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September 6, 2011
Dear School Owners, Directors and COMTA Community Members,
As many of you may or may not be aware, there have been several changes that have taken effect July 1, 2011 regarding new U.S. Department of Education regulations for schools participating in Title IV, HEA programs. Our last recent notification that was sent out to all schools owners, directors and COMTA community members was a letter dated May 23, 2011, that discussed several changes to the eligibility criteria for programs participating in Title IV financial aid programs and that COMTA has been carefully evaluating the changes to understand them and respond to our schools when they pose questions about these changes to us. To view more information from that letter, please click here.
In other recent changes, the final regulations published in the Federal Register on October 29, 2010, required institutions to report certain information about students who enrolled in Title IV eligible educational programs that lead to gainful employment in a recognized occupation (GE programs). Those regulations also provided that institutions must disclose to prospective students certain information about the institution’s GE Programs. Finally, the new regulations required institutions to notify the Department if they wish to add an additional GE Program to its list of Title IV eligible programs. All of these requirements became effective July 1, 2011. As part of this new regulation, the Gainful Employment Program Disclosures are to be made to prospective students and not enrolled students. This means that the disclosures must be made before the student signs an enrollment agreement or makes a similar commitment to begin an academic program at a school. Schools must make disclosures in five (5) main areas:
- Schools must identify the occupations for which the program is preparing students using the program’s Classification of Instructional Program (CIP) code and an online database maintained by the Department of Labor called O*NET (http://www.onetonline.org/crosswalk/CIP/).
- Schools must calculate and publish an on-time completion rate for each program.
- Schools must disclose the total cost of the program for normal time graduates, including tuition, fees, institutional charges, typical books and supplies, and room and board.
- If the school’s accrediting agency or state regulatory agency requires that the institution calculate a placement rate of any kind, the school must disclose that rate.
- Schools must disclose median debt figures for graduates of the program, breaking out those figures separately for Title IV debt, private loan debt and institutional debt.
These five sets of disclosures must be made in two places: on the school’s website or landing page for the program and on program-specific promotional materials. “Promotional materials” includes everything from brochures to radio and TV advertisements.
If you are an institution that offers Title IV Financial Aid, it is required by the U.S. Department of Education that you must have an active website to disclose this information. The institution’s website must contain the disclosed information areas above. Prospective students should not have to be compelled to sign-up first using their email address and other contact information to receive the above information; it must be disclosed on the website for all prospective students to see.
Here are some resource links to provide more information:
- http://ecfr.gpoaccess.gov/cgi/t/text/text-idx?c=ecfr&tpl=/ecfrbrowse/Title34/34cfr668_main_02.tpl – Please refer to regulation 668.6 Reporting and disclosure requirements for programs that prepare students for gainful employment in a recognized occupation.
- http://ifap.ed.gov/GainfulEmploymentInfo/
As always, the COMTA office is available to provide assistance. These disclosures are not part of the COMTA Standards at this time; we wish to support you in maintaining compliance with the Department of Education regulations and are available to help guide you to accurate information. You are encouraged to contact Kate I. (Henrioulle) Zulaski at (202) 895-1518 x849 or via email at: kzulaski@comta.org. You may also contact LaToshya Vaughn, in the event Kate Zulaski is unavailable at (202) 895-1518 x.846, or via email at Lvaughn@comta.org, if you have any questions or concerns.
Sincerely,
Kate I. (Henrioulle) Zulaski
Executive Director