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Gainful Employment: A school’s view

Gainful Employment: A school’s view. Amy Hager amyh@macc.edu Moberly Area Community College Moberly, Missouri. Impact of GE at MACC CURRENT: Twelve 1-year Programs ADDING: Twenty short-term (16-week) programs. Why do we have GE? .

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Gainful Employment: A school’s view

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  1. Gainful Employment: A school’s view

  2. Amy Hageramyh@macc.eduMoberly Area Community CollegeMoberly, Missouri

  3. Impact of GE at MACCCURRENT: Twelve 1-year ProgramsADDING: Twenty short-term (16-week) programs

  4. Why do we have GE? • “…to strengthen federal student aid programs at for-profit, nonprofit and public institutions by protecting students from aggressive or misleading recruiting practices, providing consumers with better information about the effectiveness of career college and training programs, and ensuring that only eligible students or programs receive aid. “ • October 28, 2010 DOE Press Release

  5. Why do we have GE? And… to identify the worst performing programs and cease funding for them – Essentially …to save tax payer’s money!

  6. Why do we have to comply with GE rules? To be eligible for funding under the Title IV programs.

  7. Definitions • GE Program: • June 24, 2011 Electronic Announcement #11 – Clarification - Determining whether or not an education program is a GE program

  8. Definitions • At Public or non-profit institutions, all programs except: • Programs that lead to a degree; • Programs of at least two years in length that are fully transferable to a bachelor’s degree program; and • Preparatory course work necessary for enrollment in an eligible program. • @ MACC: we have 12 one-year certificate programs currently in operation and are working on adding 20 new 16- week short term certificate programs

  9. Definitions • At proprietary institutions and postsecondary vocational institutions • All programs, except for: • Programs leading to a baccalaureate degree in liberal arts offered since January 2009 that has been regionally accredited since October 2007 • Preparatory course work necessary for enrollment in an eligible program

  10. Definitions • Disclosures: • provide information to students • Reporting: • provide information to the Department

  11. Disclosures • Must be provided on all promotional materials made available to prospective students • Disclosure on Program’s website home page • Must be simple and meaningful • Must contain direct links to any other webpage with general, academic or admission information about the program • Must be in an open format that can be retrieved, downloaded, indexed, and searched by commonly used web search applications

  12. Disclosures • Disclose for each GE Program: • Occupations (by name and SOC code) that program prepares students to enter • Links to occupational profiles on O*NET • Program costs –Tuition and fees • Room and board • Books and supplies • May include other costs

  13. Disclosures • Disclose for each GE Program: • On-time completion rate • Number of students who completed program during most recently completed award year for which information is available • Number of students who completed within normal time (Not 150%) • As published by institution

  14. Disclosures • Disclose for each GE Program: • Job placement rates for students completing the program • Use formula that the institutional accreditor, program accreditor, or the state requires. • Must be disclosed on a program basis, even if formula is for institutional level placement rates.

  15. Collecting Disclosure Information at MACC • Career and Technical Education Office • Placement Office • Computer Services • Financial Aid • Various Program directors • Web Master

  16. Disclosure Deadline: • For each GE Program, provide prospective students with specific information • Effective July 1, 2011 • Institutions “must” use disclosure form provided by the DOE, when available • It was not available on July 1 • I created my own form • DOE form will be released this fall, we must use by July 1, 2102

  17. MACC’s GE Disclosure Form

  18. Reporting Requirements • Institutions must annually report information on students who were enrolled in a GE program for each award year • Final Rule published on June 13, 2011

  19. Reporting Requirement • Information includes: • Student identifying information • Program identifying information • Amounts from private education loans • Amount owed on institutional financing plans • Enrollment information

  20. Reporting Requirements • Student identifying information • For each student who enrolled in a GE Program during the award year • Social Security Number • First, middle and last name • Date of birth

  21. Reporting Requirements • Program information • For each student enrolled in a GE Program • Institutions OPEID (8 digit) where student attended • Name of program as provided by institution • Classification of Instructional Program (CIP) code of educational program • Credential Level

  22. Reporting Requirements • Private education loan information • Defined in 12 CFR 226.46(b)(5) by the Federal Reserve Board • Total amount of non-Title IV loan received to pay costs associated with attendance in the GE Program • Examples –loans from financial institutions, credit unions, states and other localities, guarantee agencies and institutions of higher education

  23. Reporting Requirements • Institutional Financing Plan information • Include: • Loan, • Extension of credit, • Payment plan, or • Other financing mechanism • That would otherwise not be considered a private education loan but that results in a debt obligation that a student must pay to an institution after completing the program.

  24. Gainful Employment Reporting • NSLDS data collection available September 26, 2011 • The NSLDS Gainful Employment User Guide provides instructions for GE reporting • File layout • Submission instructions • Most recent version September 22, 2011 • NSLDS GE Submittal Template for Excel spreadsheet @ www.fsadownload.ed.gov

  25. Reporting Deadlines: • November 15, 2011 • August 2, 2011 – Electronic Announcement • For 2006-2007, 2007-2008, 2008-2009, 2009-2010 & 2010-2011 award year information • October 1 in all subsequent years • October 1, 2011 • If unable to report any of the required information, institution must provide an explanation.

  26. Gainful Employment Reporting Methods • What reporting method works best for you? • Online • Create formatted excel file on your own PC and up-load it directly NSLDS • Data entry directly into the NSLDS web site • Review data on screen, submit what is correct • GE Enrollment Reporting List Page under the Enroll tab on NSLDS • MUST have NSLDS access • Does not require a TG mailbox

  27. Gainful Employment Reporting Methods • What works best for you? • Batch • TG Mailbox needs to be identified/set-up in NSLDS • Create file using one of the 2 formats and submit via your TG mailbox • Receive Error/Acknowledgement file from NSLDS via SAIG • Resolve errors by • resubmitting batch file • Using the NSLDS upload template with the students that did not load • Entering the data directly to the web site

  28. Missing/Incomplete GE Data Circumstances • 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. • 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. • The institution is unable to report for one or more of the students who were enrolled in a GE Program. • 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.

  29. Missing/Incomplete GE Data • How to Submit Explanations of Missing or Incomplete Information • The 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. • See Gainful Employment Electronic Announcement #18 for more info

  30. Missing/Incomplete GE Data • Subject Line of e-mail – must include the first 6 digits of the institution’s OPEID and the institution’s name. • Body of e-mail – • Name, phone number, and e-mail address of a contact person at the institution. • Explanation of why the information will not be provided or will be incomplete. Indicate the award year and the specific GE Program identifiers (the institution’s name of the GE Program and the GE Program’s six-digit CIP code and its two-digit credential level code). (See NSLDS User’s Guide, page 45). • For example, “We are unable to submit data for the ABC Program 191234-01 for the 2006-2007 Award Year because . .

  31. GE Reporting So now I’ve reported…what now?

  32. Consequences of failing the GE debt measure Will begin program measures July 1, 2012

  33. Measures of Gainful Employment • GE program must meet at least one of the following three metrics: • Estimated annual loan payment of a typical graduate does not exceed 12% of his/her total earnings; or, • Estimated annual loan payment of a typical graduate does not exceed 30% of his/her discretionary income; or, • At least 35% of former students are repaying their loans • defined as reducing the loan balance by at least $1

  34. Consequences of failing the GE debt measure • Poor performing programs must fail the debt measures three times in a four-year period before losing eligibility to participate in Federal student aid programs.

  35. Debt Measures • Loan Repayment Rate must equal 35% or more • DOE will calculate by each program • Graduates and non-completers • Original outstanding principal balance of loans paid in full (+) original outstanding principal balance of payments-made loans/original outstanding principal balance of all (received during program of study)

  36. Debt Measures • Debt-to-earnings ratios • DOE will calculate both • Graduated students only • All loan debt incurred • 30% or less of discretionary income • Annual loan payment/mean or median annual earnings – (150% x poverty guideline for single person) equals discretionary income • 12% or less of annual earnings • Annual loan repayment/mean or median annual earnings equals the earnings rate • Annual earnings from Social Security Admin or other federal agency

  37. Debt Measures • Successful/Eligible programs will meet at least one of the minimum debt measure thresholds in a fiscal year

  38. Consequences of failing the GE debt measure • 1st time missed must disclose to students: • why measurement was missed; and, • how the issue will be addressed • 2nd time within 3 years, must inform students: • That their debts may be unaffordable after graduation; and, • That the program is at risk of losing eligibility to participate in federal student aid programs; and, • What their transfer options are. • 3rd time within 4 years: • The program loses eligibility • Cannot reapply for eligibility for at least 3 years

  39. GE Reporting Webinar • This week • October 13 • Register link is on IFAP

  40. Adding New GE Program • New Non-Degree GE Programs at all institutions, and new Degree GE Programs at proprietary institutions, must be reported.

  41. Adding New GE Program • For new GE Programs where the first day of class will begin on or after October 1, 2011, institutions must provide notification to the Department at least 90 days prior to the first day of class. • If the institution does not give notice at least 90 days before the first day of class, it must wait for Departmental approval before disbursing funds to students enrolled in the new GE Program and must inform students that the institution has not received the Department’s approval for the program to be eligible for federal student aid.

  42. Adding New GE Program Electronic Announcement #16 – Updated procedures • Go to the institution’s E-App at www.eligcert.ed.gov . • Section A, Question 1, select Update Information and select “Nondegree/Vocational Program,” and/or “Degree Program” as appropriate. • Section E, Questions 26 and 27, complete as appropriate to report new GE Programs. Note: In Question 27 the Date First Provided can be a future date. • When entering details about degree programs for which you are providing notification, please indicate the type of degree (Associate, Bachelor, Master, Doctoral, or specific professional degree) as part of the program name in the Name of Program field. • Section K, Question 69, enter the following - “This application includes notification of new gainful employment program(s). The required documentation will be mailed with the signature page.” • Section L, enter requested information, print and sign. • Submit the application electronically following the instructions in the E-App. • Mail the following to the address provided in the E-App: • Signature page, • Current letter of accreditation and any attachments • Current valid state license or other authorization, and • Written notice of intent to offer an educational program

  43. Adding New GE Program • Electronic Announcement #5 • Notice Format for Intent to Offer an Educational Program Gainful Employment • I required the Dean of Career and Technical Education programs to complete the following

  44. Adding New GE Program • Descriptions and documentation provided by an institution can cover more than one new GE Program, if the same, or similar, process was used by the institution to determine the need for the Program. • Each new program request should provide the following: • Institution Name and OPEID • Program Name(s) and Program CIP Code(s) supported by the following ocumentation:

  45. Adding New GE Program • Narrative description of how the institution determined the need for the program. • For example, describe what need this program will address and how the institution became aware of that need. If the program is replacing a current program(s), identify the current program(s) that is being replaced by the new program(s) and provide details describing the benefits of the new program(s). If the program will be offered in connection with, or in response to, an initiative by a governmental entity, provide details of that initiative. The institution must retain documents that support this description for review or submission to the Department upon request.

  46. Adding New GE Program 2. Narrative description of how the program was designed to meet local market needs, or for an online program, regional or national market needs. • For example, indicate if Bureau of Labor Statistics data or State labor data systems information was used, and/or if State, regional, or local workforce agencies were consulted. Include how the course content, program length, academic level, admission requirements, and prerequisites were decided; including information received from potential employers about course content; and information regarding the target students and employers. The institution must retain copies of documents and its analysis for review and submission to the Department upon request.

  47. Adding New GE Program 3. Narrative description of any wage analysis the institution may have performed, including any consideration of Bureau of Labor Statistics wage data related to the new program. The institution must retain copies of analysis documents for review and submission to the Department upon request.

  48. Adding New GE Program 4. Narrative description of how the program was reviewed or approved by, or developed in conjunction with, one or more of the following: • Business advisory committees • Program integrity boards • Public or private oversight or regulatory agencies (not including the state licensing /authorization agency and accrediting agency) • Businesses that would likely employ graduates of the program • For example, describe the steps taken to develop the program, identify when and with whom discussions were held, provide relevant details of any proposals or correspondence generated, and/or describe any process used to evaluate the program. The institution must retain, for review and submission to the Department upon request, copies of meeting minutes, correspondence, proposals, or other documentation to support the development, review, and/or approval of the program.

  49. Adding New GE Program 5. Date of the first day of class. Include both: • The first day the program was or will be offered by the institution, and • The day you would like to begin disbursing Title IV funds to students enrolled in the program.

  50. Adding New GE ProgramMACC’s recent history • Career and Technical Education Dean campaigned for twenty (20) new short-term, 16 week certificate programs within last year • Wanted to offer programs beginning in spring 2012 • Approved by Curriculum Committee in spring • Approved by Board of Trustees in spring • Submitted to CBHE for approval in summer • Submitted to HLC for approval in summer • Waiting on approval from CBHE and HLC • Submit to DOE for program approval for financial aid

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