Posts Tagged ‘title IV’

By Ronald L. Holt, Esq., Partner

The author is an attorney practicing in the Higher Education practice at the firm of Dunn & Davison, LLC.

On July 26, 2010, the U.S. Department of Education (“DOE”) issued a notice of proposed rulemaking (the “GE NPRM”) that proposes a two-part ‘gainful employment’ test (the “GE Standards”) intended to be used to measure Title IV eligibility of the following academic programs:

(1) ALL Title IV eligible academic degree and non-degree programs offered by for profit institutions (excluding any liberal arts baccalaureate degree program); and

(2) All Title IV eligible non-degree programs offered by any nonprofit and public institutions (mostly community colleges).

Assuming the final version of the GE regulations is published by November 1, 2010, the regulation would become effective as of July 1, 2011. By its current terms, however, it will not apply to most programs until July 1, 2012 but on July 1, 2011 it will be applied to the lowest 5th percentile in performance of each kind of program (as explained in Part H below on page 11). The GE NPRM is published at 75 Federal Register 43615-43708 (July 26, 2010); it can be accessed at

http://www.ifap.ed.gov/fregisters/FR072610ProgramIntegrity.html

A separate NPRM, which was issued on June 18, 2010 and which covers a wide range of proposed new ‘integrity’ regulations, establishes new requirements for colleges to make disclosures to students and the DOE about various components of the GE Standards. For each program, the institution must annually report its CIP code (Classification of Instructional Programs), the SOC codes (standard occupational code) of occupations for which the program provides training, the graduates in the institution’s last fiscal year and the federal and private debt of those graduates. The institution also must disclose to all students: the cost of each program, the on-time graduation rate of each program, the median debt load for each program (as defined in the GE Standards), and the placement rate for each program beginning by June 30, 2013.
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Email Ron at rholt@dunndavison.com.
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Sent to you on behalf of The Art Institute of Fort Lauderdale President Chuck Nagele:

As you know, The Art Institute of Fort Lauderdale has been a longtime supporter of your organization and the good work you do.  As an education provider, we not only feel the responsibility to help shape the lives of our students, but also to shape the community we call home.  The Art Institute of Fort Lauderdale takes tremendous pride in providing our students the education and skills they need to make an impact in the workplace, and in tandem with you, we also work to provide them opportunities to have an impact on the lives of those around us.   Simply put, we value our association with your organization, as well as the opportunities it affords our students.

At present, our schools are fighting an important policy issue that has the potential to greatly limit opportunities for our students and, thus, limit our ability to give back to our community.  The Department of Education has proposed a rule, deceptively named “Gainful Employment,” that could potentially restrict access to Title IV student loans necessary for most low/moderate-income students.  Under the proposed rule, a program’s eligibility for financial assistance is determined under a series of arbitrary and loosely researched metrics.  Students’ access to financial assistance would be restricted, preventing the student from attending the career program and thereby eliminating future opportunities to partner with your organization.  In fact, one study, conducted by a University of Chicago economist Jonathan Guryan, estimated that 360,000 students would be impacted by the proposed rule.

We respectfully request your assistance.  Please log on to: http://www.aiactioncenter.com
and follow the prompts. You can simply choose the paragraph you would like, add a comment, if you wish, and then hit sent. They will automatically send your letter to the legislators.

Thank you, again, for the work your organization does, and for the strong relationship you have with our school.  We value this partnership, and appreciate your willingness to assist us at this important time.  Should you have any questions about the “Gainful Employment” rule or our letter request, please do not hesitate to contact me directly.

Sincerely,

Chuck Nagele
President, The Art Institute of Fort Lauderdale