Learn about the latest developments in the new Gainful Employment and Financial Value Transparency rules and what it means for schools in 2024.Continue reading
Discover the advantages and disadvantages of financial aid software compared with an integrated financial aid module.Continue reading
Financial aid software, pre-built reports and the National Student Clearinghouse are resources that help small financial aid teams stay Title IV compliant.Continue reading
By upgrading to a new, integrated student information system, schools can organize data, improve efficiency and promote better communication.Continue reading
To improve career and trade school attendance, use a student information system with clock and credit-based attendance software.Continue reading
Managing career and trade school data can be complex. A student information system (SIS) simplifies student data management and federal reporting requirements.Continue reading
When boiled down, education is primarily about experience and outcome. Prospective students and families weighing their college and/or career preparation options often consider several key factors‘among them, affordability and financial aid, program completion time, courses of study, location and potential co-curricular or professional opportunities. And while students are often trying to piece together the educational experience that will best fit them, they are also seeking to understand the likely outcome of that education in the long run‘the anticipated return on a hefty investment.
When Title IV financial aid funds are at play in that very investment, the federal government also wants to see that taxpayer dollars are allocated to schools and programs that set students up for success, which is where gainful employment (GE) disclosure and reporting come in. It’s important for institutions to understand what gainful employment is, what regulations surround it, why it matters and how to accurately disclose and report required information.
An Introduction to Gainful Employment
After an extensive rulemaking process, new gainful employment regulations were published on October 31, 2014 and went into effect on July 1, 2015. The new regulations have more rigorous standards for accountability and transparency to further protect students from poor and sometimes fraudulent career preparation programs that have historically left them saddled with debt they cannot repay. To ensure that students are being put on a path to success, the Department of Education requires certain schools to demonstrate that they adequately prepare students for a�?gainful employment in a recognized occupationa�? in order to be eligible to receive (and continue receiving) Title IV student financial aid funds.
Gainful employment regulations apply to roughly 3,700 institutions around the country, including non-degree educational programs at public and private nonprofit institutions and virtually all educational programs at for-profit and proprietary institutions. These often include post-secondary certificate and diploma programs, training programs and technical and vocational education. Programs leading to an associate’s, bachelor’s, graduate or professional degree at public and private nonprofit institutions of higher education are not considered gainful employment programs in this sense and do not need to comply with the gainful employment standards.
What is a�?Gainful Employment in a Recognized Occupationa�??
Three debt measures are used to determine whether or not institutions are preparing their students for gainful employment in a recognized occupation: repayment rate, debt-to-earnings ratios based on annual income, and debt-to-earnings ratios based on discretionary income. These measures are intended to show that students are prepared for adequate job placement in recognized occupations that pay reasonable living wages, and that students are not so buried in educational debt that their loan payments absorb the bulk of their income.
- Repayment Rate
The rate of loan repayment must be at least 35 percent for gainful employment programs to remain eligible for Title IV funds. Repayment rate = original outstanding principal balance of loans paid in full plus the original outstanding principal balance of payments-made loans, divided by the original outstanding principal balance. The value of the fraction is multiplied by 100 to get the repayment rate.
For every gainful employment program, the Department of Education will calculate debt-to-earnings ratios based on information supplied by the institution for a specified cohort period (two or four years) as well as from the Social Security Administration.
- Annual Earning Rate = median annual loan payment divided by the greater of the mean or median annual earnings of graduates. The a�?passa�? threshold for gainful employment standards is that graduates’ annual loan payments are less than or equal to 8 percent of their annual earnings. The a�?faila�? threshold is that the annual loan payment is greater than 12 percent of annual earnings.
- Discretionary Income Rate = median annual loan payment divided by the discretionary income of graduates (i.e. the higher of the mean or median annual earnings, less 1.5 times the Health and Human Services Poverty Guidelines). The a�?passa�? threshold for gainful employment regulations is that graduates’ annual loan payments are less than or equal to 20 percent of their discretionary income. The a�?faila�? threshold is that the annual loan payment is greater than 30 percent of discretionary income.
Programs are considered in the a�?zonea�? if their calculations fall between the a�?passa�? and a�?faila�? thresholds. a�?Faila�? marks for two out of three consecutive years or a combination of a�?faila�? and a�?zonea�? marks for four consecutive years will render a gainful employment program ineligible for Title IV funding.
Understanding Disclosure and Reporting
Schools must disclose information about their gainful employment programs to the public using the Gainful Employment Disclosure Template to help students make informed decisions. In addition, they must submit an official, comprehensive report about students enrolled in these programs to the Department of Education’s central database for student aid, the National Student Loan Data System (NSLDS).
According to the Department of Education, disclosure of the following data on the institution’s website and in promotional materials is required for each gainful employment program:
- Occupations associated with program (by name and SOC code)
- Typical program completion time
- On-time completion rate
- Program costs
- Placement rate
- Median loan debt
Also according to the Department of Education, reporting of the following data to the NSLDS is required for each student who received Title IV funds for a gainful employment program that they either completed or withdrew from:
- Tuition and fees assessment before aid or credits are applied
- Cost of books, supplies and equipment
- Institutional debt owed apart from Title IV debt (e.g. obligations such as library or laboratory fees)
- Private loans
The Gainful Employment Reporting Process
Institutions must report on an award year (July 1 through June 30). A student enrolled for more than one award year must be reported in each award year, and a student enrolled in more than one program must be reported for each program. This is accomplished through batch reporting (fixed width or comma separated value formats) through an institution’s Student Aid Internet Gateway (SAIG) Mailbox or online reporting through the NSLDS Professional Access website (NSLDSFAP).
The fully integrated financial aid module in Campus Café’s Student Information System (SIS) streamlines what can be a confusing and cumbersome government reporting process. Our integrated SIS collects and compiles data for NSDLS reporting as well as other required reports for state and government agencies. In addition, it services student communication, billing and packaging related to financial aid and ensures accurate tracking of student placements and hiring metrics. Campus Café complies with federal reporting and keeps tabs on changes in regulations to ensure that the specific needs of your career or vocational school are met.
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The process of accreditation is complex for institutions of higher education–and has been changing significantly over the past few years. To get a handle on the process as it is now, you should understand:
- The effects for-profit institutions are having on accreditation
- How the reputational balance between regional and national accreditors is changing
- The implications of the recent ACICS collapse, and what it says about the difficulties of reputation management
- How Title IV funds will be affected by growing student debt
- The importance of tracking and managing student funds resulting from accreditation through a Student Information System (SIS)
The right accreditation can help you validate the value that you offer your students, particularly if you are a less-known institution without an established brand.
Who performs accreditation?
An accreditor is essentially a membership organization made up of the institutions it accredits, and standards are developed by collaboration between the accreditor and the member institutions. It’s more like being a member of a club that cares strongly about its reputation than it is like being supervised by some external agency.
Accrediting organizations must complete a review process overseen by the Department of Education (USDE) and the National Advisory Committee on Institutional Quality and Integrity (NACIQI). The Council for Higher Education Accreditation (CHEA) also reviews accreditors, and its opinion is significant, but the USDE’s approval is key.
Accrediting organizations are either institutional, examining and certifying entire institutions, or programmatic/specialized, certifying particular professional programs.
There are two main types of institutional accrediting organizations
- Regional, accrediting largely academic, non-profit institutions
- National, accrediting largely for-profit institutions, with career-oriented programs, though there are also faith-related accreditors for religious institutions.
National accreditors will accredit non-degree institutions, while regionals will not.
There are six regional accreditors, each with a long history. There also six national accreditors, one of which, ACICS has recently run into instructive trouble.
Because of the difference in emphasis, as well as concerns about less-strict standards for national accreditation, students often find trouble transferring credits from a nationally accredited school to a regionally accredited school.
Increasingly, however, more for-profits are gaining regional accreditation. And as they become members of these organizations, their influence over accreditation expectations and process will grow.
These certify particular professional programs. There are nearly 50 of these, with multiple accreditors for some programs. Business education, for example, has three possible accrediting organizations.
Programmatic accreditation is essential for programs such as engineering, nursing, or architecture that require professional licensing in order to practice. Some smaller programs in disciplines such as communications may choose not to seek it.
The accreditation process
To get accredited, an institution must perform an extensive self-evaluation, following the procedures of the accrediting organization. There will then be on-site surveys from the accreditor. Once accreditation is achieved, regular updates will be required, though of less intensity than the original application. All of these functions are supported by a Student Information System (SIS).
Accreditor reputation and the fate of ACICS
In September, the USDE stripped the Accrediting Council for Independent Colleges and Schools (ACICS) of its authority to accredit schools. ACICS was the largest of the national accreditorsand was the accreditor for Corinthian Colleges and ITT Technical Institute, both troubled and now-closed for-profit institutions.
Nearly 250 institutions enrolling over half a million students now face the challenge of finding new accreditation, imperiling access to billions of federal educational dollars.
ACICS appealed this decision on October 21, 2016. No matter what the outcome, this is a sobering event for schools that depend on accreditation to maintain their viability, both in terms of reputation and in access to federal educational funds.
Schools can’t just take for granted that their accreditor is giving the best value. During the financial crisis of 2007/2008, credit rating agencies Standard & Poor’s, Fitch, and Moody’s revealed that they had not been objectively measuring the value of what they were recommending. Investors relying on their ratings suffered financial consequences.
Specific criteria for choosing an accreditor will be covered in a later post in this series.
The benefits of accreditation
In a world of many educational institutions competing for students and their associated federal educational funds, accreditation provides useful institutional discipline, participation in a community of like-minded institutions, and ability to contribute to shaping the future standards for educational excellence.
Accreditation also allows newer and smaller educational institutions who do not have the advantage of strong brand visibility, or who are striving to extend their reach, to gain visibility and validation.
And accreditation ensures the steady and predictable flow of federal education dollars, without which most higher education institutions would be unable to function.
The issue of financial aid money
Accreditation not only certifies the quality and reputation of an educational institution’it also controls the distribution of federal financial aid funds as part of Title IV.
It is impossible to recognize the impact of accreditation without understanding how much nearly every institution depends on these funds, including Pell Grants and other academic grants, Federal Family Education and other loan programs, and Federal Work-Study money. Without this funding, many institutions would need to close their doors.
The average full-time undergraduate student in the U.S. received over $2,000 in Pell Grants alone in 2013. The average student now leaves college nearly $23,000 in student-loan debt.
The impact of accreditation is significant both for each institutionand for each student. Institutions need to pay attention to the funding that comes with their students, both for their own bottom line, and to protect the interests of their students. Both of you have a lot of skin in this game.
How accreditation became as important as it is
Why do accreditors also control the flow of federal funds to post-secondary educational institutions? It’s not necessarily an automatic connection.
Before the 1950s, there were a variety of regional, voluntary membership associations that developed standards for anyone claiming to provide higher education. They cared about their reputationsand the reputations of their fellow institutions. The money involved was private money, or from occasional charitable endowments, and did not need to pay attention to accreditation if they did not choose to.
Then the WWII and Korean War GI Bills brought federal dollars to schools, followed, over the next few decades, by the various Title IV funds previously discussed. There was an increasing amount of money involved, which changed the stakes of accreditation.
Instead of creating some kind of Federal Accreditation Agency, the federal government decided instead to use the existing accreditation system to determine eligibility for these federal educational dollars. The government understood that the flexibility of the private system made it worth keeping. That is still the system in place, though government oversight has grown over time, as the amount of money at stake has increased.
Help when facing the accreditation process
A robust Student Information System (SIS) should support your accreditation efforts. Much of the information you supply to the accreditor will come straight out of your SIS. The reporting requirements are significant. Trying to do it without a good SIS can adversely affect your chances of getting accepted by a reputable accreditor. It’s well worth getting an SIS in place before starting an accreditation process.
If you fail to accurately track the Title IV funds that come along with accreditation, you can find you can find yourself subject to costly fines and lawsuits. An SIS helps ensure that the funds are applied to the appropriate tuition, mandatory fees, and housing charges.
Some of the functions you should look at when considering an SIS:
- Data collection : does the SIS work with your existing business processes to collect and maintain data?
- Reporting: can the SIS generate the reports required by accreditors and government agencies?
- Operation management: will the SIS support you in monitoring student achievement, attendance, and satisfaction?
A good SIS not only supports your business operations, but helps keep your students informed, happy, and high performing. It also makes it possible to keep students up to date on the status of their grants, loans, and other sources of support, as well as recommending possible funding sources.
One step at a time
Accreditation is a long and significant process. We’ll be covering the essential steps here over the next few months, so be sure to check back regularly.
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Sometimes it can be hard to quantify the value of a Student Information System (SIS). You know you need one because it provides necessary user interfaces and critical data for strategic decision making, but does it really translate to the bottom line, and save the institution valuable costs and resources?
The answer is a definitive yes. Intuitively, it’s impossible to imagine running an organization effectively without one. The most obvious tangible benefit is the number of man-hours saved from an integrated student information system rather than tracking information in spreadsheets (or multiple databases that don’t talk to each other). But more specifically, I’ve outlined 5 instances where an integrated student softwarewill directly save your institution money or bring more revenue in the door.
#1. Mastery of Government Funding & Federal Reporting
We don’t have to tell you, but a recent report by the GAO (1) found that the government requirements for student financial aid were the a�?most burdensomea�? on colleges and universities, costing hundreds of man-hours and untold dollars to compile. The National Association of Student Financial Aid Administrators echoed this, saying that handling governance took so much time it left less opportunity for counselors to meet in person with students.
Given the immense sums involved it doesn’t appear these regulations are going anywhere, so it’s best for institutions of higher education to develop ways to minimize the burden. Paramount to this is a good student information system.
An SIS will help collect and compile the data for all the required reports for state and government agencies. These include IPEDS, Title IV/NSDLS, Graduate-to-Employment reports, as well as accreditation with some of the requirements outlined here.
The data collected by the Independent Post-secondary Education Data System (IPEDS) covers seven areas: institutional characteristics, institutional prices, enrollment, student financial aid, degrees and certificates conferred, student persistence and success, institutional human and fiscal resources.
Some of the data that a student information system will have available in real-time for these reports is
- enrollment by state, age, ethnicity
- graduate completions by field of study
- retention and graduation rates
- faculty and staff demographic data
- revenues and expenditures
The process for administering student financial aid is defined under Title IV of the Higher Education Act. The regulations change annually and a school is responsible for understanding each student’s eligibility for the various grants and loans including, Federal Pell Grant, Federal Supplemental Education Opportunity Grant (SEOG), Federal Teacher Education Assistance for College & Higher Education Grant (TEACH), Federal Direct Stafford Loans ‘ Subsidized, Unsubsidized, Grad PLUS and Parent PLUS etc.
Federal regulations require all schools to apply Title IV financial aid funds to tuition, mandatory fees, housing charges and book deferments.
If these federal funds aren’t tracked and applied to student charges correctly it could be costly in terms of fines and lawsuits. A fully integratedschool managementsystem will either handle all the Title IV reporting or tightly integrate with Title IV specialty software.
The other area that a student information system becomes vital is for the calculations required for meeting Title IV eligibility. In recent years new regulations have been instituted for graduate to employment rates and now institutions must certify that each of their gainful employment programs meets the accreditation requirements.
#2. Increase Student Retention
In a prior post on student retention I describe in detail all the ways a student information system can help keep more students enrolled.
This is of great importance since upwards of 30% of students won’t reach completion. When a student drops out, additional funds must be expended to attract and enroll the next student, in addition to the opportunity cost of future revenue.
Without a strong retention program, cost and reputation become central issues. A good student information system with retention scoring, degree auditing, judicial tracking, student attendance and grade book can make all the difference.
For more on how these features help your retention program check out my post, An Integrated Student Information System is Your Best Friend for Retaining Students.
#3. Integrated Data for Better Decisions
Probably the most important way an SIS saves money for your institution is by giving users real-time access to student recordswithout requiring extra resources. Some small to mid-sized schools fall into a trap of purchasing separate school management systems for admissions or student retention and find they need additional man-hours for keeping the data in sync across all departments.
A bigger issue is schools who already have an SIS but purchase the latest new stand-alone software (admissions, for example) with a slick new user interface, hoping to integrate it with their existing SIS. Unfortunately, they realize afterwards the added costs required to maintain both systems outweigh the benefits, and often they plot a costly new course with additional software, training and implementation expenses.
For more details on why this can be a mistake check out, Student Management Software ‘ Integrated ERP or Best of Breed.
#4. More Effective Recruiting
The cost of recruiting a student who eventually enrolls is over $2,400 (2). So all the time and money planning, managing and measuring the recruiting and admissions programs shouldn’t be wasted. The distribution of texts, emails and letters that are well tracked in a workflow that triggers automatic follow up is essential to an efficient recruiting operation.
While efficiency of operations is beneficial, what’s more important is how effective the recruiting operation is at finding and attracting the right candidates. An SIS with a robust admissions module will offer key insights into outreach programs that bear the most fruit and provide the tools for admissions counselors to focus on the most receptive candidates to grow enrollments.
#5. Better Accountability and Fraud Prevention
When mistakes or errors occur, it can be difficult to determine the source. If it’s an honest mistake you want to identify it so it can be rectified. Schools are under increasing scrutiny to guard against unauthorized or malicious activity and need tools to quickly identify areas of concern.
In either case the goal is to hold people working in the system accountable for their actions. That’s why a robust student information system will have an in-depth audit trail and user permission system that allows granular access and records of all changes.
Mistakes can occur when individuals are given access to areas they don’t need, so they inadvertently make a change to something they don’t understand. Robust controls are the key to accountability. User awareness that the system keeps tabs on all activity is a strong incentive for good behavior and accurate recording of data.
Institutions should routinely examine their school administration systems to ensure that they are providing a strategic advantage. If the system is not providing a high level of service or does not provide accurate and easy to obtain reporting, then alternatives should be investigated. The costs associated with poor recruitment, retention, reporting, and accountability may outweigh the cost of replacement. Return on investment should always be measured against these costs to keep your organization running smoothly and efficiently.
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About the Author
Joe Stefaniak has been a leading expert for almost 30 years in the development and implementation of software solutions for higher education. His expertise is in helping colleges and schools streamline operations and manage information for better decision making through analysis and application of best practice software. He founded SCAN Business Systems in 1986. Its flagship product, Campus Café, has grown into a leading provider of educational student information systems. He holds a degree in Business Administration from Northeastern University.