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ED Dear Colleague Letters

ED’s Dear Colleague Letters (DCLs) on IFAP: Oct-Dec 2014

DCL – GEN-14-22: December 18, 2014 – Apprenticeships and the Federal Student Aid Programs

This Dear Colleague Letter (DCL) highlights schools’ ability to use FSA programs to support apprenticeship programs as part of the Administration’s efforts to double the number of apprentices in the United States in the next five years.  The letter provides guidance to those schools who may offer educational programs with an apprenticeship component.   In order for a student who is in an apprenticeship program to be able to receive FSA funds, the apprenticeship component has to be part of an otherwise Title IV-eligible program.  The program must lead to a degree, diploma, certificate, or other recognized credential that the institution awards.  The program must also meet all other requirements related to program length, both in regard to weeks of instructional time, as well as the number of credit or clock hours.  Any school that may offer an apprenticeship program or have a program that includes an apprenticeship component should review this DCL in detail.

DCL – GEN-14-23: December 19, 2014 – Competency-Based Education Programs – Questions and Answers

ED provides further clarification on the topic of competency-based education (CBE), including direct assessment programs.  The guidance is provided in a question and answer format.  ED gives further guidance regarding the distinction between credit-hour competency-based education and direct assessment; requirements for establishing credit hour equivalencies in direct assessment programs; requirements for regular and substantive interaction between students and faculty; prohibitions on paying Title IV aid for credit earned through prior learning assessments; satisfactory academic progress in CBE scenarios; the impact of Return of Title IV Funds provisions; and, accrediting agencies’ roles in reviewing CBE programs.  Schools that offer, or may be planning to offer, CBE programs are well-advised to analyze the information ED provides through this DCL.

Federal Registers

FR – Posted October 20, 2014 – Final Rule:  Violence Against Women Act

This Final Rule implements the changes made by the Violence Against Women Act (VAWA) to the Jeanne Clery Disclosure of Campus Security Policy and Campus Crime Statistics Act (the Clery Act).  The final regulations here were developed after ED’s review of the comments received based upon the June 20, 2014, Notice of Proposed Rulemaking.  The regulations increase reporting requirements and expect that campuses will prevent dating violence, domestic violence, sexual assault, and stalking through prevention and awareness programs.  The Federal Register is available in PDF format at Federal Register, Volume 79, No. 202, Monday, October 20, 2014, page 62752.  A link to this regulation is also provided in the Electronic Announcement dated October 20, 2014.

FR – Posted October 23, 2014 – Final Rule:  Direct PLUS Loans – Final Regulations

These updated regulations revise the definition of “adverse credit history” as applicable to the Federal Direct PLUS Loan Program.  The regulations will require that borrowers who have an adverse credit history, but are nevertheless approved for the PLUS Loan due to obtaining an endorser for the loan, or due to extenuating circumstances that exist, receive loan counseling before receiving the loan. This is true whether it is a Parent PLUS Loan or a Graduate PLUS Loan.  These regulations have an effective date of July 1, 2015, but it is anticipated that an early implementation of these regulations will be allowed, potentially for as early as March 2015.  More information will be forthcoming.  This is the first update to the regulations governing adverse credit history determinations since the Direct Loan Program was implemented in 1994.  The Federal Register containing these regulations is available in PDF format at Federal Register, Volume 79, No. 205, Thursday, October 23, 2014, page 63317.  A link to this regulation is also provided in the Electronic Announcement dated October 23, 2014.

FR – Posted October 31, 2014 – Final Rule:  Gainful Employment

This Federal Register provides the much anticipated revised regulations related to Gainful Employment (GE) reporting and the resulting impact of the reporting.  Specifically, these regulations provide for looking at GE programs in two separate contexts.  The first is the accountability framework that defines what it means to prepare students for GE in a recognized occupation.  This includes the metrics for determining the achievement of the program in providing the quality education and training that leads to successful student loan repayment.  The other context in which programs are looked at is the transparency framework.  This is where the regulations are intended to increase the quality and availability of information related to the outcomes of the students in GE programs.  The Federal Register containing these regulations is available in PDF format at Federal Register, Volume 79, No. 211, Friday, October 31, 2014, page 64890.  A link to this regulation is also provided in the Electronic Announcement dated October 31, 2014.

 

THE INFORMATION PROVIDED TO YOU IS FAME’S OPINION BASED ON OUR INTERPRETATION OF THE ISSUES AND EVENTS PROVIDED AND OUR INTERPRETATION OF THE TITLE IV REGULATIONS AS THEY MAY APPLY. FAME SHALL NOT BE LIABLE FOR ANY ERRORS CONTAINED HEREIN OR FOR ANY DAMAGES WHATSOEVER ARISING OUT OF OR RELATED TO THE USE OF THIS INFORMATION.

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