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Session 5 Principles of Excellence – Executive Order 13607 Carolyn Baker, David Bergeron, Marty Session 5 Principles of Excellence – Executive Order 13607 Carolyn Baker, David Bergeron, Marty Guthrie, Jessica Shedd, and Robert Worley | Nov. 2012 U. S. Department of Education 2012 Fall Conference

Department of Veterans Affairs 2 Department of Veterans Affairs 2

Executive Order Overview • • • Signed by President Obama on April 27, 2012 Executive Order Overview • • • Signed by President Obama on April 27, 2012 Designed to provide information, support, and protections to Federal education beneficiaries Strengthens oversight, enforcement, and accountability activities within educational benefit programs Establishes Principles of Excellence as guidelines for educational institutions receiving Federal funding Expands student data collection efforts to better understand educational outcomes Requires development of a Centralized Complaint System for students 3

Principles of Excellence The Principles encourage schools to: • Prior to enrollment, provide students Principles of Excellence The Principles encourage schools to: • Prior to enrollment, provide students a personalized form covering the total cost of an educational program • Program costs, student debt estimates, and Federal financial aid options upfront • Provide educational plans for all military and veteran education beneficiaries • End fraudulent and aggressive recruiting techniques and misrepresentation • Provide accommodations for service members and reservists absent due to service requirements • Designate a point of contact for academic and financial advising • Ensure accreditation of all new programs prior to enrolling students • Align institutional refund policies with those under Title IV 4

Working Groups • Three working groups to implement the Executive Order: • Information • Working Groups • Three working groups to implement the Executive Order: • Information • Reports • Enforcement • Comprised of representatives from: • VA • DOD • Department of Education • Department of Justice • Consumer Financial Protection Bureau (CFPB) • Federal Trade Commission (FTC) 5

Implementation Work • Letter sent to Educational Institutions, May 2012 • Outlined Principles of Implementation Work • Letter sent to Educational Institutions, May 2012 • Outlined Principles of Excellence, encouraged compliance, & requested notice of intent to comply • 6, 184 schools (3, 514 main campuses) posted on GI Bill website • Conducted three informational webinars in June for schools and professional organizations (GI Bill website, School Resources) • GI Bill Trademark Registered Oct 16, 2012 – associated policy under development • Finalized Financial Aid Shopping Sheet (Dept ED Jul 12) • Submitted 90 -day status reports on Implementation, Enforcement, & Compliance to White House • Outreach: SCO Assoc. , School Assoc. , VSOs, SAAs 6

Ongoing Implementation Work • • • Developing streamlined tools to compare educational institutions • Ongoing Implementation Work • • • Developing streamlined tools to compare educational institutions • Crosswalk naming conventions between ED and VA Strategy for developing Service member/Veteran outcome measures Procedures for targeted risk-based reviews of institutions to assess compliance with the Principles Uniform procedures for receiving, processing, sharing complaints across State Approving Agencies and with other agencies Awaiting feedback/release of 90 -day Executive Order Progress Reports Developing Centralized Complaint System 7

Centralized Complaint System • Centralized Complaint System to register, track, and respond to complaints Centralized Complaint System • Centralized Complaint System to register, track, and respond to complaints • • • Builds upon existing online, phone, and in-person intake at VA and Do. D Forum for students to report concerns about recruiting and other issues Standardized complaint form, though intake will be conducted by each agency individually Complaints will be stored in the Federal Trade Commission’s Consumer Sentinel Network database Agencies will follow uniform procedures for receiving, processing, and sharing complaint information Do. D and VA may expand compliance reviews to incorporate institutions with complaints submitted through this system Database will be accessible to agencies to review external complaints, run reports, and identify trends that potentially warrant criminal or civil investigation Do. D and VA working Paperwork Reduction Act (PRA)/System of Records Notification (SORN) process for complaint information collection Working toward spring 2013 initial implementation 8

Department of Defense 9 Department of Defense 9

Do. D Policy Do. D Instruction (Do. DI) 1322. 25 Voluntary Education Programs March Do. D Policy Do. D Instruction (Do. DI) 1322. 25 Voluntary Education Programs March 15, 2011 The Do. DI establishes Voluntary Education policy States institution eligibility criteria for tuition assistance (TA) Requires a signed memorandum of understanding (MOU) with Do. D by an educational institution providing educational programs through the Do. D TA program • Do. DI 1322. 25, Encl. 3, 1. 0. “To receive TA the institutions home campus must be a signatory of the Do. D Voluntary Education Partnership MOU and the MOU must be posted on the Do. D website. ” • • • 10

Key Stakeholders’ Concerns Institutions 3. d. (1) Adhering to the Servicemembers Opportunity Colleges (SOC) Key Stakeholders’ Concerns Institutions 3. d. (1) Adhering to the Servicemembers Opportunity Colleges (SOC) Consortium Principles, Criteria, and Military Student Bill of Rights; especially waiving degree residency requirements. 3. d. (2) Recognize, accept, and award military training and education credit where appropriate, from the Army/ACE Registry Transcript System IHE 4. c. Educational Plan (1) Institutions will provide an evaluated educational plan to the Service member and his or her Service 11

Key Stakeholders’ Concerns Military and Veteran’s Organizations Aggressive marketing and loan defaults • Skills Key Stakeholders’ Concerns Military and Veteran’s Organizations Aggressive marketing and loan defaults • Skills required for employment • Schools meeting Service members and Veteran’s special needs • 12

Key Stakeholders’ Concerns Health Education Labor and Pension (HELP) Committee Ensuring quality – Service Key Stakeholders’ Concerns Health Education Labor and Pension (HELP) Committee Ensuring quality – Service members and Veteran’s are receiving an education that will lead them to employment, certification, and licensure • Disclosure of information • Aggressive marketing and loan defaults • 13

Highlights of Changed MOU Requirements Servicemembers Opportunity Colleges Member (SOC) Non-SOC Member* • Adhere Highlights of Changed MOU Requirements Servicemembers Opportunity Colleges Member (SOC) Non-SOC Member* • Adhere to the SOC Consortium Principles, Criteria • Adhere to the Military Student Bill of Rights • Have a processes to determine credit awards and learning acquired for specialized military training and occupational experience when applicable • Recognize and use the ACE Guide to the Evaluation of Educational Experiences in the Armed Services • Disclose its transfer credit policies prior to enrollment • Disclose its policies regarding award of academic credit for prior learning experiences • Disclose any academic residency requirements • Disclose institution’s programs and costs, including tuition, fees, and other charges • Provide access to an institutional financial aid advisor • Prior to enrollment, provide information on institutional “drop/add, ” withdrawal, and readmission policies and with potential impact of military duties • Conduct academic screening / competency testing; make placement based on student readiness. • Designate POC to provide appropriate academic and financial aid counseling and student support services • Policy in place banning recruitment inducements • Refrain from high-pressure recruitment tactics / incentive based directly or indirectly on securing enrollments or Federal financial aid (to include TA) *All of the non-SOC member requirements are included the SOC Principles and Criteria and the Bill of Rights 14

DOD MOU – Current Status All staffing internal to Do. D has been completed DOD MOU – Current Status All staffing internal to Do. D has been completed • Do. DI 1322. 25 is currently at OMB • 60 days after posting all schools must be a signatory of the Do. D MOU and their name posted on the Do. D MOU website: http: //www. dodmou. com/ IF A SCHOOL CURRENTLY HAS A SIGNED MOU WITH DOD THERE IS NO REQUIREMENT TO RESIGN OR SIGN THE MOU POSTED ON THE FEDERAL REGISTER, UNLESS THE SCHOOL ELECTS TO DO SO NO MILTARY STUDENT WILL BE DENIED TA BECAUSE A SCHOOL HAS NOT SIGNED THE MOU UNTIL IMPLEMENTATION OF POLICY AS DIRECTED BY OSD NO SCHOOL SHOULD BE DENIED ACCESS TO A MILITARY BASE BECAUSE THEY HAVE NOT SIGNED THE MOU UNTIL IMPLEMENTATION OF THE POLICY AS DIRECTED BY OSD 15

Executive Order 13607 signed April 27, 2012 • • • Requires institutions to provide Executive Order 13607 signed April 27, 2012 • • • Requires institutions to provide information, support, and protections to Federal education beneficiaries Strengthens oversight, enforcement, and accountability activities within educational benefit programs Establishes Principles of Excellence as guidelines for educational institutions receiving Federal funding Expands student data collection efforts to better understand educational outcomes Requires development of a Centralized Complaint System for students 16

Do. D Focus - POE Requirements Do. D Requirements: 1. Require Schools to: a. Do. D Focus - POE Requirements Do. D Requirements: 1. Require Schools to: a. Provide Students with an Education Plan b. Provide students with a personalized, standardized form with costs, financial aid and outcome measures c. Inform students of the availability and eligibility Federal financial aid before arranging private student loans d. End fraudulent and unduly recruitment on military installations e. Obtain approval of institution accrediting agency for new course or program offerings before enrolling students f. Allow service members and reservists to be readmitted to a program if they are temporarily unable to attend class or have to suspend their studies due to service requirements g. Have a refund policy that is aligned with the refund of unearned student aid rules applicable to Federal student aid h. Designate a point of contact for academic and financial advising 2. Provide military students, prior to using their benefits, streamlined tools to compare educational institutions using key measures for affordability and value through the VA’s e. Benefits portal 3. Create an interagency Centralized Complaint System 4. Establish new uniform rules and strengthen existing procedures for access to military installations by education institutions 5. Establish procedures for targeted risk-based program reviews of institutions to ensure compliance with the principles Currently in the MOU to be released: • Full requirement 1. a, c, d, h. • Partial requirement: 1. g. What needs to be included/additional verbiage in the MOU: 1. b, e, f, g. Tasks to be performed: 2, 3, 4, and 5. MOU Change 3 will be published Spring of 2013 17

Refund Policy g. Have a refund policy that is aligned with the refund of Refund Policy g. Have a refund policy that is aligned with the refund of unearned student aid rules applicable to Federal student aid Do. D will be implementing: 20 USC 1098 cc – Tuition refunds or credits for members of armed forces Sec. 1098 cc. Tuition refunds or credits for members of armed forces • AND Title 34: Education Part 668 – Student Assistance General Provisions Subpart B – Standard for Participation in Title IV, HEA Programs § 668. 22 Treatment of Title IV funds when a student withdraws. 18

Readmission f. Allow service members and reservists to be readmitted to a program if Readmission f. Allow service members and reservists to be readmitted to a program if they are temporarily unable to attend class or have to suspend their studies due to service requirements Do. D will be implementing: Department of Education 34 CFR 668. 18 - Readmission requirements for Service members (a) General. (1) An institution may not deny readmission to a person who is a member of, applies to be a member of, performs, has performed, applies to perform, or has an obligation to perform, service in the uniformed services on the basis of that membership, application for membership, performance of service, application for service, or obligation to perform service. (2) (i) An institution must promptly readmit to the institution a person described in paragraph (a)(1) of this section with the same academic status as the student had when the student last attended the institution… (iv) (A) If the institution determines that the student is not prepared to resume… 19

Standardized Form Provide students with a personalized, standardized form with costs, financial Aid, and Standardized Form Provide students with a personalized, standardized form with costs, financial Aid, and outcome measures b. Do. D will recommend schools use: Department of Education DCL GEN-ID 12 -17 Publication Date: August 30, 2012 Commitment to use the Financial Aid Shopping Sheet 20

Complaint System 3. Create an interagency Centralized Complaint System Do. D, Department of Justice, Complaint System 3. Create an interagency Centralized Complaint System Do. D, Department of Justice, Consumer Financial Protection Bureau, Department of Education, and Veterans Affairs are creating a centralized school complaint system The system will: • Receive school complaints/concerns from all Agencies • Process complaints • Refer matters for civil or criminal enforcement The pilot system will be operational spring of 2013. 21

Military Base Access 4. Establish new uniform rules and strengthen existing procedures for access Military Base Access 4. Establish new uniform rules and strengthen existing procedures for access to military installations by education institutions Do. D is implementing the following policies in the spring of 2013 Institutions may access military bases to provide education, guidance, and training opportunities ONLY • Marketing firms or companies that own and operate higher-learning institutions will not have access to the bases • May have access to military bases to provide education guidance to their students: Access only through the base education officer via a written proposal (a) Have a signed MOU with Do. D; (b) Be chartered or licensed by the State government in which the services will be rendered; (c) Be State approved for the use of veteran’s education benefits; (d) Course offering must be provided by postsecondary institution accredited by a national or regional accrediting body recognized by the U. S. Department of Education; and (e) Have an on base student population of at least 20 active duty military students • 22

Military Base Access (cont’d) ESOs will: ü Fully consider requests from ALL types of Military Base Access (cont’d) ESOs will: ü Fully consider requests from ALL types of institutions complying with Do. DI requirements ü Be consistent in treatment of ALL types of institutions ü Must maintain copies of all correspondence to include acceptance and denials The installation commander (or delegated authority) will grant final approval and have the authority to deny, suspend, or withdraw permission from ALL types of institutions as deemed appropriate and fair. 23

Department of Education 24 Department of Education 24

Improving Transparency & Accountability President tasked Administration to provide relevant information to students and Improving Transparency & Accountability President tasked Administration to provide relevant information to students and families to help them make financially-sound higher education decisions • Particularly for veterans, military spouses, and their families Led to several new tools to support choice process • College Scorecard • Financial Aid Shopping Sheet 25

Information to Inform Choice • Provide prospective veteran and service member students with a Information to Inform Choice • Provide prospective veteran and service member students with a personalized and standardized form to help understand the total cost of the educational program including: • • • tuition and fees; the amount of that cost that will be covered by Federal educational benefits; the type and amount of financial aid they may qualify for; their estimated student loan debt upon graduation; information about student outcomes; and other information to facilitate comparison of aid packages offered by different educational institutions; Inform veteran and service member students about the availability of Federal financial aid and have in place policies to alert those students of their potential eligibility for that aid before packaging or arranging private student loans or alternative financing programs. 26

Suite of Consumer Choice Tools CATC with Scorecards College Navigator “Shopping Sheet” ED Institution Suite of Consumer Choice Tools CATC with Scorecards College Navigator “Shopping Sheet” ED Institution Private Sector or Government 27 Aid Offer Comparison Tools

Financial Aid Shopping Sheet • • • Stage of choice process: choosing where to Financial Aid Shopping Sheet • • • Stage of choice process: choosing where to enroll Standardized, clear, and concise format for providing prospective students their personalized financial aid offer Designed to help prospective students and their families better understand the costs of college before making the final decision on where to enroll Identifies the type and amount of aid qualified for and allows for easy comparison of aid packages offered by different institutions Fulfills information requirements for key pieces of Executive Order 13607 28

QUESTIONS? 29 QUESTIONS? 29

VA Contact Information Robert M. Worley II Director Veterans Benefits Administration Education Service Department VA Contact Information Robert M. Worley II Director Veterans Benefits Administration Education Service Department of Veterans Affairs http: //www. GIBILL. VA. gov/ 30

DOD Contact Information Carolyn L. Baker Chief, Voluntary Education Programs OUSD (P&R) MC&FP (SL/Ed) DOD Contact Information Carolyn L. Baker Chief, Voluntary Education Programs OUSD (P&R) MC&FP (SL/Ed) 4800 March Center Drive, Suite 14 E 08 Alexandria, VA 22350 -2300 Do. D Voluntary Education Web Page: http: //apps. mhf. dod. mil/voled 31

ED Contact Information • David. Bergeron@ed. gov • Marty. Guthrie@ed. gov • Jessica. Shedd@ed. ED Contact Information • David. [email protected] gov • Marty. [email protected] gov • Jessica. [email protected] gov • Shopping. [email protected] gov 32