NYSFAAA STATE WIDE TRAINING 10/5/11

GAINFUL EMPLOYMENT ‘ROUND TABLE’

Howard LesliePresenter, Moderator, Colleague and

Friend

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

THIS IS AN OPEN FORUM WEBINARDO 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 ENGAGEMENTEveryone’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 ENGAGEMENTIf 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 GE-Questions@ed.gov. 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 ENGAGEMENTOur 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.

AGENDASummary/DiscussionGE DisclosuresGE ReportingGE New ProgramsImpact on PPAs – are you in compliance?

GE Metrics

ALL INFO GE ON IFAP

GE DISCLOSURESJuly 1st 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 DISCLOSURESThe 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 DISCLOSURESThe 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 DISCLOSURESJuly 1st 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 2010-2011 award year, but was not Title IV eligible in one or more of the award years between 2006-2007 and 2010-2011.

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 (2006-2007 through 2010-2011).

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 (2006-2007 through 2010-2011).

Any other circumstance where the institution is unable to meet the regulatory reporting requirements by the established timelines for reporting.

GE REPORTINGThe required explanation(s) of missing or incomplete GE Program information must be submitted by an institution in an e-mail sent to GE-Missing-Data@ed.gov.

Subject Line of e-mail - include the first 6 digits of the your OPEID and the institution’s name.  

Body of e-mail –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 REPORTINGSUMMARY OF DATA ELEMENTS

GE REPORTINGNSLDS RECORD LAY

OUT

GE REPORTING

Let’s share experiences

GE New ProgramsTHINGS 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

Opinion.Don’t forget the calendar – early

implementation?For now you must abide by the current

regulations!

GE New Programs

GE New Programs

GE New Programs

GE New Programs

GE New ProgramsE-App, PPA, ecar

Let’s share experiences

GE MetricsTwo 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 Metricsrepayment

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 incomernings

Earnings Rate

Discretionary Income Rate

Average Annual Loan Payment AmountMean or Median Annual Earnings

Average Annual Loan Payment Amount Mean or Median Annual Earnings less 1.5 X poverty

guideline

DGE Metricsto-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

PnGE 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.

PeGE Metricse Requirements

GE Metrics

oFY 2012 Debt Measures – to be released early 2013

oFY 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