Student Entrance And Exit Counseling: What Are The School’s Responsibilities?

1. Student Entrance And Exit Counseling:What Are The School’s Responsibilities? Connections Collaboration Communication Ohio Association Of Student Financial Aid Administrators 2011 Spring Conference “Collaboration, Connections, Communication”

2. Before We Begin • The information contained in this presentation is not comprehensive, is subject to constant change, and therefore should serve only as general, background information for further investigation and study related to the subject matter and the specific factual circumstances being considered or evaluated.  Nothing in this presentation constitutes or is designed to constitute legal advice.

3. Agenda • Entrance Requirements • Exit Requirements • Exit Best Practices • Case Western Reserve University • Ohio State University • Baldwin-Wallace College • Best Practices Discussion • Leveraging Entrance and Exit to achieve school debt management and financial literacy goals.

4. Source for School Requirements • NCHELP Integrated regulations. • http://www.nchelp.org/elibrary/index.cfm?parent=86 • 34 CFR 685Integrated Regulations Incorporating Program Integrity Final Rules (published in October 29, 2010 Federal Register) and Gainful Employment Final Rules (published October 29, 2010) and Foreign School Final Rules (published in November 1, 2010 Federal Register) Developed by the NCHELP Program Regulations Committee. Updated: 12/06/2010

5. Entrance Requirements • § 685.304 Counseling borrowers. (a) Entrance counseling. (1) Except as provided in paragraph (a)(8) of this section, a school must ensure that entrance counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan student borrower prior to making the first disbursement of the proceeds of a loan to a student borrower unless the student borrower has received a prior Direct Subsidized, Direct Unsubsidized, Federal Stafford, or Federal SLS Loan.

6. Entrance Requirements (2) Except as provided in paragraph (a)(8) of this section, a school must ensure that entrance counseling is conducted with each graduate or professional student Direct PLUS Loan borrower prior to making the first disbursement of the loan unless the student borrower has received a prior Direct PLUS Loan or Federal PLUS Loan. (3) – (7) See handout for entrance requirements. (8) A school may adopt an alternative approach for entrance counseling as part of the school’s quality assurance plan described in § 685.300(b)(9)….

7. Entrance Requirements (9) The school must maintain documentation substantiating the school’s compliance with this section for each student borrower.

8. Exit Counseling • Source for following slides is the same: 34 CFR 685 (i.e. Direct Loan entrance and exit counseling). • While FFELP is no longer originating new loans, schools may still have students graduating with FFELP loans. • FFELP regulations are in 34 CFR 682. • NSLDS Exit Counseling covers both programs.

9. Exit Requirements (b) Exit counseling. (1) A school must ensure that exit counseling is conducted with each Direct Subsidized Loan or Direct Unsubsidized Loan borrower and graduate or professional student Direct PLUS Loan borrower shortly before the student borrower ceases at least half-time study at the school.

10. Exit Requirements (2) The exit counseling must be in person, by audiovisual presentation, or by interactive electronic means. In each case, the school must ensure that an individual with expertise in the title IV programs is reasonably available shortly after the counseling to answer the student borrower’s questions. As an alternative, in the case of a student borrower enrolled in a correspondence program or a study- abroad program approved for credit at the home institution, the student borrower may be provided with written counseling materials within 30 days after the student borrower completes the program.

11. Exit Requirements (3) If a student borrower withdraws from school without the school’s prior knowledge or fails to complete the exit counseling as required, exit counseling must be provided either through interactive electronic means or by mailing written counseling materials to the student borrower at the student borrower’s last known address within 30 days after the school learns that the student borrower has withdrawn from school or failed to complete the exit counseling as required.

12. Exit Requirements (4) The exit counseling must— …. See handout for exit requirements. (5) The school must ensure that the information required in paragraph (b)(4)(xiii) of this section is provided to the Secretary within 60 days after the student borrower provides the information. • (b)(4)(xiii) Require the student borrower to provide current information concerning name, address, social security number, references, and driver’s license number and State of issuance, as well as the student borrower’s expected permanent address, the address of the student borrower’s next of kin, and the name and address of the student borrower’s expected employer (if known).

13. Exit Requirements (6) If exit counseling is conducted through interactive electronic means, a school must take reasonable steps to ensure that each student borrower receives the counseling materials, and participates in and completes the exit counseling.

14. Exit Requirements (7) The school must maintain documentation substantiating the school’s compliance with this section for each student borrower.

15. Dear Colleague Letter 2010-03-29 • Subject: New Exit Counseling Tool on the National Student Loan Data System (NSLDS) • http://ifap.ed.gov/eannouncements/0329NewExitCounselingToolNSLDS.html • Key Facts About Exit Counseling Requirements and the New NSLDS Tool • NSLDS Newsletter #26 • Record Layouts for Schools • Technical Update and Record Layouts for Lenders • Submittal Template Spreadsheet for Upload Tool • Future Enhancements • Contact Information

16. Exit Counseling • New to DL for 10-11 • Previously Mapping Your Future • Our Plan: • Run list of graduating students w/ loans • Populate in ProSAM document tracking • Withdrawn/Less than half time students

17. Exit Counseling Continued • E-mail students exit counseling information as well as a link to NSLDS • Pull in exit counseling completion information from SAIG mailbox • PDF Attachment to e-mail • Train/Update Staff • Coordinate with Graduate Schools

18. Entrance Counseling • www.studentloans.gov • Students with PLUS Loan – Document Tracking • Pull in files daily • Required for origination in ProSAM • Foreshadow during orientations for students and parents

19. OSU Entrance Counseling Process • Loan Entrance Counseling” becomes a to-do list item in the student’s self-service portal when they become required to complete entrance counseling • Files containing lists of students who have completed entrance counseling are sent to our SAIG mailbox and retrieved • The information from these lists is updated in our SIS through an automatic process • The completed entrance counseling to-do lists are rolled forward each year

20. OSU Exit Counseling Process • “Loan Exit Counseling” becomes a to-do list item in the student’s self-service portal when they become required to complete exit counseling • Files containing lists of students who have completed exit counseling are sent to our SAIG mailbox and retrieved • These lists are then compared to a list of outstanding exit counseling to-do checklists from our SIS using a homegrown database • The comparison process exports a list of to-do checklists that we update manually in our SIS

21. OSU Exit CounselingCommunication Timeline *Exit counseling also becomes a “to-do” list item in the student’s self-service portal at this time.

22. Baldwin-Wallace CollegeEntrance Counseling • All new students are informed that our office will not be able to originate their loans until they complete both the Entrance Counseling and Master Promissory Note (MPN) on studentloans.gov • Entrance Counseling/MPN information is downloaded into our system when complete. • DOE Entrance Counseling Guides are available at Orientation and in the Financial Aid Office

23. Baldwin-Wallace College Exit Counseling • Graduation lists are retrieved from the Office of Registration and Records • Email notices are sent to all students on the graduation list with a link to the “Exit Counseling” web page and an invitation to attend a “Financial Literacy/Exit Counseling” session in April. • Group sessions are scheduled on two days in April (3 sessions/day) • Students continue to receive emails until they’ve completed the online Exit Counseling

24. Baldwin-Wallace CollegeExit Counseling (continued) • Exit Counseling information is downloaded into our system when complete and reports are generated. • DOE Exit Counseling Guides are available at the group sessions and in the Financial Aid Office. • Exit Counseling web page includes: • DOE Online Exit Counseling • NSLDS Link • Links with information on repayment options, consolidation and forgiveness/cancellation • Repayment calculators • Ombudsman information • Financial literacy information

25. Questions? • Thank you! • Jeff Johnston, Sallie Mae • Adam Dilulio, Case Western Reserve University • Casey Kearns, Ohio State University • Carrie Euype, Baldwin-Wallace College • Cheryl Willard, Baldwin-Wallace College Ohio Association Of Student Financial Aid Administrators 2011 Spring Conference “Collaboration, Connections, Communication”