Nautochia Webb, Training Officer Federal Student Aid U.S. Department of Education Gainful Employment Overview & Update 2016 NJASFAA Conference April 15, 2016

Agenda GE Basics Debt to Earnings Measurements GE Calculations Disclosures & Certifications The GE Completers List Challenges Resources 2

Gainful Employment Basics 3 3

Regulations Final Rule published October 31, 2014 Effective – July 1, 2015 New Disclosures Effective – January 1, 2017 Dear Colleague Letter GEN – posted June 30,

Which Programs are GE Programs The HEA provides that to be Title IV-eligible an educational program must be offered by: A public or non-profit postsecondary educational institution, if the program leads to a degree; or Any institution, if the program prepares students for “gainful employment in a recognized occupation” Generally, all non-degree programs must lead to gainful employment Generally, most programs at for- profit institutions must lead to gainful employment 5 5

Which Programs are GE Programs Electronic Announcement #53 – What is a Gainful Employment (GE) Program? Electronic Announcement #53 GE Operations Manual GE Programs include – Teacher certification programs leading to a certificate awarded by the institution 6 6

RELEASE FINAL DEBT-TO- EARNINGS RATES TO INSTITUTIONS WINTER 2016 Important Dates REPORTING JUL 31, 2015 (For 2008/09 to 2013/14 Data) OCT 01, 2015 (For 2014/15 Data) COMPLETERS LIST CHALLENGES DUE FROM INSTITUTIONS 45 DAYS LATER DRAFT DEBT-TO- EARININGS RATES TO INSTITUTIONS SUMMER 2016 DRAFT DEBT-TO-EARNINGS RATES CHALLENGES DUE FROM INSTITUTIONS 45 DAYS LATER COMPLETERS LIST TO INSTITUTIONS THIS WINTER DISCLOSURES (UPDATES) JAN 2016 DISCLOSURES (NEW REGULATORY REQUIREMENTS) JAN 2017 PROGRAM CERTIFICATIONS DEC 2015 & Ongoing 7 7

GE Reporting Report all Title IV Students by July 31, 2015 Report 2008–09 through 2013–14 award years Programs with Medical and Dental Residencies report 2007–08 through 2013–14 award years Report 2014–15 Award Year by October 1, 2015 Report 2015–16 Award Year by October 1, 2016 Title IV students only 8 8

Debt to Earnings Measures 9 9

Debt to Earnings Overview 10

Gainful Employment Measure Debt-to-earnings (D/E) rates Annual Earnings D/E rate Discretionary Income D/E rate Passing: Annual D/E < = 8% or Discretionary D/E < = 20% Failing: Annual D/E > 12% and Discretionary > 30% Zone: Annual D/E > 8% and 20% and <= 30% 11

Cohort Periods D/E rates are calculated using debt and earnings of students who complete a GE program during a specific cohort period Cohort period is either two- or four-years Two-year cohort used if 30 or more students completed during the period Four-year cohort used if fewer than 30 students completed during the two-year cohort period If fewer than 30 students completed during the four-year cohort period, D/E rates will not be calculated 12

GE Rates Calculation 13

D/E Rates Calculation Discretionary Income Rate = annual loan repayment divided by (the higher of the mean or median annual earnings less(1.5 times the HHS Poverty Guideline)) Annual earnings rate = annual loan payment divided by the higher of the mean or median annual earnings 14

G/E Rates Calculations Exclusions Any of student’s Title IV loans are in a military-related deferment Any of student’s Title IV loans have been approved or are under consideration for a T/P disability discharge Student was enrolled in any other program during the calendar year for which SSA earnings are obtained For undergraduate GE programs, student completed a higher- credentialed undergraduate program at the same institution For graduate GE programs, the student completed a higher- credentialed graduate GE program at the same institution The student is dead 15

Gainful Employment Results Program’s loses Title IV eligibility if: D/E measures – Fails in two out of three years OR D/E measures - Fails or in the zone for four consecutive years 16

Disclosures & Certifications 17

Required Disclosures Occupations Normal time to complete program On-time graduation rate for completers Tuition & fees, books & supplies, room & board Placement rate for completers (as determined by State or Accreditor methodology) Median loan debt Other program information provided by the Secretary 18

Required Disclosures On-Time Graduation Rate for Completers Specify the percent of students who completed in the most recently completed award year within normal time Step 1 Determine how many students completed in the most recently completed award year. Step 2 Determine the number of students in Step 1 who completed within normal time. Step 3 Divide the number in Step 2 by the number in Step 1. Then, multiply by

Required Disclosures Example: On-Time Graduation Rate for Completers Total number of students who completed in the AY Number of students who completed within normal time 20

Required Disclosures On-Time Graduation Rate for Completers Leaves of absence Time if a student withdrew and then returned Enrollment in other programs if the student did not complete the other program Educational Costs Provide tuition & fees charged for completing the program within normal time Provide typical costs for books & supplies (unless included in tuition and fees) Provide costs for room & board, if applicable Other expenses are optional, but provide a link/access to program cost information under Student Right-to- Know Median Loan Debt Specify the median (not mean) loan debt incurred by students who completed the program Three categories of debt  3 medians! Title IV, HEA program loans Private education loans Institutional financing plans 21

Disclosure Template The template is an application that creates a standardized Web page with the GE disclosure information Web page must be hosted on Institution’s site If you offer multiple programs with the same CIP Code and Credential Level, consider separate disclosure templates if there is a significant difference in the: Published length of the program Tuition, fees, or other costs Placement rate calculations (e.g., offered in different States) See GE Electronic Announcement #25! 22

Disclosure Availability Include the Template in all promotional materials about the GE program Promotional materials include invitations, ads, course catalogs, social media, etc. that mention or otherwise refer to a specific GE program If not feasible to include the Template, include a live link or URL to it and clearly explain what is available at that Web page Post the Template on your institution’s Web page Prominently display direct links to the Template on: The GE program home page Other institutional Web pages about the GE program 23

Disclosures Under New Final Rules Transition from current disclosure requirements to requirements of the final regulations Consumer testing & Focus groups Seek comments on new disclosure template Guidance and technical assistance Delay in effective date of new disclosure requirements until January 1, 2017, gives the Department time to conduct consumer testing and prepare new disclosure template 24

Potential Future Disclosure Items Primary occupations Program’s completion and withdrawal rates Length of the program Number of clock-hours, credit-hours or equivalent, as applicable, in the program Total cost of tuition and fees, and the total cost of books & supplies, and equipment that a student would incur for completing the program within the length of the program Placement rate for the program Mean or median earnings of specific groups groups of students Most recent program cohort default rate Most recent annual earnings rate Total number of individuals enrolled in the program during the most recently completed award year Loan repayment rate Of individuals enrolled in the program during the most recently completed award year, the percentage who received a Title IV loan or private loan for enrollment in the program Median loan debt of all of specific groups of students Whether program does or does not satisfy specific educational prerequisites for licensure Whether program is programmatically accredited and the name of the accreditor Link to ED’s College Navigator website or similar federal resource 25

Certifications Transitional Certification Required of currently participating institutions offering GE programs New or returning institutions that have an E-App in process will have the required certifications included in the resulting Program Participation Agreement (PPA) Must be submitted to the Department no later than December 31, 2015, unless: Institution has submitted an E-App that resulted or will result in a new PPA executed between July 1, 2015 and December 31, 2015 Must be signed by institution’s President/Chancellor/CEO Certifications renewed when institution recertifies PPA 26

Certifications Institution must update information about its GE programs using the Application to participate in Federal Student Aid Programs (E-App) so that its Eligibility and Certification Approval Report (ECAR) is current Institution must certify that each GE program it offers: Is approved by a recognized accrediting agency or otherwise included in the institution’s accreditation by its recognized accreditation agency If a public vocational institution, is approved by a State agency recognized to approve such programs in lieu of accreditation Is programmatically accredited if required by a Federal governmental entity or by a governmental entity in the state where the institution is located or in which it is otherwise required to obtain State approval 27

Certifications Changes after transitional certification requirement has been met Institution adding or revising GE information on E-App that does not result in a new PPA must provide a new certification each time the E-App is updated Includes: Establishing or reestablishing the eligibility of a program Discontinuing a program’s eligibility Ceasing to provide a program for 12 consecutive months Losing program eligibility Changing a program’s CIP code, or credential level ED will monitor (on an ongoing basis) certifications for accuracy and completeness GE Electronic Announcement #54 – Certification Requirements for Gainful Employment Programs Reminds institutions of the requirement to provide ED with an accurate listing of their GE programs 28

The GE Completers List 29

The GE Process Draft GE Completers List Draft GE Completers List Challenge Final GE Completers List Request Earnings Data from SSA by Program Draft GE Debt-to-Earnings Calculation Draft GE Debt-to-Earnings Challenge Final GE Debt-to-Earnings Calculation GE Alternate Earnings Appeal 30

The GE Completers List What is a Completers List? A list of the students who completed a GE Program during the cohort period as reported to NSLDS What is its Use? Institutions review the completers list for accuracy Obtaining the annual earnings from SSA To calculate GE Debt-to-Earnings rates For earnings for disclosures 31

The Completers List – Cohort Period Students who completed a GE Program during the Cohort Period will appear on the GE Completers List Cohort Period For 2014 – 2015 calculation year: 2-year (2YP) cohort = students graduating in and award years 4-year (4YP) cohort = students graduating in , , , and award years 2-year (2YP-R) cohort = students in medical/dental residency programs graduating in and award years 32

The GE Completers List - Exclusions Students are excluded from both the numerator and denominator of the Debt-to-Earnings rates for the following reasons: In School In Military Death Disabled SSA match limit Subsequently completed higher credential program In school and/or in military exclusions are based on the calendar year (2014) of the earnings year from SSA 33

The Draft and Final Completers List Draft Completers List Sent to institution’s TG mailbox associated with the Batch Gainful Employment Notification Package Delivered with message class: GECOMBOP File Layout for the GE Completers list is located in the Gainful Employment User Guide Appendix C Final Completers List Contains data from the Draft Completers List and any updates provided by FSA based on approved challenges Sent to institution’s TG mailbox associated with the Batch Gainful Employment Notification Package Delivered with message class: GECOMBOP File Layout for the GE Completers list is located in the Gainful Employment User Guide Appendix C 34

The Draft and Final Completers List Distributed through SAIG Institutions should sign up for the Batch Gainful Employment Notification Package at the SAIG Enrollment Web site Institutions must be signed up for Batch Gainful Employment Notification Package to receive the GE Completers List If institutions are not signed up for the Batch Gainful Employment Notification Package, institutions will not receive the GE Completers List If this occurs, institutions can request the GE Completers List Report on the NSLDSFAP Web site 35

Requesting the GE Completers List Report To request an ad-hoc report, click on the corresponding active bullet number to the left of the Report ID column 36

Requesting the GE Completers List Report Select File Format, Output Results, and then Submit 37

Requesting the GE Completers List Report School users who select the Single File option will receive the Completers List for all GE programs for the institution during the current Calculation Year in a single file School users who select the Multiple Files option will receive backup data for each GE program for the institution during the current Calculation Year in separate files. The GE Completers List Report will produce the GE completers reported by NSLDS that relate to the portion (Draft or Final) of the GE Calculation Cycle that is occurring at the time of the request 38

Requesting the GE Completers List Report Sent to the TG mailbox associated with the user that made the report request Delivered with message class: Summary Level/Condensed : GECOMSOP Backup Detail : GECOMPOP File Layout for the GE Completers List Report is located in the Gainful Employment User Guide Appendix B.3 39

Challenges 40

Data Challenges and Appeals System (DCAS) The Data Challenges and Appeals Solution (DCAS) is a new system that will allow institutions to challenge their self-reported data as well as Department-calculated metrics For the first release, DCAS will allow institutions to submit data challenges and corrections to the draft GE completers list DCAS provides institutions with ability to submit: Data corrections to the draft GE completers list Changes to the draft GE completers list to either add or remove students 7 41

Participation Management For access to DCAS, you will need to sign up through SAIG Enrollment – Authorized users may be enrolled in the DCAS Service by a School’s (or organization’s) Primary Destination Point Administrator (DPA) Enrollment via the Student Aid Internet Gateway (SAIG) Enrollment Website Detailed instructions can be found on IFAP – Gainful Employment Electronic Announcement #67Gainful Employment Electronic Announcement #67 Note for Foreign School Users: Need to complete an updated paper SAIG Enrollment form to enroll for DCAS Online Service

Types of adjustments: Add Student Change Student Data Corrections Challenges to Draft Completers List 9 43

Add Program Student and Program GE Records for: Title IV Programs not in NSLDS Person Data Conflict Higher Credential Level Completers CIP/CL Change Add a GE Record (to correct an omission) Add Student Adjustment 10 44

Change Student Adjustment Change Exclusion Flag on GE Completers List for: Student is Dead Student in Total and Permanent Disability, Pending or Granted Student in Military-Related Deferment Status During Earnings Year Student Enrolled in Another Title IV Program During Earnings Year Student Completed Higher Credential GE Program Person Data Conflict 11 45

Data Correction Adjustment Submit Corrections to Program GE Record Award Year Program Attendance Begin Date Program Attendance Begin Date for Award Year Program Attendance Status Date Program Attendance Status Date during Award Year Private Loans Amount Institutional Debt Tuition and Fees Length of GE Program Length of GE Program Measurement Enrollment Status as of 1 st Day of Enrollment in Program Allowance for Books, Supplies and Equipment Data Correction – Delete GE Records This is your last chance for this D/E calculation to correct data that your institution reported! 12 46

What is a Case? In order to challenge the GE completers list data, institutions will have to create a case. A case is defined as collection of student record(s) to be submitted for challenge and is maintained at an OPEID+CIP/CL level

What is a Case? Case ID is a combination of the type of challenge, Challenge Year, OPEID (6 digit), CIP, CL, and a 3-digit unique identifier e.g. DCL Adjustments to the draft GE completers list can be classified into three types: Add Student Change Student Data Corrections 14 48

DCAS Case Processing Steps Two primary roles exist for the school user – School Case Preparer and School Case Manager Note : Certain actions can only be performed by School Case Managers 1. Login to DCAS (Authentication of the user is performed by AIMS) 2. Select Perspective (i.e., user role) 3. Create a Case 4. Add adjustments to the case a. SSN Search b. Select/Create Record c. Add/update data elements d. Add attachments and/or comments e. Save Record 15 49

DCAS Case Processing Steps 5. Manage created case 6. Complete Case 7. Certify Case/Decertify a Case (School Case Manager only) a. Performed when a case is ready to be submitted to FSA for processing (Certify); or b. When a case previously certified, but not yet submitted, needs to be updated. (Decertify) 8. Transfer Case (School Case Manager only) - Performed if case needs to transferred to a different preparer. This can happen only if the case is not yet certified and submitted 9. Submit Case (School Case Manager only) Once a case is submitted, school user can no longer edit the case

DCAS things to remember 1. A new program cannot be added to your Draft Completer List using the DCAS Challenge Process. 2. For Person Data Conflicts, if the incorrect record for the Student is on the GE Backup File, the incorrect record must be excluded from the file using a Change Student Adjustment. The new “corrected” Student record can be added using the Add Student Adjustment. 3. For students identified as completing a Higher Credentialed GE program, the existing record on the GE Backup file will require a Change Student adjustment to exclude the record from the Completer List. The Higher Credentialed GE program student will need to be added using the Add Student Adjustment. 4. For a CIP/CL change, both a Change Student and Add Student Adjustment will be required. 5. When submitting challenges to Draft Completers List and data corrections, you also need to remember to correct the GE data on NSLDS. 6. Data Corrections submitted through DCAS are your last chance to correct data on the Completers List

Resources 52

GE Resources Electronic Announcements #54 and #66 Electronic Announcements #54#66 Link to E-App: Transitional Certifications Due December 31 st 53

GE Resources GE Operations Manual DCAS User Manual DCAS Training Material NSLDS Gainful Employment User Guide All materials are on the IFAP Gainful Employment Page:

GE Disclosure Resources GE Disclosure Template negreg-summerfall.html negreg-summerfall.html Requirement Template application Quick start guides Bulk data file upload tool Help desk: , 55

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Region II Training Officer 57 Nautochia Webb Region II: NJ, NY, PR, V irgin Islands

Region III Training Officers Amber Johnson Craig Rorie Region III: DC, DE, MD, PA, VA, WV 58

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QUESTIONS? 60