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New Directors Seminar Compliance. Private Licensed Schools. Sign In. Sign in if you haven’t already done so. Logistics. Snacks Restrooms Organization and schedule. New Division Name. Division of Occupational Training Schools Applies to PDE Division only

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new directors seminar compliance

New Directors SeminarCompliance

Private Licensed Schools

sign in
Sign In
  • Sign in if you haven’t already done so
logistics
Logistics
  • Snacks
  • Restrooms
  • Organization and schedule
new division name
New Division Name
  • Division of Occupational Training Schools
  • Applies to PDE Division only
  • Board is still the Board of Private Licensed Schools
  • Schools are still called Private Licensed Schools
contents
Contents
  • Foundations – Statute, Regs, and Memos
  • Board organization
  • Electronic sites
  • Secure Website Access
  • Annual Statistical Report
  • Board Approvals Required
  • Notifications Required
  • License Renewal
contents continued
Contents Continued
  • Contents of PDE Website
  • Program Changes
  • Site Visits
  • Advertising
  • Admissions Representatives
  • Student Records - transcripts
  • Records Repository
contents continued1
Contents Continued
  • Complaints
  • Enforcement Action
  • Possible Sanctions
  • Common Pitfalls
  • Rigid Deadlines
  • Closing Procedures
  • Questions and Answers
today s powerpoints are on the web
Today’s PowerPoints are on the Web
  • Public Website: http://www.education.state.pa.us
board of private licensed schools
Board of Private Licensed Schools
  • 15 members
  • 14 appointed by Secretary of Education
  • 1 ex officio representative of Attorney General
  • 4 year terms
  • Term limits of 2 consecutive terms
board s standing committees
Board’s Standing Committees
  • Executive Committee
  • Financial Review Committee
  • Review and Recommendation Panel
  • Curriculum Committee
  • Hearing Panels
legal authority
Legal Authority
  • Statute
  • Regulations
  • Board Policy Memos
board policy memos
Board Policy Memos
  • Numbered memos that explain the regulations or create policy not addressed in the regulations.
  • Violation of the memos can result in enforcement action.
board policy memos1
Board Policy Memos

Memo #38 – Establishes Cure Period

  • Provides for a 10 day cure period (business days) for schools to provide any needed revisions for their program applications.

Memo #52 - Scholarships

  • Must be a minimum of 25% of tuition cost
  • Cannot be used as a discount, premium, or

special endorsement.

Memo #65 – Limits Program Applications

  • Limits the number of new program applications to three per Board meeting.
staff
Staff
  • The Pennsylvania Department of Education staffs the Board
  • Each school assigned to a staff member
  • Current staff
    • John Galganovicz
    • Robert Kline
    • Ed Rech
  • All Staff at (717)783-8228
questions
Questions?
  • Any questions specific to the Board, its authority or organization?
internet resources
Internet Resources
  • PDE Website: http://www.education.state.pa.us
  • Secure Website – via login
  • Financial forms and instructions:

ftp://ftp.state.pa.us/pub/PDE_PUBLIC/PLSFinancial

accessing secure website
Accessing Secure Website

Steps:

  • Obtain user name and password for EdHub – do this on-line at http://www.education.state.pa.us
  • Director sends e-mail to RA-edhubadmin@state.pa.us to request access to PLS software
  • Receive confirmation that account is ready
  • Go to EdHub and log on
  • Access PLS Application
annual statistical report
Annual Statistical Report
  • MUST be submitted between July 1 and September 30 each year.
  • Submitted electronically
  • Failure to submit is a violation punishable by a fine of at least $500 or revocation.
pde 3808
PDE-3808
  • School program profile
  • Know how to access
  • Confirm accuracy
  • Used by accreditation, vet ed, other funding sources
questions1
Questions
  • Questions on web resources, PDE-3808 or annual report?
board approvals required
Board Approvals Required
  • Relocation
  • Expansion
  • Remote Location
  • New Branch
    • All Require site visit ($500 fee), certificate of occupancy, bond rider
  • Scholarship (requires FRC approval)
  • Change of Ownership (requires FRC approval)
  • Name Change or Alternate Name
notifications required
Notifications Required
  • Change in Director – PDE-340
  • Change in Acting Director – PDE-340
  • Program Changes – PDE 3744
reportable events
Reportable Events
  • Material change in financial condition
  • Lapse in surety
  • School files for bankruptcy
  • Building code violation
  • Environmental hazard
  • Title IV audit
how to report
How to Report
  • Send letter to the Division
  • No form provided
additional information needed
Additional Information Needed
  • Change in e-mail account
  • Change in phone number
questions2
Questions
  • Any questions regarding issues that need Board approval, issues that require staff approval or reportable events?
license renewal
License Renewal
  • First is due one year from first licensure
  • Subsequent due every two years
  • MUST be renewed prior to expiration
  • Reminder will be sent, but school is responsible
  • Renewal form PDE-3123
components of renewal app
Components of Renewal App
  • Form PDE-3123 with signature
  • Fee ($500 - $4,400)
  • Financial Statement (PDE-2006 or audited)
  • Evidence of surety
  • Ethics statement
  • Records Repository
  • Enrollment Agreement
  • Catalog
  • Changes to PDE-3808
  • Confirmations
questions3
Questions
  • Questions on renewals?
program changes
Program Changes
  • Submitted on PDE-3744
  • Must be less than 25% change in clock hours
  • Cannot be a substantive change to objectives
  • Approval required PRIOR to implementation
  • Also required for tuition changes
delivery method
Delivery Method
  • A change in delivery method of less than 25% of the program can be reported as a program change.
  • Note: Approval is required PRIOR to implementation
  • A change in delivery method for more than 25% of the program requires a new program application.
questions4
Questions
  • Questions on Program Changes?
advertising
Advertising
  • No blind advertising
  • No advertising in the help wanted
  • No salaries
  • No misrepresentation
  • No superlatives
  • No implication of college or university
  • Must use approved school name
  • No advertising unapproved programs
advertising con t
Advertising Con’t
  • No guarantee of employment
  • No guarantee of admission to another institution
  • No guarantee of credit transfer
  • No bait and switch
  • No premiums
  • No discounts
  • No demeaning of another school
questions5
Questions
  • Questions on advertising?
site visits
Site Visits
  • Expansion of instructional space
  • Remote location
  • Branch location
  • Relocation
    • All requested in writing by school - $500 fee
    • All require Certificate of Occupancy
    • Bond rider
    • All require Board approval
  • Compliance Visit
    • Scheduled by staff, no fee
compliance visit
Compliance Visit
  • Once every 3 years for unaccredited schools
  • Once every 4 years for accredited schools
  • Tour school, talk with students and staff, check facilities, certificate of occupancy, capacity, equipment, director and faculty credentials, program approvals, license posted, advertising, scholarships, catalog, enrollment agreement, student records.
student record check
Student Record Check
  • Current students
    • Enrollment agreement, proof of admission criteria, transcript, account information
  • Graduates
    • Transcript with all 7 components
  • Withdrawals
    • Transcript with all 7 components
    • Refunded correctly
      • Last date of attendance, % of program, refund date, refund amount,
questions6
Questions
  • Questions about site visits, including compliance visits?
student refunds and withdrawal policies
Student Refunds and Withdrawal Policies
  • Calculated in accordance with 22 PA Code 73.134
  • Determined by the percentage of the program completed
  • Refund amount and date of refund should be in the student file for all those who have withdrawn.
refunds 6 weeks
Refunds + 6 weeks
  • Up to 5 days after signing but before classes – 100% (including reg fee)
  • After 5 days and before classes 100% minus reg fee
  • During first 7 days – 75%
  • Within 25% - 55%
  • Within 50% - 30%
  • After 50% - no refund
refunds 6 weeks1
Refunds < 6 weeks
  • Up to 5 days after signing but before classes – 100% (including reg fee)
  • After 5 days and before classes 100% minus reg fee
  • Up to 10% – 90%
  • Within 25% - 55%
  • Within 50% - 30%
  • After 50% - no refund
refunds distance ed
Refunds Distance Ed
  • Up to 5 days after signing but before sending in first lesson – 100% (including reg fee)
  • After 5 days after signing but before sending in first lesson 100% minus reg fee
  • Completed up to 10% of lessons – 90%
  • Completed up to 25% of lessons- 75%
  • Completed up to 50% of lessons - 50%
  • After 50% - no refund
refunds
Refunds
  • Students cannot be required to request withdrawal in writing.
  • If a student stops attending, a refund is due if they completed less than 50%
refunds1
Refunds
  • Refunds must be calculated based on the last date of recorded attendance
    • If the school takes attendance, use recorded date
    • If the school does not take attendance, use the last written evidence of attendance –a homework assignment, quiz or test.
refunds deadline
Refunds - Deadline
  • Refunds must be made within 30 days of the last date of recorded attendance
  • Take into consideration the time it takes to cut a check – the refund must be mailed within 30 days
  • This may mean that you need to start the refund process well before 30 days from the last date of attendance
leave of absence
Leave of Absence
  • A leave of absence must be requested by the student in writing
  • Refunds are required if student fails to return from a leave of absence
date of determination
Date of Determination
  • Title IV concept
  • Does not exist in PA
  • PA student refunds must be based on last date of recorded attendance and not on date of determination.
questions7
Questions
  • Questions about refunds?
admission representatives
Admission Representatives
  • Required if students will be asked to sign enrollment agreement anyplace off the school property
  • Not required for marketing – education fairs, etc – if students do not enroll
  • PDE-5006
  • $300 Fee
  • Must be renewed annually
transcripts
Transcripts
  • Must be maintained for 50 years
  • Must be placed with a repository when the school closes
  • Must contain 7 items
    • Student Name
    • Student ID Number
    • Program Name
    • Grades for all Subjects
    • Date of Entrance
    • Date of Graduation or Withdrawal
    • Award received (diploma, certificate, or AST/ASB degree
records repository
Records Repository
  • Must be maintained at all times
  • Must be submitted with each renewal
  • No fee can be required after closure
  • Service fees may be charged to students
  • Should be with another PLS
questions8
Questions
  • Questions admission representative licenses, transcripts or records repository requirement?
complaints
Complaints
  • We encourage complainants to try to resolve the situation with the school director first – but not required
  • Complaint is submitted to PLS – with signature
  • Complaint is sent to school for response
    • 30 days to respond in writing
complaints con t
Complaints Con’t
  • Complaint will be investigated
  • Conversations with complainant
    • Conversations with school
    • Possible Visit to School
  • A resolution may be proposed
  • Complaint will be closed OR
  • Complaint will be referred to RRP
enforcement action
Enforcement Action
  • Complaint or potential violation is referred to RRP by staff
  • RRP may order a Notice of Violation
    • 14 days to respond
  • RRP may direct an Order to Show Cause
    • 20 days to respond
  • School can request a hearing
  • Full Board votes on final adjudication
possible sanctions
Possible Sanctions
  • $500 fine for first violation
  • $750 fine for second violation
  • $1000 fine for third violation
  • $1000 fine for unlicensed activity
    • Plus 5-year ban on licensure
  • Suspension of license
  • Revocation of license
questions9
Questions
  • Questions about complaints and enforcement actions?
common pitfalls
Common Pitfalls
  • Late Annual Report
  • Late Renewal
  • Late Quarterly Reporting
  • Failure to make timely refunds
  • Failure to make accurate refunds
  • Instructor reads from book
    • Students stepping in as instructors
  • Instructor cancels or shortens classes
common pitfalls con t
Common Pitfalls Con’t
  • Textbooks late or unavailable
  • Retroactive tuition increase
  • Using an unapproved school name
  • Advertising
    • In employment column
    • Blind
    • Salaries
deadlines
Deadlines
  • Renewal Application
    • 7th of month before expiration
    • $500 fine possible
  • New Program Applications
    • 10 weeks before Board Meeting as published
  • Quarterly Reporting
    • 3 weeks before Board meeting – see letter
  • Annual Statistical Report
    • Before September 30
closing procedures
Closing Procedures
  • Notify staff in writing 30 days prior
  • Teach out all students
  • Place records with repository
additional closing steps if students still enrolled
Additional Closing Steps If Students Still Enrolled
  • Notify all current students in writing
  • Identify teach out institutions for all students
  • Provide PLS with name and contact information for all students
  • Provide PLS with current transcript for all current students
  • Provide PLS with current account card for all current students
note re closure
Note Re Closure
  • A closed school can be fined for failure to comply with closure requirements.
questions10
Questions
  • Please ask any questions.
  • If questions arise later, contact the Division at (717)783-8228