A triad of regulatory agencies have emerged including: (1) USDE, (2) State agencies, and (3) Accreditation agencies working together to over see and approve a multitude of educational institution's standards, policies, licensing, advertising, federal financial aid etc in an effort to create transparency and trust and to elevate academic standards. Our schools administrators, staff and instructors need to be fully aware of the required standards and policies to ensure students are treated fairly, that federal aid (title IV) funding may be obtained and high standards can be maintained, etc.
I have a question. What if your training is not adequate enough to know what you are saying is true?
I believe changes to the regulatory environment have strengthened protections for students, including those receiving federal assistance. For example, recent changes to the reporting of Crime/Safety statistics, related to the Clery Act, make ALL schools more accountable to the safety of students. The recognition of Constitution Day as a requirement for receiving Title IV funds is another instance of the changing regulatory environment. Personally, we believe this is a tremendous idea as we are trying to develop engaged citizens as well as successful professionals.
Roman,
I want to thank you for your detailed observations and hope that other course participants will read your post. In many ways the compliance process, indeed, has become tedious and cumbersome. The sad irony is that this can take focus away from the true missions of our institutions and, ultimately, the success of our students and graduates. There must be a balance between the necessity of regulation and the importance of student outcomes. In other words, a culture of compliance, going beyond simply adhering to the requirements, can facilitate truly successful student outcomes when we're all complying for the right reasons.
Jay Hollowell
Many recent changes have taken place in the Regulatory environment the past few years. Some examples:
R2T4 is now more complicated process layered on top of various state, accreditor and institutional refund policies. Colleges that offer courses in modules, which for many students is the most effective way to learn with higher levels of engagement and scheduling flexibility, it is nearly impossible to fully automate R2T4, requiring labor intensive handling. The 1st, 3rd, and 6th most common audit findings involve R2T4, and 20-30% of all findings are related to R2T4. The process necessitates a tedious exchange of information between instructors, academics, bursar, registrar, and financial aid. It is more cumbersome than actually awarding aid in the first place!! The calculation isn’t logical either. In a module program, you effectively have double- pro-ration of Pell Grants, which all but takes away Pell Grants from a withdrawn student. They Should allow calculations to be made at the scheduled end of a semester, as students may take a module off unscheduled, requiring a refund a reapplication process when they return.
I think you will see more administrative and compliance ‘slip-ups’ in financial aid offices that will have a devastating impact on a particular college, especially at smaller institutions where one or two people that have too much responsibility for all of these regulations.
Consumer disclosure requirements are important, but they have evolved to where it is a huge effort to comply, and students have become numb to constant notifications. We really need a reset to provide information in one place, one format - College Navigator, constitution day, voter registration, campus safety and crime statistics, VAWA, FERPA notices, athletics, notice of consumer info available, shopping sheets, information for veterans, and gainful employment program disclosures.
And on GE, we have an enormous reporting burden on the horizon, similar to what we had before the last reporting requirements were vacated. It literally took a team of programmers months to extract and format data per the specifications which required a separate record for every enrollment instance a student had. Very detailed information, and I can’t see how that information could have been interpreted properly for every college with the multitude of systems and policies that the data reflected.And on top of that, this regulation will say that a high school grad who earns 1400/month with no debt is better off than a college educated person earning 2000/month 2 years after graduating with a 250/month loan payment. That person would need to have payments of no more than $160 a month to be considered gainfully employed. Additionally, when you think about it, it really doesn’t make sense to measure the value of an education based on a wage reported to SSA a few years after graduation. We know that degrees have a huge lifetime lift in earnings and every higher level of degree obtained is worthwhile. Actually data and employers show that the program you choose is FAR more important than where you pursue your degree. We should be focusing on getting students into fields that are valued by employers if we want to see more students gainfully employed….and happier employers.
Verification – simplifying verification involved creating 5 verification forms over the previous one. Just adds more training and confusion.
150% direct sub loan limits per grade level. This is a huge administrative burden, but it is also going to prevent students who got degrees in less employable fields from being able to go back and get a degree in a field where they can actually get a job and have a more lucrative career. They will more often be finding their T4 resources restricted to the point they will be unable to pursue a different field.
IRS Police - We also tend to be policing the accuracy of tax returns, which should be the job of the IRS
Regulation has increased over time as a direct response to deceptive practices among post-secondary education providers. I am a new employee at a relatively new school so I don't have a historical perspective; however, we currently do spend a significant amount of time on regulations and documentation.
The biggest impact has been on additional reporting requirements and the designated staff needed to complete reports. Smaller institutions do not have designated departments to complete these time consuming reports. College's have incurred additional expense to complete these tasks.
I believe that the regulations have changed in the past few years for the school I work at, due to the accreditation, but I feel that regulations and standards are important for quality and integrity of a school. I have always had to adhere to regulations coming from the military technical school environment, and I feel it is a critical trait of an organization's culture as well as status. I feel the regulations will continue to be strict and is meant to ensure a ethical approach to school management is maintained.
Vickie and David, Thanks for your on-target comments:
It's almost a situation of "the forest as opposed to the trees." We have no choice but to acutely focus on compliance, but, as you suggest, doing it simply to meet a regulatory requirement often leaves the student out of the equation. I agree that compliance and ethics are not the same thing - compliance ensures we adhere to the checklist and ethics, moreso, guide our actions for a greater good. Additionally agreeing, compliance and student satisfaction are not the same thing - compliance sets a minimum benchmark where student satisfaction requires, and rightly so, a maximum effort.
Jay Hollowell
The increasing regulatory environment has impacted schools in so many ways over the years, and the impact is still increasing. Particular areas include additional disclosures (gainful employment, completion rates, new VAWA regulations, etc) Secondly, with the changes in the CDR regulations and the potential changes in 90/10, compliance is even more of an administrative burden to a school.
I feel that in order to keep up with this ever-changing environment, schools with limited resources are forced to spend more time on "compliance" leaving less time to spend on "student satisfaction".
Well said, David!
I think you have hit on a crucial observation regarding the characteristics of a compliance culture. As you reference, there are ways to comply to the necessary full disclosure of information needed by students to make informed decisions about their education, however, a culture of compliance looks not only at adhering to a regulation or requirement, but focuses on the best, most helpful and student-friendly way to disclose the information. A huge difference! Thanks for your comments!
Jay Hollowell
I agree, David. Compliance is not necessarily synonymous with ethical. Just because we comply with every regulation or standard, there are still ways in which schools can be unethical.
The increasing regulatory environment has impacted schools in so many ways over the years, and the impact is still increasing. Particular areas include disclosures (gainful employment disclosures, completion rates, new VAWA regulations, etc) Secondly, with the changes in the CDR regulations and the potential changes in 90/10, compliance is even more difficult.
Personally, I feel that in order to keep up with this ever-changing environment, schools with limited resources are forced to spend more time on "compliance" leaving less time to spend on "student satisfaction".
I think it's important to note that "compliance" is not necessarily synonymous with being transparent or ethical, though we all certainly hope "being compliant" is close enough to get the job done. For example, if we're hypothetically handing students 200 pages of small-type documentation upon enrollment, detailing placement rates, policies and procedures, financial aid availability, and so on, all nestled into a verbose, opaque document filled with legalese and industry-specific jargon, we might be "compliant" in that we're "providing" all of the necessary information a new student might need, but we're not being particularly transparent - we all know there's no way a prospective student is realistically going to read all 200 pages of that document, much less understand 95% of the industry-specific legal boilerplate within it. It's bad enough when cell phone companies and cable companies do that sort of thing - the last thing we need is for colleges to start embracing that tradition as well.
Jeanine,
Thank you for joining the forum. It is good to know that your campus is holding itself to very high standards.
Cindy Bryant
The regulatory environment has become more stringent over the past few years. The school that I work for has always held the highest level of standards in adhering to USDE and accrediting agency. We have had more internal audits to ensure all files are in compliance. As a campus, we are all working as a team to have a basic understanding of each departments policies and procedures. This promotes better communication and awareness of what is required for each department. This helps us to provide our students with a positive and healthy learning environment.
Aaron,
While the more restrictive work environment has been difficult and burdensome for many schools the positive side is that much more training is occurring across the country and the colleges are becoming stronger. Federal aid will always be changing and dependent upon where the U.S. sits economically the regulations will become more lenient or stricter.
Cindy Bryant
I have seen tighter and more rigorous changes to my own schools policies and procedurs. There has also been an increase in training and offered learning to stay ahead of all the changes that constantly occur in the financial aid world. To be blunt, it has gotten more and more difficult, while the funds available to the students have diminished or become harder to secure. Hopefully things may change in the future, but I dont know...
Every year that passes has seen tighter and more directed changes to the Financial Aid process on the Federal and State requirements. While many of these changes are good and attempt to stop certain people from abusing the system, they also force more process steps for everyone, both for prospective students and Financial Aid officers. Most of the changes force a student to shorten their time while pursuing higher education or only allowing for a few choices, and can be a bit unforgiving if a student makes a mistake or changes their mind. This is just my perspective of the last 10 years in Financial Aid.
Trudy,
Good evening...thank you for sharing your thoughts with the forum.
Cindy Bryant
The regulatory environment has become one that is particularly discriminatory towards proprietary schools. For example, when ideas about Gainful Employment regulations were floating around, the staff here were very confused that it solely applied to us, but not public or private colleges and universities. Why would the government not be equally concerned that graduates of those institution be working in a way to be able to pay back their student loans? The way regulations are imposed it feels like there is an assumption of guilt until proven innocent.
The impact of these changes is that we are relying more heavily on organizations like OACCS to remind the government to even the playing field by recognizing the vital role we play in working with an underserved population that has so many strikes against them. For example, we take on a population that is more likely to default on their loan due to lack of financial literacy and is more likely to take out full loan borrowing for living expenses to make ends meet. That doesn't mean we didn't do our job in raising up their living situations.
