Download 2016 ILASFAA Annual Conference April 6

SESSION TITLE
NON-FINANCIAL AID ISSUES THAT
AFFECT FINANCIAL AID ELIGIBILITY
BRIGET BIERNAT JANS
DEPAUL UNIVERSITY
IT’S TIME TO LIGHT THE LIGHTS
2016 ILASFAA ANNUAL CONFERENCE
APRILILASFAA
6 – 8, 2016,
HILTON
, LISLE, IL
2016
ANNUAL
CONFERENCE
APRIL 6 – 8, 2016, HILTON, LISLE, IL
Don’t Get Upstaged!
2016 ILASFAA Annual Conference
2
Financial aid isn’t
just about financial aid
 Large amounts of money come with
substantial responsibilities
 Not all of which appear to be related to helping
students pay for college
 Congress uses institutional eligibility for
financial aid as a way to control or rectify
many seemingly unrelated issues
2016 ILASFAA Annual Conference
3
Dean: This feels like the
tail wagging the dog.
2016 ILASFAA Annual Conference
4
Dean: This feels like the
tail wagging the dog.
Me: Yes, but the feds are
paying for the dog food.
2016 ILASFAA Annual Conference
5
Program Participation Agreement
(PPA)
 The document that gives your institution the
right to participate in the Federal Student Aid
Programs.
 Spells out institutional obligations rather
broadly
2016 ILASFAA Annual Conference
6
Drug Abuse Prevention
 Certify that you have a drug abuse prevention
program in operation
 Must be deemed accessible to any officer,
employee or student
2016 ILASFAA Annual Conference
7
Campus Security Policy
& Crime Statistics
 Certify that you are in compliance with the
disclosure requirements of Section 485(f) of
the Higher Education Act (HEA)
 "Jeanne Clery Disclosure of Campus Security
Policy and Campus Crime Statistics Act"
2016 ILASFAA Annual Conference
8
Campus Security Policy
& Crime Statistics
 Procedure and facilities for reporting security
concerns, emergencies and crimes
 Law enforcement authority of campus security
and their relationship to local law enforcement
 Policy that encourages accurate, prompt
reporting of all crimes when the victim in
unable
2016 ILASFAA Annual Conference
9
Campus Security Policy
& Crime Statistics
 Description of type and frequency of
programs designed to inform students and
employees about campus security procedures
and practices
 Description of programs designed to inform
students and employees about the prevention
of crimes
2016 ILASFAA Annual Conference
10
Campus Security Policy
& Crime Statistics
 Statistics concerning occurrences
 on campus
 in or on non-campus buildings or property, and
 on public property
• most recent calendar year, and during the 2 preceding
calendar years for which data are available
2016 ILASFAA Annual Conference
11
Campus Security Policy
& Crime Statistics
 Must provide specific statistics for









murder
sex offenses, forcible or non-forcible
robbery
aggravated assault
burglary
motor vehicle theft
manslaughter
arson
arrests or persons referred for campus disciplinary action
for liquor law violations, drug-related violations, and
weapons possession
2016 ILASFAA Annual Conference
12
Campus Security Policy
& Crime Statistics
 Must break out any of the above if they are
classified as hate crimes, based on perceived or
actual








Race
Gender
Religion
National origin
Sexual orientation
Gender identity
Ethnicity
Disability of the victim
2016 ILASFAA Annual Conference
13
Campus Security Policy
& Crime Statistics
 Report crime statistics to ED
 Distribute to campus populations
 October 1st each year
2016 ILASFAA Annual Conference
14
Campus Security Policy
& Crime Statistics
 Policy concerning monitoring and recording
criminal activity at off-campus student
organizations
 Policy regarding the possession, use, and sale
of alcoholic beverages and enforcement of
underage drinking laws
 Policy regarding the possession, use, and sale
of illegal drugs
2016 ILASFAA Annual Conference
15
Campus Security Policy
& Crime Statistics
 Statement advising where to get information
about registered sex offenders
 Campus policies regarding emergency
response and evacuation
 Policy regarding timely reports to the campus
community on crimes considered to be a
threat to other students and employees
 Must withhold the names of victims
 Maintain a crime log
2016 ILASFAA Annual Conference
16
Title VI
 Civil Rights Act of 1964
 Bars discrimination based on race, color or
national origin
 Applies to programs or activities receiving federal
financial assistance
 Enforced by ED’s Office of Civil Rights
2016 ILASFAA Annual Conference
17
Title IX
 Education Amendments of 1972
 Bars discrimination based on sex
 Requires gender equity for boys and girls in
every educational program that receives
federal funding
 Include sexual harassment, the failure to
provide equal opportunity in athletics, and
discrimination based on pregnancy
 Enforced by Office of Civil Rights within the
Department of Education
2016 ILASFAA Annual Conference
18
Section 504
 Rehabilitation Act of 1973
 Bars discrimination based on physical handicap
 Applies to all programs receiving federal
funding
 Paved the way for the Americans with
Disabilities Act (ADA)
2016 ILASFAA Annual Conference
19
Standards for Safeguarding
Customer Information
 16 CFR Part 314
 Standards set in Gramm-Leach-Bliley Act
 Financial Services Modernization Act of 1999
 Ensure security and confidentiality of customer
records and information
 Any breach in data security is seen as a
demonstration of a lack of administrative
capability
 Strongly encouraged to advise students of
breaches
2016 ILASFAA Annual Conference
20
Accreditation & State Regulation
 Acknowledge that accreditors and state are
authorized to share institutional information
with ED
 Under the HEA, accreditation cannot be
recognized by ED unless the institution agrees
to submit to initial arbitration prior to any
legal action involving the institution’s
accreditation
2016 ILASFAA Annual Conference
21
Miscellaneous
 Charging fees
 Institution cannot charge fees to students for
administering federal funds
 Job Placement rates
 If advertising job placement rates, institutions must
provide statistics to prospective students
 State licensing requirements
 Must publish requirements for jobs for which an
educational program is offered
2016 ILASFAA Annual Conference
22
Miscellaneous
 Not knowingly hire anyone for the
administration of Title IV funds who has been
convicted or pled guilty of a crime involving
federal funds or fraud
 Can’t impose penalty on students if federal
funds are delayed
 No bonuses or incentive pay to employees for
enrolling students
 Acceptable for enrolling foreign students
2016 ILASFAA Annual Conference
23
Miscellaneous
 Must demonstrate a reasonable relationship
between the length of GE programs and the
recognized occupations for which they
prepare students
 Program length annot be more than 50% of the
state requirements
 Annually develop, publish, administer and
enforce an education loan code of conduct
 34 Code of Federal Regulations Section 601.21
 NASFAA makes a version available
2016 ILASFAA Annual Conference
24
Miscellaneous
 Annually compile, maintain and make available a
preferred lender list, if institution has a
preferred lender arrangement
 Develop and implement written plans to
combat unauthorized distribution of copyright
materials
 Including disciplinary procedure for violations of the
policy
2016 ILASFAA Annual Conference
25
Miscellaneous
 Submit teach out plans to accreditor in cases
of
 Limitation, suspension or termination of Federal
Student Aid eligibility
 Loss of accreditation
 Loss of state authorization
 Closure of a location offering 100% of a program
 Institutional intention to cease operations
2016 ILASFAA Annual Conference
26
Miscellaneous
 Must have a drug abuse prevention program
 Mentioned again
 Voter registration
 National Voter Registration Act of 1993 – Motor Voter
Law
 Requires good faith effort to distribute a mail voter
registration form, requested and received from the
State, to each student enrolled in a degree program
• Not required for students studying through distance
education only
2016 ILASFAA Annual Conference
27
Miscellaneous
 Cant use federal funds to lobby members,
officers or employees of Congress
 Must disclose institutional funds spent on lobbying
2016 ILASFAA Annual Conference
28
Miscellaneous
 Drug-free workplace statement
 Mentioned yet again
 Distribute to everyone
 Must include what actions may be taken against
employees who violate the prohibition
 Establish a drug-free awareness program
•
•
•
•
•
Dangers of drug abuse
Institutional policy
Available counseling and rehabilitation services
Penalties for violations in the workplace
Employers must provide notice of convicted employees to
ED’s Director of Grants and Contracts Service
2016 ILASFAA Annual Conference
29
Miscellaneous
 Debarment, suspension and other responsibility matters
 No fraud or criminal offenses committed by the institution’s
principals
•
•
•
•
•
•
•
•
•
•
•
•
Bribery
Anti-trust violations
Embezzlement
Theft
Forgery
Bribery
Falsification or destruction of records
Making false statements
Tax evasion
Receiving stolen property
Making false claims
Obstruction of justice
 Not currently under indictment
2016 ILASFAA Annual Conference
30
Miscellaneous
 Annual distribution of drug and alcohol
prevention policy
 Déjà vu?
 All employees and any student taking at least one
class
• Not required for students only taking continuing
education units
 Biennial review of drug and alcohol abuse
prevention program
2016 ILASFAA Annual Conference
31
Constitution & Citizenship Days
 September 17th each year
 educational institutions receiving Federal funding
are required to hold an educational program
pertaining to the United States Constitution
 If falls on religious holiday, you can celebrate either
the week before or the week after.
 Federal Register: May 24, 2005,Vol. 70, No. 99
• Not listed in either your PPA or FSA Handbook
2016 ILASFAA Annual Conference
32
Resources
 Program Participation Agreement
 Available at www.eligcert.ed.gov
 FSA Assessments
 http://www.ifap.ed.gov/qahome/fsaassessment.html
 The Handbook for Campus Safety and
Security Reporting
 http://www2.ed.gov/admins/lead/safety/campus.ht
ml
2016 ILASFAA Annual Conference
33
Questions???
2016 ILASFAA Annual Conference
34
Contact Information
Briget Jans
[email protected]
312-362-8348
2016 ILASFAA Annual Conference
35