Gainful Employment - Overview

1. Gainful Employment - Overview Wayne Kruger, Director of Operations St. Petersburg College

2. Agenda • Gainful Employment Program Defined • Disclosure Requirements • New GE Programs • Reporting Requirements • Metrics and Sanctions • Lessons Learned from the first year • Questions

3. Gainful Employment Program Defined

4. Gainful Employment Program • Rule applies at the program level, not institution • GEN-11-10, is your best guide • Virtually all educational programs offered by for-profit institutions are GE Programs • Virtually all non-degree educational programs awarded by a public or private non-profit institution are GE Programs • Not all educational programs that lead to a degree awarded by a public or private non-profit institution are GE Programs

5. Gainful Employment Program • 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. • Public institutions and not-for-profit institutions – All programs, except for -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.

6. Recognized Occupation • Programs that are GE programs are defined as helping student seek GE in an recognized occupation • One identified by a Standard Occupational Classification (SOC) code established by OMB; or • One identified by an Occupational Network O*NET-SOC code established by the U.S. Department of Labor; or • One determined by the Secretary of Education in consultation with the Secretary of Labor.

7. Gainful Employment Programs • A Gainful Employment Program is identified by its: • 6 digit OPEID • 6 digit CIP Code (Classification of Instructional Program) • 2 digit Credential Level • New Programs = new CIP Code or new 01/04 credential level

8. Credential Levels for GE • 01 = Undergraduate certificate • 02 = Associate’s degree • 03 = Bachelor’s degree • 04 = Post baccalaureate certificate • 05 = Master’s degree • 06 = Doctoral degree • 07 = First-professional degree

9. Disclosures

10. Gainful Employment Disclosures-General • For each GE Program, institution must provide prospective students with specific information • Effective July 1, 2011 • Institution must use disclosure form provided by the Department, when available • At this point only a draft is floating around so schools are still able to use their own format • Institutions must comply with these disclosure requirements independently until form is fully available

11. Annual Disclosure Requirement • July 1, 2011 – may use 2009-10 data to calculate metrics • Update with 2010-11 data for graduation within a “reasonable amount of time” • Annual updates to be completed within a “reasonable amount of time” after each subsequent award year • Should soon be moving to update to 11-12 data if you have already moved over to 10-11 data.

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 – for entire program in normal completion time. Can be actual or average. • Tuition and fees • On-campus 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 the same as 150% used for other purposes • As published by institution

14. Normal Time Frame Defined • Time necessary to complete all requirements according to college catalog • “Typically two years for an AA degree and various for certificate programs” • Must be time based • Transfer students get full “normal time” • Program changes do not adjust “normal time” • To be counted as completing on time, a student who changes programs at the institution and begins attending a new program must complete within the timeframe beginning from the date the student began attending the prior program

15. Disclosures • Disclose for each GE Program: • Median loan debt incurred by students who complete the program • Title IV loan debt –Amount borrowed • Private educational loan debt –Amount borrowed • Institutional finance plans – Amount owed

16. Disclosures • Disclose for each GE Program: • Job placement rates for students completing the program using the NCES methodology • NCES methodology not ready at this time • Until then use formula that the institutional accreditor, program accreditor, or the state requires

17. Web Disclosures • Disclosure Information on Program’s website home page • Each GE Program must have a dedicated 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

18. Print Media Disclosures • Catalogs and Schedules – complete disclosures “whenever feasible” • If not feasible because of size or structure must include URL or live link to website • Postcards, flyers, brochures, etc • Example: “For more information about our graduation rates, the median debt of students who completed the program, and other important information, please visit our website at www.ABCcollege.program” • Print materials must be revised within a reasonable amount of time since many have already been printed for this year or sent to printers for next

19. New GE Programs

20. New Programs-Timelines • If the first day of class will begin on or after July 1, 2011 and before October 1, 2011, notification must be provided no later than July 1, 2011 • If the institution does not provide the required notification by July 1, 2011, it must wait for Departmental approval before disbursing funds to students enrolled in the new GE Program. The institution must also inform students that the program has not been approved by the Department to be eligible for federal student aid. • 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

21. New Programs-Timelines • An institution that provided notice of a new GE Program at least 90 days before the first day of class (or July 1, 2011 if applicable) of that new program may begin offering the additional program without receiving Departmental approval unless: • the Department requests, at least 30 days prior to the date the program is scheduled to begin, additional information; or • otherwise informs the institution to delay the start of the additional program.

22. New Programs - Notifications • Must include sufficient narrative information to demonstrate that the program meets the requirements of an eligible GE Program and to support the need for the program • How need of program was determined • How college became aware of need of program • How the program was designed to meet market needs • Wage analysis and wage data related to the new program • Consultation processes with external entities • Can cover multiple programs if same or similar process used • Updating a program already on your PPA even if its changing the CIP code does not prompt the new program regulations

23. New Programs – NPRM • September 27, 2011: posted notice of NPRM • Possible changes to which programs have to be reported as new, other possible ways to report programs to speed up the process • Limiting the new gainful employment programs for which an institution must apply to the Department to those programs that are (1) the same as, or substantially similar to, failing programs that the institution voluntarily discontinued or programs that became ineligible under the debt measures for gainful employment programs, and (2) programs that are substantially similar to failing programs

24. Reporting

25. Gainful Employment Reporting Requirements • Institution must annually report information on students who were enrolled in a GE program for each award year – • Student identifying information • Program identifying information • Amounts from private education loans • Amount owed on institutional financing plans • Enrollment information

26. Reporting Requirements • Should have by now reported years: • 2006-2007, 2007-2008, 2008-2009, 2009-2010, and 2010-11 award year information • If unable to report any of the required information, institution must provide an explanation. Explanation sent to GE-Missing-Data@ed.gov. • Comments by Jeff Baker have been that very few if any schools would be approved and he listed several examples of reasons schools were denied this • Schools without any or believe they are without any GE programs should send something in so that the department does not come looking for data • Annual data submission for 2011-2012 GE data has been set to be October 15th

27. Gainful Employment Electronic Announcement #12 • A big announcement at least for the Florida Colleges, perhaps other schools as well. • If students are enrolled in only the degree program and are not also enrolled in a separate certificate program, it is the degree program that should be evaluated using the guidance in Gainful Employment • If the institution also offers a separate certificate program, students enrolled in the degree program only should not be included in either the disclosures or reporting for the separate certificate program

28. Gainful Employment Electronic Announcement #12 • If students are enrolled in a certificate program, even if the enrollment is concurrent with enrollment in the degree program, those students must be included in the certificate GE Program’s reporting and disclosures • If a significant number of the students enrolled in the degree program are awarded only the certificate and not the degree, the students enrolled in the degree program must be included in the disclosures and reporting for a certificate GE Program

29. Reporting your data • See NSLDS Newsletter dated 09/22/2011 for details on reporting your data as well as the NSLDS GE User Guide • The NSDLS allows for reporting student data using the following methods • Batch fixed length file, exchanged via SAIG • Batch CSV file, exchanged via SAIG • Online direct entry one student at a time via NSLDS website • Online direct upload using NSLDS gainful employment submittal template

30. GE Metrics and Sanctions

31. A whole new alphabet soup • OOPB: Original Outstanding Principal Balance (includes capitalized interest) • LPF: Loans Paid in Full • PML: Payments Made Loan • 2YP: 3rd & 4th FY’s prior • 2YP-A: Most recent 2-year period (for FY12-14 only) • 2YP-R: 6th & 7th FY’s prior (for programs with residencies) • 4YP: 3-6th FY’s prior • 4YP-R: 6th-9th FY’s prior (for programs with residencies)

32. The Department’s goals: • That students in GE programs are not left with difficult challenges due to unaffordable debt and poor employment prospects, and • Taxpayer investment in Title IV HEA student aid is well spent • First set of rates in 2012 are informational, first official rates will be in 2013

33. GE 2 Metrics: • Repayment rate considers FFELP and Direct loans borrowed by all program attendees, whether they completed the program or not. • A percentage of the loan amounts that a GE Program’s former students are repaying (weighted for loan balance) • Debt-to-earnings ratios consider only program completers but include private loans and debt obligations to the school • the average educational loan annual repayment amount as a proportion of the average borrowers’ annual income

34. GE Metrics – Repayment Rate: • Assesses whether FFEL and Direct Loan debt incurred to attend a program is being repaid at a rate that implies gainful employment: OOPB of LPF + OOPB of PMLOOPB OOPB = Original Outstanding Principal Balance LPF = Loans Paid in Full PML = Payments-Made Loans Typically includes loans in the 3rd and 4th year of repayment

35. Repayment Rate • A loan is successfully being repaid if: • Its balance is reduced by at least $1.00 over the course of the year or paid in full; • It is on track to being forgiven due to public service employment; • Borrower is making payments under an interest‐only or income‐based repayment plan, but limited to no more than 3% of the OOPB; or • For post-baccalaureate programs, is a consolidation loan and all interest accrued over the course of the year has been paid

36. Repayment Rate • For the most recent fiscal year, excludes: • Loans in an in-school deferment or a military-related deferment • Loans discharged, or pending discharge, for death or total and permanent disability

37. Repayment Rate • Example: Former StudentOOPB Student A $ 8,000 Student B $ 6,000 Student C $ 4,000 Student D $ 10,000 • OOPB = $28,000 (total amount for all borrowers in 2YP) • Only student D is successful in repaying • Repayment rate = $10,000 / $28,000 = 35.714%

38. Debt Includes: • All Federal loans • All Private loans • Amount due to institution at time of graduation • Repayment calculated using: • 6.8% Interest Rate • Variable Repayment term: • 10 years: Certificate and Associate degrees • 15 years: Bachelor and Master’s degrees • 20 years: Doctoral and Professional degrees

39. GE Metrics - Debt-to-Earnings Ratio: • Earnings Rate Average Annual Loan Payment Amount Mean or Median Annual Earnings • Discretionary Income Rate Average Annual Loan Payment Amount Mean or Median Annual Earnings less 1.5 X poverty guideline

40. GE Metrics - Debt-to-Earnings Ratio: • SSA will provide the median and mean earnings of program graduates. • Schools can verify the lists of individuals submitted to SSA. However, the earnings data will be subject to SSA’s strict protections on individual privacy.

41. GE Metrics - Debt-to-Earnings Ratio: • Exclude students -- • With one or more loans in a military-related deferment status • With loans discharged, or pending discharge, for death or total and permanent disability • Enrolled in school

42. GE Sanctions and Appeals • First GE programs become ineligible in 2015, based on 2012, 2013, 2014 metrics • Generally, the rate measures borrowers in their third and fourth years of repayment • GE programs must pass at least one of the three metrics to remain eligible for Title IV • Repayment rate of at least 35%, Debt-to-Earnings rate of less than 12% of total earnings, or 30% of discretionary income. • Only programs that fail the measures three out of four fiscal years will lose eligibility

43. GE Sanctions and Appeals • Gives program an opportunity to improve • If a program fails all three metrics: • After one failure • Institution must disclose the amount by which the program missed minimal acceptable performance and program plan for improvement • Establish a three-day waiting period before students can enroll

44. GE Sanctions and Appeals • If a program fails all three metrics: • After two failures within three years: • Inform students in the failing program their debts may be unaffordable; the program may lose eligibility; and what transfer options exist • After three failures within four years: • Program loses Title IV eligibility for at least three years but can continue without federal student aid

45. GE Sanctions and Appeals • Failing programs do not lose eligibility immediately • Standards help programs raise performance • Analysis indicates that, with the opportunities for improvement, it is estimated that - • Eight percent of programs will fail at least once • Two percent of programs will ultimately lose eligibility

46. GE Sanctions and Appeals • Institutions can correct the repayment rate data using a process similar to one used to challenge cohort default rates • For debt-to-earnings ratios, SSA will provide median and mean earnings of program graduates • Institutions can verify lists of individuals submitted to SSA; earnings data subject to strict protections on individual privacy

47. GE Sanctions and Appeals • Institutions can also submit alternative earnings data based upon surveys or state longitudinal data systems (permanently) • During transitional period, institutions can submit analyses based upon Bureau of Labor Statistics data on typical earnings for particular jobs

48. GE Sanctions and Appeals • To reward programs that improve rapidly: • ED will accept repayment rates based on two most recent years, rather than third and fourth years in FY 2012, 2013, 2014 calculations • To target worst programs: • ED will cap eligibility losses at 5% of public, non-profit, and for-profit programs until 2015 • Regulations fully effective in 2016 based on FY 2015 data – no cap on eligibility losses

49. Lessons Learned

50. Updating SAIG • One thing that a lot of schools have missed is that you actually have to go in and update your SAIG mailbox to get access to all the GE reports they plan to produce • Be sure to log into the FSA Web Enroll site and have your DPA update the mailbox to get GE information • Adding this will require your DPA to send off a new CPS/SAIG enrollment form