]

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QUESTIONS?

Documents

Disclosure Requirements and Consumer Information