oklahoma tech centers conference federal update. please take our short survey about training...
TRANSCRIPT
Oklahoma Tech Centers Conference
Federal Update
Please Take Our Short Survey About Training
s.zoomerang.com/s/KevinCampbell-TX
No WWW in URL
2
3
Training
4
FSATRAINING.INFO
• Available now on fsatraining.info• Step-by-step lessons on how to set up the Global, App
Express, Pell and Packaging modules• How to work with Institutional Student Information
Records (ISIRs)• How to use the Packaging module to award aid to your
students• EDExpress 2.0 for 15-16 now available
• See DCL ANN 15-10 published last month
EDExpress Training
5
6
Ask-A-Fed at the FSATC
7
8
FSA ID: The FSA PIN
ReplacementPerson Authentication
Service (PAS)
Introducing the FSA ID
• FSA is adopting the best practice of using a username and password instead of personal information
• The FSA ID • Requires users to enter less information (2
fields instead of 4)• Provides more secure access to user’s
information• Links to PIN information during registration • Offers self – service capability (name change)
New FSA ID login
Old PIN login
The FSA ID will modernize access for students, parents and borrowers to FSA systems
Will be updated
9
Introducing the FSA ID
• The FSA ID (username and password) will replace PIN for students, parents and borrowers accessing FSA systems starting May 10, 2015
(was originally scheduled for April 26)
New FSA ID login
Old PIN login
The FSA ID will modernize access for students, parents and borrowers to FSA systems
Will be updated
10
The FSA ID
• The FSA ID is for the applicant’s use ONLY!• Students must obtain their own FSA ID for FSA
purposes• Parents must obtain their own FSA ID for FSA
purposes• See July 17 EA
The FSA ID will modernize access for students, parents and borrowers to FSA systems
11
12
Gainful Employment
13
Gainful Employment - Regulations
Notice of Proposed Rulemaking (NPRM)• Federal Register - March 25, 2014• OPE Website with discussions and materials associated with GE negotiated
rulemaking:
http://www2.ed.gov/policy/highered/reg/hearulemaking/2012/gainfulemployment.html
Final Federal Register - October 31, 2014• Effective date - July 1, 2015
• http://ifap.ed.gov/fregisters/attachments/FR103114Final.pdf
Which Programs are GE Programs
At public institutions and not-for-profit institutions, all programs are GE Programs except for – Programs that lead to a degree
ED means that program grants the degree Programs of at least two years in length that are designed to be fully transferable to a bachelor’s degree program
Preparatory coursework necessary for enrollment in an eligible program (loan only)
14
15
Gainful Employment MeasureDebt-to-earnings (D/E) ratesAnnual Earnings D/E rateDiscretionary Income D/E ratePassing: Annual D/E < = 8% or Discretionary D/E < = 20%
Failing: Annual D/E > 12% or Discretionary > 30%
Zone: Annual D/E > 8% and < = 12% or Discretionary D/E > 20% and <= 30%
15
16
Gainful Employment Results
Program’s loses Title IV eligibility if: D/E measures – Fails in two out of three
years OR
D/E measures - Fails or in the zone for four consecutive years
16
GE Reporting GE reporting now available in NSLDS
(GE EA #52 - 2/11/15) Report all Title IV students by July 31, 2015
Report 2008-09 through 2013-14 award years
Report following award years by October after end of the award year Report 2014 – 2015 Award Year by October 1, 2015
17
18
Gainful Employment – Current Disclosures
Court left regulations (34 CFR 668.6(b)) in place that require schools to disclose certain GE Program data•Schools must use the Department’s GE Disclosure Template to provide all GE disclosures• Schools must have updated their GE program disclosures with
13-14 information no later than January 31, 2015• GE Electronic Announcement #50 (9/11/14)
• Template updates include: improved printing capabilities, updated SOC codes, optional context boxes, graduate certificate option, school name on output screen, bulk upload tool used if certain criteria met with different length programs
• Technical questions: (855) 359-3697 or [email protected]
19
Disclosures Under New Final Rules
• Through December 31, 2016, current disclosure requirements remain in effect• Occupations; Normal time to complete program;
On-time graduation rate for completers; Tuition & fees, books & supplies, room & board; Placement rate for completers (as determined by State or Accreditor methodology); and Median loan debt
• Institutions must comply with new disclosure requirements (October 31, 2014 Final Rules) beginning January 1, 2017• conduct consumer testing, hold focus groups and
prepare new disclosure template
GE Resources• GE Information Page on IFAP
• Federal Register Notices; DCLs; Electronic Announcements; FAQs; Webinars; Presentations; Resources
http://www.ifap.ed.gov/GainfulEmploymentInfo/indexV2.html
• GE presentations at the FSA Training Conference• fsaconferences.ed.gov – sessions #GS1, 30, 58
• EAs- various EAs up to #57 on GE issues • ANN-15-01 - Recorded Webinar – GE Reporting • NSLDS Newsletter 49, July 22 GE and Enrollment Reporting
send questions to [email protected]
20
21
Gainful Employment Requirements
•
22
PolicyPotpourri
Ability to Benefit (ATB)• The Consolidated and Further Continuing
Appropriations Act, 2015 reinstated the ATB alternatives for Title IV student eligibility for students enrolled in “career pathway programs”• Applies to students who are enrolled or who first enroll in an eligible program of study on or after July 1, 2014
• Pell limitations for students who first enroll in an eligible program on or after July 1, 2015
23
24
Ability to Benefit (ATB)
• This provision does not reinstate the ATB rules from the past
• It is limited to Career Pathway Programs• ED issued a DCL, GEN 15-09 on this topic
in May
25
Career Pathway Program
• A CP Program is a program with two parts• One part contains “Adult Education” courses
• By definition, this work is below the postsecondary level
• One part contains a postsecondary work that if looked at by itself, would be an eligible Title IV program
26
Career Pathway Program
• ED will not determine if a school’s CP Program is a CP program
• The CP Program does not have to be reported to ED• The part that is, by itself, an eligible postsecondary program must be reported
27
Career Pathway Program
• A student enrolled in a CP Program who already has earned a HS Diploma or a recognized equivalent does not need this new provision to be eligible for T4
• A student without a HS Diploma or a recognized equivalent CAN establish T4 eligibility via this new provision
28
Career Pathway Program and ATB• A student without a HS Diploma or a recognized
equivalent CAN establish T4 eligibility by using the old ATB methods• Pass an ED approved ATB test• OR• Complete 6 credit hours or 225 clock hours that are
applicable to an academic credential at your school, not necessarily the academic credential being sought by the student• If the student is earning the necessary 225 hours at your school, he is not Title IV eligible while earning the 225 hours
29
Career Pathway Program and T4
• The hours that make up the Adult Education part of the CP Program do not count as hours for T4 eligibility purposes
• If remedial hours are being used as hours that are part of the postsecondary program, they cannot be used as hours in the Adult Education part of the CP Program
30
Career Pathway Program and Pell
• Students in this type of program who have established eligibility via ATB are paid Pell on a different Pell payment schedule
• Schedules are attached to GEN 15-09
• USCIS has issued a new G-845 with an expiration date of May 31, 2018
• Replaces the old G-845 that expired on January 31, 2015
• See June 29, 2015 EA for more info
G-845
31
Dear Colleague LettersGEN-15-05 – 2015-16 Unusual Enrollment History
Flag2015-2016 UEH Flag has expanded to consider–
• An applicant’s prior receipt of, in addition to a Federal Pell Grant, a Federal Direct Loan (not including Direct Consolidation Loans or parent PLUS Loans)
• The prior four, instead of three, award years • For 2015-2016, UEH Flag evaluation includes the 2011-2012,
2012-2013, 2013-2014, and 2014-2015 award years
32
Dear Colleague Letters
A school may self-select a student for UEH (not selected by ED) if enrollment problems are suspected
• Self-selected students treated as if have UEH 3 flag
GEN-13-09 provides full institutional resolution guidance
33
Dear Colleague Letters
GEN 15-18
• Reminds schools of their obligation to protect student data
• DCL includes resources
34
35
Return of Title IV Funds
36
Scheduled Hours vs Completed Hours
• Regs that define a payment period use the concept of successfully completed clock hours
• Regs that govern R2T4 require the use of scheduled clock hours to calculate the R2T4
• Not an apples to apples comparison but there is overlap that can create some confusion
37
Completed Hours
• Regs that define a payment period use the concept of successfully completed clock hours
• What is “successfully completes”?• Student has both attended and passed the hours• Program is 1000 clock hours• AY is 900 clock hours and 26 weeks• Student clocks 500 hours but only receives credit for 400• Student has 600 hours remaining in program• Student is in PP 1, NOT PP 2
38
Scheduled Hours
• Scheduled hours are mandated for R2T4 calculations
• On the day the student withdrew, how many hours was he or she scheduled to complete on that day?
• Use that figure for the R2T4 calculation• Used to calculate the % of the PP that has been
“completed” for R2T4 purposes• If student has completed more hours than was
scheduled, use SCHEDULED
39
R2T4 and Scheduled Clock Hours
• If the academic year is 900 clock hours and 26 weeks of instruction, the payment period (PP) is…• 450 clock hours
And• 13 weeks of instruction
40
R2T4 and Scheduled Clock Hours
Student has completed 250 clock hours out of the first 450 clock hour PP
In what PP is the student?
PP 1
41
R2T4 and Scheduled Clock Hours
Student has completed 250 clock hours out of the first 450 clock hour PP
Student withdraws
How many hours are used in the R2T4 calc?
We don’t know. We need the scheduled hours.
42
R2T4 and Scheduled Clock Hours
Student has completed 250 clock hours out of the first 450 clock hour PP but was scheduled to complete 300 on the day the student withdrew.
How many hours are used in the R2T4 calc?
300. 300/450 66.66% No $ to return
43
R2T4 and Scheduled Clock Hours
Student completed 250 clock hours out of the first 450 clock hour PP but was scheduled to complete 500 on the day the student withdrew.
In what PP is the student?
How many hours are used in the R2T4 calc?
500. 500/450 111.11% or 100% No $ to return
PP 1
44
R2T4 and Scheduled Clock Hours
Student completed 550 clock hours of her 1200 clock hour program.
In what PP is the student? PP 2
45
R2T4 and Scheduled Clock Hours in PP 2
Student completed 550 clock hours of her 1200 clock hour program.
In what PP is the student?
When the student completed PP 1 (450 clock hours) she was scheduled to have completed 550.
When the student withdrew in PP 2 she was scheduled to have completed 750 clock hours of the program and was scheduled to have completed 200 clock hours since PP 1 ended.
PP 2
46
R2T4 and Scheduled Clock Hours in PP 2
When the student completed PP 1 (450 clock hours) she was scheduled to have completed 550.
When the student withdrew in PP 2 she was scheduled to have completed 750 clock hours of the program and was scheduled to have completed 200 clock hours since PP 1 ended.
What number of hours do we use for “hours scheduled to complete”?
ED has never said…
47
R2T4 and Scheduled Clock Hours in PP 2
When the student completed PP 1 (450 clock hours) she was scheduled to have completed 550.
When the student withdrew in PP 2 she was scheduled to have completed 750 clock hours of the program and was scheduled to have completed 200 clock hours since PP 1 ended.
What number of hours do we use for “hours scheduled to complete”?
One could argue that the correct number is 200 200 / 450
48
R2T4 and Scheduled Clock Hours in PP 2
When the student completed PP 1 (450 clock hours) she was scheduled to have completed 550.
When the student withdrew in PP 2 she was scheduled to have completed 750 clock hours of the program and was scheduled to have completed 200 clock hours since PP 1 ended.
What number of hours do we use for “hours scheduled to complete”?
One could argue that the correct number is 750 750 / 900
49
R2T4 and Scheduled Clock Hours in PP 2
• When there is no set guidance, schools are expected to establish a reasonable process based on the statutory and regulatory language
• Include the rationale in your policy• The Office of Postsecondary Education is aware of
this lack of guidance and may issue guidance in a future DCL or a future Handbook
50
Real Life Example
• School’s academic year is 900 hours/26 weeks. Student was enrolled in school’s Information technology program of 900 hours. Student has perfect attendance for 83 school days (6 hrs/day) and has clocked 498 hours but has successfully completed only 400 hours of curriculum. School won’t pay student until he or she successfully completes 450 hours. At this point, student drops. School determines that same day student withdrew and prepares to do the R2T4.
51
Real Life Example
• School (based on the scenario above) will calculate the R2T4 for the student withdrawing in the second payment period and use the amount of a second Pell disbursement as “could have been disbursed” to come up with a figure for a post withdrawal amount. However, they have noted on the R2T4 that there will be no post withdrawal disbursement because the student did not successfully complete all of the curriculum hours in the first payment period.
• This is incorrect because the student had not entered the second payment period. This incorrect solution may also be describing a DL rule that a second or subsequent disbursement cannot be made when a student withdraws. This late disbursement rule does not apply to Pell Grants.
52
Real Life Example • When it comes to institutional charges on the scenario above,
wouldn’t we consider the student is still in the first payment period as well because he did not successfully complete the payment period even though he has clocked 500 hours?
• YES• If so, would the institutional charges be calculated only for the
first payment period (450 hours) if the school does it by the payment period?
• YES• What happens to the 50 additional hours the student clocked? • THEY DON’T EXIST FOR TITLE IV PURPOSES. TITLE IV $
CAN NEVER BE USED TO PAY FOR THESE CHARGES
53
2015-2016Processing
54
FAFSA Definition of Parent
Old definition was: biological or adoptiveNew definition is: biological, adoptive or person that the state has determined to be the parent
For example, a person listed on the birth certificateClarifying who is not a parent
List of people who are not considered a parent unless they have legally adopted the student will now include widowed stepparent
55
https://studentaid.ed.gov/sites/default/files/who-is-my-parent.png
56
Foster Care Benefits
Require all FOTW applicants to tell us if they are or were in foster care to ensure people entitled to benefits receive themSeparate from current dependency question
New question will be earlier in application process“Yes” answer will result in SAR comment with hyperlink to information regarding benefits, and hyperlink will also appear on FOTW confirmation page
57
Separated – FAFSA GuidanceFor FAFSA purposes, a married couple is separated if the couple is considered legally separated by a state, or if the couple is legally married but has chosen to live separate lives, including living in separate households, as though they were not married. If you and your spouse are separated but living together, select “I am married / remarried,” not “I am separated.” NOTE: When two married persons live as a married couple but are separated by physical distance (or have separate households), they are considered married for FAFSA purposes.
Data Retrieval Tool – Amended Returns
• In the filtering question, unusually large number of applicants report filing an amended return• Rewording question to specifically ask if they have filed a 1040-X amended return
• Help text will also refer to the 1040-X and make clear what the 1040-X is
58
Data Retrieval Tool – Timing Issues
• Some applicants who are eligible to use the tool find there is no data to import due to owing taxes
• New hyperlink statement: “How you filed your taxes can affect if tax information is available to import.”• Hyperlink will lead to help text that explains timing for tax information availability
59
60
Help Text ChangesGender question
Clarifying help text to state we are asking about sex at birthCitizenship status
Adding help text regarding DACA (Deferred Action for Childhood Arrivals) to help students in this category identify themselves
Should answer that they are neither citizens or eligible noncitizensAlthough they can receive Social Security numbers, they are not eligible for Title IV
61
2015-16 SAR Comments
• 2015-16 SAR Comment Codes and Text Guide just published on IFAP
• July update• Excellent tool for understanding and explaining
eligibility issues
• AVG• Volume 1• Volumes 3-6• Appendices• Volume 2 coming soon! Watch IFAP
2015-16 FSA Handbook
62
• New feature in HB started in 14-15
• Acronyms and Glossary• Business Office Functions• Reporting and Disclosure Requirements
2015-16 FSA Handbook Appendices
63
64
Blue Book to be Shelved
• The Blue Book contained info specifically for School Business Offices
• All the content that was in the Blue Book is now in the FSA HB rendering the Blue Book unnecessary
• It will no longer be published
Here lies the Blue Book, never were so many words written and so few read.
Verification for Now and for the Future
65
• Same verification items and Verification Tracking Groups to be verified as 2014-2015
• Applicant will remain in original 2015–2016 Verification Tracking Group for the entire 2015–2016 award year record
• Federal Register published June 25, 2014• GEN-14-11 published June 30, 2014• EA November 24, 2014 – Suggested Text
66
2015-16 Verification
• The V4 and V5 tracking process in FAA Access that began in the 2014-15 processing year WILL CONTINUE for 2015-16.
67
V4/V5 Tracking Results – 2015-2016
https://faaaccess.ed.gov
V4/V5 Tracking Results – 2015-16
68
Whom to report: student for whom school received an ISIR with a Verification Tracking Group of V4 or V5 AND for whom school requested verification documentation
• Do NOT include students the school selected for verification of identity or high school completion status
When to report: 60 days following the institution's firstrequest to the student to submit the required V4 or V5 identity and high school completion documentation
• changes to previously submitted Identity Verification Results must be updated within 30 days
69
Verification 2016-17
• ED published a Federal Register with the 2016-17 Verification requirements on June 26, 2015
• A DCL, GEN 15-11 was published soon after on June 29
• For the most part, the verification process is the same as in 15-16 with a couple of exceptions
70
Verification 2016-17• V code 3, Child Support Paid, will not be used in
2016-17• In limited situations, a student’s V code may change
based on corrections submitted• The change will always be from V1, 4, or 6 to V5,
the Aggregate Group• If moved to V5 from one of the others, no
disbursements can be made until verification is complete
• If disbursements were made prior to being moved to V5, they are a student liability, not a school liability
To ensure quality training we ask all participants to please fill out an online session evaluation
https://s.zoomerang.com/s/KevinCampbell-TX
Survey feedback is a tool to help us improve our training, justify training/travel expenditures and to listen to our customers
Please provide any comments regarding this training or the trainer to:
Jo Ann Borel, Title IV Training Supervisor [email protected]
Training Feedback
71
Need Help?
72
Research and Customer Care [email protected]
Reach FSA855.FSA.4FAA -- 1 number to reach 10 contact centers!
Campus Based Call Center eZ-AuditCOD School Eligibility Service GroupCPS/SAIG Foreign Schools Participation DivisionNSLDS Research and Customer Care CenterG5 Nelnet Total & Permanent Disability Team
Your Region VI Training Officers:
Trevor Summers
214.661.9468
Rick Renshaw
214.661.9506
Kevin Campbell
214.661.9488
Contact Information
73
Thank You, Oklahoma Tech Centers!
74
75
