Foreign Schools Program Participation Potpourri

1. Session 42 Foreign Schools Program Participation Potpourri Marcia Fediw, Margery Harvey, and Michael Stein| Dec. 2015 U.S. Department of Education 2015 FSA Training Conference for Financial Aid Professionals

2. Agenda • Satisfactory Academic Progress Policy (SAP) • Return to Title IV Policy (R2T4) • Consumer Disclosures • Resources • FSA Coach Training Suite • Foreign School Assessments • Foreign Schools Handbook

3. Satisfactory Academic Progress • Satisfactory Academic Progress (SAP) is a Student Eligibility Requirement • Institution Must Have a Reasonable SAP Policy • Differs from Institutional Policy • Qualitative and Quantitative Component • Must be Monitored Annually or at the End of Every Payment Period • Must Notify Student of Results of SAP Evaluation that Impacts Student’s Aid Eligibility

4. Satisfactory Academic Progress • Qualitative Component of SAP • Usually the Grade Point Average (GPA) • Other Comparable Measure Against a Norm • SAP Policy Must State the Minimum Qualitative Benchmark • Quantitative Component of SAP • Defines Maximum Timeframe for Program Completion • For Undergraduate and Graduate Medical Programs–150% of Published Length of Program • For Graduate Programs–Defined by Institution and Based on Length of Program

5. Satisfactory Academic Progress • Quantitative Component Continued • Describes Pace Students Must Progress Through Program • Calculated by Dividing Cumulative Hours Attempted by Cumulative Hours Completed, Excluding Remedial Courses • Policy Must State How Qualitative and Quantitative Impacted by: • Incompletes, Withdrawals, Repetitions, Transfer Credits • Credits Accepted from Another Institution Towards Students Program Must Count as Attempted and Completed Hours

6. Satisfactory Academic Progress • Financial Aid Warning • Optional • Must Describe This Status in Your Policy • Must Use Term “Financial Aid Warning” • Warning Allowed if SAP Measured Each Payment Period • Aid Can be Disbursed for One Payment Period • Student Does Not Need to Appeal

7. Satisfactory Academic Progress • Probation • Optional • Policy Must State Conditions Under Which a Student May Appeal • Student’s Appeal Must State: • Why He/She Failed to Make SAP • What Has Changed to Allow Student to Meet SAP in the Future • Institution Must Determine if Student Will be Able to Make SAP by End of Next Payment Period or; • Will be Placed on Academic Plan That Ensures Student Meets SAP at Certain Point in Time

8. Satisfactory Academic Progress • Academic Plan May Be Simple or Detailed • Student Must Successfully Appeal • First Term Under Plan is Considered Probation • Plan May be for Multiple Terms • If No Appeal Process, Policy Must State How Student May Re-establish Title IV Eligibility • Cannot Have Two Consecutive Terms of Warning or Probation

9. Return to Title IV • R2T4 Calculation Required if a Student Does Not Complete a Payment Period • Different From Institutional Refund Policy • R2T4 Calculation Determines How Much Direct Loan Funds Student Has Earned • Student Earns Funds Through Attendance • Unearned Funds May Need to Be Returned • R2T4 Worksheet: ifap.ed.gov

10. Return to Title IV • R2T4 Policy Should Address: • How Your Institution Establishes the Last Day of Attendance • Institutions Required to Take Attendance • Institutions Not Required to Take Attendance • Formal Leave of Absence Policy, if Your School Has One • For Purposes of R2T4 must meet Department’s Definition at 668.22(d) • Include Process for Post-Withdrawal Disbursements • Include Process for Calculation of Funds Earned by Student • Include School and Students’ Responsibility for Returning Unearned Aid

11. Return to Title IV • R2T4 Policy Should Address: • Include Order for Returning Direct Loan Funds • Include Timeframe for the Return of Funds • Include the Required Return of Direct Loan Funds as Required by Consumer Information • Indicate How Return Fund Requirements are Provided to Students in Writing • Include Examples of R2T4 Calculations • Include Procedures for School to Pay Portion of Student’s R2T4 to Secretary

12. Return to Title IV • R2T4 Policy Should Address: • Include Procedures for Providing Written Notice to the Borrower if School Pays R2T4 to the Secretary on Behalf of the Borrower

13. Consumer Disclosures • Participating foreign schools must provide information about their institution, including information about financial aid, its campus, facilities, student athletes, and gainful employment programs, as well as information to prevent drug and alcohol abuse • A notice, containing a list of consumer information that it must make available and procedures for obtaining this consumer information, must be provided annually to all enrolled students

14. Consumer Disclosures • The notice must be distributed individually, and may be delivered through a mailing or publication, e.g., postal service, campus mail, or e-mail • Disclosures may be made through websites, however paper copies must be provided upon request

15. Consumer Disclosures • Required disclosures are identified in regulations & program participation agreement • 34 C.F.R. § 668.41(a)-(g))

16. Consumer Disclosures • Examples include: • Institutional information (including costs) • Financial assistance available to students • Institution-wide completion or graduation rates, retention rates, & transfer-out rate as applicable • Placement of, and types of employment of graduates of the institution’s programs, including data sources, and placement rates calculated • Type of graduate and professional education programs that graduates of the institution’s baccalaureate degree programs enroll

17. Consumer Disclosures • Certain consumer disclosure requirements apply only to foreign graduate medical schools • The Department publishes the USMLE pass rates, completion rates, and median and mean student debt level information for participating foreign graduate medical schools at studentaid.ed.gov/prepare-for-college/ choosing-schools/types/international

18. FSA COACH • FSA Coach Training Suite – Interactive for New and Experienced Financial Aid Administrators • Basic Training for Foreign Schools - 23 lessons, 30 hours of instruction on Federal Student Aid Program Administration • DCL ID:ANN-15-14 • fsatraining.info • Intermediate Training – Coming Soon

19. FSA Foreign School Assessments • Students - Student Eligibility • Schools - Institutional Eligibility, Default Prevention & Management, Consumer Information, Automation • Managing Funds – Fiscal Management, Return of Title IV Funds • Available on Foreign School Information Page on IFAP • ifap.ed.gov/ForeignSchoolInfo/ForeignSchoolInfo.html

20. Foreign Schools Handbook • Published March 2015 • ifap.ed.gov/ForeignSchoolInfo/ForeignSchoolInfo.html • Contains Information Applicable Only to Foreign Schools • Incorporates Recent Guidance, Including • Ineligible Courses at Foreign Institutions (Dear Colleague Letter GEN-14-20) • Title IV Eligibility of Programs Containing Internships and Externships

21. Foreign Schools Handbook • Four Chapters: • Chapter 1 General Eligibility and Participation Requirements • Chapter 2 Audits and Financial Standards • Chapter 3 Foreign Graduate Medical Schools • Chapter 4 Foreign Veterinary and Foreign Nursing Schools

22. School Eligibility Service Group Ron Bennet – Director, School Eligibility Service Group, Washington, DC (202) 377-3181 School Eligibility Service Group General Number: (202) 377-3173 or e-mail: CaseTeams@ed.gov Or call the appropriate School Participation Division manager below for information and guidance on audit resolution, financial analysis, program reviews, school and program eligibility/recertification, and school closure information New York/Boston School Participation Division Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont, New Jersey, New York, Puerto Rico, Virgin Islands Betty Coughlin, Director (646) 428-3737 Tracy Nave – Boston (617) 289-0145 Patrice Fleming – Washington, DC (202) 377-4209 Chris Curry – New York (646 428-3738 Philadelphia School Participation Division District of Columbia, Delaware, Maryland, Pennsylvania, Virginia, West Virginia Nancy Gifford, Director (215) 656-6436 John Loreng – Philadelphia (215) 656-6437 Sherrie Bell – Washington, DC (202) 377-3349 Clery/Campus Security Jim Moore – Washington, DC (202) 377-4089 Multi-Regional and Foreign Schools Participation Division Michael Frola, Director – Washington, DC (202) 377-3364 Barbara Hemelt – Washington, DC (202) 377-4201 Joseph Smith – Washington, DC (202) 377-4321 Mark Busskohl – Washington, DC (202) 377-4572 Atlanta School Participation Division Alabama, Florida, Georgia, Mississippi, North Carolina, South Carolina Christopher Miller, Director (404) 974-9297 David Smittick – Atlanta (404) 974-9301 Vanessa Dillard – Atlanta (404) 974-9418 Chicago/Denver School Participation Division Illinois, Minnesota, Ohio, Wisconsin, Indiana, Colorado, Michigan, Montana, North Dakota, South Dakota, Utah, Wyoming Douglas Parrott, Director (312) 730-1532 Earl Flurkey – Chicago (312) 730-1521 Brenda Yette – Chicago (312) 730-1522 Sarah Adams – (312) 730-1514 San Francisco/Seattle School Participation Division American Samoa, Arizona, California, Guam, Hawaii, Nevada, Palau, Marshall Islands, North Marianas, State of Micronesia, Alaska, Idaho, Oregon, Washington Martina Fernandez-Rosario, Director (415) 486-5606 Gayle Palumbo – San Francisco (415) 486-5614 or Seattle (206) 615-3699 Dyon Toney – Washington, DC (202) 377-3639 Erik Fosker – San Francisco (415) 486-5606

23. QUESTIONS?