Strategies for Managing the Expanding Universe
of Annual Disclosure and Reporting Requirements
Aaron D. Lacey
Thompson Coburn LLP
INTRODUCTION
Thompson Coburn LLP
• Full-service firm with 375+ attorneys
• Offices in Chicago, Los Angeles, St. Louis, Southern Illinois, and
Washington, D.C.
Higher Education Practice
• Counsel clients concerning federal, state, and accrediting agency laws
and standards, to include federal financial aid programs and
consumer information.
• Represent institutions in litigation, as well as administrative
proceedings before state licensing entities, accrediting agencies, and
federal government.
• Assist clients with the postsecondary mergers and acquisitions,
contract drafting and negotiation, policy creation and
implementation, and compliance systems design.
INTRODUCTION
Aaron D. Lacey
• Partner, Higher Education Practice
• Served four years as Senior Vice President of Regulatory
Affairs and Strategic Development for a multi-campus,
postsecondary education company, with 24 campus
locations and online division.
• Prior to going in-house, served eight years in the
postsecondary education practice of prominent
Washington, D.C. law firm.
PRESENTATION OUTLINE
General CI Strategy
•
CI Resources, CI Systems, Housing CI, Tracking CI,
Disclosing CI
Strategy for Select CI Disclosures
•
Net Price Calculator, Annual Security Reports, Drug
and Alcohol Prevention Information, Student-Rightto-Know, Voter Registration, FERPA, Gainful
Employment Disclosures
GENERAL CONSUMER
INFORMATION STRATEGY
CI RESOURCES
IFAP Consumer Information Page
• CI Disclosures at a Glance (31 Pages; last updated
April 2014)
• 11 Training Activities (last updated 2012-2014)
• Institutional and Financial Assistance Information, Drug and
Alcohol Prevention, Consumer Information for Student Athletes
Student Right-to-Know Act, Campus Security, FERPA,
Safeguarding Customer Information, Fire Safety Reports and
Student Housing, Misrepresentation, Loan Disclosures, Gainful
Employment Disclosures
• http://ifap.ed.gov/qahome/qaassessments/consu
merinformation.html
CI RESOURCES
Higher Education Compliance Alliance
• Created by the National Association of College
and University Attorneys in partnership with
thirty other higher education associations,
provides centralized repository of information
and resources for compliance with federal laws
and regulations.
• Includes Resources by Topic and Compliance
Matrix
• http://www.higheredcompliance.org
CI RESOURCES
Campus Legal Information Clearinghouse
• Collaborative effort between American Council
on Education and The Catholic University of
America's Office of General Counsel.
• Resources by Topic
• http://counsel.cua.edu
CI RESOURCES
REGucation
• Blog offering practical advice and insight to assist
postsecondary community to manage regulatory
environment.
• Focus includes universe of disclosure, reporting,
and training requirements associated with
participation in the federal student aid programs.
• http://thompsoncoburn.com/news-andinformation/regucation.aspx
CI SYSTEMS
• Consumer information is an institutional
responsibility; key data are controlled and
produced by a wide range of individuals within
the organization.
• Create systems designed (1) to direct to your
attention information or correspondence
relating to your CI responsibilities and (2) to
facilitate coordination among campuses and
administrative verticals.
CI SYSTEMS
•
Put into place a Regulatory
Correspondence Policy
– Requires that all substantive correspondence
to/from regulators be copied to those
responsible for CI
•
Create and use CI flow charts
CI SYSTEMS
2013-2014 Gainful Employment Disclosure Template (GEDT) Flow Chart
Following, please find a listing of each data element that will be entered into the Gainful Employment
Disclosure Template in order to generate the required GE Disclosures for each program at each campus, for the
2012-2013 school year. Each data element is annotated to indicate the source of the required data. Unless
otherwise stated, the period under review is July 1, 2012, through June 30, 2013. We are producing GEDT
templates only for Title IV eligible programs.
·
6-Digit OPEID Code. This data can be generated from CV in connection with the primary data pull.
·
8-Digit OPEID Code. This data can be generated from CV in connection with the primary data pull.
·
CIP Code. This data can be generated from CV in connection with the primary data pull. We agreed that
we would use the 6-digit CIP Code associated with the most recent version of each program.
·
Approved Name for Program. This data can be generated from CV in connection with the primary data
pull. We agreed that we would use the program name associated with the most recent version of each
program. Compliance will quality check the name against the approved program name listed on the ACCSC
website, prior to entering the data into the GEDT.
·
Credential Level. This data can be generated from CV in connection with the primary data pull.
·
SOC Codes and Accompanying Occupation Titles. This data can be selected for each program during the
data entry process.
·
Tuition and Fees (for the entire program, assuming normal time completion). This data can be
generated from CV in connection with the primary data pull. We agreed that we would use the tuition and
fees associated with the most recent version of each program. We also agreed that we would pull the tuition
and fees information separately, then create a separate column generating a tuition and fees total for the
entire program (which is what must be entered into the GEDT). Prior to entering the data into the GEDT,
Compliance will quality-check these totals against an independent spreadsheet provided by Finance.
·
Estimated books and supplies total. This data can be generated from CV in connection with the primary
CI SYSTEMS
•
Automate Monitoring of External
Resources
– My IFAP (Electronic Announcements, DCLs)
– NASFAA, NAICU, AACC, APSCU
– Inside Higher Education, Chronicle
•
Create a Compliance Calendar
CI SYSTEMS
SCHOOL
School A
School B
School C
School B
School B
School A
School D
School X
School A
School A
All Schools
School B
School C
School D
DUE TO
DUE TO AGENCY
STATUS
STATUS COMMMENTS
COMPLIANCE
* Indicates that this event has not yet been confirmed for the current year, but occurred in the prior year on this date.
Orange coloring denotes an on-site visit by agency personnel.
Purple coloring denotes an approval expiration.
APRIL
City X
Submit Business License Application to City X upon
4/1/13
receipt of sales tax identification number.
ACCSC
Onsite visit for Paralegal will be scheduled between
4/1/13*
4/1/13 & 7/31/13. (When possible, this entry should
be updated to the date set by ACCSC for the visit.)
City Y
Liquor License Renewals due to the City Y.
4/1/13
2/13-Fingerprinting required.
State of TN Corporate Annual Report due to Secretary of State in
4/1/2013*
Tennessee
TWC
Update PS-005
4/1/2013*
USDE
IPEDS Spring Collection Closes.
4/10/13
NCCPE
Audited Financial statements due to the Nebraska
3/15/13
2/25- Fwd Financial Statements upon
Coordinating Commission for Postsecondary
reciept.
Education (Nebraska State Grant program).
ACCSC
Student Satisfaction Report due to the Accrediting
4/1/12
4/15/13
Commission of Career Schools and Colleges.
IBHE
Annual Renewal Application due to the Illinois Board
4/15/13
2/22- Applications submitted after this
of Higher Education.
date are not guaranteed a response by
June 30, 2013.
WIA
Quarterly WIA State of Tennessee Report due to the
4/16/2013*
Tennessee Department of Labor and Workforce
Development, Division of Workforce Development.
IPEDS
Spring IPEDS (Integrated Postsecondary Education
4/25/2013*
Data System) Data Collection closes (Fall Enrollment,
Graduation Rates & Finance) closes for Coordinator.
OSBCCS
Agent Permit Renewals due to the Ohio State Board of
4/27/2013*
Career Colleges and Schools-Stambaugh & Meleg
ACCSC
Change of Location On-Site Evaluation Visit
4/30/13
1/10 Form and fee due 2/10
City X
City X Liquor License Expires.
4/31/2013*
9/11/11- Renewal application due to
the city 4/1.
MAY
AGENCY
SUMMARY OF FILING, RESPONSE, OR REVIEW
HOUSING CI
• Build a Resource Library
– Compliance Calendar
– Official Correspondence
– Unofficial Correspondence
– Current and Past CI Disclosures
– Flow Charts and Evidence of CI Distribution
– Laws and Regulations
– Agency Guidance
– Agency Tutorials and Training
DISCLOSING CI
• Build a CI Website
– Post everything! Well, almost
everything...
– Holds all CI for all brands, unless
prohibited, or bad for business
– Easier for students and regulators
– Easier for staff
– Facilitates Notice and Distribution
– Mitigates exposure to student litigation
DRAFTING CI
• If possible, makes notices and disclosures
location, time, and brand neutral
• Include revision date
• Consider including annual distribution date if
annual distribution required
• Place on company or school letterhead
• Include statement regarding consistency
between oral statements and written
disclosure
• Take advantage of opportunity to offer
explanatory comments
STRATEGIES FOR SELECT
CONSUMER INFORMATION
DISCLOSURES
FEBRUARY: NET PRICE CALCULATOR
Requirement: Must post net price calculator
on website and include prominent disclaimer:
– Stating estimate is not final, is not binding, and
may change;
– Stating that student must complete FAFSA to
be eligible for FSA funds; and
– Providing link to USED FAFSA website.
FEBRUARY: NET PRICE CALCULATOR
Timing: Must update NPC on an annual basis.
USED releases updated versions of NPC
template in January annually (e.g., template for
2013-14 data will be released in January 2015).
Institutions using USED NPC template should
update their NPC shortly thereafter.
FEBRUARY: NET PRICE CALCULATOR
Strategy: Use USED template; create CI flow
chart; place link to NPC on CI Website.
Citation: 20 U.S.C. 1015a(a); 20 U.S.C.
1015a(h); DCL GEN 08-12, page 33.
Key Resource:
http://nces.ed.gov/ipeds/resource/net_price
_calculator.asp
MARCH: ANNUAL SECURITY REPORTS
Requirement: Each year, must (1) distribute
to all students and employees Annual
Security Report, to include crime statistics for
incidents that occur on campus (2) report
crime statistics to Department, and (3) if
applicable, compile and distribute annual fire
safety report. Prospective students and
prospective employees must receive notice of
report and receive report upon request.
MARCH: ANNUAL SECURITY REPORTS
Timing: Updated ASR and crime statistics
must be published by October 1. Gathering
crime statistics is most challenging piece,
start early to permit time for agencies,
campuses, and security personnel to respond.
MARCH: ANNUAL SECURITY REPORTS
Strategy: Ensure agency letter is detailed; use USED
templates; keep copies of all correspondence; track
correspondence and completion of tasks; post ASR to
CI Website and distribute notice to new students and
employees and annually to all; ensure notice satisfies
specific requirements.
Citation: 34 CFR 668.41(a); 34 CFR 668.41(e); 34 CFR
668.46; 34 CFR Part 668 Subpart D, Appendix A.
Key Resource:
http://www2.ed.gov/admins/lead/safety/campus.html;
http://clerycenter.org.
LAGNIAPPE: VAWA
• In March 2013 Violence Against Women
Reauthorization Act of 2013 (VAWA) amended
Clery Act requiring schools (1) to compile statistics
concerning sexual assault, domestic violence,
dating violence, and stalking; and (2) to adopt
policies, procedures, and programs pertaining to
these crimes in their ASR.
• Under VAWA, 2014 ASR should have included new
policies, as well as new statistics for 2013 (best
effort). New statistics for 2013 and 2014 will be
reported in 2015 ASR.
• New regulations issued October 20, 2014. Review
carefully - they go well beyond VAWA!
APRIL: DRUG & ALCOHOL ABUSE PROGRAM
Requirement: Must institute drug and alcohol abuse program,
consisting of at least two parts:
1. Annually distribute in writing to each student and employee:
• Standards of conduct that clearly prohibit the unlawful possession, use,
or distribution of illicit drugs and alcohol by students and employees on
the school’s property or as part of any of the school’s activities
• Description of applicable legal sanctions under state, local, and federal
law
• Description of health risks
• Description of available counseling, treatment, rehabilitation, or re-entry
programs
• Clear statement that school will impose sanctions for violation of
standards of conduct and a description of sanctions
Students who enroll or employees who are hired after the annual
distribution must receive the information.
APRIL: DRUG & ALCOHOL ABUSE PROGRAM
2. Conduct biennial review of school’s Drug and Alcohol
Abuse program that:
• Determines the effectiveness of the program and
implements needed changes
• Determines the number of drug and alcohol-related
violations and fatalities that occur on the school’s campus
or as part of the school’s activities, and are presorted to
campus officials
• Determines the number and type of sanctions that are
imposed
• Ensures that sanctions are consistently enforced
Biennial review is available to public upon request.
APRIL: DRUG & ALCOHOL ABUSE PROGRAM
Timing: Flexible, can be carried out at any
point during year.
Strategy: Distribute annually to every student
and employee and supply to all new students
and employees upon arrival; have students
and employees sign evidence of receipt; save
annual distribution notices and record results
of biennial review; post info to CI Website;
ensure policies match ASR.
APRIL: DRUG & ALCOHOL ABUSE PROGRAM
Citation: 34 CFR 86
Key Resource:
http://ifap.ed.gov/qahome/qaassessments/c
onsumerinformation.html
LAGNIAPPE: FSA PENALTIES FOR DRUG
VIOLATIONS
Effective August 14, 2008, must provide to every
student upon enrollment a separate, clear, and
conspicuous written notice with information on the
FSA Penalties for drug law violations detailed in 20
U.S.C. 1091(r)(1). Also, to any student who has lost
FA eligibility due to drug law violations, must
provide separate, clear, conspicuous written notice
of the loss and advise of ways to regain eligibility
under 20 U.S.C. 1091(r)(2). See 34 CFR 668.40; DCL
GEN 08-12, pages 101 through 102.
LAGNIAPPE: FSA PENALTIES FOR DRUG
VIOLATIONS
Prepare separate, one-page notice with
signature block, provide with Drug and
Alcohol Abuse Program disclosure; save
annual distribution notice; post info to CI
Website.
MAY 1: EMERGENCY SYSTEM TEST
Requirement: Must develop and test
emergency response and evacuation
procedures on at least an annual basis.
Timing: May 1 - because its May Day!
Strategy: Record evidence that test was
conducted; remember that this is not just a
compliance exercise; consider third-party
providers.
MAY 1: EMERGENCY SYSTEM TEST
Citation: 34 CFR 668.46(g)(6).
Key Resources:
http://www2.ed.gov/admins/lead/safety/ca
mpus.html; http://clerycenter.org.
JUNE: STUDENT-RIGHT-TO-KNOW
Requirement: Must annually make available
completion/graduation rate and, if applicable,
transfer-out rate; must circulate detailed
notice of availability.
Timing: Annual notice can be made at any
time, but must publish most recent SR2K data
by July 1 of each year; data reported annually
in IPEDS Graduation Rate Survey (closed
February 26 in 2014).
JUNE: STUDENT-RIGHT-TO-KNOW
Strategy: Old model disclosure no longer
sufficient; leave time to produce disaggregated
data; make sure disclosure explains data; post
data to CI Website and circulate detailed notice;
keep record of notice distribution.
Citation: 34 CFR 668.41(a) - (d); 34 CFR 668.45;
34 CFR 668.8(b)(1)(ii)
Key Resource:
http://ifap.ed.gov/qahome/qaassessments/cons
umerinformation.html
LAGNIAPPE: RETENTION RATES
• Must make available the retention rate of
certificate or degree seeking, first-time,
undergraduate students; must circulate
detailed notice of availability. 34 CFR
668.41(d)(3).
• Include with SR2K disclosure; Data reported in
IPEDS Fall Enrollments Survey (closed April 23
in 2014); will be available for easy inclusion.
• Make sure disclosure explains data; post data
to CI Website and circulate detailed notice;
keep record of notice distribution.
DEFUNCT SR2K DISCLOSURE
Student Right-to-Know Rates
As of July 1, 2010
______________________________________________________
Student Right-To-Know refers to a federally-mandated public disclosure of
an institution’s Completion/Graduation Rate and Transfer-Out Rate. This
information is provided in compliance with the Higher Education Act of
1965, as amended. This is a "cohort" study; that is, a group of students who
are first-time freshmen who are enrolled full-time and are degree-seeking is
identified in a fall term and their outcomes are measured over a period of
time.
The outcomes measured are Completion/Graduation (the total number of
students in the cohort who earn either a degree, a certificate, or who
successfully completed a two-year-equivalent transfer-preparatory program)
and Transfer-Out (the total number of cohort non-completers who were
identified as having enrolled in another institution).
Graduation (and transfer-out) rates do not include students who left the
school to serve in the armed forces, on official church missions, or in the
foreign service of the federal government. Students who died or were totally
and permanently disabled are also excluded.
The completion/graduation rate at Sample College is 59%.
In 2006, 118 students enrolled as first-time, full-time students at Sample
College. Within 150% of normal time to completion as of August 31, 2009,
70 had graduated from Sample.
SAMPLE MODERN SR2K DISCLOSURE
Student-Right-to-Know and Federal Retention Rate Disclosure
Our School
Effective Date: July 1, 2014
Pursuant to the federal Student Right-to-Know Act, on an annual basis, our school determines and makes available an
overall graduation rate of certificate or degree-seeking, first-time, full-time, undergraduate students. In addition, our
school also provides the Student-Right-to-Know graduation rate disaggregated by various sub-categories, as
determined and defined by the U.S. Department of Education.
The Student Right-to-Know graduation rate is based on a "cohort study,” meaning that a group or “cohort” of students is
identified and then monitored over a period of time. The current rates, set out below, are based on the group of
students who enrolled for the first-time, as full-time students, between September 1, 20XX and August 31, 20XX. The rate
represents the number of those students who earned their degree or certificate within 150% of the normal time required
to complete their program. The rate does not include students who left school to serve in the armed forces, on official
church missions, or in the foreign service of the federal government. Students who died or were totally and permanently
disabled also are excluded.
It’s important to note that the Student Right-to-Know graduation rate is calculated at the school level. In other words,
there is one rate for the entire school, not a rate for each specific program. Certain institutions also are required to
calculate and distribute graduation or completion rates for students receiving athletically related student aid, as well as
transfer-out rates. These requirements, however, are not applicable to our school. The most recent, disaggregated
Student-Right-to-Know graduation rate for our school is set out in the following chart:
Student Category
Number of Students
Number Graduating
Within 150%
Graduation
Rate
-
-
-
Men
Women
Nonresident Alien
Hispanic/Latino
American Indian or Alaska Native
Asian
Black or African American
Native Hawaiian or Other Pacific Islander
White
Two or More Races
Race and Ethnicity Unknown
Received Pell Grant
Received Subsidized Stafford Loan but no Pell Grant
Received No Subsidized Stafford Loan or Pell Grant
OVERALL
Our school also makes available each year a federal retention rate, which is the percentage of first-time, full-time
students from the previous fall who are still enrolled, or successfully completed their program, the following year. Like the
Student-Right-to-Know graduation rate, this retention rate is based on a cohort study and calculated at the school level
(i.e., there is one rate for the entire school, not a rate for each specific program). The most recent federal retention rate
for our school is set out in the following chart:
Women
Nonresident Alien
Hispanic/Latino
American Indian or Alaska Native
Asian
Black or African American
Native Hawaiian or Other Pacific Islander
White
Two or More Races
Race and Ethnicity Unknown
SAMPLE MODERN SR2K DISCLOSURE
-
-
-
Received Pell Grant
Received Subsidized Stafford Loan but no Pell Grant
Received No Subsidized Stafford Loan or Pell Grant
OVERALL
Our school also makes available each year a federal retention rate, which is the percentage of first-time, full-time
students from the previous fall who are still enrolled, or successfully completed their program, the following year. Like the
Student-Right-to-Know graduation rate, this retention rate is based on a cohort study and calculated at the school level
(i.e., there is one rate for the entire school, not a rate for each specific program). The most recent federal retention rate
for our school is set out in the following chart:
Number of Students in Fall 2010
Number Still Enrolled or Completed as of Fall 2011
Retention Rate
Current and prospective students may request a paper copy of this disclosure from the Campus Director, or by emailing
consumerinfo@ourschool.edu. This disclosure also is available on our school’s website at www.ourschool.edu/right2know.
The Student-Right-to-Know graduation rate for our school is based on data reported by the school in connection with
the National Center for Educational Statistics (NCES) Integrated Postsecondary Education Data System (IPEDS) 20XX20XX Graduation Rate Survey. The federal retention rate is based on data reported by the school in connection with the
NCES, IPEDS 20XX-20XX Enrollment Survey.
“-“ Indicates that there were no students in this category, or that the student population for this category is too small to be disclosed with
confidence or confidentiality (i.e., 10 or fewer students).
Sample Student-Right-to-Know and Federal Retention Rate Disclosure (Effective: Month XX, 2014)
Our School
Page 1 of 1
AUGUST: VOTER REGISTRATION INFORMATION
Requirement: Make good faith effort to distribute
voter registration form (for federal elections and state
elections for governor or other State chief executive)
to every student. Will be considered in compliance if
electronically distribute voter registration form (can
provide link where form can be downloaded).
Electronic message must be devoted exclusively to
voter registration.
Timing: Quarterly distribution best. But in the least,
must be sufficiently in advance of November
elections.
AUGUST: VOTER REGISTRATION INFORMATION
Strategy: Provide quarterly notice to all students (and
employees) via email with link to registration form on
state site; discuss importance of voting, set out state
and federal election calendar; keep record of
distribution notice; post information to CI Website.
Citation: 20 USC 1094(a)(23) and DCL GEN 08-12.
Key Resource: U.S. Election Assistance Commission at
http://www.eac.gov/voter_resources/register_to_vot
e.aspx
NOVEMBER: ANNUAL FERPA NOTICE
Requirement: Must annually provide notice to all
students about:
•
•
•
Right to review educational records, request amendment
of records, consent to disclosures or personally
identifiable information, and file complaints with USED;
Procedures for reviewing educational records and
requesting amendment of records; and
Policy regarding disclosures to school officials with
legitimate educational interest in educational records.
NOVEMBER: ANNUAL FERPA NOTICE
Timing: Flexible, can be carried out at any point
during year.
Strategy: Make sure all required elements
included; use model forms; distribute via email
and post to CI Website; keep record of notice
distribution.
Citation: 34 CFR 668.41(c) and 34 CFR Part 99.
Key Resource: Family Policy Compliance Office at
http://www2.ed.gov/policy/gen/guid/fpco/index
.html
LAGNIAPPE: FERPA DIRECTORY INFORMATION
• To disclose directory information without
prior consent, must provide students notice
of directory information that include ( 1)
types of information school has designated as
directory information; and (2) student’s right
to refuse use of directory information; and (3)
time period student has for notifying school
in writing. 34 CFR 99.37.
• In addition to including with annual FERPA
notice, post directory information notice on
CI Website and put it in your application for
admission.
DECEMBER: UPDATE GE DISCLOSURE TEMPLATES
Requirement: For each GE program, must disclose in promotional
materials mentioning program and on school website:
• Department of Labor SOC Code(s) related to program CIP Code
with links to O*NET occupational profiles;
• On-time graduation rate;
• Tuition and fees (normal time);
• Typical costs for books and supplies, and room and board, if
applicable;
• Job placement rate (fed formula never developed, so only if you
calculate state/accreditor rates); and
• Median loan debt incurred by students who completed the
program (separately by Title IV loans, private loans, and
institutional debt).
DECEMBER: UPDATE GE DISCLOSURE TEMPLATES
Timing: Effective January 31, 2014,
institutions must use Gainful Employment
Disclosure Template (GEDT) to create
webpage containing the required disclosure
information for each GE program. Institutions
expected to update GE disclosure information
at least annually.
DECEMBER: UPDATE GE DISCLOSURE TEMPLATES
Strategy: Update cost and fee data in real-time
to mitigate exposure to misrepresentation
claims; for same reason, consider updating ontime graduation rates and median loan info each
year after June 30, and outcomes after annual
report go in; otherwise update everything in
December; create CI flow chart.
Citation: 34 CFR 668.6(b)
Key Resource: IFAP GE Page:
http://ifap.ed.gov/GainfulEmploymentInfo/
LAGNIAPPE: PROPOSED GE DISCLOSURE
CHANGES
• Proposed changes would expand the amount
of information that “may” be required to be
disclosed;
• With limited exception, disclosures would be
made only for students who received federal
financial aid funds;
• Disclosures could be required to be
disaggregated by whether student completed
the program;
• USED could change the required disclosures
from year to year;
LAGNIAPPE: PROPOSED GE DISCLOSURE
CHANGES
• Still would require update at least
annually;
• Continued option to disclose separate
templates for each location or form of GE
program if leads to clearer information for
students (GE Electronic Announcement #
25 (September 28, 2011)); and
• Would require hardcopy GEDT disclosure
to any prospective student.
LAGNIAPPE: PROPOSED GE DISCLOSURE
CHANGES
• Would include calculation of additional
rates (most would be calculated by USED
using reported information):
– Four completion rates per GE program; two based on
full-time enrollment on first day, and two based on
part-time enrollment on first day.
– Two withdrawal rates per GE program; the percentage
who withdrew within normal time, and the percentage
who withdrew within 150 percent.
– A borrower based repayment rate for borrowers with
FFEL or Direct Loans for enrollment in a GE program.
LAGNIAPPE: PROPOSED GE DISCLOSURE
CHANGES
• First set of expanded disclosures (for
results of AY 2014-15 and including
disclosures based on information that
USED must provide) “likely” required by
January 2016.
CONTACT INFORMATION
Aaron D. Lacey
Partner, Higher Education Education Practice
Thompson Coburn LLP
alacey@thompsoncoburn.com
314-552-6405
CONDITIONS OF USE/DISCLAIMER
• The purpose of this presentation is to provide news
and information on legal issues and all content
provided is for informational purposes only and
should not be considered legal advice.
• The transmission of information from this
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relationship with the viewer. Participants should
not act on the information contained in any of the
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• If you desire legal advice for a particular situation,
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