Request to Identify Burdensome Regulations: Disclosures, Reports

By Joan Berkes, Policy & Federal Relations Staff

NASFAA continues to seek member input about regulations that should be recommended to the Department of Education (ED) for repeal, replacement, or modification. The initial article in this series explained the basis of this solicitation and requested input on verification. The second article sought opinions on rules related to the return of Title IV funds for withdrawn students, and on the Direct Loan Program. The third article concerned the Pell Grant and campus-based programs, and issues related to non-traditional program formats. Today we seek member views on regulations governing disclosures (including student consumer information) and reporting requirements. Appendix F to the FSA Handbook describes the various institutional disclosure and reporting requirements.

Please give your recommendations either as a comment to this article, or in an email to, using the subject line "Regulatory Reform."

When submitting your recommendations, you may want to consider the following:

Reports and reporting can be an important source of data to inform public policy, but how much is enough? Other reports are generated to communicate information to ED that is needed to administer Title IV programs, such as eligibility and disbursement. Is there unnecessary duplication? Is timing appropriate and are deadlines reasonable?

There is a plethora of disclosures associated with Title IV participation, many of which are required by law. Content, timing, targeted population, and methods of distribution may all be sources of unnecessary burden. What do students and their families need to know about your institution, and is there a way to streamline that information without sacrificing transparency?

Since disclosure requirements are a tangled amalgamation of statutory, regulatory, and procedural rules, please be as specific as you can about burden improvements you'd like to see.


Publication Date: 8/7/2017

Jeff A | 8/7/2017 2:29:05 PM

Many disclosure items are already collected by ED. Let's consolidate all disclosure requirements under the framework of the College Scorecard.

Lissa W | 8/7/2017 10:34:46 AM

In addition to the GE disclosure template requirements required in Part 668.412, colleges and universities are often required to disclose multiple consumer information documents required by state approval agencies, chancellors offices or accrediting bodies. In many cases the information disclosed in these additional consumer facing documents offer similar outcome information based on differing cohorts required for data collection and reporting.

Prospective students searching for educational programs that match their career objectives are best served by simple, direct and factual information that provides a snapshot of program outcomes. Establishing a minimum gainful employment disclosure requirement for prospective students that could be met by state or accreditation requirements would eliminate the need for a GE template if the disclosure requirements have been met by an alternative regulatory requirement.

I would like to suggest that Title 34 Part 668.412 should be reviewed for reciprocity with all other regulatory agencies requiring program outcomes disclosure requirements.

Joel T | 8/7/2017 10:14:15 AM

1) Gainful Employment
2) Net Price Calculator
3) Shopping Sheet

All three are seemingly viewed by no one and are nothing more than an administrative burden to colleges and universities. At some point I think we should ask ED why were are providing information that no one looks at except for them...

I would also admit that Consumer Information is quite the bear to maintain, but I do believe that it's a good idea to have a hub that houses information in one place for students to review.

Eric A | 8/7/2017 9:48:13 AM

Consumer info is WAY TOO BURDENSOME and complicated. Takes an army on campus to maintain, and no student looks at the info. SULA is a waste of time, since aggregate sub limits already took care of this issue. Shopping Sheets also need to go. Such a pain to manage those with our software company.

Laurie W | 8/7/2017 9:15:49 AM

I completely agree with Tony's comments regarding SULA. Overly burdensome and redundant sums up my feelings about SULA regulations, not to mention difficult to explain to students and parents.

Tony L | 8/7/2017 9:2:52 AM

I'd like to see the SULA regulations be repealed. The reporting is overly burdensome and it is a redundant regulation as annual and aggregate Subsidized limits were already in place.

Jan B | 8/7/2017 8:14:45 AM

I'd like for the electronic delivery of the consumer information disclosures to be clarified (so that electronic delivery is OK) since some disclosures have to be distributed on paper (at least, that's the way it's interpreted at some schools). "On paper" is not up-to-date in this electronic day and age...the regulations should be clarified.

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