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Gainful Employment Update

Session 25. Gainful Employment Update. Cynthia Hammond and John Kolotos | Nov-Dec. 2016 U.S. Department of Education 2016 FSA Training Conference for Financial Aid Professionals. Agenda. Regulations Which Programs Are GE Programs Reporting Metrics Certifications. Regulations.

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Gainful Employment Update

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  1. Session 25 Gainful Employment Update Cynthia Hammond and John Kolotos | Nov-Dec. 2016 U.S. Department of Education 2016 FSA Training Conference for Financial Aid Professionals

  2. Agenda • Regulations • Which Programs Are GE Programs • Reporting • Metrics • Certifications

  3. Regulations • Final Rule published October 31, 2014 • Effective July 1, 2015 • New Disclosures Effective January 2017 • Dear Colleague Letter GEN-15-12 – posted June 30, 2015

  4. Which Programs Are GE Programs • The HEA provides that to be Title IV-eligible an educational program must be offered by: • A public or non-profit postsecondary educational institution, if the program leads to a degree; or • Any institution, if the program prepares students for “gainful employment in a recognized occupation” • Generally, all non-degree programs must lead to gainful employment • Generally, most programs at for-profit institutions must lead to gainful employment

  5. Which Programs Are GE Programs • GE Electronic Announcement #53 – What is a Gainful Employment (GE) Program? • GE Operations Manual

  6. GE Reporting • Report all Title IV Students by July 31, 2015 • Report 2008-2009 through 2013-2014 award years • Programs with Medical and Dental Residencies report 2007-2008 through 2013-2014 award years • Report 2014-2015 Award Year by October 1, 2015 • Report 2015-2016 Award Year by October 1, 2016 • Title IV students only

  7. Reporting Accuracy • Data Quality • Completeness • Accuracy • Consistency • Data Quality Reviews • Data Corrections in Reporting Data (corrections submitted to the Draft Completers List do NOT transfer to your underlying GE reporting data)

  8. Debt-to-Earnings Measures

  9. Debt-to-Earnings Overview

  10. Cohort Periods • D/E rates are calculated using debt and earnings of students who complete a GE program during a specific cohort period • Cohort period is either two or four years • Two-year cohort used if 30 or more students completed during the period • Four-year cohort used if fewer than 30 students completed during the two-year cohort period • If fewer than 30 students completed during the four-year cohort period, D/E rates will not be calculated

  11. Cohort Periods • Two-year cohort is students who completed the program during the 3rd and 4th award years prior to award year for which rates are calculated • Four-year cohort is students who completed the program during the 3rd,4th, 5th and 6th award years prior to the award year for which rates are calculated • D/E rates calculation for 2014-2015 • Two-year cohort period is 2010-2011 and 2011-2012 • Four-year cohort period is 2008-2009, 2009-2010, 2010-2011 and 2011-2012

  12. D/E Rates Calculation • Exclusions • Any of student’s Title IV loans are in a military-related deferment • Any of student’s Title IV loans have been approved or are under consideration for a Total and Permanent Disability discharge • Student was enrolled in any other eligible program during the calendar year for which SSA earnings are obtained • For undergraduate GE programs, student completed a higher-credentialed undergraduate GE program at the same institution • For graduate GE programs, the student completed a higher-credentialed graduate GE program at the same institution • The student is dead

  13. D/E Rates Calculation Annual Loan Payment Annual Earnings – (1.5 x Poverty Guideline ($11,770)) Discretionary Income Rate = Annual Earnings Rate Annual Loan Payment Annual Earnings =

  14. Accountability Metrics • The Department will analyze the salary data for the 2014 calendar year and the debt of the graduates in the 2010-2011 and 2011-2012 award year (in the typical case – absent issues of small programs, medical students, etc.)

  15. Calculating Median Loan Debt • Median Loan Debt of Program Completers, • Amortized Over Repayment Period, • At the Appropriate Average Interest Rate Annual Loan Payment = • To calculate median loan debt, take for each student, the lesser of: • the loan debt incurred; or • the total tuition, fees, books, equipment, and supplies • Remove, if applicable, the appropriate number of highest loan debts related to graduates that are unmatched by SSA; then • Calculate the median of the remaining amounts

  16. Calculating Median Loan Debt • SSA can’t find one number—remove highest value • Median Debt is $25,000

  17. Calculating Median Loan Debt • Attribution: • The Department uses the reported enrollment dates to attribute a student’s loan amounts to the relevant GE program. In instances where a student was enrolled in more than one GE program during a loan period, we attribute a portion of the loan to each program in proportion to the number of days the student was enrolled in each program • In instances where a loan was made for a period that included enrollment in both a GE program and in a non-GE program, the loan will be attributed to the GE program under the assumption that the student would have taken out the loan if the student was enrolled only in the GE program

  18. D/E Rates Calculation • Annual loan repayment • Calculated by determining the median loan debt of students who completed the program during the applicable cohort and amortizing that debt • Includes private education loans and total amount outstanding on any other credit extended by the institution • Capped at lesser of total amount of student’s tuition and fees, books and supplies, and equipment or the total amount of debt the student incurred for the program

  19. D/E Rates Calculation • Annual earnings • Based on earnings obtained from SSA • ED submits a list to SSA of students who completed the program during the cohort period and received Title IV aid • SSA calculates and returns the mean and median annual earnings of students on the list for whom it was able to match earnings data for the GE “earnings year” • SSA does not provide individual earnings data or the identity of any student

  20. Draft D/E Results

  21. Draft D/E Challenges • Challenges to Draft Debt-to-Earnings Rates: • October 9th: Earnings data distributed to institutions (GESSA1 report on IFAP) • Night of October 19th: GE draft D/E backup data and draft rates distributed to schools (GEDMP1/GEDMY1) • October 24th: Start of 45-day challenge period • December 7th (11:59 p.m. EST): End of challenge period for Draft D/E Rate data • ALL CHALLENGES AND SUPPORTING DOCUMENTATION MUST BE SUBMITTED BY DECEMBER 7TH.

  22. D/E Rates Calculation • Corrections and Challenges – two 45-day periods • Corrections following the release of the Draft Completers Lists • Correct inaccuracies in school-entered reporting data (CIP codes, institutional debt figures, tuition and fees amounts, etc.) • Correct improper inclusion/exclusion from the list • Challenges following the release of the Draft D/E Rates • Limited to Title IV loan debt information only • Webinars on understanding and on challenging your Draft D/E rates were held in October: slides, transcripts, and audio recordings are available on the IFAP site

  23. D/E Rates Calculation

  24. Draft D/E Challenges • GE tab on NSLDS FAP site: • GE D/E List • Debt-to-Earnings List Page: See detail on students’ GE programs associated with draft rates • Debt-to-Earnings Update Page: Input draft D/E challenges • Submit Draft GE D/E Challenges: Turn in your D/E challenges to the Department

  25. Draft D/E Challenges • Resources: • GE Electronic Announcement #94 • Resources page – in the Gainful Employment section of the IFAP site • Webinars: Reading Your Draft GE Debt-to-Earnings Rate Files and Submitting Draft GE Debt-to-Earnings Challenges • Reminder: the sole purpose of challenges is to revise any incorrect Title IV loan data (dates, amounts, etc.)

  26. Certification

  27. Certification • Transitional Certification - Due December 31, 2015 • Required of currently participating institutions offering GE programs • New or returning institutions that have an E-App in process will have the required certifications included in the resulting Program Participation Agreement (PPA) • Must be signed by institution’s President/Chancellor/CEO • Certifications renewed when institution recertifies PPA or when something materially changes

  28. Certification • Institution must update information about its GE programs using the Application to participate in Federal Student Aid Programs (E-App) so that its Eligibility and Certification Approval Report (ECAR) is current • Institution must certify that each GE program it offers: • Is approved by a recognized accrediting agency or otherwise included in the institution’s accreditation by its recognized accreditation agency • If a public vocational institution is approved by a State agency recognized to approve such programs in lieu of accreditation • Is programmatically accredited if required by a Federal governmental entity or by a governmental entity in the state where the institution is located or in which it is otherwise required to obtain State approval

  29. Certification • Satisfies applicable educational prerequisites (in the State in which the institution is located or in which it is otherwise required to obtain state approval for professional licensure or certification requirements in that State) so that a student completing that program and seeking employment in that State qualifies to take any licensure or certification examination needed to practice or find employment in an occupation that the program prepares students to enter • Is not substantially similar to a program offered by the institution that, in the prior three years, became ineligible under the D/E rates measure or was failing, or in the zone, and was voluntarily discontinued by the institution • Programs that share the same four-digit classification of CIP code are considered to be substantially similar

  30. Certification • Changes after transitional certification requirement has been met • Institution adding or revising GE information on E-App that does not result in a new PPA must provide a new certification each time the E-App is updated • Includes: • Establishing or reestablishing the eligibility of a program • Discontinuing a program’s eligibility • Ceasing to provide a program for 12 consecutive months • Losing program eligibility • Changing a program’s CIP code or credential level • ED will monitor (on an ongoing basis) certifications for accuracy and completeness

  31. Certification • GE Electronic Announcements #54, #66, #77 • Link to E-App: https://eligcert.ed.gov/ • Email GECertification@ed.gov • Certifications must be updated as programs are added or changed

  32. GE Resources

  33. Session 26 Gainful Employment Disclosures • Presenters: Cynthia Hammond and Greg Martin

  34. QUESTIONS? • Cynthia Hammond, • Assistant Director, Policy Liaison and Implementation, Federal Student Aid • cynthia.hammond@ed.gov • 202-377-4236 • John Kolotos, Policy Analyst, • Office of Postsecondary Education • John.kolotos@ed.gov • 202-453-7646

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