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ACCET Conference 2015 Federal Updates for Vocational Institutions.
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Transcript of ACCET Conference 2015 Federal Updates for Vocational Institutions.
ACCET Conference 2015
Federal Updates for Vocational Institutions
PresentersSteve Gunderson, President /CEO
Sally Samuels, Director of Compliance
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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
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The proposed Reg would eliminate requiring a program that could be credit hour per the state & accrediting agency to have to be clock hour
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Also eliminates the requirement that the hours associated with the credits must be completed
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Impact-better for our schools & students3
Clock to Credit Conversion (669.8 (k)(1)
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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
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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
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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
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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
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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
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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
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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
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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
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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
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Credit balances must be returned within 14 days of the date the R2T4 calculation is completed
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Returns are due 45 days from the DOD unless the state or accrediting agency requires a shorter time frame
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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!
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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
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Goal: Omnibus Appropriations bill for rest of FY16
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Our language: Delay GE and other rules until Reauthorization!
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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?)
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Accountability (Appropriate protections applied to all institutions!)
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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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The Road Ahead! Committees Report
Hill Day: March 15/16, 2016
House & Senate Consideration
Conference Report
“Happy New Year!”