Jeanine,
Thank you for joining the forum. It is good to know that your campus is holding itself to very high standards.
Cindy Bryant
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.
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".
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
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".
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
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.
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.
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.
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
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
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.
I have a question. What if your training is not adequate enough to know what you are saying is true?
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.
Regulatory processes have affected our school with regard to placement rates. We have developed and written policies and procedures for every step of the admissions process including: scripts, training manuals, and additional disclosures. These have allowed us to not only to adhere to compliance with each individual applicant, but to remain honest and transparent as well.
Amanda,
Thanks for your question. It is, of course, imperative that an institution's associates are confident in the training they are receiving. If not, the institution as a whole, in collaboration with employees, should research and implement training that is current, accurate and on-target, particularly if the training relates to compliance and regulatory requirements. That aside, if an associate is unsure of what he or she is saying is true, when interacting with students or potential students for example, then they are best to be conservative and base such communications on information, such as student outcomes, that is accurate, transparent and fully disclosed. The school catalog is also an important resource for school information as long as it is correct and up-to-date in its content. Hope this helps.
Jay Hollowell
Terrence,
Absolutely, working professionals that also have a sense of community and service! Thanks!
Jay Hollowell
Gainful employment and the FERPA. My school is adhering to the new changes with positive attitude.
The current administration is not for-profit friendly. For example: the proposed gainful employment regulations would increase undue scrutiny mainly on the for-profit sector, while not applying the same amount of scrutiny on the public sector. Public colleges and university take the same federal aid and grant degrees that do not lead to gainful employment.
The impact is still increasing, With that we will see an increase in faculty and staff training. Schools must ensure they are in compliance to maintain higher standards of the programs being offer providing gainful employment.
