College Admission & Gainful Employment: Implications of ACE EOI and Select Federal Regulations

1. College Admission & Gainful Employment: Implications of ACE EOI and Select Federal Regulations Mr. Jose Dela Cruz Coordinator – Academic Affairs Projects Oklahoma State Regents for Higher Education

2. Agenda • State Department of Education ACE Graduation Requirements • EOI Exams and College Admission • Gainful Employment COSA Presentation 12 January 2012

3. State Department of Education ACE Graduation Requirements • The Achieving Classroom Excellence Act (ACE) is a statewide effort to raise expectations for student achievement in Oklahoma public schools, which was implemented on June 7, 2006. The requirements began with the students who entered the ninth grade in the 2008-2009. • ACE sets forth requirements that must be met in order for a student to earn a diploma from an Oklahoma public high school • To demonstrate mastery in the subject areas listed below, all students must score Proficient or Advanced on the associated End-of-Instruction (EOI) exams. • ACE Algebra I; • ACE English II; and • Two of the following five: ACE Algebra II,ACE Biology I,ACE English III,ACE Geometry, orACE United States History • ACE graduation requirement statement on high school diplomas: • “The student has met the graduation requirement of demonstrating mastery in the state academic content standards.” OAC 210:10-13-16 COSA Presentation 12 January 2012

4. EOI Exams and College Admission • A student who does not successfully complete the required number of EOI exams and is not a high school graduate, but whose high school class has graduated is eligible for admission into community colleges using policy section 3.9.6.C.2 [ Adult Admission] • The Council on Instruction (COI) Admission/Retention/Transfer (ART) committee recognizes that students in some areas of the state may have limited access to community colleges due to geographical location • The consensus of the COI ART committee for regional and research institutions is that these institutions may admit students who do not successfully complete the required number of EOIs via: • The alternative admission category [institutions may admit up to 8 percent of freshman or 50 freshman, whichever is higher, who do not meet regular admission criteria]; OR • The president may request to the Chancellor an exception to policy 3.9.4.A1 [research] or 3.9.4.B1 [regional]. NOTE: In addition to students being admitted under the parameters detailed above, it is also understood that these students will have participated in the ACT or SAT and be admitted consistent with the 3.19 Assessment and 3.20 Remediation policies, and will have meet curricular and performance requirements, except as allowed under the 3.9.6.B Alternative Admission policy for the regional and research universities. COSA Presentation 12 January 2012

5. ACE EOI Implications on Financial Aid • Concerns have been raised about students’ eligibility for: • OKC-GO • Ticket to Rose • Tulsa Achieves • Students must be high school graduates to be eligible for OKPromise. Our read of published eligibility requirements indicate a high school diploma or graduation from a particular district or high school is required. COSA Presentation 12 January 2012

6. Gainful Employment Program Requirements • The U.S. Department of Education released two sets of final regulations for career college programs. • The first set of regulations effective July 1, 2011 (issued October 28, 2010) imposes new reporting and disclosure requirements for gainful employment programs, as well as a new notice and approval process for creation of these programs. • The second set of regulations (issued June 13, 2011) requires these programs adequately prepare students for gainful employment or risk losing access to federal student aid. These “debt measures” are effective July 1, 2012. The first year a program could lose aid access is 2015. COSA Presentation 12 January 2012

7. What do the Regulations Require? • Under the new regulations, programs must satisfy at least one of three tests to remain eligible for Title IV aid: • At least 35% of former students are repaying their loans (shown if a loan is paid in full, the balance is reduced by at least $1, the student is on track for public service forgiveness, or the student is making income-based payments) • Estimated annual loan repayment of a typical graduate will not exceed 12% of his/her total earnings • Estimated annual loan repayment of a typical graduate will not exceed 30% of his/her discretionary income (These tests are administered on a program-by-program basis and calculated on an October 1 to September 30 fiscal year. Results must be disclosed per 34 C.F.R. §668.6(b)(1)(v)) COSA Presentation 12 January 2012

8. How Does an Institution Identify if its Programs Satisfy the Tests? • Institutions generally will not have access to all data necessary to independently calculate whether the tests have been satisfied. Rather, the Department of Education will perform calculations based on information submitted by the institution through the National Student Loan Data System and median incomes obtained from the Social Security Administration. • The Department of Education’s calculations will be forwarded to schools. Institutions may verify the list of students submitted to the Social Security Administration, but may not access individual earnings data. • Institutions may challenge the Department of Education’s calculations through use of earnings from state-sponsored data systems, an appropriately-conducted institutional survey, and Bureau of Labor statistics. COSA Presentation 12 January 2012

9. What if All Three Tests are Failed? • Failure of all three tests in a single year results in additional required disclosures to students explaining the amount by which the program failed the tests and the actions planned to improve program performance. • Failure of all three tests in two consecutive years or two years of a three-year period results in required warnings to students that their debts may be unaffordable and the program may lose Title IV eligibility. • Failure of all three tests in three years of a four-year period results in ineligibility for Title IV aid and a prohibition from reapplying for Title IV aid for at least three additional years. COSA Presentation 12 January 2012

10. Position of the State Regents • State Regents’ staff provide updates as needed to chief academic officers (CAO) during Council on Instruction (COI) meetings. • Recommended that CAO’s work with their financial aid offices due to financial aid implications. COSA Presentation 12 January 2012

11. Question/Comments? Mr. Jose Dela Cruz (405) 225-9141 jcruz@osrhe.edu COSA Presentation 12 January 2012