1. MASFAA 2013 October 6 th – 9 th, 2013 Indianapolis, Indiana Consumer Information and Disclosures Dana Kelly Regional Director and Trainer Nelnet Partner Solutions

2. What must be disclosed?

3. What Must Be Disclosed  General disclosures ◊ Institutional information ◊ Financial aid information ◊ Family Educational Rights & Privacy Act (FERPA) 34 CFR 99.7 ◊ Student Right-To-Know Act (educational outcomes) Retention, completion, graduation, and transfer-out rates Placement and types of employment of graduates Types of graduate/professional programs in which graduates from four-year programs enroll 3

4. What Must Be Disclosed  Athletic disclosures ◊ Equity in Athletics Disclosure Act (EADA)  Drug and alcohol abuse prevention ◊ 34 CFR 86.100  Security and safety disclosures ◊ Campus security (Cleary Act) Hate crimes ◊ Fire safety ◊ Missing student notification policy ◊ Emergency notification ◊ Emergency response and evacuation 4

5. Campus Crime and Fire Safety  Annual reports published and distributed to students and employees by October 1  Distribution through publications and mailings ◊ Direct mailing via USPS, campus mail, or email ◊ Publications provided to each individual ◊ Posting on the website 5

6. What Must Be Disclosed  Vaccination policy  Student body diversity ◊ Schools must disclose the percentage of enrolled, full-time students in the following categories: Male Female Pell Grant recipients Self-identified members of a racial/ethnic group  Plans for improving academic programs 6

7. What Must Be Disclosed  Voter registration information ◊ Program Participation Agreements (PPA) ◊ Schools must make a good faith effort to distribute voter registration forms to students and make voter registration forms widely available Satisfied by sending an email with state’s voter registration form or internet address to the form Message exclusively about voter registration 7

8. What Must Be Disclosed  Textbook information ◊ Pricing information posted on online course schedule ◊ GEN-10-09  Copyright policies and sanctions ◊ Peer-to-peer file sharing ◊ A sample statement and other copyright requirements are included in GEN-10-08 8

9. What Must Be Disclosed  Provisions for books and supplies for Pell- eligible students ◊ Under certain conditions, Pell-eligible students must be able to obtain or purchase, by the seventh day of a payment period, their required books and supplies  Transfer of credit policies ◊ Disclosure current transfer of credit policies ◊ Disclose school with which there is an articulation agreement 9 Program Integrity Final Rule

10. What Must Be Disclosed  FSA loan disclosures ◊ Financial assistance information Terms and conditions of FSA loans ◊ Student loan information published by ED ◊ Entrance and exit loan counseling www.studentloans.gov Student loan publications available for order at www.fsapubs.org www.fsapubs.org 10

11. www.fsapubs.org 11

12. What Must Be Disclosed  Private student loan disclosures ◊ Preferred Lender Arrangements (PLA) ◊ Information on private loans Provide prospective borrower with TILA disclosures Inform borrowers of possible eligibility for FSA loans and that FSA loan terms may be more favorable ◊ Private loan disclosures must be presented in manners distinct from FSA loan information ◊ Provide information needed for student to complete the self-certification form 12

13. What Must Be Disclosed  Code of Conduct ◊ Required under Program Participation Agreement (PPA)  Schools must: ◊ Develop a code ◊ Publish prominently on institution’s website ◊ Administer and enforce such code ◊ Annually inform the institution’s officers, employees, and agents of code requirements  Additional requirements for Preferred Lender Arrangements (PLAs) 13

14. What Must Be Disclosed  Net price calculator ◊ Schools must post a net price calculator on their websites by October 29, 2011 ED’s template published October 29, 2009 http://nces.ed.gov/ipeds/resource/net_price_calcul ator.asp http://nces.ed.gov/ipeds/resource/net_price_calcul ator.asp ◊ May use ED’s calculator, develop own, or contract with a third party ◊ Include “at a minimum the same data elements” found in ED’s template 14

15. What Must Be Disclosed  Teacher preparation program report ◊ Required for schools that prepare teachers for initial state certification or licensure ◊ Report annually to state and public ◊ Refer to GEN-08-12 for specific reporting requirements 15

16. What Must Be Disclosed  Information on written arrangements to provide educational programs must be made available to enrolled and prospective students ◊ Written arrangements: Between eligible institutions For study abroad Between an eligible institution and an ineligible institution 16 Program Integrity Final Rule

17. What Must Be Disclosed  Gainful employment information ◊ Program Integrity Regulations  Information webpage ◊ http://www.ifap.ed.gov/GainfulEmploymentInfo/i ndex.html http://www.ifap.ed.gov/GainfulEmploymentInfo/i ndex.html Regulations Dear Colleague Letters and Electronic Announcements FAQs Available training Additional resources 17

18. What Must Be Disclosed  Constitution and Citizenship Day ◊ A Constitution Day program must be conducted on September 17 ◊ Not in the Title IV regulations ◊ Additional information and resources http://www.archives.gov/fed- employees/constitution-day.html http://www.archives.gov/fed- employees/constitution-day.html http://memory.loc.gov/ammem/collections/contine ntal/ http://memory.loc.gov/ammem/collections/contine ntal/ http://www.archives.gov/exhibits/charters/charters.html http://www.archives.gov/exhibits/charters/charters.html 18

19. How must it be disclosed?

20. How It Must Be Disclosed  Annual direct notice to all enrolled students regarding the availability of consumer information ◊ General disclosures (presented on slide 3) ◊ FERPA ◊ Athletic disclosures (if applicable) ◊ Annual security and fire safety reports ◊ Athletic program participation rates and financial support data 20

21. How It Must Be Disclosed  Annual direct notice must include a brief description of consumer information and how to access more details ◊ If provided on a website, disclose exact address for accessing the details ◊ Include a statement that the institution will provide a paper copy of the information on request 21

22. How It Must Be Disclosed  Disclosure through websites ◊ A school may post information that must be disclosed to the school websites For enrolled students or current employees − Internet or an intranet website For prospective students or employees − Internet website 22

23. Frequently Missing Disclosures

24.  Drug and Alcohol Abuse Prevention  FERPA Notification  Voter Registration  Satisfactory Academic Progress Policy 24

25. Frequently Missing Disclosures  Drug and Alcohol Abuse Prevention ◊ Institutions must certify that they have adopted/implemented a program to prevent drug and alcohol abuse As part of the program, institutions must distribute certain information to students and employees annually (34 CFR § 86.100) Must do a biennial review of the program to determine effectiveness, needed changes, and whether disciplinary sanctions are consistently enforced Must provide review results upon request 25

26. Frequently Missing Disclosures  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 ◊ 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 26

27. 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 27

28. Frequently Missing Disclosures  Annual FERPA Notification ◊ Must specify procedures for exercising rights ◊ Must specify criteria for determining who constitutes a school official and what constitutes a legitimate educational interest 28

29. Frequently Missing Disclosures  Voter Registration ◊ Institutions in nearly every state and D.C. must: Make a good faith effort to distribute a mail 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 29

30. Frequently Missing Disclosures  Voter Registration ◊ May distribute the form electronically ◊ Institutions in ID, MN, NH, ND, WI, WY, and the territories are exempt 30

31. 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 ◊ Make sure consumer disclosures for SAP accurately reflect those policies 31

32. What other resources are available?

33. Resources  FSA Assessments on consumer information FSA Assessments on consumer information  National Postsecondary Education Cooperative National Postsecondary Education Cooperative 33

34. Resources  FSA Handbook – Volume 2, Chapters 6-8 FSA Handbook – Volume 2, Chapters 6-8  Regulations – 34 § 668, Subpart D34 § 668, Subpart D  GEN-08-12 (especially pages 95-102) GEN-08-12  Email FERPA@ed.gov with FERPA questionsFERPA@ed.gov 34

35. Resources  Model FERPA notifications Model FERPA notifications  SAP ◊ Final program integrity regulations published October 29, 2011 Final program integrity regulations published October 29, 2011 35

36. Resources  Additional Campus Crime and Fire Safety resource ◊ The Handbook for Campus Safety and Security Reporting The Handbook for Campus Safety and Security Reporting ◊ Accompanying online tutorial Campus Safety and Security Reporting Training 36

37. Campus Security Website http://www2.ed.gov/admins/lead/safety/campus.html#han dbook 37

38. Resources  Additional Campus Crime and Fire Safety resources ◊ Campus crime and fire safety statistics Campus crime and fire safety statistics ◊ Crime statistics Crime statistics 38

39. Consumer Information Disclosures At-a-Glance 39

40. Thank You! Dana Kelly National Trainer Nelnet Loan Servicing dana.kelly@nelnet.net 336-848-6441 40