Shoptalk 612, July 12, 2011

Industry Update

ED provides gainful employment guidance regarding degree programs that include certificates

In Dear Colleague Letter (DCL) GEN-11-10, ED provided guidance to assist schools in identifying gainful employment (GE) programs. ED stated that for public and private nonprofit schools, awarding students one or more certificates as part of a degree program does not create a GE program based upon the awarding of the certificates. However, nearly all degree programs offered by for-profit schools are GE programs. The only exception is a program that leads to a bachelor's degree in liberal arts, provided the school has been regionally accredited since October 2007, and has offered the program since January 2009.

In a new electronic announcement #12 published July 8, 2011, ED provides supplemental guidance regarding a student who is enrolled in a degree program in which the student may also receive a certificate during the program. The announcement provides guidance, as follows:

If students are enrolled in a certificate program, even if the enrollment is concurrent with enrollment in a degree program, these students must be included in the certificate GE program's reporting and disclosures. If the degree program itself is considered a GE program (i.e., the degree program is being offered by a for-profit school), these students must also be included in the GE degree program's reporting and disclosures as noted in electronic announcement #11.
If a "significant number" of the students enrolled in the degree program are awarded only a certificate and not the degree, the students enrolled in the degree program must be included in the disclosures and reporting for students enrolled in the certificate program. This means that degree program students will be reported as certificate program students for this purpose.

ED did not define a "significant number" of students. A school will need to make a reasonable determination as to what constitutes a significant number of students for this purpose.
If the degree and the certificate programs are not separate programs, and a significant number of the students enrolled in the degree program are awarded only the certificate, the school must treat the degree program as a GE certificate program for which the school must comply with the gainful employment regulatory requirements.

Learn more
In addition to TG's flowchart, "Identifying a Gainful Employment (GE) Program," you'll find a variety of other resources for understanding the new requirements through TG's Program Integrity Final Rules Web page and ED's Gainful Employment Information page. For specific questions, please contact TG's Customer Assistance team at (800) 845-6267, or send an email message to cust.assist@tgslc.org.

Current special allowance rates: quarter ending June 30, 2011

For the quarter ending June 30, 2011, the average rate for three-month commercial paper (financial) was 0.19 percent. This rate is also used to compute the Participant Yield paid to ED on loans subject to the loan participation purchase program. For loans where the special allowance payment is based on the bond equivalent rate of 91-day Treasury Bills, the average rate during the quarter ending June 30, 2011, for 91-day Treasury Bills was 0.05 percent.

The FFELP special allowance rates for the most recent quarter are available on TG Online.

Questions
If you have any questions, please contact TG Customer Assistance at (800) 845-6267, or send an email message to cust.assist@tgslc.org.

Closed school corner

The following table provides a list of newly reported school closures and corrections from the Postsecondary Educational Participants System (PEPS) and from the July 2011 Closed School Monthly Report supplied by ED. Schools listed are those with which TG has done business or to which TG has otherwise provided services.

Newly reported closures
OPE School ID	School Name/Address	Unofficial Closure Date	ED's Official Closure Date
00349800	Lambuth University 705 Lambuth Blvd. Jackson, TN 38301-5296	N/A	06/30/2011