Springing in to Action
As spring has just begun, there are a number of upcoming dates to keep in mind. In this Regulatory Bulletin reminder, we provide a brief list of important events and dates that schools need to have on their calendar. It is important to plan your schedule of activities accordingly.
March 29, 2015 – The new PLUS Loan regulations regarding adverse credit standards go into effect. These regulations were published in the Federal Register on October 23, 2014 and posted on IFAP. The published effective date for the regulations was July 1, 2015. However, in a Federal Register notice on January 14, 2015, ED announced that the regulations would be implemented on March 29, 2015. An Electronic Announcement was posted on IFAP on January 27, 2015 emphasizing this date change. Schools must implement the new regulatory standards pertaining to adverse credit by March 29, 2015. This will entail ensuring your internal policies and procedures, as well as informational material regarding PLUS Loans are updated accordingly (whether in print and/or electronic versions).
April 13-15, 2015 – The annual FAME Management and Financial Aid Conference, April 13-15, 2015, will be held at the Westin Beach Resort & Spa, Ft. Lauderdale, FL.
April 16, 2015 – Schools that plan to submit either an Incorrect Data Challenge or a Participation Rate Index Challenge to their draft cohort default rates (CDRs) must have their challenge submitted by no later than 45 days after the appeal period began. As indicated in the February 23, 2015 Electronic Announcement in which the CDRs were announced, the time period for challenging the school’s draft CDR data began March 3, 2015. This generates a deadline of April 16, 2015, as the date by which schools must submit a challenge.
July 1, 2015 – The new Violence Against Women Act (VAWA) regulations were published on October 20, 2014, and are effective on July 1, 2015. Schools must ensure they have appropriately addressed their needs for updating policies, procedures, and training required by the new VAWA regulations. This includes ensuring a method of monitoring and reporting the new categories of crimes stipulated in the regulations. The crimes of sexual assault, domestic violence, dating violence, and stalking (physically or electronically) have been added to those previously required to be reported and acted upon. Schools must also ensure they have appropriate policies and procedures in place for prevention programs and awareness campaigns about these newly designated areas of crime. Likewise, schools must have instituted a victim’s bill of rights related to violence. Further, the school must ensure it is prepared to meet the now required policies and protocols for reporting, investigation, and disciplinary proceedings (grievance and adjudication). This includes making certain school personnel involved in the investigations and proceedings have received the appropriate annual training. (See the FAME Regulatory Bulletin dated March 11, 2014, for more information.)
July 1, 2015 – The latest edition of the Gainful Employment regulations published on October 31, 2014, are effective this date. (Minor technical corrections to the regulations were published on December 4, 2014.)
July 31, 2015 – All schools with gainful employment (GE) programs must report by this deadline under the new GE regulations that became effective July 1, 2015 (see above). The data that will be first reported for most programs is for the award years of 2008-2009 (the seventh award year prior to the required reporting date) through 2013-2014 (the second award year prior to the required initial reporting date of July 31, 2015). Note that if the program for which data is being reported is a medical or dental program that requires a residency or internship (this refers to doctoral programs, not allied health programs), the data will be reported for the second through eighth award years prior to the initial reporting date. See the FAME Inside Report article, “Gainful Employment Redux,” in the January 2015 edition for more information.
October 1, 2015 – Schools must submit their Annual Security Report (ASR) by this date. This year’s ASR must take into consideration the requirements of the new VAWA regulations that became effective July 1, 2015.
Fall 2015 – Based upon the published information from ED, schools should see the first college ratings based upon the President’s planned Postsecondary Institution Ratings System (PIRS) “in the 2015 school year.” The final details of the system are not yet available. But, those interested in reading ED’s information on “College Ratings and Paying for Performance” may find discussion at ED’s Web site at http://www.ed.gov/college-affordability/college-ratings-and-paying-performance and also in their most recent Fact Sheet on the topic dated December 19, 2014. Finally, there is a series of ED blog postings on the subject, the most recent of which is at Progress Toward Designing a New System of College Ratings. That posting contains links to the two prior postings on the subject, as well.
With all of the upcoming items of importance highlighted in this Regulatory Bulletin reminder, one has plenty of key financial aid dates to have entered on their calendar. May you keep a spring in your step as you move with purpose toward seeing each of these important occasions result in the outcome desired.
This material is presented for informational and educational purposes only and should not be considered to be giving legal advice.