Consumer Information & Disclosures

Presentation To | Webinar Wednesday

What must be disclosed?

What must be disclosed

• General disclosures– 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 4-year programs enroll

What must be disclosed

• Athletic disclosures– Equity In Athletics Disclosure Act (EADA)

• Drug and alcohol abuse prevention– 34 CFR 86.100

• Security and safety disclosures– Campus security (Cleary Act)

• Hate crimes

– Fire safety– Missing student notification policy– Emergency notification– Emergency response and evacuation

Campus crime and fire safety

• 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

What must be disclosed

• Vaccination policy• Student body diversity

– Schools must disclose the percentage of enrolled, full-time students in the following categories:• 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• 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

What must be disclosed

• Provisions for books and supplies for Pell eligible students– Under certain conditions, Pell eligible students

must be able to obtain or purchase, by the 7th day of a payment period, their required books and supplies

• Transfer of credit policies– Disclose current transfer of credit policies– Disclose school with which there is an articulation

agreement

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

• www.dl.ed.gov• Student loan publications available for order at

www.fsapubs.org

www.fsapubs.org

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 manner distinct from FSA loan information

– Provide information needed for student to complete the self-certification form

What must be disclosed

• Code of Conduct– Required under Program Participation

Agreement (PPA)• Schools must:

– 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_cal

culator.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

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

What must be disclosed

• Information on written arrangements to provide educational programs must be made available to enrolled and prospective students– Written arrangements:

• Between eligible institutions,• For study-abroad, and • Between an eligible institution and an ineligible

institution

Program Integrity Final Rule

What must be disclosed

• Gainful employment information– Program Integrity Regulations

• Information webpage– http://www.ifap.ed.gov/GainfulEmploymentInfo/index.html

• 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

• http://www.archives.gov/fed-employees/constitution-day.html• http://memory.loc.gov/ammem/collections/continental/• 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

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, and – Include a statement that the institution will provide

a paper copy of the information on request

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

– Internet or an intranet website• For prospective students or employees

– Internet website

Who should disseminate?

Who should disseminate

• Each school must have at least one individual who is available full-time to disseminate consumer information– May have multiple employees designated to meet

full-time availability requirement

• ED may waive the requirement if enrollment is too small to necessitate full-time availability

What are the related program review findings?

Program review findings

• Consumer information requirements not met– Policies not developed– Policies not provided to students

• Examples: – SAP– R2T4

– New HEOA consumer information requirements not implemented

Program review findings

• Crime awareness requirements not met– Policies did not contain all required

elements– Inadequate distribution of statistics and

policies– Failure to report statistics on website or

crimes reported in wrong category

Program review findings

• Misrepresentation in school publications– False information and unsubstantiated

claims– Incorrect information about:

• Educational programs, and • Transferability of credits

Penalties for misrepresentation

• FSA eligibility may be:– Limited – Suspended, or – Terminated

• Civil fines may be imposed– Up to $25,000 per violation or

misrepresentation

What other resources are available?

Available resources

• 2011-2012 Federal Student Aid Handbook– Volume 2: School Eligibility and Operation

• Chapter 6: Providing Consumer Information• Chapter 8: Campus Safety, Reports & Other

Requirements– Information on safety report contents– Sample statement of report availability

» For combined security and fire report

Available resources

• 2011 FSA Conference Presentations– Student Loan Consumerism– Partnering for Compliance and Consumer

Protection• Available at:

– http://ifap.ed.gov/presentations/2010FSAConference.html

Available resources

• Additional Campus Crime and Fire Safety resource– The Handbook for Campus Safety and

Security Reporting• http://www2.ed.gov/admins/lead/safety/campus

.html#handbook

– Accompanying online tutorial• Campus Safety and Security Reporting Training

34

Campus security website

• http://www2.ed.gov/admins/lead/safety/campus.html#handbook

Available resources

• Additional Campus Crime and Fire Safety resources– Campus crime and fire safety statistics

• http://ope.ed.gov/security/

– Crime statistics• http://nces.ed.gov/collegenavigator/

http://ope.ed.gov/security/

Available resources

• FERPA resources– Family Policy Compliance Office (FPCO)

webpage • Regulations• Sample notification

– http://www2.ed.gov/policy/gen/guid/fpco/ferpa/ps-officials.html

– MSWord version available

– Consumer Information Assessment Module• Activity 6

38

Available resources

• Information Required to be Disclosed Under the Higher Education Act of 1965

• Available at: http://nces.ed.gov

Available resources

• FSA Assessment Modules– Designed to assist schools in evaluating

financial aid policies, processes and procedures• http://ifap.ed.gov/qahome/fsaassessment.html

FSA Assessment Modules

FSA Assessment Modules

Consumer Information Disclosures At-A-Glance

Our Own Disclosure!

• Nelnet is glad help schools access all the information needed to make their jobs easier and to best help students.

• We cannot offer opinion or interpretation of FSA policies in all circumstances.

• If you have specific questions about the your programs and procedures, please contact FSA directly.

Questions?

Dana Kelly

Regional Director and Trainer

dana.kelly@nelnet.net

336.848.6441