NASFAA Resources to Help Members Comply with Consumer Disclosure Requirements

In light of a new report that suggests some institutions are struggling to comply with new consumer information requirements, we would like to highlight the many resources NASFAA provides to help members comply with the complex  and ever-growing disclosure regulations.  

According to the report, "The Truth Behind Higher Education Disclosure Laws," the "large majority" of higher education institutions are in noncompliance with consumer information disclosures required in order to be eligible for federal financial aid under Title IV of the Higher Education Act. Education Sector and the American Enterprise Institute for Public Policy Research developed the report by posing as students and contacting a random sample of 152 public and private four-year colleges and universities to obtain information colleges are required to provide under the Higher Education and Opportunity Act.

The report recognizes that the "law itself allows so much variation in compliance as to render much of the information all but useless for students and parents choosing colleges." However, the report also found that:

  • Only 25% of schools provided requested information on graduation rates for Pell Grant recipients
  • 60% provided requested information on types of graduate and professional education that graduates of the institution’s four-year degree programs enroll
  • 67% provided requested information on employment placement

While schools seem to struggle with the above disclosures, a larger percentage of the contacted schools provided other consumer information:

  • 99% provided credit transfer disclosures
  • 97% provided textbook price disclosures
  • 86% provided information on articulation agreements
  • 86% provided private loan disclosures

The amount and variety of consumer information schools are required to disclose has increased rapidly since 2008 creating a serious administrative challenge. Some institutions have had to implement as many as 25 new reporting requirements since 2008 -- an increase of nearly 50 percent. The complexity of these disclosures vary greatly. Some, like the net-price calculator, are extremely complicated to implement. Others, like gender ratios among part-time assistant coaches (as highlighted by the report, "The Truth Behind Higher Education Disclosure Laws") are less complicated but still require time and money to report.

NASFAA continues to advocate lawmakers, policymakers and Obama administration officials at the U.S. Department of Education to simplify disclosure requirements to more effectively communicate consumer information to students and families and reduce the administrative burden. We continue to highlight that growing disclosure requirements are a huge administrative burden and can be more confusing, duplicative, and voluminous than helpful to students.

While our advocacy efforts continue, we encourage you to utilize the resources below to ensure your campus is in compliance with all the disclosure requirements to eliminate any possibility of losing eligibility to participate in the Title IV student aid programs.

Disclosure Resources:

NASFAA Member Resources:

HEOA Summary 

2010-11 Self-Evaluation Guide, Part 1 

  • Section 6: Consumer Information
  • Section 7: Family Education Rights and Privacy Act (FERPA) 

NASFAA Policies & Procedures Tools 

  • Section 5: Consumer Information Requirements

Private Education Loan Disclosure Models 

Compiled Title IV Regulations   

  • Part 601—Institution and Lender Requirements Relating to Education Loans, Subparts B and D
  • Part 668—Student Assistance General Provisions, Subpart D

2011-12 CORE -- Financial Aid Fundamentals

  • Toolkit C: Guide to Student Financial Aid Reporting, Disclosure, and Recordkeeping Requirements* 

Program Integrity and Gainful Employment Guidance 

Net Price Calculator Buyer’s Guide (NASFAA website under Members/Professional Practice Tools/How-to Guides tabs)

Net Price Calculators: Finding the Right Fit (Student Aid Transcript Vol. 21 No.3)

The Award Letter: A Model Concept Tool 

U.S. Department Of Education Resources: 

2010–11 FSA Handbook: Volume 2, Chapter 6 -- Providing Consumer Information

Information Required to be Disclosed Under the HEA -- Suggestions for Dissemination (National Postsecondary Education Cooperative)

IFAP Gain Employment Disclosures Q&A 

2011 NASFAA Conference Presentations 

  • Consumer Information
  • Gainful Employment
  • The New Net Price Calculator
  • Program Integrity Regulations   

Final Rule: Disclosures Required by Program Integrity Rules (Federal Register)

Final Rule: Family Educational Rights and Privacy Act -- FERPA (Federal Register)

GEN-11-12: Students Enrolled for a Trial Period That Leads to a Regular Student (Dear Colleague Letter)
see discussion for standards of participation 

GEN-11-10: Gainful Employment Disclosures  (Dear Colleague Letter)

GEN-10-09: Guidance to Assist Textbook Publishers and Institutions of Higher Education in Implementing Section 133 of the HEA  (Dear Colleague Letter)

GEN-10-08: Institutional Requirements for Combating the Unauthorized Distribution of Copyrighted Materials by Users of the Institution’s Network  (Dear Colleague Letter)

Resources for Students and Parents

 Tools to Help Students Evaluate Colleges 

Choose a Trade or Vocational School Carefully 

Family Policy Compliance Office (FPCO) 

FERPA for Students 

College Preparation Checklist 

College Affordability and Transparency Center 

College Navigator Website 


Publication Date: 11/4/2011

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