Consumer Information
Compliance, Evaluation
and Communication
Kevin Piotrowski
Massachusetts College of Pharmacy
and Health Sciences
Consumer Information
Information that you have the right to know
as a consumer according to federal law.
Name Variations
• Student Consumer Information
• Public Disclosure
• Student Right to Know
• Federal Disclosure Notices
• Federal Compliance and Disclosures
• University Disclosure Statements
• Federal Compliance
• Statements, Disclosures
Legislation
Higher Education Opportunity Act
HEOA reauthorized the Higher Education Act of 1965 and
established new institution-based disclosure requirements
 Net price calculator
 Codes of conduct
 Textbook cost information
 Private loan disclosures (self-certification form)
Enacted August 14, 2008
Public Law 110-315
Dear Colleague Letter GEN-08-12
Legislation
Negotiated Rulemaking
Non-loan disclosure issues negotiated Spring 2009
 Campus Safety
 Peer-to-peer file sharing
 Educational outcomes information
NPRM published August 21, 2009
Final rule published October 29, 2009
Final rules went into effect July 1, 2010
Recent Legislation
Program Integrity Issues – School and Student disclosures
 Written arrangements
 Disbursement
 Incentive compensation
 Gainful employment
 State authorization as a component of institutional eligibility
 Definition of credit hour to determine program eligibility
 High school diploma definition
 Verification of information included on student aid application
NPRM published June 18, 2010
Final rule published October 29, 2010
Final rules went into effect July 1, 2011 (Verification was July 1,
2012)
Main Focus
Compliance
Evaluation
Communication
Compliance
• Law
• Regulations
• Sub-regulatory guidance
• Institutional policies and procedures
Institutional Disclosure Requirements
There are currently over 40 disclosure requirements
associated with Title IV
There are over 200 data requirements embedded
within the disclosures
Disclosures include:
• Notice of Availability of Institutional and Financial Aid Information
• Contact Information for Assistance in Obtaining Aid Information
• Student Financial Aid Information
• Notice of Federal Student Financial Aid Penalties for Drug Law
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Violations
Privacy of Student Records – FERPA
Consumer Information on College Navigator
Facilities and Services Available to Students with Disabilities
Student Body Diversity
Price of Attendance
Net Price Calculator
Disclosures include:
• Refund Policy, Requirements for Withdrawal and R2T4
• Textbook Information
• Academic Program (Educational Programs, Instructional Facilities,
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and Faculty)
Transfer of Credit Policies and Articulation Agreements
Institutional and Program Accreditation and Approval
Copyright Infringement Policies and Sanctions (including computer
use and peer-to-peer file sharing)
Teacher Preparation Program Report
Drug and Alcohol Abuse Prevention Program
Vaccination Policies
Disclosures include:
• Security Report – October 1st each year
• Missing Person Notification Policy
• Fire Safety Report and Fire Log
• Information for Crime Victims about Disciplinary Hearings
• Retention Rate
• Completion/Graduation and Transfer-Out Rates (including
disaggregated completion/graduation rates)
• Completion/Graduation and Transfer-Out Rates for Students
Receiving Athletically Related Student Aid (including disaggregated
completion/graduation rates)
• Placement in Employment
Disclosures include:
• Job Placement Rates
• Types of Graduate and Professional Education in which the
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Institution’s Graduates Enroll
Intercollegiate Athletic Program Participation Rates and Financial
Support Data
Voter Registration Forms
State Grant Assistance
Student Loan Information Published by the Department of Education
National Student Loan Data System
Entrance Counseling for Student Borrowers
Exit Counseling for Student Borrowers
Disclosures include:
• Private Education Loan Disclosures (Self-Certification Form)
• Code of Conduct for Education Loans
• Preferred Lender Lists
• Preferred Lender Arrangements (PLA) and Annual PLA Report
• Written arrangements
• Disbursement
• Incentive compensation
• Gainful employment
• State authorization as a component of institutional eligibility
• High school diploma definition
• Verification of information included on student aid application
Evaluation
• Development
• Implementation
• Communication
• Annual Assessment
Institutional Responsibility
As is all statutory and regulatory compliance
pertinent to Title IV; what varies is how each
institution divides the responsibilities as part of
administrative capability.
Evaluation
 Identify what information applies to your institution and
what needs to be disclosed
 Recognize and know the individuals/groups/departments
responsible for each disclosure and for annual review
Evaluate the Language
Review and interpret regulatory language to
address the ‘spirit’ of the law
Always make a ‘good faith’ effort to comply with
laws and regulations
Notice of Availability of Institutional
and Financial Aid Information
Each year a school must provide to enrolled students a
notice containing a list of consumer information it
must disseminate, and the procedures for obtaining the
consumer information. Schools must provide this notice
through a one-on-one distribution. – FSA Handbook, Vol.
2, Ch. 6
Notice of Federal Student Aid
Penalties for Drug Law Violations
•Provide to each student upon enrollment, a separate,
clear, and conspicuous written notice about the loss of
eligibility as a result of a conviction under any federal
or state law involving the possession or sale of illegal
drugs while receiving Title IV funds.
•Individual notice, in a timely manner, to students who
lost eligibility and how to regain eligibility.
Student Financial Aid Information
Deferments required to be published for federal
educational loans (information is on DL Disclosure)
Under the terms and conditions that you receive Federal Student Loan assistance,
you may obtain deferral of the repayment of principle and interest for:
Service under the Peace Corps Act
Service under the Domestic Volunteer Service Act of 1973
Comparable service as a volunteer for a tax-exempt organization of demonstrated
effectiveness in the field of community service
Student Loan Information
Student Loan information published by the
Department of Education
Privacy of Student Records - FERPA
•Must be disclosed if receiving any types of funds from
any Department of Education Program (includes
student financial aid)
•One of the few disclosures that must be made directly
to students and made available.
Information on College Navigator
•Data is published by the Department of Education
which is reported by each institution to NCES in
IPEDS
•Required to be made available on the institution’s
website
Facilities and Services Available to
Students with Disabilities
Information made available to prospective and enrolled
students about facilities and services available to
students with disabilities, including students with
intellectual disabilities.
Net Price Calculator
•Required to be published on website by October 29, 2011
•Individual net price estimates must have prominent disclaimer
that estimate is not final or binding
•Student must complete FAFSA to be eligible for and receive
federal student funds
•Must include link to FAFSA
May use Federal or Institutional methodology to
approximate student’s EFC
Textbook Information
•Provisions are statutory and the Secretary has no
regulatory authority. Statutory refers to laws passed by the state of
federal government. Regulatory means a rule issued by some agency that
the government has given authority to regulate an industry.
•Must be disclosed on the institution’s Internet course
schedule: ISBN and retail price for required and
recommended textbooks and supplemental materials
for each course.
Copyright Infringement
•Summary of penalties for violation of federal
copyright laws
•Unauthorized peer to peer file sharing: institution’s
policy and disciplinary actions.
Teacher Preparation Program Report
Each institution must provide a report annually to the
state and to the general public in relation to:
•Goals
•Assurances
•Pass rates and scaled scores
Drug and Alcohol Abuse Prevention
Program
•Annually distribute information in writing to each
student and each employee
•Required to do biennial review of the institution’s
program and upon request, make available to
Department of Education and the public
Security Report – Cleary Act
Additions include:
•Crime statistics for larceny-theft, intimidation,
destruction/damage/vandalism of property as hate
crimes
•Any other crime involving bodily injury
•Missing person notification
•Sex offenses – review data (registered sex offender
link)
Completion/Graduation Rates
Graduation rates must be disaggregated by:
•Gender
•Ethnicity
•Recipients of Federal Pell Grant
•Recipients of a Subsidized Stafford Loan who did not receive a
Pell Grant
•Students who did not receive either a Pell Grant or a subsidized
Stafford Loan
Voter Registration Forms
This requirement does not apply to institutions in
states that do not have a voter registration requirement
or that allow voters to register at the time of voting
Preferred Lender Arrangement (PLA)
and Preferred Lender List
•Covered Institution – Institution that receives any Federal
funding
Does not include private loans:
funded by institution’s own funds
funded by donor-directed contributions
Made under title VII or VIII of Public Service Act
Made under a State-funded financial aid program, if terms and
conditions of the loan include a loan forgiveness option for public
service
Entrance and Exit Counseling for
Student Loan Borrowers
In full compliance with the use of:
•Entrance counseling https://studentloans.gov
•Exit counseling www.nslds.ed.gov
Advanced Funds for Pell Grant Eligible
Students to Obtain Books and Supplies
Students do not have to opt-in to this process but an
institution is required to have an opt-out process
Online Programs
Online student who wants to file a complaint within
the state in which s/he resides:
http://www.mcphs.edu/about-mcphs/importantnotices
Satisfactory Academic Progress
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Pace
GPA
Maximum Timeframe
Types of coursework used in calculation
Appeals
Warning, Probation, Academic Plan?
Added to Program Participation
Agreement (PPA)
•Institutions must develop, publish, administer and
enforce a code of conduct with respect to loans made
under title IV, HEA loan programs in accordance with
601.21
•For any year an institution has a PLA, annually
compile, maintain and make available to students, a list
of private education loans the institution recommends
Added to Program Participation
Agreement (PPA)
• Institutions must, upon request of an enrolled or
admitted student applicant of a private education loan,
provide the applicant with the self-certification form and
the information needed to complete it
• Institutions must have developed and implemented
written plans to effectively combat unauthorized
distribution of copyrighted materials by users of their
network and periodically review alternative legal sources
and provide to students
Communication
Basic Principle
 Who does the information need to be communicated to?
 What information needs to be communicated?
 Where does the information need to be communicated?
 When does the information need to be communicated?
 Why does the information need to be communicated?
 How does the information need to be communicated?
Institutional Responsibility
As is all statutory and regulatory compliance
pertinent to Title IV; what varies is how each
institution divides the responsibilities as part of
administrative capability.
Communication
Information that must be provided to:
 Prospective students and families
 Current students and families
 Prospective and current students
 Prospective student athletes (parents, guidance counselors
and coaches)
 Current and prospective employees
 College bookstore
Communication
Information made available to:
 Prospective students and families
 Current students and families
 Current student athletes
 Prospective and current students
 Public
Communication
 Information that must be
published on website
 Information that must be provided
to current and prospective
borrowers
Communication
Centralized Location
Pros
• One location to
update/review
• Ensures all requirements
are addressed
• Accessible for all students
• Assists with demonstrating
to administration /
generating institutional
responsibility
Cons
• Need to keep information
updated
• Ensure all requirements are
addressed
• Still need to ensure that
certain information is
provided directly to specified
individuals
Continuously Review Information
• FASFA
• EFC – Estimated Financial Contribution
• Financial need is calculated by adding your educational
resources to the difference between the cost of attendance
and your expected family contribution
• Contact your guarantor for repayment
• Financial aid will fund your education
• Updated information (interest rate for Subsidized loans)
More than
2900
Principles of Excellence
As of September 25, 2012, more than 2900 institutions have
agreed to the Executive Order signed by the President in April
2012 establishing Principles of Excellence for Educational
Institutions Serving Service Members, Veterans, Spouses, and
Other Family Members.
316
Federal Shopping Sheet
As of September 25, 2012, 316 institutions have agreed to
adopt the Federal Shopping Sheet.
On the Horizon
ACCEPT Act
• Attempt to crack down on aggressive recruiting process and
expand penalties for misrepresented information
• Disclosure sheet for students and families created by Department
of Education and Consumer Financial Protection Bureau
• Add to PPA about deceptive practices in relation to misleading
consumers
ACCEPT Act
Disclosure would include:
• COA
• Average net price and link to NPC
• Average net price for students receiving Title IV and broken down
by family income
• Percent of students receiving aid
• CDR
• Average percentage of student borrowing federal loans
• Average federal student loan debt for graduates
• Transfer out rate
• Completion/graduation rate
Resources
•FSA Handbook; Volume 2/School Eligibility/ Chapter 6,
Chapter 7 and Chapter 8
http://www.ifap.ed.gov/ifap/byAwardYear.jsp?type=fsahandboo
k&awardyear=2012-2013
•NPEC: Information Required to Be Disclosed Under the Higher
Education Act of 1965
http://nces.ed.gov/pubsearch/pubsinfo.asp?pubid=2010831rev
Resources
• Federal Register
http://ifap.ed.gov/ifap/byYear.jsp?type=fregisters
• The Handbook for Campus Safety and Security Reporting
http://www2.ed.gov/admins/lead/safety/handbook.pdf
• National Center for Educational Statistics
http://nces.ed.gov/
Resources
• The Equity in Athletics Data Analysis Cutting Tool
http://ope.ed.gov/athletics/
• Higher Education Center for Alcohol, Drug Abuse, and
Violence Prevention
http://www.higheredcenter.org/
• Constitution Day
http://constitutioncenter.org/constitution-day/
Assessment Tools
NASFAA Policies and Procedures Tools
 Assessing Regulatory Requirements
Self Evaluation Guides
Compiled Title IV Regulations
http://www.nasfaa.org/products/compiledregs/2012/Compiled_Title_IV_Regulations.aspx
IFAP Quality Assurance Program
http://ifap.ed.gov/qahome/qaassessments/consumerinformation.html
Contact Information
Kevin Piotrowski
Director, Student Financial Services
Massachusetts College of Pharmacy and Health Sciences
179 Longwood Avenue
Boston, MA 02115
617-879-5061
kevin.piotrowski@mcphs.edu