1. Consumer Disclosure Requirements and Tools
Session 31
Consumer Disclosure Requirements and Tools
Ashley Higgins and Amber Johnson | Dec U.S. Department of Education 2014 FSA Training Conference for Financial Aid Professionals

2. Agenda Student & Family Tools Select Disclosure Topics Resources
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

3. 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

4. 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.”

5. Number of FTFT students receiving such aid
Net Price Calculator
What is net price?
The average yearly price actually charged to first-time, full-time (FTFT) undergraduate students receiving student aid at the institution
Total need- and merit-based Federal, State, and institutional grand aid awarded to FTFT students
Institution’s Cost of Attendance (average annual cost of tuition and fees, room and board, books, supplies, and transportation
Number of FTFT students receiving such aid

6. Net Price Calculator 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

7. Net Price Calculator Input Elements Minimum required data 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

8. Net Price Calculator 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

9. Net Price Calculator
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

10. Net Price Calculator 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

11. Net Price Calculator Where must the NPC be located?
Varies by institution
Make it easy to find – see National Postsecondary Education Cooperative (NPEC) guidance at d= rev

12. Net Price Calculator 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

13. Net Price Calculator 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

14. Net Price Calculator 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

15. Net Price Calculator
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

16. Net Price Calculator 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)

17. Net Price Calculator Center

18. Net Price Calculator Resources
NPC Information Center culator.asp
FAQs
Quick start guides
Bulk upload tools
EFC tables
Template source code

19. Net Price Calculator Resources
Help Desk: or
GEN-13-07:

20. 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

21. Textbook Information 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

22. Textbook Information 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”

23. Information for students
Textbook Information
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

24. Textbook Information 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)

25. 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

26. Textbook Information 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

27. Textbook Information Resources
GEN ookGuidance.html
GAO report (released June 6, 2013)

28. Resources for Schools Statute – HEA
Section 132(h) – NPC
Section 133 – textbook information
Section 485 – bulk of disclosures
Regulations –
34 CFR §668, Subpart D
34 CFR Part 86 (Drug-Free Schools & Communities)
FSA Handbook – Vol. 2, Chapters 6-8

29. Resources for Schools FSA Assessments on consumer info
ormation.html
NPEC report and supplement
0831rev (part 1)
C (supplement)

30. 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 32

31. 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

32. Frequently Missing Disclosures
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

33. Frequently Missing Disclosures
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

34. 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

35. 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

36. 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

37. Frequently Missing Disclosures
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

38. 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 and
Ensure that your consumer disclosures for SAP accurately reflect those policies

39. Resources HEOA changes http://familypolicy.ed.gov
GEN (especially pages )
Model FERPA notification officials.html

40. Resources Copyright infringements SAP
GEN published 6/4/
Final regulations published 10/29/ anProgrammaticFinalRule.html
SAP
Final program integrity regulations published 10/29/

41. 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

42. College Affordability & Transparency Center

43. College Scorecard

44. 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

45. College Navigator

46. 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

47. College Navigator Provides: Retention and graduation rates
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

48. College Navigator

49. Financial Aid Shopping Sheet

50. Financial Aid Shopping Sheet

51. Financial Aid Shopping Sheet
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)

52. Financial Aid Shopping Sheet
Continuous improvement based on feedback from students, FAAs, and guidance counselors
For version, we:
Adjusted the wording for clarity
Added glossary to explain terms
Expanded customizable box for institution-specific information

53. Financial Aid Shopping Sheet
Website with resources aid-shopping-sheet
Development history
Annotated Shopping Sheet
Institutions using the Shopping Sheet
FAQs
HTML specifications
Institutional metric data file

54. StudentAid.gov

55. 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

56. StudentAid.gov
Integrates with FSA’s social media outlets

57. Contact Information
Ashley Higgins
Office of Postsecondary Education
Phone:
Amber Johnson
Federal Student Aid
Phone:

58. QUESTIONS?