NYSFAAA STATE WIDE TRAINING 10/5/11 GAINFUL EMPLOYMENT ‘ROUND TABLE’

1. NYSFAAA STATE WIDE TRAINING 10/5/11GAINFUL EMPLOYMENT ‘ROUND TABLE’

2. Howard LesliePresenter, Moderator, Colleague and Friend

3. TODAY’S GOALS • Now that the first two Gainful Employment deadlines have passed, we want to make sure everyone: • Has done everything they need to • Knows what to do next • Understand the potential ramifications of the Gainful Employment Regulations.

4. THIS IS AN OPEN FORUM WEBINAR • DO NOT hold your questions for the end. Your questions are the second most important aspect of today’s session. • The most important portion of today’s session is to hear the answers to everyone’s questions. • We want everyone to participate as we are ALL BIRDS OF A FEATHER – aka – IN THE SAME BOAT.

5. RULES OF ENGAGEMENT • Everyone’s phone will be muted except for your State Wide Training Co-Chairs (Vera and Beth). • If you have a question, comment or response: • You can type it in the comments box – choose the ‘staff’ tab. Vera or Beth will jump in and pose the question/comment. • You can type in that you have a question, comment or response to a question. Vera or Beth will tell me that John Smith has a Q, C or Response. I will then un-mute John and put him back on mute when complete.

6. RULES OF ENGAGEMENT • If your co-chairs believe that we need to move on they may ask everyone to hold questions to the end. • If there are any questions that relate to compliance – no one should guess what the answer is. That would be very dangerous. Your co-chairs will note the question and submit it to GE-Questions@ed.gov. When they get a response they will share them on NYSFAAA-L. • We are scheduled to end at noon. However, we have arranged to go as late as 12:30 if necessary.

7. RULES OF ENGAGEMENT • Our plan is to record this webinar and make it available on the NYSFAAA website and/or utube. • Once it has been posted to the web we will let everyone know via NYSFAAA-L. • WARNING: By virtue of your asking or responding to a questions (or any other verbal comment) you are giving NYSFAAA permission to record you and make it public. • FURTHER WARNING: Do not say something you might regret.

8. AGENDA • Summary/Discussion • GE Disclosures • GE Reporting • GE New Programs • Impact on PPAs – are you in compliance? • GE Metrics

9. ALL INFO GE ON IFAP

10. GE DISCLOSURES July 1st deadline required disclosures • The name and U.S. Department of Labor's Standard Occupational Classification (SOC) code of the occupations that the program prepares students to enter, along with links to occupational profiles on the U.S. Department of Labor's O*NET Web site or its successor site. • The on-time graduation rate for students completing the program.

11. GE DISCLOSURES • The tuition and fees the institution charges a student for completing the program within normal time. • The typical costs for books and supplies (unless those costs are included as part of tuition and fees), and the cost of room and board, if applicable. • The job placement rate for students completing the program.

12. GE DISCLOSURES • The median loan debt incurred by students who completed the program (separately by Title IV loans and by other educational debt to include both private educational loans and institutional financing) as provided by the Secretary. • Other information the Secretary provided to the institution about the program.

13. GE DISCLOSURES • July 1st deadline • (Current) Impact if you are not in compliance • Are you in compliance? Many institutions think they are but they are not. • DOE Position on the deadline

14. GE DISCLOSURES Let’s share experiences

15. SAMPLE COMPLIANT DISCLOSURE

16. GE REPORTING • Why? • Who? • When? • DOE position on the deadline? • What if I cannot/did not?

17. GE REPORTING • Circumstances that Require Submission of Missing or Incomplete Explanations (see Gainful Employment Electronic Announcement #18 on August 9, 2011) • 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.

18. GE REPORTING • Circumstances... • 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.

19. GE REPORTING • Circumstances.. • 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.

20. GE REPORTING 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. • Subject Line of e-mail - include the first 6 digits of the your OPEID and the institution’s name. • Body of e-mail –provide the name, phone number, and e-mail address of a contact person at the institution. This is the person they will contact if we have any questions on the missing or incomplete data explanation provided. • Then add the explanation

21. GE REPORTINGSUMMARY OF DATA ELEMENTS

22. GE REPORTINGNSLDS RECORD LAY OUT

23. GE REPORTING Let’s share experiences

24. GE New ProgramsTHINGS MIGHT BE CHANGING • On September 27, 2011, DOE published in the FederalRegistera Notice of Proposed Rulemaking (NRPM) that proposes changes to the regulations to streamline the application and approval process for new educational programs • Opinion. • Don’t forget the calendar – early implementation? • For now you must abide by the current regulations!

25. GE New Programs

26. GE New Programs

27. GE New Programs

28. GE New Programs

29. GE New ProgramsE-App, PPA, ecar Let’s share experiences

30. GE MetricsTwo Standards – Three Measures • Repayment Rate – • A percentage of the loan amounts that a GE Program’s former students are repaying (weighted for loan balance). • Debt to Earnings Ratio – • For the GE Program’s completers, the average educational loan annual repayment amount as a proportion of the average borrowers’ annual income. 30

31. GE MetricsrepaymentRate • Loan repayment rate for a program calculated annually using the following ratio: • OOPB = Original Outstanding Principal Balance • LPF = Loans Paid in Full • PML = Payments-Made Loans OOPB of LPF plus OOPB of PML OOPB

32. GE Metrics debt to incomernings • Earnings Rate • Discretionary Income Rate • Average Annual Loan Payment Amount • Mean or Median Annual Earnings less 1.5 X poverty guideline • Average Annual Loan Payment Amount • Mean or Median Annual Earnings

33. DGE Metricsto-Earnings-Earnings • Calculating of the annual loan payment • Uses the program's median loan debt, • Amortized at 6.8% over – • 10 years for a certificate or AA program, • 15 years for a baccalaureate program, or • 20 years for a graduate program

34. PnGE Metrics • A program must pass at least one of the three rates to be a Gainful Employment Program eligible for Title IV participation. • Repayment rate of at least 35%. • Debt-to-Earnings rate of less than • 12% of total earnings, or • 30% of discretionary income.

35. GE Metrics Loss of TIV Eligibility Failing ALL 3 metrics for three FYs in a four year period Earliest year for eligibility lossis FY 2015: if ALL 3 Metrics failed for FYs 2014, 2013, 2012 Must wait 3 years before re-applying for program eligibility

36. PeGEMetricse Requirements • A program is a failing program for a year if it does not meet ANY of the minimum standards. • After one year’s failure institution must — • Disclose to students and prospective students the amount by which the program did not meet the minimum standards and any plans for improvement; • Establish a three‐day waiting period before students can enroll.

37. GE Metrics FY 2012 Debt Measures – to be released early 2013 FY 2011 Debt Measures – to be released early 2012 * *for information purposes only (Per info at NASFAA Conference we can expect this June 2012)

38. GE Metrics Let’s share thoughts and strategies