ACCET Conference 2015

Federal Updates for Vocational Institutions

PresentersSteve Gunderson, President /CEO

steve.gunderson@apscu.orgAPSCU

Sally Samuels, Director of Compliance

compliance@fameinc.comFAME

2

LOGO

Sec.668.165(b)(1)(ii), pg 28536 Notice and Authorizations

Requires all credit balances for students/parents to be paid prior to requesting funds

5/18/15 NPRM-Possible Impact

Proposed change makes no distinction between HCM1 & HCM 2

Issue-cash flow problem for all schools

3

The proposed Reg would eliminate requiring a program that could be credit hour per the state & accrediting agency to have to be clock hour

1

Also eliminates the requirement that the hours associated with the credits must be completed

2

Impact-better for our schools & students3

Clock to Credit Conversion (669.8 (k)(1)

4

Repeat Course Work

The change would allow a student in an integrated curriculum (such as Nursing) to repeat a passed course, only once, when repeating a failed course in the same term

Positive impact on SAP for all institutions with integrated programs

5

Third Party Servicers

Validate student eligibility before initial disbursement of Title IV funds

Validate student’s eligibility before receiving each subsequent disbursement

• SAP• Attendance

Perform R2T4 refund calculationsImpact-Requires more monitoring by 3rd party servicers

6

Reinstates ATB as alternative

Student must be enrolled in an eligible career pathway program, 225 hours or 6 credit

Transitions the student from an adult ED program to post secondary education and training, to employment

Career Pathways (CPP)

Must be a separate program

7

More guidance to follow

Accrediting nor ED will currently approve program

School is responsible for determining eligibility

CPP (cont)

Impact- ED has stated that the private career sector normally will not qualify unless they partner with an eligible public school

8

LOGO

Clery Act • Only statistics are

published; incomplete policies ( at least 15 pages)

• Missing biennial report• Emergency

notifications/warnings- no procedures in place

VAWA• No on going training for

students & staff• Title IX coordinator not

designated• Policies missing

information

Consumer Information Issues

9

Missing GE information or links on program information page; catalog, student handbooks, flyers

Program length includes break time or allowable absent hour time

Not using required template/ information not updated

Institutional debt as of LDA not included

GE Disclosures

10

Institutions use a different measurement that a payment period (end of mod not midpoint of AY)

1

Drop/ re-enroll handled incorrectly especially for clock hour/credit hour programs

2

Policy worded incorrectly, financial aid warning & probation3

Satisfactory Academic Progress

11

Incorrect scheduled days or clock hours used

Title IV funds received after LDA must be funds that could have been disbursed

Unofficial withdrawals-attendance taking institutions must use a DOD of no more than 14 days after LDA

Incorrect rounding, calculate to 4 decimals, round down to 3 decimals

Return of Title IV Funds

12

Step 5- incorrect; if charging by a longer period than used for the R2T4 calculation; use the larger of Title IV received or prorated institutional cost in L

1

Credit balances must be returned within 14 days of the date the R2T4 calculation is completed

2

Returns are due 45 days from the DOD unless the state or accrediting agency requires a shorter time frame

3

Return of Title IV Funds

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Prepared for ACCET ConferenceOctober 27, 2015

Steve GundersonPresident and CEO

APSCU

Federal Updates for Vocational Institutions

HEA Reauthorization

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Our GOAL in this Congress!

“Defense to Repayment” Negotiated Rulemaking – Begins January 2016

Another Negotiated Rulemaking???

Higher Education community & Congress feel this should be addressed in HEA Reauthorization!

16

Another example of regulatory overreach

The Agenda is Full

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The current Debt Ceiling is set at $18.113 trillion

Debt Ceiling

Current Speaker John Boehner (R-OH) will try to move a debt ceiling bill before he retires from Congress

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The United States Debt Ceiling must be increased by November 5, 2015

CR until December 11th

1

Goal: Omnibus Appropriations bill for rest of FY16

2

Our language: Delay GE and other rules until Reauthorization!

3

Omnibus Funding Bill

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HEA Roadblock

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NCLB: Standing in the

Way!

Before the End of this

Before the End of this Congress!!

Kline wants to finish before he retires!before he retires!

HEA Reauthorization

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Key Issues

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APSCU

GE

Market/Ads

Outcomes

90/10

Simplicity (The same for everyone! One grant, one loan?)

1

Accountability (Appropriate protections applied to all institutions!)

2

Transparency (User Friendly!)3

APSCU Priorities: SAT!

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Common Metrics for all!1

Replace Burdensome Regulations!

2

Risk-based metrics!3

APSCU Priorities: Fairness!

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Simplify Forms!

ATB Restoration!

Year-Round Pell Grants!

APSCU Priorities: Student Aid

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Simplify repayment options!

Constant annual loan limits!

Give Institutions authority to limit loans to education costs!

APSCU Priorities: Student Loans

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HEA Reauthorization

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Senator Alexander at our Workforce Symposium: Simplified Financial Aid

Application Restore Year-round Pell One Grant/ One Loan Remove the Regulations! (all 59!) Accreditation for the Future Discourage Over-borrowing “Skin-in-the-Game”

Accreditation Concepts & Proposals

1

Consumer Information & Transparency

2

“Skin-in-the-Game”3

Senator Alexander Releases 3 White Papers

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29

The Road Ahead! Committees Report

Hill Day: March 15/16, 2016

House & Senate Consideration

Conference Report

“Happy New Year!”