Ashley Higgins and Amber Johnson| Dec. 2015

U.S. Department of Education

2015 FSA Training Conference for Financial Aid Professionals

Consumer Disclosure Requirements and Tools

Session 19

Agenda• Student & Family Consumer Information Tools

• College Affordability & Transparency Center; College Navigator; College Scorecard and StudentAid.gov

• Shopping Sheet

• Clery Act Update

• Net Price Calculator

• Additional Disclosures

• Resources and References

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Student and Family Tools

• There is overlap between

• Information you disclose to the public (i.e., enrolled students, prospective students, employees, etc.) and

• Information you report to the Department

• We use information that you report to create tools for students and families

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College Affordability & Transparency Center

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http://collegecost.ed.gov/catc/

College Navigator

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http://nces.ed.gov/collegenavigator/

College Navigator

• Department’s college search tool

• Information on over 7,400 institutions participating in the HEA programs

• Data from IPEDS, FSA, and OPE

• Over 1.7 million site visits last year

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College Navigator

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• Provides:• General institutional info

• Admissions requirements

• Tuition and fees and average net price

• Programs and majors/fields of study offered

• Retention and graduation rates

• Athletics statistics

• Campus safety statistics

• Accreditation information

• Cohort default rates

College Navigator

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The College Scorecard• Released Sept. 2015• Designed to help

students and families find the best fit for them

• Reflects the input of thousands of students, counselors, institutions, researchers, and policymakers

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Scorecard Data

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• The site emphasizes access, affordability, and outcomes

• Constructed from federally available data (IPEDS and NSLDS)

• Includes:– Nationally comparable data on earnings

– New median debt and repayment rate figures

– Data disaggregated by student subgroup to aid institutions in understanding their outcomes

• Data are also available as downloadable files

Future Plans

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• The Department will work to build on the Scorecard in future iterations of the site, including:– Making technical (website) adjustments– Adding new website features– Updating and improving the data

• For questions about the College Scorecard, please contact collegescorecard@rti.org

StudentAid.gov

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StudentAid.gov• FSA’s streamlined website

• Includes comprehensive information on the student aid life cycle

• Builds in tips and guides for students• FAFSA4caster• Repayment Estimator• Things to consider in selecting a school• Links to StudentLoans.gov• Comparing colleges brochure

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StudentAid.gov

• Integrates with FSA’s social media outlets

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Financial Aid Shopping Sheet• Standardized, clear, concise format helps prospective

students understand and compare financial aid offers

• Adopted by over 3,000 institutions

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Shopping Sheet FAQs

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I received a letter stating that I have to adopt the Shopping Sheet. I thought the Shopping Sheet was voluntary?

In section 2(a) of Executive Order 13607, which established the Principles of Excellence, it states that the Principles should require participating institutions to “prior to enrollment, provide prospective students who are eligible to receive Federal military and veterans educational benefits with a personalized and standardized form, as developed in a manner set forth by the Secretary of Education.” That personalized and standardized form is the Shopping Sheet.

Shopping Sheet FAQsIf my institution participates in the Principles of Excellence, to whom should I give the Shopping Sheet?

Participating institutions are expected to provide the Shopping Sheet to undergraduate and graduate service members, veterans, military spouses, and other military family members covered by EO13607.

Many institutions that have agreed to comply with EO 13607 have also indicated to the Department that they intend to provide the Shopping Sheet to all of their students, in addition to those receiving veterans benefits.

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Shopping Sheet FAQsDoes my institution participate in the Principles of Excellence?

Institutions that have signed on to the Principles can be found at http://department-of-veterans-affairs.github.io/gi-bill-comparison-tool/

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Shopping Sheet FAQs

Can I just post the Shopping Sheet to my website? How is this different than the Net Price Calculator (NPC)?

The Shopping Sheet is very different from the NPC. While the NPC provides an estimate of a prospective student’s financial aid, the Shopping Sheet is meant to summarize a student’s actual award letter. Therefore, it is usually given to a student at the same time they would receive his or her aid information at your institution, and posting a generalized Shopping Sheet does not fulfil the requirement to provide the Shopping Sheet in the Principles of Excellence.

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Shopping Sheet FAQs

How can the Shopping Sheet replace my award letter? There isn’t enough room for the required information.

The Shopping Sheet is not meant to replace your institution’s award letter. It’s meant to act as a summary or cover sheet to help students weigh their options before selecting an institution.

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Shopping Sheet FAQsWhere can I find an editable pdf copy of the Shopping Sheet?

Because it would be extremely labor-intensive to manually create each student’s Shopping Sheet, the Department does not provide an editable pdf. Instead, we offer the html code for the Shopping Sheet for a school’s software provider to adapt. In the event a school does not wish to use a software provider, we have added Shopping Sheet functionality to EDExpress, the Department’s free software. An institution does not need to use EDExpress for other purposes to use it to create the Shopping Sheet.

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Shopping Sheet FAQs

Can I change the Shopping Sheet by adding my school colors or switching the order of the sheet?

No. An institution must provide the Shopping Sheet in the exact format shown on the Shopping Sheet website. That said, an institution may remove the Pell Grant and Subsidized Loans sections in the case of letters to graduate students. This is because we believe that keeping the Shopping Sheet uniform is the simplest way for students to compare aid awards from multiple institutions.

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Financial Aid Shopping Sheet• Website with resources www.ed.gov/financial-aid-shopping-sheet

• Development history

• Annotated Shopping Sheet

• Institutions using the Shopping Sheet

• FAQs

• HTML specifications

• Institutional metric data file

• ShoppingSheet@ed.gov

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A note about the Clery Act

• Final regulations implementing the changes VAWA made to the Clery Act were published in October 2014

• Institutions are now required to report incidents of domestic violence, dating violence, and stalking in their ASRs and to the Department

• Institutions are also required to report how many crimes were found to be “unfounded” as well as the contact information of their lead Title IX coordinator

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Clery Act, continued• Significant changes were also made to the required policy statements

included in an institution’s ASR

• For 2014 ASRs, institutions were required to make a good-faith effort to include incidents of domestic violence, dating violence, sexual assault, and stalking for calendar year 2013

• The Department did not collect data on incidents of domestic violence, dating violence, sexual assault, and stalking for the 2013 calendar year in this year’s collection. Only data for calendar year 2014 were collected

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Clery Act, continued

• The Department is still working to update the Handbook to include the changes made by VAWA

• For questions about Clery and reporting, contact our helpdesk at:

• 800-435-5985 or campussafetyhelp@westat.com

• For more on the Clery Act, visit Session 38, Complying with the Clery Act

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Background• HEA requires you to disclose certain information as part

of Title IV participation• Disclosures often require information from offices across

the institution, not just the financial aid office• Schools may face penalties for noncompliance

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Net Price Calculator• Section 132(h) of the HEA states:“Each institution of higher education that receives

Federal funds under Title IV shall make publicly available on the institution’s website a net price calculator to help current and prospective students, families, and other consumers estimate a student’s individual net price at such institution of higher education.”

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Net Price Calculator• What is net price?

• The average yearly price actually charged to first-time, full-time (FTFT) undergraduate students receiving student aid at the institution

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Institution’s Cost of Attendance (average

annual cost of tuition and fees, room and board, books, supplies, and

transportation)

Total need- and merit-based Federal, State, and institutional

grant aid awarded to FTFT students

Number of FTFT students receiving such aid

Net Price Calculator

• What is required?• ED was required to develop a net price calculator template

• Institutions had two years from release of template to post a NPC to their websites• Required by 10/20/2011• May use ED’s template or an IHE-developed NPC• Must include minimum data elements

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Net Price Calculator• Minimum required data elements

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Input Elements•Student’s income•Number of people in household•Dependency status (or factors that estimate dependency status)

Output Elements•Estimated total price of attendance•Estimated tuition and fees•Estimated room and board•Estimated books and supplies•Estimated miscellaneous expenses (personal, transportation, etc.)•Estimated total grant aid•Estimated net price•Percent of the cohort (FTFT) that received grant aid

Net Price Calculator

• Include required disclaimers and link in NPC• Estimate is not final or binding on ED, the institution, or

the State

• Students must complete the FAFSA to be eligible for Title IV aid

• Link to the FAFSA

• ED template has these built in

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Net Price Calculator• Who counts as a “first-time, full-time” (FTFT) student?

• First-time = a student who has no prior postsecondary experience attending any institution for the first time at the undergraduate level

• Full-time = a student enrolled for 12+ semester credits, 12+ quarter credits, or 24+ contact hours a week each term

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Net Price Calculator• Who must have a NPC?

• Institutions with any FTFT students

• Foreign schools are exempt

• Approximating the student’s EFC• You may use either Federal Methodology or Institutional Methodology

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Net Price Calculator• Where must the NPC be located?

• Varies by institution

• Make it easy to find – see National Postsecondary Education Cooperative (NPEC) guidance at http://nces.ed.gov/pubsearch/pubsinfo.asp?pubid=2010831rev

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Net Price Calculator• May I rename the NPC?

• Best bet for full compliance is to call it a “net price calculator”

• May I include loans in our NPC?• Net price definition takes into account scholarships and grants

• Calculation must not consider loans

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Net Price Calculator• When and how often must we update our NPC?

• Update on an annual basis, when new data become available to do so

• COA and grant aid data are from the same year and represent actual, not projected data

• ED releases updated versions of the template annually around January

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Net Price Calculator• How should we account for VA and DOD benefits?

• Not need- or merit-based grant/scholarship aid, so not subtracted from COA in calculating net price

• You may collect information that will provide more accurate cost estimates, but—• Provide HEA-required NPC first• Clearly ID whether/how these benefits were included

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Net Price Calculator• May we use a 3rd party’s (e.g., State,

college system, private servicer) NPC?• NPC must be accessible via your “.edu” URL

• Calculator must have all minimum elements

• Institution-specific data

• NOTE: do not direct users to ED’s website

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Net Price Calculator• Does ED use the NPC URLs reported to IPEDS?

• YES. Please make sure they work and are correct!• Net Price Calculator Center

• College Scorecard

• College Navigator

• Zip file (available on NPC Information Center)

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Net Price Calculator Center

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http://collegecost.ed.gov/netpricecenter.aspx

Net Price Calculator• Resources

• NPC Information Center http://nces.ed.gov/ipeds/resource/net_price_calculator.asp

• FAQs

• Quick start guides

• Bulk upload tools

• EFC tables

• Template source code

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Net Price Calculator• Resources

• Help Desk: npc@inovas.net or 1-877-299-3593

• GEN-13-07: http://ifap.ed.gov/dpcletters/GEN1307.html

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Textbook Information• Section 133 of the HEA requires institutions

to disclose textbook information to—• Students

• College bookstores

• Applies to each IHE receiving Federal financial assistance

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Textbook Information• Information for students

• Disclose on the web-based schedule of courses used for pre-registration and registration purposes

• Include ISBN and retail price info of required and recommended textbooks and supplemental materials for each course

• You decide the format

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Textbook Information• Information for students

• A: Include ISBN and retail price info of required and recommended supplemental materials for each course

• If not A, then B: If ISBN not available, provide the author, title, publisher, and copyright date

• If not B, then C: If you determine the disclosure is not practicable, say “TBD”

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Textbook Information• Information for students

• In addition to pricing information, include a notice on your paper-based written course schedule• Let students know that information is available on the web-based course schedule

• Specify the URL for the web-based course schedule

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Textbook Information• Information for college bookstores

• College bookstore = a bookstore “operated by, or in a contractual relationship or otherwise affiliated with” the institution

• Institutions must provide certain information to a college bookstore (see next slide)

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Textbook Information• Information for college bookstores

• Your institution must tell the bookstore:

• The course schedule for the upcoming academic period

• For each upcoming course/class:

– The ISBN and retail price (or alternatives B or C, as needed) for each required or recommended textbook or supplemental materials

– The number of students enrolled

– The maximum student enrollment

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Textbook Information• Additional information

• HEA encourages institutions to disseminate information to students about:• Programs for renting or purchasing used textbooks

• Guaranteed buy-back programs

• Alternative content delivery programs

• Other cost-saving strategies

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Textbook Information• Resources

• GEN-10-09 http://ifap.ed.gov/dpcletters/GEN1009FinalTextbookGuidance.html

• GAO report (released June 6, 2013) http://www.gao.gov/products/GAO-13-368

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Resources for Schools• Statute – HEA

• Section 132(h) – NPC

• Section 133 – textbook information

• Section 485 – bulk of disclosures

• Regulations – www.ecfr.gov

• 34 CFR §668, Subpart D

• 34 CFR Part 86 (Drug-Free Schools & Communities)

• FSA Handbook – Vol. 2, Chapters 6-8

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Resources for Schools• FSA Assessments on consumer info• http://ifap.ed.gov/qahome/qaassessments/

consumerinformation.html

• NPEC report and supplement• http://nces.ed.gov/pubsearch/pubsinfo.asp?

pubid=2010831rev (part 1)

• http://nces.ed.gov/pubsearch/pubsinfo.asp?pubid=NPEC2012831 (supplement)

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Frequently Missing Disclosures• In this session:

• Annual Notice

• Drug and Alcohol Abuse Prevention

• FERPA Notification

• Voter Registration

• Copyright Infringement

• Satisfactory Academic Progress (SAP) policies

• In other sessions:• Gainful Employment Overview – session 31

• The Clery Act and Title IX Compliance – session 38

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Frequently Missing Disclosures

• Annual Notice• Institutions must distribute a notice each year to all enrolled students

• The notice must list and briefly describe the information that the school is required to disclose and tell the student how to obtain the information

• “Notice” means a 1:1 communication

• If you post the information on an Inter- or Intra-net website, you must include the exact electronic address where the information is posted in the notice

• State in the notice that you will provide a paper copy of the information upon request

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Frequently Missing Disclosures• Drug and Alcohol Abuse Prevention

• Institutions must certify that they have adopted/implemented a program to prevent drug and alcohol abuse, and must:• Distribute certain information to students and employees annually

(34 CFR §86.100)• Conduct a biennial review of the program to determine

effectiveness, needed changes, and whether disciplinary sanctions are consistently enforced

• Provide review results upon request

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Frequently Missing Disclosures• Drug and Alcohol Abuse Prevention

• Information to include:

• Standards of conduct that clearly prohibit the unlawful possession, use, or distribution of drugs and alcohol

• Description of sanctions under state, local, and Federal law

• Description of available drug or alcohol counseling, treatment, or rehabilitation programs

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Frequently Missing Disclosures• Drug and Alcohol Abuse Prevention

• Information to include:

• Description of health risks associated with the use of illicit drugs and alcohol

• Clear statement that institution will impose sanctions on students and employees for violations of the standards of conduct and a description of sanctions

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Frequently Missing Disclosures• Annual FERPA notification

• Must inform students of their rights under FERPA to:

– Inspect and review education records

–Seek to amend education records

–Consent to disclosure of PII from his/her education records, except as specified by law

–File a complaint with the Department if institution doesn’t comply• Must specify procedures for exercising rights• Must specify criteria for determining who constitutes a school official

and what constitutes a legitimate educational interest

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Frequently Missing Disclosures• Voter Registration

• Institutions in nearly every State and DC must:• Make a good faith effort to distribute a mail-in voter registration form to

each student enrolled in a degree/certificate program and physically in attendance

• Make the voter registration form widely available to students at the institution

• Request forms from the state 120 days prior to the voting registration deadline

• May distribute the form electronically*Institutions in ID, MN, NH, ND, WI, WY, and the territories are exempt

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Frequently Missing Disclosures• Copyright infringement (peer to peer file sharing)

• Institutions must disclose to prospective and enrolled students:

• Explicit statement that unauthorized distribution of copyrighted material may subject student to civil and criminal liabilities

• Description of the institution’s policies on unauthorized P2P file sharing, including disciplinary actions

• Summary of penalties for violation of Federal copyright laws

* There is also a PPA component to the copyright infringement requirements

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Frequently Missing Disclosures• SAP Policies

• Make sure you have updated your SAP policies to conform with the regulatory changes that were effective July 1, 2011 and

• Ensure that your consumer disclosures for SAP accurately reflect those policies

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Resources

• HEOA changes• GEN-08-12 (especially pages 95-102)

http://ifap.ed.gov/dpcletters/GEN0812FP0810.html

• http://familypolicy.ed.gov

• Model FERPA notification http://www2.ed.gov/policy/gen/guid/fpco/ferpa/ps-officials.html

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Resources

• Copyright infringements

• GEN-10-08 published 6/4/2010 http://ifap.ed.gov/dpcletters/GEN1008.html

• Final regulations published 10/29/2009 http://ifap.ed.gov/fregisters/FR102909GeneralandNonLoanProgrammaticFinalRule.html

• SAP

• Final program integrity regulations published 10/29/2011 http://ifap.ed.gov/fregisters/FR102910Final.html

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QUESTIONS?

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