1. Gainful Employment One School’s Journey National American University
10/15/2016

2. National American University
For-Profit Institution
31 Campuses
Majority Non-Traditional Students
Diplomas
Associates
Bachelors
Masters
Doctorates
All programs, All students must be reported
Except if Not Federal Financial Aid Recipient
National American University
10/15/2016

3. 34 Campuses-The Initial numbers
July 31, 2015 Initial reporting
94,929 unduplicated students for award years 2008/09 through 2013/14
124 files (each campus/award year combination had to be separate, some campuses opened later than 2008/09)
349 Error records corrected directly in NSLDS within 10 days of receiving the corrections file
October 1, 2015 Data for 2014/15 students
15, 929 unduplicated students for award year 2014/15
51 Error records corrected directly in NSLDS within 10 days of receiving the corrections file
October 1, 2016 Data for 2015/16 students
13, 821 unduplicated students for award year 2015/16
59 Error records corrected directly in NSLDS within 10 days of receiving the corrections file
National American University
10/15/2016

4. Debt to Earnings Calculation
Annual Earnings Rate
Annual Loan Repayment divided by
Mean or Median Annual Earnings (whichever is higher)
Discretionary Income Rate
Mean or Median Annual Earnings (whichever is higher) minus 150% of HHS Poverty Guideline
National American University
10/15/2016

5. What can we review for correctness?
Debt Amount for Calculation limited to:
Total tuition and fees, books and supplies and equipment OR
Total debt attributable to the program (Federal student Loans, Private Education Loans and Institutional Debt)
Whichever is less
Annual Loan Repayment Length for the above debt depends on degree level
Annual Earnings
Based on individual students submitted to Social Security Administration
Mean and Median calculated based on 2 calendar years preceding the year in which the rates are calculated
Discretionary Earnings 150% of $11,770 = $17,655
Calculation Exclusions
Military, permanent disability discharge, enrolled in another program during the years the mean and median were calculated, completed a higher degree at same school, deceased
National American University
10/15/2016

6. Completers List Received July 28, 2016
Department of Education combined all campuses into one Completers File
43 Programs
2123 Students
Discovered many students were not reported due to:
Enrolled in the BS degree but had completed the AAS degree requirements during this time and graduated with the AAS degree
Called GE about this and were told that if the student was not in attendance in the graduated degree at the time of graduation they could not be reported
National American University
10/15/2016

7. Who do we Review? 2123 Students! Only 2 people work GE-Only 45 days
Review only Programs w/small numbers?
Review only Students w/amounts of tuition and fees higher than average?
29 Programs w/less than 30 completers even with 4 year cohort
3 Programs w/ completers
4 Programs w/ completes
2 Programs w/ completers
5 Programs w/ more than 70 completers
5 Diploma students
70 Associates students
139 Bachelors students
0 Master
0 Doctorate
National American University
10/15/2016

8. What we Reviewed
45 Days to submit cases (Challenges) to the Completers list information
More time/people we could have reviewed more students
Total amount of student’s tuition and fees, books and supplies and equipment
Student’s enrollment begin and graduation dates
Did not review students in programs with less than 30 completers even on a 4 year cohort
139 Students reviewed
95 submitted cases
Had to not only submit the case but also had to correct the NSLDS data directly in NSLDS GE reporting
Only 1 case not approved (Student was not in initial reporting)
National American University
10/15/2016

9. What did you Review? How did it turn out?
National American University
10/15/2016

10. SSA Earnings File and Draft Debt to Earnings Rates
Received October 10, 2016
43 Programs
13 Programs no Earnings Data-Less than 30 completers
16 Programs used a 4 year cohort
My preliminary guess at the Debt to Earnings rates using our average graduated student debt level by degree type turned out to be completely wrong
We now have to work on corrections for the debt measures (received 10/19/16)
Review each student’s individual underlying loans
Loan period start and end dates
Loans prior to starting SULA tracking did not have a reduced loan period if the student withdrew
Loan amounts minus refunds and cancels
National American University
10/15/2016

11. Deadline Complications!!
Week of September 12-NAU’s Independent Audit of all campuses
September 30-FISAP
October 1-Early FAFSA
New forms, processes and software setup to complete for this
October 1-Yearly Gainful Employment Data
10 days after file received-Gainful Employment Data Corrections
This year also reviewed all 1398 Graduates for the year to ensure they were reported
October 17-During the week the draft Debt to Earnings measures sent
Starts the 45 day challenge period
October 19-IPEDs Fall Collection for Keyholders
November 2-IPEDs Fall Collection for Coordinators
What Else?
National American University
10/15/2016