NYSFAAA STATE WIDE TRAINING 10/5/11 GAINFUL EMPLOYMENT ‘ROUND TABLE’

TODAY’S GOALS Now that the first two Gainful Employment deadlines have passed, we want to make sure everyone: Has done everything they need to Knows what to do next Understand the potential ramifications of the Gainful Employment Regulations.

THIS IS AN OPEN FORUM WEBINAR DO NOT hold your questions for the end. Your questions are the second most important aspect of today’s session. The most important portion of today’s session is to hear the answers to everyone’s questions. We want everyone to participate as we are ALL BIRDS OF A FEATHER – aka – IN THE SAME BOAT.

RULES OF ENGAGEMENT Everyone’s phone will be muted except for your State Wide Training Co-Chairs (Vera and Beth). If you have a question, comment or response: You can type it in the comments box – choose the ‘staff’ tab. Vera or Beth will jump in and pose the question/comment. You can type in that you have a question, comment or response to a question. Vera or Beth will tell me that John Smith has a Q, C or Response. I will then un-mute John and put him back on mute when complete.

RULES OF ENGAGEMENT If your co-chairs believe that we need to move on they may ask everyone to hold questions to the end. If there are any questions that relate to compliance – no one should guess what the answer is. That would be very dangerous. Your co-chairs will note the question and submit it to When they get a response they will share them on NYSFAAA-L. We are scheduled to end at noon. However, we have arranged to go as late as 12:30 if necessary.

RULES OF ENGAGEMENT Our plan is to record this webinar and make it available on the NYSFAAA website and/or utube. Once it has been posted to the web we will let everyone know via NYSFAAA-L. WARNING: By virtue of your asking or responding to a questions (or any other verbal comment) you are giving NYSFAAA permission to record you and make it public. FURTHER WARNING: Do not say something you might regret.

AGENDA Summary/Discussion GE Disclosures GE Reporting GE New Programs Impact on PPAs – are you in compliance? GE Metrics

ALL INFO GE ON IFAP

GE DISCLOSURES July 1 st deadline required disclosures The name and U.S. Department of Labor's Standard Occupational Classification (SOC) code of the occupations that the program prepares students to enter, along with links to occupational profiles on the U.S. Department of Labor's O*NET Web site or its successor site. The on-time graduation rate for students completing the program.

GE DISCLOSURES The tuition and fees the institution charges a student for completing the program within normal time. The typical costs for books and supplies (unless those costs are included as part of tuition and fees), and the cost of room and board, if applicable. The job placement rate for students completing the program.

GE DISCLOSURES The median loan debt incurred by students who completed the program (separately by Title IV loans and by other educational debt to include both private educational loans and institutional financing) as provided by the Secretary. Other information the Secretary provided to the institution about the program.

GE DISCLOSURES July 1 st deadline (Current) Impact if you are not in compliance Are you in compliance? Many institutions think they are but they are not. DOE Position on the deadline

GE DISCLOSURES Let’s share experiences

SAMPLE COMPLIANT DISCLOSURE

GE REPORTING Why? Who? When? DOE position on the deadline? What if I cannot/did not?

GE REPORTING Circumstances that Require Submission of Missing or Incomplete Explanations (see Gainful Employment Electronic Announcement #18 on August 9, 2011) The institution has no GE Programs. The GE Program was Title IV eligible in the award year, but was not Title IV eligible in one or more of the award years between and

GE REPORTING Circumstances... The institution is a foreign school and will not be reporting for a GE Program because there were fewer than 10 students enrolled in the program in the relevant award year. Note: Domestic institutions must report for all GE Programs, regardless of the number of students who were enrolled.. The institution is unable to report for one or more of the required award years ( through ). The institution is unable to report for one or more of its GE Programs.

GE REPORTING Circumstances.. The institution is unable to report all of the information required for each student who was enrolled in a GE Program in the required award years ( through ). Any other circumstance where the institution is unable to meet the regulatory reporting requirements by the established timelines for reporting.

GE REPORTING The required explanation(s) of missing or incomplete GE Program information must be submitted by an institution in an sent to Subject Line of - include the first 6 digits of the your OPEID and the institution’s name. Body of –provide the name, phone number, and e- mail address of a contact person at the institution. This is the person they will contact if we have any questions on the missing or incomplete data explanation provided. Then add the explanation

GE REPORTING SUMMARY OF DATA ELEMENTS

GE REPORTING NSLDS RECORD LAY OUT

GE REPORTING Let’s share experiences

GE New Programs THINGS MIGHT BE CHANGING On September 27, 2011, DOE published in the Federal Register a Notice of Proposed Rulemaking (NRPM) that proposes changes to the regulations to streamline the application and approval process for new educational programs Federal Register Opinion. Don’t forget the calendar – early implementation? For now you must abide by the current regulations!

GE New Programs

GE New Programs E-App, PPA, ecar Let’s share experiences

GE Metrics Two Standards – Three Measures  Repayment Rate –  A percentage of the loan amounts that a GE Program’s former students are repaying (weighted for loan balance).  Debt to Earnings Ratio –  For the GE Program’s completers, the average educational loan annual repayment amount as a proportion of the average borrowers’ annual income. 30

GE Metrics repayment Rate Loan repayment rate for a program calculated annually using the following ratio:  OOPB = Original Outstanding Principal Balance  LPF = Loans Paid in Full  PML = Payments-Made Loans OOPB of LPF plus OOPB of PML OOPB

GE Metrics debt to income rnings Earnings Rate Discretionary Income Rate Average Annual Loan Payment Amount Mean or Median Annual Earnings Average Annual Loan Payment Amount Mean or Median Annual Earnings less 1.5 X poverty guideline

D GE Metrics to-Earnings -Earnings  Calculating of the annual loan payment  Uses the program's median loan debt,  Amortized at 6.8% over –  10 years for a certificate or AA program,  15 years for a baccalaureate program, or  20 years for a graduate program

Pn GE Metrics  A program must pass at least one of the three rates to be a Gainful Employment Program eligible for Title IV participation.  Repayment rate of at least 35%.  Debt-to-Earnings rate of less than  12% of total earnings, or  30% of discretionary income.

GE Metrics Loss of TIV Eligibility Failing ALL 3 metrics for three FYs in a four year period Earliest year for eligibility loss is FY 2015: if ALL 3 Metrics failed for FYs 2014, 2013, 2012 Must wait 3 years before re-applying for program eligibility

 A program is a failing program for a year if it does not meet ANY of the minimum standards.  After one year’s failure institution must —  Disclose to students and prospective students the amount by which the program did not meet the minimum standards and any plans for improvement;  Establish a three ‐ day waiting period before students can enroll. Pe GE Metrics e Requirements

GE Metrics o FY 2012 Debt Measures – to be released early 2013 o FY 2011 Debt Measures – to be released early 2012 * *for information purposes only (Per info at NASFAA Conference we can expect this June 2012)

GE Metrics Let’s share thoughts and strategies