MASFAA ConferenceSamoset Resort - Rockport, Maine

Consumer Information and Disclosures

Annmarie Weisman | 10.22.2012

Agenda

• Review types of required disclosures• Provide references with regulatory, statutory, and

other citations• Provide additional resources• Q and A

Note: Regulatory citations are Title 34 unless otherwise noted

Method of Disclosure

• 668.41(b)(c) and 668.44 • Provides general definitions and information

about how to disclose required consumer information

Academic Program Improvement Plan

• What• Requirement to make available any plans for improving

academic programs

• When: August 14, 2008

• Who/Where• Academic Affairs Office; Publication office

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Peer-to-Peer File Sharing• What: Develop and implement written plans to effectively combat

unauthorized distribution of copyrighted materials• All users within network• Includes: technology deterrents, reviews, legal alternatives,

education efforts, gov’t & and school penalties/liabilities

• When: August 14, 2008

• Who/Where: • IT Office; Legal Affairs• Provost; Publication Office

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Retention, Placement, Graduate School Rates

• What• Make Available

• Institution’s retention rate as reported to IPEDS• Placement of and employment obtained by graduates of degree

or certificate programs (if calculated)• Types of graduate and professional education in which

graduates of 4 yr. degree programs enroll

• When: August 14, 2008

• Who/Where: Registrar, Career Placement, Academic Affairs, Research, Student Affairs, Alumni Relations

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Completion/Graduation Rates

• What• Additional Categories

• Gender, race/ethnic group, TIV awarding (Pell & Stafford)

• When • August 14, 2008• 2-year degree granting schools – 11/12 Academic Year

• Who/Where• Registrar’s Office• Financial Aid Office• Publication/Research

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Campus Security Information

• Institutional security policies and crime statistics 668.46• Clery (Campus Security) Act: 668.46

• Crime Statistics• Timely Warning and Emergency Notification• Daily Crime Log• Emergency Response/Evacuation• Missing Student Notification Policy

Campus Security Report• What

• Hate crime data includes: larceny – theft, simple assault, intimidation, and vandalism

• Statement on law enforcement authority of campus security• Relationship with State and local police (including

agreements/MOUs to investigate crimes)

• When: August 14, 2008 (1st submitted in October 1, 2010 report)

• Who/Where• Security/Public Safety Office, Executive Offices• Publication, Research and Development Office

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Campus Security Report• What

• Emergency Response and Evacuation Procedures• Immediate notification to campus community (and larger segment if

applicable)• Notification system/content• Responsible parties• Annual tests of process

• When: August 14, 2008 (1st submitted in October 1, 2010 report)

• Who/Where• Security/Public Safety Office, Executive Offices• Publication, Research and Development Office

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Campus Security Report• What

• Missing Student Notification (on-campus housing)• Student opportunity to provide confidential contact• Responsible parties to report information to• Police notified under applicable laws (24 hours)• If under 18 (not emancipated), parents notified

• When • August 14, 2008 (1st submitted in October 1, 2010 report)

• Who/Where• Security/Public Safety Office, Student Affairs, Residential Services

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Annual Fire Safety Report• What

• Required for schools with On Campus Student Housing• Fire statistics for 3 year calendar period

• Fires, injuries/death, property damage

• Procedures and plans around fire safety• Systems, drills, education/training, improvements, specific policies – smoking,

candles, etc., responsible parties, evacuation procedures

• Maintain Fire Log

• When: August 14, 2008 (1st submitted in October 1, 2010 report)

• Who/Where• Public Safety/Security, Residential Services, • Executive Offices, Publications, Research

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Drug and Alcohol• What

• Separate, clear notification to students regarding penalties for drug violations

• Separate, clear notification to students who lost eligibility that they are ineligible for TIV aid and how to regain eligibility

• Biennial review of drug and alcohol abuse program includes:• Number of violations/fatalities on campus or part of campus activities• Number of and types of sanctions imposed

• When: August 14, 2008

• Who/Where• Security/Public Safety Office, Student Affairs, Publications/Research

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Transfer Credit, Diversity & Vaccinations

• What• Transfer of credit policy (including criteria) and list of articulation

agreements• Student diversity (gender/ethnicity) of enrolled full-time Pell

recipients• Vaccination Policies

• When• August 14, 2008

• Who/Where• Executive Offices, Provost, Registrar, Financial Aid • Medical Services

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Textbooks

• What• Textbook Information

• Include on Internet course schedule the ISBN & retail price • If not available - author, title, publisher, copyright date• Written course schedule contain reference to textbook information

on Internet schedule• Share textbook information with bookstore if requested– Also include number enrolled & max students in each class

• When: July 1, 2010

• Who/Where• IT Office, Provost, Registrar, Bookstore

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Net Price Calculator (NPC)• What

• Must post an NPC on website using school data to provide estimated net price information to current/prospective students • Must include a link to FOTW (fafsa.gov)• Average yearly price actually charged to full-time, first-year

undergrads (COA minus average need/non-need financial aid)• Use ED’s or institution’s calculator

• When: on site by October 29, 2011

• Who/Where• IT Office, Admissions, Registrar, • Financial Aid Office, Budget Office

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NET Price Calculator Help Desk:

(877) 299-3593 npc@inovas.net

Campus Disciplinary Policy

• What• PPA requires school to disclose (upon written request) to an

alleged victim of a crime of violence or non-forcible sex offense the results of a disciplinary hearing against an alleged student perpetrator

• When: August 14, 2009

• Who/Where• Legal Counsel, Student Affairs, Disciplinary Board

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Private Education Loans• What

• Provide disclosures under TILA section 128(e):• Applications/Solicitations; Loan Approval; Loan Consummation• Use Federal Reserve Board form or school’s own• Federal Reserve Board contact number - 202-452-3667

• School loans not considered private education loans if: – 90 days or less; paid back in 1 year with no interest

• Self-Certification Form - ED developed (cannot change)• Must be given if requested by student (3rd party lender)• Must be obtained and maintained by school if school is lender

• Effective: Loan disclosures – February 14, 2010• Self-Certification Form – GEN-10-01 (2/14/2010)

18NEW – Part 601 added to Title 34

Preferred Lender Arrangement

• What • Annual Disclosure to prospective/current students regarding

PLA with (FFEL and) private education lenders (website/written materials)• School loans not private education loans and/or in a PLA

under certain criteria – Short-term loans, school funds, Donor-directed funds, Title

VII/VIII Public Service Health, state aid programs with public service forgiveness option

• Effective: August 14, 2008 (regulations – July 1, 2010)

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NEW – Part 601 added to Title 34

School Code of Conduct

• What• Develop and publish code of conduct with respect to (FFEL and) private education loans

• Prohibit conflict of interest with responsibilities of school staff with loan duties • annually inform such staff

• Required for schools in any TIV loan program

• Effective: August 14, 2008

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Family Educational Rights & Privacy Act

• “FERPA”• 34 CFR Part 99• Annually notify students of rights under FERPA, including procedures for exercising rights to inspect/review records

• HIPPA & FERPA• 34 CFR Part 99; 45 CFR Parts 160, 162, and 164

• Health & Safety Exemption Requirement: • 34 CFR 99.31(a)(10) and 34 CFR 99.36• Public Law 107-56 and DCL April 12, 2002 

Other Consumer Information

• Each year a school must provide to enrolled students a notice containing a list of consumer information it must disseminate, and procedures for obtaining the information• Schools must provide this notice through a one-on-one

distribution• Financial assistance availability

• R2T4, SAP, Verification, ATB, types of aid, etc.• Institutional Information

• Cost of attendance, academic programs, refund policy, approving agencies, etc.

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Other Consumer Information

• Student Right-to-Know Act requires schools to disclose:• Completion or graduation rates and, if applicable, transfer out

rates for a specific cohort of the general student body• For schools that offer athletically related student aid,

completion or graduation rates and, if applicable, transfer out rates of students receiving athletically related student aid, if the school offers athletic aid• Must provide student athlete graduation rate information to

potential student athletes, parents, and high school coaches and guidance counselors upon making offer of athletic aid

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Other Consumer Information

• Equity in Athletics Disclosure Act - Co-ed institution of higher education that participates in an FSA program AND has an intercollegiate athletic program must prepare an annual report (provided to ED and consumers)• Contains participation rates, financial support, and other

information on men/women intercollegiate athletic programs• Required to publish report by October 15 and make available to

students, prospective students, and public

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Beginning Approaches

Committee?• Senior Administrator (e.g., VPAA – or final authority)• Athletics• Financial Aid• Institutional Research• IT• Campus Security• Dean of Students• Marketing• Career Services• Others?

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Getting Started

How: Collect information from units across campus

Determine compliance from Fin Aid, IR, VPAA

Publish to new consumer website & disseminate

When: Each semester email sent to BU constituents

Annual update to consumer website, student handbook,…

Where: Consumer Website, Catalog, Handbook, Safety & Security website

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Points to Consider

• Obtain support and approval from other offices• Educate campus and gain campus support• Create a system with checklists, calendars,

responsibilities, overall tracking system • Share your information• Cover your bases• Stay abreast of new regulations and share• Reward and recognize your efforts

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Resources

Resources

• 2012-13 FSA Handbook, Volume 2, Ch. 6 & 8

• 34 CFR 668.41-49 (Information)

• 34 CFR 99 (FERPA)

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Go to FSA Assessments for a complete listing of all required disclosures!

Go to FSA Assessments for a complete listing of all required disclosures!

Go to FSA Assessments for a complete listing of all required disclosures!

Higher Education Opportunity Act

• HEOA reauthorized the Higher Education Act of 1965 and established new institution-based disclosure requirements

• Enacted August 14, 2008• Public Law 110-315• Dear Colleague Letter GEN-08-12• http://www.ifap.ed.gov/dpcletters/GEN0812FP0810.html

Negotiated Rulemaking

• Non-loan disclosure issues negotiated Spring 2009• NPRM published August 21, 2009• Final rule published October 29, 2009

• http://www.regulations.gov/search/Regs/home.html#documentDetail?R=0900006480a4d8d9

• Final rules went into effect July 1, 2010

Other Institutional Information• DCL GEN 08-12

• Penalties associated with drug-related offenses• College Navigator Website• Student Body Diversity• Textbook information• Teacher Preparation Program Report• Voter Registration Form

Other Institutional Information

• Availability of Employee for Dissemination: 668.48

• Constitution and Citizenship Day: Federal Register 5/24/2005

Other Campus Security Information

• Handbook for Campus Crime Reporting• Under revision

• will include all campus safety topics• Campus Security Help Desk: 1-800-435-5985• Help Desk email:

Campussecurityhelp@westat.com

• FSA Assessments: Consumer Information, Activities 5 and 8

Information for Athletes

• Completion/graduation rates for the general student body: 668.48

• Calculating the rates 668.45• Disclosing the rates 668.45; 668.48• Completion/graduation rates for student

athletes: 668.45; 668.48• Equity in Athletics Disclosure Act 668.47 • Disclosure of the Report; 668.47

• Must submitted at: http://surveys.ope.ed.gov/athletics

Financial Assistance andInstitutional Information• Financial Assistance Information: 668.42• Institutional Information: 668.43

• Required School Information 668.43• Net Price Calculator DCL GEN 08-12• Vaccination PolicyDCL GEN 08-12 and 20 U.S.C. 1092(a)(1)

• Copyright Information 668.43(a)(10)

Safeguarding Student Information

• Establishing and Maintaining an Information Security Program 

• Pub. L. No. 106-102• US Code 15 U.S.C. 6801(b), 6805(b)(2)

Gainful Employment

• Gainful Employment• IFAP Gainful Employment Link*• 668.6(a); 668.6(b); 668.7• *Review the IFAP Gainful Employment link on a regular basis for

current updates and to view the Questions & Answers section.

Evaluation

Thank you for your attention!

To provide feedback to me and my supervisor, please complete an evaluation form.

Help with Title IV Questions

• For Schools• Research and Customer Care Center (RCCC)• 1-800-433-7327• fsa.customer.support@ed.gov

• For Students• Federal Student Aid Information Center (FSAIC)• 1-800-4FED-AID

School Participation Divisions

Contact Information

• For follow-up questions on this session, contact me at:

• Annmarie Weisman, Training Officer• annmarie.weisman@ed.gov• 215-656-6456

• To provide feedback to my supervisor:

• Jo Ann Borel, Supervisor• joann.borel@ed.gov• 281-758-8122

QUESTIONS?