CONSUMER INFORMATION AND DISCLOSURE REQUIREMENTS

Transcription

1 CONSUMER INFORMATION AND DISCLOSURE REQUIREMENTS Amy Hager Director of Financial Aid, Moberly Area Community College Missouri Association of Student Financial Aid Personnel {MASFAP}, President Elect

2 OASFAA CONFERENCE SPONSOR SPRING 2016 Thank you to Great Lakes Educational Loan Services, Inc. for their sponsorship of the OASFAA 2016 Spring Conference!

3 GOALS Background College Navigator Shopping Sheet Clery Act and Violence Against Women Act Drug and Alcohol Abuse Program Net Price Calculator New Perkins and Cash Management Many other Disclosures! Resources and References Available

4 CONSUMER INFORMATION BACKGROUND HEA requires institutions 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

5 66 Consumer Information and Disclosure Requirements! CONSUMER INFORMATION AT-A-GLANCE

6 SO MUCH TO DO! WHO IS GOING TO DO IT? IT CAN BE OVERWHELMING.

7 INSTITUTIONAL OFFICES WITH RESPONSIBILITY Financial Aid Office Registrar Admissions Business Office/Bursar Campus Police/Security Human Resources Athletics ADA/Disability Services Institutional Research Administration Student Housing Book Store Counseling Center Veterans Services Career Services Ombudsman Study Abroad Office Information Technology Services Public Relations/Communications Student Health Services Administration President/Provost Legal Counsel

8 BEST PRACTICES Appoint someone to Coordinate Work with all institutional departments Coordinate timing of notices, reporting, and disclosures Stays current on all changing requirements

9 GENERAL DISCLOSURE REQUIREMENTS ANNUAL NOTICE (34 CFR ) 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 Unofficial three-click rule.

10 COLLEGE NAVIGATOR WEBSITE HEA SECTION 132 Must provide link to College Navigator on school s website Collects data from schools to provide information about our schools to the U.S. Department of Education

11 COLLEGE NAVIGATOR 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

12 FINANCIAL AID SHOPPING SHEET Standardized, clear, concise format helps prospective students understand and compare financial aid offers Cannot be changed! Must appear in the exact format shown on the Shopping Sheet website. Not intended to replace your institution s award letter it is meant to act as a summary or cover sheet to help students consider all their option when selecting an institution. Adopted by over 3,000 institutions Institutions that have signed on to the Principles can be found at

13 FINANCIAL AID SHOPPING SHEET Website with resources Development history Annotated Shopping Sheet Institutions using the Shopping Sheet FAQs HTML specifications Institutional metric data file

14 THE CLERY ACT Applies to all schools that participate in the Title IV FSA programs Compliance begins on effective date of the PPA Exempt if the school only offers distance education programs and foreign institutions Must be distributed annually, by October 1. The Annual Security Report issued by October 1, 2016 will be the first to include three calendar years, under the new crime categories and definitions.

15 THE CLERY ACT BASIC COMPONENTS Maintain Crime Log and Publish Annual Security Report Maintain Fire Log and Publish Annual Fire Safety Report Collect Crime Reports from Campus Security Authorities Request Crime Statistics from Local Law Enforcement Submit Crime and Fire Statistics to ED Missing Student Identification and Notification Procedures Emergency Notification and Evacuation Procedures Issue Warnings and Alerts

16 THE CLERY ACT VAWA CHANGES (2014) Added crimes to be included in the annual ASR and policy statements for: Dating Violence, Domestic Violence, and Stalking For 2014 ASRs, institutions were required to make a good-faith effort to include incidents of domestic violence, dating violence, sexual assault, and stalking for calendar year 2013 The Department will not collect data on incidents of domestic violence, dating violence, sexual assault, and stalking for the 2013 calendar year Policies on sexual assault, dating violence, domestic violence and stalking must include descriptions of: Programs for new students and employees on prevention awareness Bystander intervention training Ongoing prevention and awareness education programs Procedures for when an incident is reported Prohibition on retaliation Institutions are also required to report how many crimes were found to be unfounded as well as the contact information of their lead Title IX coordinator

17 THE CLERY ACT VAWA CHANGES Definitions and clarifications: Clery geography are for which crime statistics must be reported. Includes: Campus property Non-campus properties owned by the institution outside contiguous geographical area, frequented by students and support institutional purposes Non-campus properties owned or controlled by a student organization reorganized by the institution Any area within jurisdiction of campus security

18 THE CLERY ACT VAWA CHANGES Definitions and Clarifications: Clarifies sexual assault terminology (consistent with the FBI) Hate crimes include gender identity and perceived gender as additional bias categories Does not make any changes to existing institutional obligations under Title IX Institutions must address how crime statistics are publically available without disclosing personally identifying information.

19 Disciplinary Hearings: THE CLERY ACT VAWA CHANGES Policies and Procedures for disciplinary hearings but address specific areas Officials must participate in training Accuser and accused have the right to advisor of their own choice

20 THE CLERY ACT The Department is still working to update the Handbook to include the changes made by VAWA For questions about Clery and reporting, contact our helpdesk at: (800) or

21 DRUG AND ALCOHOL ABUSE PREVENTION P.L FSA requirements based on the 1989 amendments of the Act Schools must: Implement a drug and alcohol abuse prevention program Provide information to students, faculty, and employees Provide a drug-free awareness program for its employees if school participates in Campus-Based Programs

22 DRUG AND ALCOHOL ABUSE PREVENTION Institutions Must: Have in operation a drug and alcohol abuse program that has is accessible to any officer, employee, or student (34 CFR ) Distribute annually to students and employees (electronic or paper) Conduct a review of the program every 2 years to determine: Effectiveness Needed Changes Consistency of disciplinary sanction enforcement Provide review results upon request

23 DRUG AND ALCOHOL ABUSE PREVENTION Biennial Review must include: Number of drug and alcohol-related violations and activities that occur on school campus or as a part of the school s activities and that are reported Number and type of sanctions imposed by school as a result of drug and alcohol-related violations and fatalities on school campus or as a part of the school activities

24 DRUG AND ALCOHOL ABUSE PREVENTION Information to be distributed annually: Standards of conduct that clearly prohibit 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 for violations of the standards of conduct and a description of sanctions.

25 DRUG AND ALCOHOL ABUSE PREVENTION Drug-Free Workplace for Schools with Campus-Based Programs Establish a drug-free awareness program to provide information to employees Distribute notice to employees of prohibited unlawful activities and actions resulting from employee violations Notify ED and take appropriate action when it learns of an employee s conviction under any criminal drug statute. Applies to all offices and departments of a school that receives Campus-Based funds.

26 NET PRICE CALCULATOR HEA SECTION 132(H) 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. Must be easy to find ED uses the NPC URL reported to IPEDS Reported on the College Scorecard and College Navigator websites

27 What is required? NET PRICE CALCULATOR 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 10/29/2011 May use ED s template or an independently developed NPC Must include minimum data elements Calculations includes Grants and Scholarships only does not include loans Updated annually using prior year data

28 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 Institution s Cost of Attendance (average annual cost of tuition and fees, room and board, books, supplies, and transportation (-) Total need- and merit-based Federal, State, and institutional grant aid awarded to FTFT students (=) Number of FTFT students receiving such aid

29 NET PRICE CALCULATOR RESOURCES See National Postsecondary Education Cooperative (NPEC) guidance at: NPC Information Center under Tools for Schools on IFAP.ed.gov FAQs; Quick start guides; Bulk upload tools; EFC tables; Template source code GEN-13-07: NPC Help Desk:

30 NEW REQUIREMENTS FEDERAL PERKINS LOANS (GEN 16-05) Notice and Explanation to Student must include: End of future availability Repayment and forgiveness benefits available to Direct Loan borrowers are not available to Federal Perkins Loan borrowers Borrower s option to consolidate into Direct Consolidation Loan, including any benefits provided by so doing Comparison of Direct and Perkins Loan interest rates The borrower has reached Maximum annual borrowing limit for Direct Subsidized Loans (current borrowers); or Maximum annual borrowing limit for Direct Subsidized and Unsubsidized Loans (new borrowers)

31 NEW CASH MANAGEMENT DISCLOSURES (FEDERAL REGISTER VOL 80, NO. 210, 10/30/2015) Applies to institutions that: Contract with third party servicer to process Title IV credit balances or to offer or market account that would receive Title IV balance (Tier 1); or, Arrange for a financial institution to offer or market accounts (Tier 2)

32 ANNUAL FERPA NOTICE (34 CFR (C); 34 CFR 99) Inform all enrolled students of their FERPA rights to: Inspect, review and amend education records File a complaint with ED if institution doesn t comply Consent to disclose PII from his/her education records, except as specified by law If disclosing directory information without prior consent, school must provide to student a notice that includes: Types of directory information Student s right to refuse all or some of the information and the timeframe to do so in writing

33 ACADEMIC PROGRAMS (34 CFR ; 34 CFR ) Each school must make available to prospective and enrolled students information about the academic program of the school, including: Current degree programs and other educational and training programs Instructional, laboratory, and other physical plant facilities that relate to the academic program Faculty and other instructional personnel Any plans by the school for improving the academic program [upon determination by the school that such a plan exists]

34 WRITTEN ARRANGEMENTS (34 CFR (a)) Must make available to prospective and enrolled students the following information about programs designed to be offered in part by other entities: Portion of the program not being offered by the home school Name and location of the other organization/school Method of delivery not being offered by the home school Estimated additional costs that may be incurred due to arrangement

35 TRANSFER CREDIT (34 CFR (a)) Each school must disclose and make available to prospective and enrolled students a statement of the school s transfer of credit policies that includes, at a minimum: Any established criteria the school uses regarding the transfer of credit earned at another school A list of schools with which the school has established an articulation agreement

36 COPYRIGHT INFRINGEMENT POLICES (34 CFR (a)) Schools must readily make available to enrolled and prospective students the school s policies and sanctions related to copyright infringement, including: Statement that explicitly informs students that unauthorized distribution of copyrighted material, including unauthorized peer-to-peer file sharing, may lead to civil/criminal liabilities A summary of penalties for violation of federal copyright laws School s policies about unauthorized peer-to-peer file sharing and disciplinary actions taken against students who engage in illegal downloading or unauthorized distribution of copyrighted materials using the school s information technology system

37 TEXTBOOKS (HEA SECTION 133) Include on Internet course schedule the International Standard Book Number (ISBN) & retail price If not available - author, title, publisher, copyright date If not practicable to disclose indicate TBD Written course schedule contain reference and address to textbook information on Internet schedule Share textbook information with school bookstore if requested Also include number enrolled & max students in each class/course

38 ACCREDITATION/APPROVAL/LICENSURE (34 CFR ; 34 CFR ) Make available to prospective and enrolled students: Names of associations, agencies, or governmental bodies that accredit, approve, or license the school and programs Procedures for obtaining or reviewing documents describing accreditation, approval, or licensing

39 FSA PENALTIES FOR DRUG LAW VIOLATIONS (34 CFR ) Institutions must provide to each student (at time of enrollment) a separate and clear written notice that advises that a student who is convicted for any drug offense while receiving Title IV aid will result in a loss of eligibility for any Title IV, HEA grant, loan or work-study assistance. Students who have lost eligibility, an institution must provide them with a separate, clear, and conspicuous notification of Title IV eligibility loss and must advise the student how Title IV eligibility may be regained

40 JOB PLACEMENT RATES (34 CFR (b)(10) A school that advertises job placement rates as a means of recruiting students to enroll must make available to prospective students, at or before the student applies for enrollment: Most recent available data concerning employment and graduation statistics Any other information necessary to substantiate the truthfulness of the advertisements Relevant state licensing requirements of the state in which the school is located for any job for which the course of instruction is designed to prepare students

41 STUDENT BODY DIVERSITY (HEA SEC. 485(A)(1)(Q)) Make available to current and prospective students data about student body diversity, including percentage of enrolled, full-time students in the following categories: Male Female Self-identified members of a major racial or ethnic group Federal Pell Grant recipients

42 VOTER REGISTRATION (HEA SECTION 487(a)(23)) Institutions in nearly every State and DC must: Distribute voter registration forms (for federal elections and state elections for governor or other chief executives) to enrolled students Make voter registration form widely available to students Request forms 120 days prior to voting registration deadline May distribute the form electronically Does not apply to schools in states that do not have a voter registration requirement or that allow voters to register at the time of voting Institutions in ID, MN, NH, ND, WI, WY, and the territories are exempt

43 VACCINATION POLICY HEA SECTION 485(A)(1)(V) Schools must make available to enrolled and prospective students information about school policies regarding vaccinations

44 BOOKS AND SUPPLIES 34 CFR (I) Provide disbursement policy on how Pell eligible students will obtain or purchase books and supplies by 7th day of the payment period

45 STUDENTS WITH DISABILITIES 34 CFR ; 43; 231 Must make available to prospective and enrolled students information about facilities and services available to students with disabilities, including intellectual disabilities

46 CONSTITUTION DAY SECTION 111 OF DIVISION J OF PUB. L Must provide to students served by the school an educational program each September 17 commemorating the signing of the Constitution

47 AND SO MANY MORE! General financial aid information Cost of Attendance Refund Policies SAP Policy Completion/Graduation and Transfer-out Rates Equity in Athletics Disclosures Retention rates Gainful Employment Disclosures Entrance and Exit Counseling Preferred Lender Lists Private Education Loan Disclosures Code of Conduct Disbursement policies Etc., Etc., Etc Placement rates

48 RESOURCES NASFAA Webinar Series FSA Assessments Consumer Information Consumer Information Disclosures At-A-Glance information.html FSA Handbook Volume 2, Chapters 6-8 Appendix F Institutional Reporting and Disclosure Requirements for FSA Programs

49 Amy Hager President-Elect, Missouri Association of Student Financial Aid Personnel Director of Financial Aid, Moberly Area Community College , extension