Gainful Employment - Overview

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Gainful Employment - Overview

• Rhonda Mohr, Student Financial Assistance
  Programs
• Myrna Huffman, Management Information Systems

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Agenda

• How did we get here?
• Gainful Employment Defined
• Disclosure Requirements
• New GE Programs
• Reporting Requirements
• Questions

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Federal Title IV Regulatory Process

• Negotiated Rulemaking -November 2009 through
  January 2010
• Notice of Proposed Rulemaking (NPRM) -June 18,
  2010
• Notice of Proposed Rulemaking (NPRM) -July 26,
  2010
• Two sets of Final Rules published on October 29,
  2010, with effective dates of July 1, 2011
• Program Integrity Including Gainful Employment
  Reporting and Disclosures
• Gainful Employment New Programs
• Final Rules on metrics unofficial draft
  published June 2, 2011

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Federal Government Communications

• CCCSFAAA Conference December 2010
• Regional Training Events Winter 2011
• DCL Gen 11-10 issued April 20, 2011
• May 25/26 webinars announced May 5, 2011
• GE Webpage announced May 12, 2011
• DCL Gen 11-10 correction issued May 20, 2011
• GE Reporting Draft User Guide issued May 23, 2011
• Webinar training May 25-26, 2011
• New GE Programs guidance June 1, 2011
• Updated GE Reporting User Guide issued June 3,
  2011

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CCCCO Communications

• August 2, 2010 NPRM Comments
• September 9, 2010 NPRM Comments
• February 7, 2011 FA Regional Representatives
  Meeting
• March 15-16, 2011 All FA Directors Meeting
• April 27, 2011 CFAO list serve memo
• May 16, 2011 FA Regional Representatives
  Meeting
• June 2, 2011 Letter from Linda Michalowski and
  Patrick Perry
• June 7, 2011 CFAO/CSSO list serve memo

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Gainful Employment Statute

• An educational program is Title IV eligible only
  if the program
• Is offered by a public or non-profit institution
  and leads to a degree or transfer or
• Is offered at any institution and leads to
  gainful employment in a recognized occupation.
• Referred to as a Gainful Employment Program or a
  GE Program.

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Recognized Occupation

• One identified by a Standard Occupational
  Classification (SOC) code established by OMB or
• One identified by an Occupational Network
  ONET-SOC code established by the U.S. Department
  of Labor or
• One determined by the Secretary of Education in
  consultation with the Secretary of Labor.

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Gainful Employment Programs

• Public institutions and not-for-profit
  institutions
• All programs, except for
• Programs that lead to a degree
• Programs of at least two years in length that are
  fully transferable to a bachelors degree
  program and
• Preparatory course work necessary for enrollment
  in an eligible program.

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Gainful Employment Programs

• A Gainful Employment Program is identified by
  its
• 6 digit OPEID
• 6 digit CIP Code (Classification of Instructional
  Program)
• 2 digit Credential Level
• New Programs new CIP Code or new 01 credential
  level

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Credential Levels

• 01 Undergraduate certificate
• 02 Associates degree
• 03 Bachelors degree
• 04 Post baccalaureate certificate
• 05 Masters degree
• 06 Doctoral degree
• 07 First-professional degree

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Disclosures
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Gainful Employment Disclosures-General

• For each GE Program, institution must provide
  prospective students with specific information.
• Effective July 1, 2011
• Institution must use disclosure form provided by
  the Department, when available.
• Will not be available by July 1, 2011
• Draft form is available and may be used now
• Institutions must comply with these disclosure
  requirements independently until form is
  available

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Annual Disclosure Requirement

• July 1, 2011 may use 2009-10 data to calculate
  metrics
• Update with 2010-11 data within a reasonable
  amount of time
• Annual updates to be completed within a
  reasonable amount of time after each subsequent
  award year

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Disclosures

• Disclose for each GE Program
• Occupations (by name and SOC code) that program
  prepares students to enter
• Links to occupational profiles on ONET
• Program costs for entire program in normal
  completion time
• Tuition and fees
• On-campus room and board
• Books and supplies
• May include other costs

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Disclosures

• Disclose for each GE Program
• On-time completion rate
• Number of students who completed program during
  most recently completed award year for which
  information is available
• Number of students who completed within normal
  time
• Not the same as 150 used for other purposes
• As published by institution

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Normal Time Frame Defined

• Time necessary to complete all requirements
  according to college catalog
• Typically two years for an AA degree and various
  for certificate programs
• Must be time based
• Transfer students get full normal time
• Program changes do not adjust normal time
• To be counted as completing on time, a student
  who changes programs at the institution and
  begins attending a new program must complete
  within the timeframe beginning from the date the
  student began attending the prior program

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Disclosures

• Disclose for each GE Program
• Median loan debt incurred by students who
  complete the program
• Title IV loan debt Amount borrowed
• Private educational loan debt Amount borrowed
• Institutional finance plans Amount owed

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Disclosures

• Disclose for each GE Program
• Job placement rates for students completing the
  program using the NCES methodology
• NCES methodology not ready at this time
• Until then use formula that the institutional
  accreditor, program accreditor, or the state
  requires
• Not required for CCCs at this time

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Web Disclosures

• Disclosure Information on Programs website home
  page
• Each GE Program must have a dedicated page
• Must be simple and meaningful
• Must contain direct links to any other webpage
  with general, academic or admission information
  about the program
• Must be in an open format that can be retrieved,
  downloaded, indexed, and searched by commonly
  used web search applications

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Print Media Disclosures

• Catalogs and Schedules complete disclosures
  whenever feasible
• If not feasible because of size or structure must
  include URL or live link to website
• Postcards, flyers, brochures, etc
• Example For more information about our
  graduation rates, the median debt of students who
  completed the program, and other important
  information, please visit our website at
  www.ABCcollege.program
• Print materials must be revised within a
  reasonable amount of time

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New GE Programs
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New Programs-Timelines

• If the first day of class will begin on or after
  July 1, 2011 and before October 1, 2011,
  notification must be provided no later than July
  1, 2011.
• If the institution does not provide the required
  notification by July 1, 2011, it must wait for
  Departmental approval before disbursing funds to
  students enrolled in the new GE Program. The
  institution must also inform students that the
  program has not been approved by the Department
  to be eligible for federal student aid.
• For new GE Programs where the first day of class
  will begin on or after October 1, 2011,
  institutions must provide notification to the
  Department at least 90 days prior to the first
  day of class.

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• An institution that provided notice of a new GE
  Program at least 90 days before the first day of
  class (or July 1, 2011 if applicable) of that new
  program may begin offering the additional program
  without receiving Departmental approval unless
  the Department requests, at least 30 days prior
  to the date the program is scheduled to begin,
  additional information or otherwise informs the
  institution to delay the start of the additional
  program.

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New Programs - Notifications

• Must include sufficient narrative information to
  demonstrate that the program meets the
  requirements of an eligible GE Program and to
  support the need for the program
• How need of program was determined
• How college became aware of need of program
• How the program was designed to meet market needs
• Wage analysis and wage data related to the new
  program
• Consultation processes with external entities
• Can cover multiple programs if same or similar
  process used

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Reporting
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Gainful Employment Reporting Requirements

• Institution must annually report information on
  students who were enrolled in a GE program for
  each award year
• Student identifying information
• Program identifying information
• Amounts from private education loans
• Amount owed on institutional financing plans
• Enrollment information
• The GE data User Guide is available and being
  reviewed by CCCCO

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Reporting Requirements

• By October 1, 2011 all colleges must report
• 2006-2007, 2007-2008, 2008-2009, 2009-2010, and
  2010-11 award year information
• If unable to report any of the required
  information, institution must provide an
  explanation. Explanation sent to
  GE-Missing-Data_at_ed.gov.
• Annual data submissions are due on each October
  1st for subsequent years

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Resources

• GE webpage on IFAP
• http//ifap.ed.gov/GainfulEmploymentInfo/index.htm
  l
• For GE Questions
• GE-Questions_at_ed.gov
• CCCCO
• rmohr_at_cccco.edu
• mhuffman_at_cccco.edu

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