ashley higgins and amber johnson | dec. 2014 u.s. department of education 2014 fsa training...

Ashley Higgins and Amber Johnson | Dec. 2014

U.S. Department of Education

2014 FSA Training Conference for Financial Aid Professionals

Consumer Disclosure Requirements and Tools

Session 31

Agenda

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Requirements for Schools

•Select Disclosure Topics• Net Price Calculator (NPC)• Textbook Information• Frequently Missing

Disclosures

•Resources

• Student & Family Tools

• College Affordability & Transparency Center

• College Scorecard• College Navigator• Financial Aid Shopping

Sheet• StudentAid.gov

Background

• HEA requires you to disclose certain information as part of Title IV participation

• Disclosures often require information from offices across the institution, not just the financial aid office

• Schools may face penalties for noncompliance

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Net Price Calculator

• Section 132(h) of the HEA states:

“Each institution of higher education that receives Federal funds under Title IV shall make publicly available on the institution’s website a net price

calculator to help current and prospective students, families, and other consumers estimate a student’s

individual net price at such institution of higher education.”

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• What is net price?• The average yearly price actually charged to first-time,

full-time (FTFT) undergraduate students receiving student aid at the institution

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Institution’s Cost of Attendance (average annual cost of tuition and fees, room and

board, books, supplies, and transportation

Total need- and merit-based Federal, State, and

institutional grand aid awarded to FTFT students

Number of FTFT students receiving such aid


• What is required?• ED was required to develop a net price calculator template

• Institutions had two years from release of template to post a NPC to their websites• Required by 10/20/2011• May use ED’s template or an IHE-developed NPC• Must include minimum data elements

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Net Price Calculator• Minimum required data elements

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Input Elements•Student’s income•Number of people in household•Dependency status (or factors that estimate dependency status)

Output Elements•Estimated total price of attendance•Estimated tuition and fees•Estimated room and board•Estimated books and supplies•Estimated miscellaneous expenses (personal, transportation, etc.)•Estimated total grant aid•Estimated net price•Percent of the cohort (FTFT) that received grant aid


• Include required disclaimers and link in NPC• Estimate is not final or binding on ED, the institution, or the State

• Students must complete the FAFSA to be eligible for Title IV aid

• Link to the FAFSA

• ED template has these built in

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• Who counts as a “first-time, full-time” (FTFT) student?• First-time = a student who has no prior postsecondary experience attending any institution for the first time at the undergraduate level

• Full-time = a student enrolled for 12+ semester credits, 12+ quarter credits, or 24+ contact hours a week each term

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• Who must have a NPC?• Institutions with any FTFT students

• Foreign schools are exempt

• Approximating the student’s EFC• You may use either Federal Methodology or Institutional Methodology

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• Where must the NPC be located?• Varies by institution

• Make it easy to find – see National Postsecondary Education Cooperative (NPEC) guidance at http://nces.ed.gov/pubsearch/pubsinfo.asp?pubid=2010831rev

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• May I rename the NPC?• Best bet for full compliance is to call it a “net price calculator”

• May I include loans in our NPC?• Net price definition takes into account scholarships and grants

• Calculation must not consider loans

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• When and how often must we update our NPC?• Update on an annual basis, when new data become available to do so

• COA and grant aid data are from the same year and represent actual, not projected data

• ED releases updated versions of the template annually around January

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• How should we account for VA and DOD benefits?• Not need- or merit-based grant/scholarship aid, so not subtracted from COA in calculating net price

• You may collect information that will provide more accurate cost estimates, but—• Provide HEA-required NPC first• Clearly ID whether/how these benefits were included

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• May we use a third party’s (e.g., State, college system, private servicer) NPC?• NPC must be accessible via your “.edu” URL

• Calculator must have all minimum elements

• Institution-specific data

• NOTE: do not direct users to ED’s website

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• Does ED use the NPC URLs reported to IPEDS?• YES. Please make sure they work and are correct!• Net Price Calculator Center

• College Scorecard

• College Navigator

• Zip file (available on NPC Information Center)

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Net Price Calculator Center

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http://collegecost.ed.gov/netpricecenter.aspx


• Resources• NPC Information Center http://nces.ed.gov/ipeds/resource/net_price_calculator.asp• FAQs

• Quick start guides

• Bulk upload tools

• EFC tables

• Template source code

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• Resources• Help Desk: [email protected] or 1-877-299-3593

• GEN-13-07: http://ifap.ed.gov/dpcletters/GEN1307.html

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Textbook Information

• Section 133 of the HEA requires institutions to disclose textbook information to—• Students

• College bookstores

• Applies to each IHE receiving Federal financial assistance

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• Information for students• Disclose on the web-based schedule of courses used for pre-registration and registration purposes

• Include ISBN and retail price info of required and recommended textbooks and supplemental materials for each course

• You decide the format

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• Information for students• A: Include ISBN and retail price info of required and recommended supplemental materials for each course

• If not A, then B: If ISBN not available, provide the author, title, publisher, and copyright date

• If not B, then C: If you determine the disclosure is not practicable, say “TBD”

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• Information for students• In addition to pricing information, include a notice on your paper-based written course schedule• Let students know that information is available on the web-based course schedule

• Specify the URL for the web-based course schedule

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• Information for college bookstores• College bookstore = a bookstore “operated by, or in a contractual relationship or otherwise affiliated with” the institution

• Institutions must provide certain information to a college bookstore (see next slide)

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Textbook Information• Information for college bookstores

• Your institution must tell the bookstore:• The course schedule for the upcoming academic period

• For each upcoming course/class:

– The ISBN and retail price (or alternatives B or C, as needed) for each required or recommended textbook or supplemental materials

– The number of students enrolled

– The maximum student enrollment

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• Additional information• HEA encourages institutions to disseminate information to students about:• Programs for renting or purchasing used textbooks

• Guaranteed buy-back programs

• Alternative content delivery programs

• Other cost-saving strategies

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• Resources• GEN-10-09 http://ifap.ed.gov/dpcletters/GEN1009FinalTextbookGuidance.html

• GAO report (released June 6, 2013) http://www.gao.gov/products/GAO-13-368

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Resources for Schools

• Statute – HEA • Section 132(h) – NPC

• Section 133 – textbook information

• Section 485 – bulk of disclosures

• Regulations – www.ecfr.gov

• 34 CFR §668, Subpart D

• 34 CFR Part 86 (Drug-Free Schools & Communities)

• FSA Handbook – Vol. 2, Chapters 6-8

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Resources for Schools

• FSA Assessments on consumer info• http://ifap.ed.gov/qahome/qaassessments/consumerinf

ormation.html

• NPEC report and supplement• http://nces.ed.gov/pubsearch/pubsinfo.asp?pubid=2010

831rev (part 1)

• http://nces.ed.gov/pubsearch/pubsinfo.asp?pubid=NPEC2012831 (supplement)

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Frequently Missing Disclosures• In this session:

• Annual Notice• Drug and Alcohol Abuse Prevention • FERPA Notification• Voter Registration• Copyright Infringement• Satisfactory Academic Progress (SAP) policies

• In other sessions:• Gainful Employment Disclosures – session 30• Complying with the Clery Act: Practical Advice – session

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Frequently Missing Disclosures

• Annual Notice• Institutions must distribute a notice each year to all enrolled students • The notice must list and briefly describe the information that the school is required to disclose and tell the student how to obtain the information

• “Notice” means a 1:1 communication• If you post the information on an Inter- or Intra-net website, you must include the exact electronic address where the information is posted in the notice

• State in the notice that you will provide a paper copy of the information upon request

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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, and must:• Distribute certain information to students and employees annually (34 CFR §86.100)

• Conduct a biennial review of the program to determine effectiveness, needed changes, and whether disciplinary sanctions are consistently enforced

• Provide review results upon request

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• Drug and Alcohol Abuse Prevention

• 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

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Frequently Missing Disclosures• Drug and Alcohol Abuse Prevention

• Information to include:

• 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

Frequently Missing Disclosures• 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• 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 in nearly every State and DC must:• Make a good faith effort to distribute a mail-in 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

• May distribute the form electronically

• *Institutions in ID, MN, NH, ND, WI, WY, and the territories are exempt

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• Copyright infringement (peer to peer file sharing)• Institutions must disclose to prospective and enrolled

students:

• Explicit statement that unauthorized distribution of copyrighted material may subject student to civil and criminal liabilities

• Description of the institution’s policies on unauthorized P2P file sharing, including disciplinary actions

• Summary of penalties for violation of Federal copyright laws

* There is also a PPA component to the copyright infringement requirements

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• SAP Policies• Make sure you have updated your SAP policies to

conform with the regulatory changes that were effective July 1, 2011 and

• Ensure that your consumer disclosures for SAP accurately reflect those policies

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Resources

• HEOA changes• GEN-08-12 (especially pages 95-102)

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

• http://familypolicy.ed.gov

• Model FERPA notification http://www2.ed.gov/policy/gen/guid/fpco/ferpa/ps-officials.html

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Resources

• Copyright infringements• GEN-10-08 published 6/4/2010

http://ifap.ed.gov/dpcletters/GEN1008.html

• Final regulations published 10/29/2009 http://ifap.ed.gov/fregisters/FR102909GeneralandNonLoanProgrammaticFinalRule.html

• SAP • Final program integrity regulations published 10/29/2011

http://ifap.ed.gov/fregisters/FR102910Final.html

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Student and Family Tools

• There is overlap between• Information you disclose to the public (i.e., enrolled students, prospective students, employees, etc.) and

• Information you report to the Department

• We use information that you report to create tools for students and families

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College Affordability & Transparency Center

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http://collegecost.ed.gov/catc/

College Scorecard

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http://www.whitehouse.gov/issues/education/higher-education/college-score-card

College Scorecard

• Compares institution to “similar institutions” on each measure, based on IPEDS and NSLDS data

• Data is updated annually

• Possible future changes:• Enabling comparison of 2+ institutions at once

• [email protected]

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College Navigator

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http://nces.ed.gov/collegenavigator/

College Navigator

• Department’s college search tool• Information on over 7,400 institutions participating in the HEA programs

• Data from IPEDS, FSA, and OPE

• Over 2.5 million site visits last year

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College Navigator

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• Provides:• General institutional info

• Admissions requirements

• Tuition and fees and average net price

• Programs and majors/fields of study offered

• Retention and graduation rates

• Athletics statistics

• Campus safety statistics

• Accreditation information

• Cohort default rates

College Navigator

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Financial Aid Shopping Sheet

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• Standardized, clear, concise format helps prospective students understand and compare financial aid offers

• Adopted by over 2,000 institutions, representing over 48% of undergrad students (about 8.8 million)

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• Continuous improvement based on feedback from students, FAAs, and guidance counselors

• For 2014-15 version, we:• Adjusted the wording for clarity

• Added glossary to explain terms

• Expanded customizable box for institution-specific information

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• Website with resources www.ed.gov/financial-aid-shopping-sheet• Development history

• Annotated Shopping Sheet

• Institutions using the Shopping Sheet

• FAQs

• HTML specifications

• Institutional metric data file

• [email protected]

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StudentAid.gov

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StudentAid.gov

• FSA’s streamlined website • Includes comprehensive information on the student aid life cycle

• Builds in tips and guides for students• FAFSA4caster

• Repayment Estimator

• Things to consider in selecting a school

• Links to StudentLoans.gov

• Comparing colleges brochure

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StudentAid.gov

• Integrates with FSA’s social media outlets

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Contact Information

Ashley HigginsOffice of Postsecondary Education

Phone: 202-219-7061

E-mail: [email protected]

Amber Johnson

Federal Student Aid

Phone: 215-656-5998

E-mail: [email protected]

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QUESTIONS?

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ashley higgins and amber johnson | dec. 2014 u.s. department of education 2014 fsa training...

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