Foreign Schools Potpourri

1. Session 45 Foreign Schools Potpourri Andy Hagedorn and Carla Johnson | Nov-Dec. 2016 U.S. Department of Education 2016 FSA Training Conference for Financial Aid Professionals

2. AGENDA • Ineligible Courses • Consumer Information • Post-Withdrawal Disbursements (PWD) • Regulatory Timeframes • Return of Title IV Funds • Letters of Credit • Institutional Student Information Record (ISIR)

3. INELIGIBLE COURSES • Telecommunications • Measured by Direct Assessment • Study Abroad or Internship in the United States • Written Arrangements With Ineligible Entities • Unapproved Non-Degree Programs

4. CONSUMER INFORMATION • Schools Are Required to Provide Information Published by the U.S. Department of Education to Students Regarding Loan Availability • https://studentaid.ed.gov/sa/eligibility • The Publication Should Include Information About Rights and Responsibilities of Students and Schools Under Title IV, HEA Loan Programs

5. CONSUMER INFORMATION • Notification Requirements: • Annual Notice to Prospective and Enrolled Students Describing Availability of Consumer Information • Mode of Delivery

6. CONSUMER INFORMATION • Required Information About the School: • Cost of Attending the Institution • Institutional Refund Policy • Requirements/Procedures for Official Withdrawal • Treatment of Title IV funds When a Student Withdraws

7. CONSUMER INFORMATION • Required Information About the School: • Financial Aid SAP Policy • Academic Programs • Names of Associations, Agencies or Governmental Bodies that Accredit, Approve, or License the Institution and its Programs

8. CONSUMER INFORMATION • Required Information About the School: • School Official Designated to Provide Financial Aid Information to Students • Description of the Services and Facilities Available to Students With Disabilities • Study Abroad Approved for Credit by the Home Institution

9. CONSUMER INFORMATION • Required Information About the School: • A Description of the Transfer of Credit Policies Established by the Institution • A Description of Written Arrangements the Institution has Entered into in Accordance With 34 C.F.R. § 668.5 • https://studentaid.ed.gov/sa/prepare-for-college/choosing-schools/types/international#international-schools

10. CONSUMER INFORMATION • Student Right-To-Know Act: • Retention Rate • Placement Rate • Completion and Graduation Rate • Types of Graduate and Professional Education Pursued After Completing Four-Year Degree

11. FERPA • Student’s Rights Under the Family Educational Rights and Privacy Act (FERPA): • Right to Inspect and Review Education Records Maintained by the School • Right to Request the School Correct Records Which They Believe to be Inaccurate or Misleading • Right to Have Control Over the Disclosure of Personally Identifiable Information From the Records • Right to File a Complaint With the U.S. Department of Education

12. CONSUMER INFORMATION • Misrepresentation: • Nature of Education Program • Nature of Financial Charges • Employability of Graduates • Relationship With U.S. Department of Education

13. CONSUMER INFORMATION • Missing Person Notification Policy: • For Schools Providing On-Campus Housing Only • Missing Student Notification Procedures: • Student’s Contact Information Should be Registered Confidentially • Report Must be Referred Immediately to the School’s Police, Campus Security Department or Local Law Enforcement Agency • Designated School Officials Must be Notified Within 24 hours

14. GAINFUL EMPLOYMENT • Annual Disclosure – Gainful Employment (GE) Template (Academic Year) http://ope.ed.gov/GainfulEmployment/ • Exclude the Following if Program has Less Than 10 Students: • On-Time Completion Rate • Median Loan Debt (Title IV Debt, Private Educational Loan Debt, and Debt From Institutional Financing)

15. GAINFUL EMPLOYMENT • All Institutions Must Disclose the Following: • Occupations (by Name and Standard Occupational Classification (SOC) Code) • Published Length of Time it Takes to Complete the Program (Normal Time) • Program Costs • Placement Rates

16. GAINFUL EMPLOYMENT • Gainful Employment Reporting: • Report 2015-2016 Award Year - October 1, 2016 • New Disclosure Requirements - January 31, 2017 • Academic Year – July 1 to June 30

17. OTHER RESOURCES • Required Disclosures are Identified in Regulations and the Program Participation Agreement • 34 C.F.R. § 668.41(a)-(g)) • https://ifap.ed.gov/ForeignSchoolInfo/ForeignSchoolInfo.html • FSA Handbook Volume 2, Chapter 6 • Foreign School Handbook • The Handbook for Campus Safety and Security Reporting

18. POST-WITHDRAWAL DISBURSEMENT • Made Within 180 Days of the Date of Determination • Meets the Limitations on Making a Late Disbursement • Second or Subsequent Disbursement of a Direct Loan • First Year, First-Time Borrower • Valid Institutional Student Information Record (ISIR) • Valid Student Aid Report (SAR) • Signed Master Promissory Note (MPN) • Loan Originated

19. POST-WITHDRAWAL DISBURSEMENT • Required Notifications Within 30 Days of the Date of Determination: • Borrower’s Right to Decline All or a Portion of the Loan Disbursement • Request Confirmation of Any Amount to Be Credited to the Student’s Account or Directly Disbursed to the Borrower • Explain the Obligation to Repay the Loan • Specify a Deadline of at Least 14 Days for Required Response/Confirmation

20. EXCESS CASH • Three-Day Rule for Funds Received Under the Advance Payment Method • Excess Cash Tolerance

21. CREDIT BALANCE REFUNDS • Refund No Later Than 14 Days • Non-Compliant Authorization to Hold Title IV Credit Balances • Credit Balances Not Released by End of Loan Period or Award Year • Paying FSA Credit Balances by Initiating Electronic Fund Transfer (EFT)

22. R2T4 AND CREDIT BALANCES • Withdrawn Student With Credit Balance Refund • Hold All Title IV Credit Balances Until R2T4 is Calculated • Credit Balance is “Aid/Amount Disbursed” in the Calculation • Determine If Credit Balance Changes Because of Accreditor or Institutional Refund Policy • Release Credit Balance Within 14 Days

23. DEADLINES RELATED TO WITHDRAWAL • 30 Days for School to: • Perform the R2T4 Calculation • Exit Interview • Enrollment Status Reporting to National Student Loan Data System (NSLDS) • Notify Student of Eligibility for a Post-Withdrawal Disbursement (PWD) • 45 Days for School to Return Title IV Funds • 180 Days to Make PWD of Loan Funds to Student or Parent

24. RETURN OF FUNDS • 240 Days Return of Funds Rule – Unclaimed Title IV Credit Balance • 120-Day Rule (Returning Funds) • Actual Disbursement Date vs. Anticipated Disbursement Date

25. SAR vs. ISIR • Student Aid Report (SAR) • Institutional Student Information Record (ISIR) • “Paid-On” ISIR Transactions • “Pushed” ISIRs • ISIR Request from Central Processing System (CPS) • “Daily” ISIRs • Using FAA Access to CPS Online to Request ISIRs from the New ISIR Datamart

26. LETTERS OF CREDIT • Participating Institutions • Zone Alternative- Score 1.0 – 1.4, Not Exceed Three Consecutive Years • Provisional Certification - 10% LOC (Minimum) • Letter of Credit Only - 50% LOC (Minimum)

27. LETTERS OF CREDIT • Alternative to LOC for Public Schools to Be Considered Financially Responsible • Missing Compliance Audit - Once Cited

28. OTHER RESOURCES • 34 CFR 668.164(a) – Actual Disbursement Date • 34 CFR 668.166 – Excess Cash • 34 CFR 668.175 – LOC Alternative • 34 CFR 668.22(j)(1) – Time Frame for Return of Title IV Funds • FSA Handbook, Volume 4 – Processing Aid and Managing FSA Funds • FSA Handbook, Volume 5 – Withdrawals and the Return of Title IV

29. CONTACTS • Email: FSA.Foreign.Schools.Team@ed.gov • Phone: 202-377-3168 • Fax: 202-377-3486 • Mail: U.S. Department of Education Multi-Regional and Foreign School Participation Division Union Center Plaza, 7th Floor 830 First Street, NE Washington DC, 20202 (20002-5340 if Overnight/Courier)

30. SCHOOL ELIGIBILITY SERVICE GROUP (SESG)Ron Bennett - Director, School Eligibility Service Group, Washington, DC (202) 377-3181School Eligibility Service Group General Number: (202) 377-3173 or email: CaseTeams@ed.gov Or call the appropriate School Participation Division manager below for information and guidance on audit resolution, financial analysis, program reviews, school and program eligibility/recertification, and school closure information. New York/Boston School Participation Division Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont, New Jersey, New York, Puerto Rico, Virgin Islands Betty Coughlin, Director (646) 428-3737 Tracy Nave – Boston (617) 289-0145Jeremy Early– Washington, DC (202) 377-3620Chris Curry – New York (646) 428-3738 Philadelphia School Participation Division District of Columbia, Delaware, Maryland, Pennsylvania, Virginia, West Virginia Nancy Gifford, Director (215) 656-6436 John Loreng – Philadelphia (215) 656-6437 Sherrie Bell– Washington, DC (202) 377-3349 Multi-Regional and Foreign Schools Participation Division Michael Frola, Director (202) 377-3364 Barbara Hemelt − Washington, DC (202) 377-4201 Joseph Smith − Washington, DC (202) 377-4321 Mark Busskohl – Washington, DC (202) 377-4572 Michelle Allred – Dallas (214) 661-9466 Atlanta School Participation Division Alabama, Florida, Georgia, Mississippi, North Carolina, South CarolinaChristopher Miller, Director (404) 974-9297 David Smittick – Atlanta (404) 974-9301 Vanessa Dillard – Atlanta (404) 974-9418 Dallas School Participation Division Arkansas, Louisiana, New Mexico, Oklahoma, Texas Cynthia Thornton, Director (214) 661-9457 Jesus Moya – Dallas (214) 661-9472 Kim Peeler – Dallas (214) 661-9471 Kansas City School Participation Division Iowa, Kansas, Kentucky, Missouri, Nebraska, TennesseeRalph LoBosco, Director (816) 268-0440Dvak Corwin – Kansas City (816) 268-0420 Angela Beam – Kansas City 816) 268-0534 Jan Brandow – Kansas City (816) 268-0409 Chicago/DenverSchool Participation Division Illinois, Minnesota, Ohio, Wisconsin, Indiana, Colorado, Michigan, Montana, North Dakota, South Dakota, Utah, WyomingDouglas Parrott, Director (312) 730-1532 Earl Flurkey – Chicago (312) 730-1521 Brenda Yette – Chicago (312) 730-1522 Sarah Adams − Chicago (312) 730-1514 San Francisco/Seattle School Participation Division American Samoa, Arizona, California, Guam, Hawaii, Nevada, Palau, Marshall Islands, North Marianas, State of Micronesia, Alaska, Idaho, Oregon, WashingtonMartina Fernandez-Rosario, Director (415) 486-5605 Gayle Palumbo − San Francisco (415) 486-5614 or Seattle (206) 615-3699 Dyon Toney − Washington, DC (202) 377-3639 Erik Fosker – San Francisco (415) 486-5606

31. QUESTIONS?