Reporting Gainful Employment Data to NSLDS



Reporting Gainful Employment Data to NSLDS

Event ID: 321934

June 28, 2011 Webinar

Angela Smith: Hello everyone, and welcome to our webinar regarding Reporting Gainful Employment Data to NSLDS presented by Valerie Sherrer, Director of Enterprise Systems Management and Jeff Baker, FSA's Director of Policy Liaison and Implementation. My name is Angela Smith and I will be moderating today's session.

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Jeff Baker: Thank you Angela and thank you everyone for joining us this morning and we know it's particularly early for our colleagues on the West Coast. We appreciate your participation. This is the second in a series of webinars on Gainful Employment requirements. The first one we did about a month ago as a general overview of Gainful Employment and we discussed the regulatory requirements for reporting of information about students who are enrolled in Gainful Employment Programs. We discussed some of the disclosure requirements under the regulations and we mentioned briefly the requirements for adding of new Gainful Employment Programs.

This webinar is going to talk specifically about the process that will be used to report Gainful Employment information to the department using National Student Loan Data System, NSLDS, and after I give a little more introductory remarks here, Valerie will take you through the slides and take you through the process by which you will use to report Gainful Employment information. I want to emphasize what this webinar is not about. It is not going to be a very thorough description or re-description of the reporting requirements in terms of the regulatory requirements, although we will mention them. It is not going to talk about disclosures. We covered that in the earlier webinar.

And as you know, on June 13 we published another set of final regulations on Gainful Employment having to do with the metrics that will be used to determine whether a program is indeed a Gainful Employment Program. This webinar will not cover that set of regulations except very briefly in just a moment.

With that in mind, I would ask in the spirit of cooperation among yourselves to please limit your questions to questions related to the reporting of gainful employment information to the department using NSLDS -- the topic of this webinar. And if you'll be a little bit patient, you will see that Valerie has a pretty thorough presentation, so perhaps many of your questions will be answered. But please don't ask other kinds of questions, so that we can get through the ones that your colleagues are asking or at least as many as we can.

So that said, these are the topics we are going to talk about. It looks like a lot there. There is important information and downloading the presentation is an important thing to do. Plus we will be posting this webinar to our IFAP website within the next couple of days.

We have established, and hopefully you are all aware, a page on our IFAP website where you can get all kinds of information about the Gainful Employment requirements. What you see on the screen here is the URL that will take you directly to that screen. You also of course can get to it from the home page of ifap.. And we are hopeful that you are checking that website on a fairly regular basis. It includes not only the regulations but electronic announcements about Gainful Employment. We just posted Gainful Employment Announcement number 11 just on Friday to help understand what a Gainful Employment Program is. And we also have an extensive list of frequently asked questions and answers that we are updating at least two or three times a week. So please check this page on a regular basis.

I want to remind people of the authorities and the effective dates for these regulations. Under the statute of the Higher Education Act, for all intents and purposes there are only two kinds of educational programs that qualify for Federal Student Aid. Those are programs that lead to a degree or programs that lead to Gainful Employment. There are no recreational programs that are eligible for Title IV aid. They have to be degree programs or lead to Gainful Employment.

To summarize, and you have seen this information before, hopefully, it's on our website. It's in the Dear Colleague Letter GEN-11-10 and we did cover it in the earlier webinar, but to remind people that proprietary institutions and post technical vocational institutions, all of your programs, virtually all of your programs are Gainful Employment Programs, even degree programs, even degree programs. There are a couple of exceptions and you see them on the slide here.

At public institutions and not-for-profit institutions, any program that is not a degree program, with a couple of exceptions, is a Gainful Employment Program. So the big difference is that for-profit institutions, all programs or virtually all programs are Gainful Employment Programs and therefore is subject to the regulations. At not-for-profit and public institutions, degree programs, all degree programs are exempted. They are not Gainful Employment Programs.

We published two sets of final regulations on October 29 and because we publish it by November 1, 2010, these regulations go into effect July 1, 2011. We will talk about little difference on reporting in just a moment. Those regulations were part of our program integrity, regulatory package -- the reporting and the disclosures. And then on that same day, October 29, but a separate publication we issued the final regulations on the addition of new programs. And then as I mentioned on June 13 we published final regulations on the metrics that will be used to define the Gainful Employment Program.

As I noted I'll take a couple of seconds here to just summarize at a very, very high level the Gainful Employment metrics but that is not the focus of this webinar nor will we respond to questions about the metrics. We have in planning at least one and probably a couple of webinars on the metrics but it is much more important to give you as much information as possible about the reporting.

On the Final Rule we published on June 13, it defines a Gainful Employment Program as one where a significant -- and these are paraphrasing -- substantial number of the program's students are repaying their loans and we calculate what's called a repayment rate and of those students who completed the program, their educational debt is not an exceptionally high percentage of their income. And those are called debt to earnings ratios.

We will be issuing informational rates, in other words not official, there will be no sanctions or responsibilities but we will be issuing informational rates in the winter or spring timeframe of 2012 based upon among other things the data that you report to us and reporting by October 1 and then the first official rates will be issued in the winter or spring of 2013.

The Repayment Rate is the percentage of the programs, not the schools but each Gainful Employment Program, of the program's former students who are repaying their Title IV loans. And we look at the beginning and the end of a federal fiscal year to see if the students are repaying the loans.

The debt to earnings ratio -- and actually there is two ratios -- is for the students who completed the GE program. On average we look at their average educational debt, convert that to an average annual payment responsibility and compare that to the average earnings of the students who completed the program to come up with a ratio. And if the ratio is too high, that could be a problem for the educational programs. So the bottom line is that what these regs do is say that since the law says it must lead to Gainful Employment, we are defining under these regulations gainfulness, if that's a word, to be where a significant number of students are repaying their loans that they took out to get that education and that whatever they are paying it is not an exceptionally high proportion of their income.

On reporting, in summary, as I mentioned the regulations October 29 about reporting, we issued Dear Colleague Letter GEN 11-10, which you hopefully have already reviewed, if not we urge you to take a look at them. There was an attachment to that letter which we gave you our first draft of the data items that need to be included when you do your reporting.

We will be developing ways that you can look at the information that you report and we published an NSLDS Gainful Employment User Guide. We actually published two of them, the latter one of course is the latest one and that's the one that Valerie will be referring to. As you go back to your desk with information from this webinar, take a look at the guide and you will know what you need to do to report.

As noted, we originally posted the user guide on May 23 and then an updated one on June 3 where we acknowledge that were not going to have an XML reporting option and we added the tuition and fees component. That came out of the final regulations on June 13 to be an option for schools to report tuition and fees. We will be releasing another version of the user guide at the end of July.

We want to remind you that reporting is by institution, by award year, and then by student and then by the Gainful Employment Program. So a Gainful Employment Program is the institution's six-digit OPEID combined with the classification of instructional program, the CIP code, for the program and the credential level. And we have a listing of the credential levels in the user guide.

Because that's the way you will be reporting, it's possible for students to be reported more than once. If they were enrolled in more than one GE program at the school in more than one award year or the same GE program in more than one award year, if they were enrolled in more than one in different GE programs even within the same award year, you will be reporting the student multiple times. And then of course it's possible that a student was enrolled in a GE program during the award year, left without completing and then came back in that same award year, you would be reporting that student twice and that's because some of the data that we collect have to do with when the student began and ended enrollment during the award year.

Under the regulations, the first reporting will be for award years 2006-2007 through the 2010-2011 award year, the award year that's got like three more days in it, two more days in it to end, June 30, 2011, you will be reporting. Once we get by this first initial reporting, you will do award year by award year, then after this it will be one award year at a time after the completion of the award year.

Under the regulations, the reporting is due October 1 following the end of the award year. So this first reporting for these five or six award years will be due October 1, 2011. Because we are building it the same time you are, we will be ready to receive our NSLDS information on the last week or so of September.

After that you'd be able to send information throughout the year for the award year. But if you do that, you will have to make sure that your final report is up-to-date and has the proper reporting for all of the students who are enrolled in the GE program.

We do have provision in the regulation that says if a school is not able to report information on either some of its students or all of its students or all of the information on some or all of its students, you have to let us know. There is an email address there on the screen and you will have to tell us what the problem is, what it was caused by and how you are going to fix it.

Look for more information, probably an electronic announcement on this over the next couple of weeks. We will give you a little more guidance about how to structure that message. But I want to make it clear, this would be an exception, it is not acceptable to say I didn't report because I didn't get to it. These regulations have been out for several months now and you still have three more months for the reporting. This would be an extraordinary situation why you weren't able to provide the information.

And just to summarize, you will be reporting all students who are enrolled in GE Programs, GE Program by GE Program within an award year. They can be reported more than once as I mentioned, including stopped out and reentered students and students who were in the same program over multiple award years or in multiple programs within the same or multiple award years.

So that's a pretty high level summary. I hope we didn't go too fast. It should not for most of you be new information, just a reminder of things we have discussed in the other webinar and in the information we posted to our website. So Valerie is going to take us through the NSLDS reporting.

Valerie Sherrer: Hi, good morning, and thank you Jeff. Before I get started with talking about the NSLDS setup, I want to emphasize that this presentation today is based on your using the NSLDS User Guide. So, as you will see references as I go through slides that tells you where to look for what I am discussing in the NSLDS User Guide.

You're also going to notice in your User Guide as it is published today we are missing Chapter 3. We are working diligently and trying to get Chapter 3 completed. By the end of July, we hope to have it posted so that you will have all of the screens. What we are going to today is as I walk you through it you will see the screens as we have them developed at this point.

The first thing we are going to talk about is your options for how to report data to NSLDS. Our goal was to design methods of reporting that fit every school's needs. So we're offering online reporting and which you can either use in an Excel spreadsheet to upload your data or you can enter each record individually online.

We are also offering two methods of batch reporting, either you can use a fixed length record or you can use a comma-separated value, CSV, as a means to report your data through the batch SAIG method. So in order to report your data, you must be set up as an NSLDS user.

You will ask your primary destination point administrator to make sure that you have access by having access to NSLDS enrollment features. So, when you sign up on SAIG under FSA web enroll, you will make sure that one of the capabilities you have for whoever is supplying the data to NSLDS, they have the ability to do enrollment. Now we're going to talk about what you need to do to set up reporting data by batch.

First, again, make sure that you have a person at your institution who is designated to have online access to NSLDS and has the functionality of doing enrollment. This person will be able to use a TG mailbox and they will have to identify the mailbox that will be used for us to receive your batch files as well as for us to send your error files to. So we are going to need a TG mailbox that you are going to identify for your institution.

Setup for GE can only happen on NSLDS. As you know, for many of our functionalities today if you are doing Perkins reporting or you are doing overpayment, you go to SAIG to set yourself up and that's one of the features that you are able to select through your SAIG enrollment. We're doing GE a little different, so the only way that you can enroll for GE reporting is to go to NSLDS ifap. and then you must go to the screens I am going to be reviewing what you just set yourself up and give us the TG mailbox that you will be using for batch reporting.

The TG mailbox that you use must be a mailbox associated with your school. It can be associated within any NSLDS online user or it can be that TG mailbox your school uses for batch reporting. But it must be associated with your institution. Again, the TG mailbox we can't stress enough can either be an individual TG mailbox or it can be your institution.

If you are going to use a servicer, you'll have to use our online process, this screen that I am going to review with you to put your servicer's TG mailbox in it. So I would advise schools to check with their IT department to see if your school's preference is that you use a central TG mailbox for all of your NSLDS batch reporting. If that is not the case and you don't really have any batch reporting to NSLDS then use the TG mailbox associated with the person who will be doing your GE reporting.

Here is the first screen that I'm going to be reviewing with you and that is the TG mailbox. This is where you will designate which mailbox you will be logging on to -- will be used for your batch reporting. You will enter your TG mailbox number here. Be very careful that it's correct because if you try to submit any of your files and the TG mailbox is wrong, all of your files will be rejected. So this is where you are going to enter and double check that you have entered the TG mailbox correctly.

We're offering you lots of flexibility on the mailboxes that you choose to use. The main campus can choose to report for any of its additional locations or it can report for itself individually. We are rolling our GE reporting up to the six-digit mailbox -- six-digit OPEID -- so any of the school's additional locations can use the mailbox associated with the six-digit OPEID.

Once you entered a mailbox, you will be able to see all of the locations for your six-digit code, all of the TG mailbox numbers, so a six-digit school, each of the additional location can go in and enter a mailbox for each of their campuses or you can decide which campus will be reporting for -- which mailbox will be used for each individual campus.

In the example we are showing you here, there are three schools, three additional locations, and two schools are using the same mailbox and one school will be reporting for itself. These are all choices that school can make for themselves. We also give you the ability again if each location decides that you want to report for themselves, the mailbox numbers are listed there. So any branch can see which schools -- which of their additional locations are reporting data. You can all use one mailbox or each additional location can use again individual mailboxes.

TG mailboxes. When you sign up for enrolling as an NSLDS user, any NSLDS user is assigned a TG mailbox. A mailbox is where we deliver reports -- any time you want to set up the batch file to NSLDS or any time we're sending you something back for errors because you have submitted a batch file.

So if you're doing enrollment reporting yourself, you would have used your mailbox to send us your enrollment files. If you have requested reports from NSLDS, those reports are delivered to either to a central TG mailbox or they're delivered directly to the mailbox associated for your user ID. So when enrolling for NSLDS access with your PDPA, you will be assigned a user ID on NSLDS, an SAIG will also give you a mailbox so that you can exchange data with NSLDS. Just to make sure you understand that TG mailboxes are just associated with where we can send reports as a user when you request it. And this same mailbox will be what we will use for uploading, and loading data if you decide to do it by batch.

If your school already has a central mailbox where all reports are sent to, where you do any of your batch functionality with NSLDS, that would be the mailbox you will use for this function. So you can either decide to report data to NSLDS at any location associated with the six-digit ID, again you can report the data, your main campus or any campus associated with that six-digit school code can report data.

We give you an example here of where we are looking at a school that's an 00 campus and they are reporting for all five of their locations. Or that school, same school, just could choose to have their 03 campus location report for several of their locations. Or each individual campus. In this example, location 4 and 5 have decided to do their GE reporting individually. We will roll up all of their data into one measurement when we are reviewing the school's data.

Again, the TG mailbox, all files for this, for what we just reviewed for the six-digit OPEID must come from a set up TG mailbox. We are just trying to emphasize, you must have a mailbox in order for us to process your GE data and that mailbox must be associated with your institution.

If you are going to use a servicer and if you are the servicer, first the school must identify the servicer in their set up as the TG mailbox that's associated with your school. And we will allow the servicers to report multiple locations or multiple schools in one file. So, if you're a servicer, in this case we are looking at Servicer Sue. Servicer Sue has three schools that they are doing business, three distinct six-digit OPEIDs. And with this, the servicer is able to report in one file for three different schools. In the header record for this school, they're going to use a school code of 9999 as the school code in the header record, but each record for the students included will have their six- or eight-digit school code and we will count each school separately because we are looking at the school code in each individual record. So a servicer can do one batch report for all of the schools that they service.

Now when you submit your loans by batch, you are going to have an error or a submittal file summary. So files submitted by batch, we will always acknowledge that we have received your file. If it's perfect, you are simply going to get back a record saying that your records have been received and there were no errors. But if there are errors, you will get individual records for each student record that errors. We will give you no more than five errors per program record that you submit. If a single record should have more than five errors, the next time you submitted that data you would see the next errors that are on the record.

You should receive an error record within 24 to 48 hours after submitting the data. If you don't receive an error record or your acknowledgment file, you should call our customer service number. Early on in the process, we'll have to look at our timing and it might be a little bit longer than 48 hours, but once we get our process down we will let you know as soon as we process your file without errors that we have received your file and that we'll send you acknowledgment. If you do receive errors, you need to resubmit the file -- correct all the errors which we will identify, and we are going to review how to identify errors later on in the presentation. But you need to resubmit your file free of all errors.

Those who have done batch reporting to NSLDS know that we use message classes to send and receive reports as well as to upload data from you and to send back data through you. So make sure that when you're looking at the message classes here that if you are using a fixed-length record that you choose the correct message class to put your data in and the end files always end in "in." And when we receive and process your file, then we will send you an error acknowledgment file and it will go in. If you sent us a fixed length record, than the first message class here is where you would pick up your error acknowledgment file. So use the "in" for incoming records and then when we complete it and process your records, you will use the "out," you will pick up your error acknowledgment file from the out message class mailbox system.

We thought it important, when looking at the User Guide, that we review with you what -- the detailed record information that we are providing to you. So we want to make sure that you understand what's in the record format as we have given it to you in the user guide. So now we're going to take a look at the user guide Appendix A. And the first thing we are going to look at is how do you read the record layout.

The first line of the record layout tells you -- the first block tells you the field code, the next block will tell you whether or not this field is a mandatory field, whether it's a mandatory conditional field or whether the field is optional. I'm going to review all of those with you in the next few slides.

We're going to talk about whether or not this field is a character field, a date field, or a numeric value, so that's what will be in Type. We tell you the record length. We tell you the position that this particular field is and the record layout and we also give you a reference back to the original Dear Colleague Letter GEN-11-10 that tells you why we are collecting this field. So this is just a reference field from the Dear Colleague Letter. When we talk about whether or not a field is mandatory, it means that it must always be there when reporting data. For example, the social security number, name and date of birth are absolutely mandatory and if those fields are not there, your record will receive an error.

If it is an optional field, it doesn't have to be populated. NSLDS will not send you an error if the middle name is not there, it's an optional. If you don't give us tuition and fees, that's an optional field, it causes no errors. But then we have what's called a Mandatory Conditional Field. And what the Mandatory Conditional Field means that, if you give us a program, for example the student has withdrawn or completed a program, then you must give us a program attendance end date, it's absolutely mandatory. So that means if you would give us a C or W, then you have a condition that means you have to populate the Program Attendance End Date.

The next section in understanding the record layout is where we provide you with instructions on what we can tell you about that field. These are the rules that NSLDS uses, and you should use when putting the data together for that field.

The next step is the errors that you will receive. If we have a problem in loading your data, you are going to get these errors associated with the field. So in your error acknowledgment file, you're going to get a Field Code in error, Field Code for this example it would be Field Code 02 and then we will list these error codes as the error that causes record not to load. And this will tell you what you need to do to get the record fixed, so that you can correct it. For example if you will get a Field Code -- in Field Code 02 you get an error code of 09, you'd have some work to do to correct the record, to get the proper social security number.

We wanted to make sure that you had some basic things to note about the data that we're asking you to supply us with and because we are matching with the Social Security Administration on this data, we need to make sure that the name is the proper student's first name that you are not using nick names or aliases, but for like in this example if the students name was Robert, we need it to be Robert and not be Bobby or Bob because we need to be able to match with Social Security. And if you don't have a birth date, this is one of the fields that we will accept a plug value for and this is the value that must be used if you are missing the birth date.

A couple other fields that we thought we should mention is the private loan amount, and this is the total amount that you are aware of the student has borrowed from any private loan program, a credit union, maybe a state program or any other localities that offer students the ability to borrow for education. This is where you tell us about the private loans that the student has taken out for this GE Program.

For the institutional financing amount, it's the amount that the student owes you as a result of either having a payment plan or any other financing program that you might have offered the student that was not a private loan but it is associated with the institution and is not a Perkins loan which is not considered institutional financing. So, it's any loan that the school extends to the student.

And then we have the new data element that was added in the last round of updating the user guide and that is the amount of tuition and fees that the student was charged for the educational program that you have entered for this GE record. So it is the amount of tuition fees associated with that CIP and credential level for that student.

Now we are going to talk about online reporting and again this is the chapter that is not currently in the user guide. We are busy coding and getting ready -- getting all the final details of our reporting process worked out and when we publish the User Guide at the end of July, it's going to have this completed chapter in it. We're going to take a look at it now.

The first thing to note about online reporting is that you don't need a TG mailbox. So if you are confused about what a TG mailbox is, online reporting might be the method that you need to take. NSLDS offers two methods of using the online process. We will allow you to use a pre-formatted Excel spreadsheet to upload data into NSLDS. In the next couple of weeks, we are going to publish the template for uploading the data on fsadownload..

With our template, you can only use a maximum of 50 records per Excel file and this template has to be used because embedded in the template are headers and trailers and a number of edits. So if you're already starting to build spreadsheets, you will have to copy and paste into the template because that's the only way NSLDS will be able to accept the data is using our pre-formatted template that will soon be available. So look forward to an Electronic Announcement telling you that the template is available on FSA Download.

We also are giving schools the ability just to go online and simply enter one student at a time all of the fields that are required to be reported for GE. Our screens are going to allow all of you who have entered GE data either through the batch or online processes to review your data that you have entered, to update it, if you find that it's in error, you will be able to deactivate the records that you have previously reported. And all of this will need to be done online. This gives you a view of how you are going to upload the data to NSLDS. We recommend if you are going to have multiple Excel spreadsheet files of 50, we recommend that you name your files distinctly so that you can tell which file has already been uploaded. But this button here gives you the ability to browse your computer, find the file that you want to upload, put into this block here, and then hit Submit.

Once you hit the Submit button, you're going to have the opportunity to review all of the records that were in that file, you'll be able to select or deselect any record that you don't want to hit and then you can simply hit Next -- a Submit and that's going to load your records to NSLDS. This is what you are going to see once you hit the first Submit button. All of your records will come back to you. You will have the opportunity with the first arrow there to review all of your records. You will see that there's a button here that says "check all." If you want to submit all of them, you can check all. But if you find in reviewing this -- like this record, you can deselect it by hitting the box there.

And any time you deselect a record, be careful because that record will not be submitted once you hit the Submit button. So this is your opportunity to review and make sure all the records that you want to load are correct and then all you have to do is hit Submit. Once you hit Submit, records with errors will not be uploaded. If there are errors, you will be able to see those errors, you will be able to mouse over wherever there is an error in the record and it will tell you what the error code is, so why the error is rejected. Errors will appear on each record and it will need to be corrected in the template and uploaded again. So you'll have to correct it in your template and try to upload it again once you have corrected the error.

And then once it is accepted, you see the message there, it says your records have been submitted successfully and that's your indication to all of the records and that particular spreadsheet have been loaded successfully to NSLDS. And so for each file that you want to load to NSLDS, this is the process that you will use.

So for online reporting, we just want to make sure that is this an optimal way, individual reporting directly online is an optimal way for a small school who doesn't have any support with their technical office and they just need to -- they have their records online up and they are ready to enter. Once their online screens are available, you will simply be able to sit down and enter each record individually. It will allow you to see your errors immediately. They can be corrected and resubmitted while you are working through each one of the files that you are adding to NSLDS.

This is what the individual upload online process will look like. You'll be able to enter each of the fields as outlined in our guide. And once you've completed and entered all of the data, you just simply have to hit Submit. Again if that record rejected, it is going to come back and it is going to show you how much you have fields in error. So once data has been entered into NSLDS, either using NSLDS online or using Excel spreadsheet or using batch, you are going to have the ability to review all of your records if -- you will be able to deactivate or correct any record that you have uploaded.

This is a screen that will allow you to view, sort and review all records. You can simply put in a social security number and pull up one record out at a time or you can pull up all of your records. These fields here can be sorted and this is all the ways that you can sort information to bring up the records to review and correct or just to see what you have reported.

If you decided to pull up an individual record, once it's been entered into the system this is what you'll see on that record. You'll have ability to deactivate or update this record right here.

So, let's just summarize everything that we've gone over. You're going to have the ability to do batch reporting, your choices are to format either fixed or CSV, you will receive an error acknowledgment file when you use a batch reporting. That file will come through SAIG and we've given you the messages classes for both entering data and submitting your data and receiving the error file.

When you receive errors, you must correct errors, and return the file through SAIG if you're using batch. You have the ability to use it Excel pre-formatted template that we will be posting soon, in the next couple of weeks, that will allow you to upload data in batches of 50. You will be able to see records that are in error, you will have to correct them in this Excel spreadsheet and resubmit the records until they have been entered correctly.

You also have the ability to enter data directly online one GE record at a time. You'll be able to review the data on screen, make any corrections, hit Confirm and Submit and you will see instantly that your record has been submitted to NSLDS. With batch processing, our goal is to process your file within 24 to 48 hours. We will ask when we begin the process to give us a little bit more time to make sure everything is working correctly, but eventually you'll be able to submit data, especially after this first year, you'll be able to submit data at any time and we should process your GE records within 24 hours. You will need to correct and resubmit; again using batch, you will simply resubmit the data in the batch process or if there is data online that you have entered, you can correct it online.

The Department has created the GE website that you can go and get more information about GE, any technical question you have about today's presentation or the User Guide can be sent to nsldsge.. Now it's time for your questions.

Jeff Baker: Thanks, Valerie. Angela, you want to remind folks about how to submit questions please?

Angela Smith: Yes, sir. This is a reminder everyone. In order to ask your questions, please remember we are in listen-only mode. So you will have to ask your questions by typing them into the Ask a Question box located in the bottom left corner of your screen and then pressing the Submit Question button. One of our question managers will read the questions aloud and Jeff and Valerie will respond.

Jeff Baker: Thanks, Angela. Before we start, a couple of things. Cynthia and Melissa will be reading the questions. They may not read it exactly the way it was submitted because they do a little paraphrasing. They also find multiple questions on the same topic, so they do their best on the wing here to get the question right and hopefully it will resolve a number of them. We apparently had a number of questions that people wanted to get some clarity about deadlines, so let me cover that and we'll see if we can take care of that.

The regulations that were published on October 29, 2010, provide an effective date of July 1, 2011, just couple of days from now. That means that the requirement that institutions provide certain information in the disclosures about their Gainful Employment Programs are effective in a couple of days. So the regulations are pretty explicit about what has to be disclosed on your websites and then we've included additional information in the materials at the IFAP GE homepage including the Dear Colleague Letter GEN 11-10 and a whole series of questions and answers. We understand there are more questions that we have to get back to. But as a general concept you should be ready to, if you haven't already, to have that information available to your students, prospective students in just a couple of days, July 1.

In terms of the regulations that was posted on October 29 about adding of additional programs that also is effective July 1, a couple of days. So if you have a program, a new Gainful Employment Program that is going to begin on or after July 1, 2011, you have to follow the new regulations. And we put extensive information out about that both in the Dear Colleague Letter and in one of our Gainful Employment announcements, actually I think a couple of them.

While, technically the reporting under the regulation, because it was posted by October 29, is effectively July 1, 2011, the regulation specifically states that reporting is by October 1 following the end of the award year. So the reporting that we have been talking about and that Valerie took you through on the NSLDS reporting and the information we included on the website about reporting of GE programs, that reporting has to be completed by October 1, 2011, about three months from now.

So hopefully that provides some clarity. If you're still a little bit confused on it, take a look at our materials, particularly the Dear Colleague Letter GEN 11-10 because it takes you through each of those requirements with some specificity. So with that said, Valerie and I are ready to try to answer your questions. If we're not able to answer the question, we'll just say so, and we'll make a note of it and we'll get the answer and put it on our Frequently Asked Questions section of our website. Cynthia?

Cynthia Hammond: What credential level should a post-graduate or post-masters level certificate be reported at?

Jeff Baker: We have in the User's Guide and in Dear Colleague Letter GEN 11-10 a description about, I believe there are seven credential levels beginning with certificates and all the way up to post-baccalaureate credentials. So you need to review that. There is a code for each of them. I am just checking, no I guess it's not in the Dear Colleague Letter. Yes, it's in the draft data elements that was included in the Dear Colleague Letter as well as in the User Guide, so what was the specific one that was being asked?

Cynthia Hammond: Post-graduate.

Jeff Baker: A post-graduate credential?

Cynthia Hammond: Post-graduate certificate, what is the credential level?

Jeff Baker: Yeah, it's 04. Now I understand that there is a little bit of confusion because that's technically called a post-baccalaureate certificate. You have to read that as anything above a bachelor's degree. So even if it's a post-graduate, it falls into 04 and I think we may have included that on frequently asked questions, but post-baccalaureate in that reading is anything above the bachelor's degree.

Cynthia Hammond: For a vocational technical college, is an AAS degree a GE program?

Jeff Baker: Yes, when we say a degree program isn't -- at a public or not-for-profit is not a GE program, doesn't have to be because the law says degree programs are eligible, associate degrees, it's not just the typical AA degree but variations as long as it's credentialed, approved, accredited, associate degree program, similar in bachelors and graduate degrees -- an MFA for example, a Master Fine Arts is a masters degree, master degrees are not limited to MA's or MS's.

Melissa Rosade: When will the pre-formatted Excel spreadsheet be available?

Valerie Sherrer: We hope to have it posted within the next two weeks.

Cynthia Hammond: Can you provide some more information on what are institutional loans and what are not, for example is a FFEL and Direct Loan included as part of institutional loans?

Jeff Baker: No, they are not. The regulations break down student debt into three categories, Title IV loans, excluding Perkins loans so that would include FFEL loans and now Direct Loans. Private education loans that are made by private entities, usually banks and credit unions and other kinds of organizations to our students and then institutional financing which is a credit opportunity provided to the student by the institution. That would include an institutional loan as opposed to a private loan by let's say an outside bank, but there are other institutional credit opportunities including some long-term installment credit and so on. The added distinction, when you report -- we will get the Title IV loans directly because we have all of that in NSLDS. You'll be reporting for the students who completed the program their private loans and to anticipate a question, obviously you may not be aware of every private loan because the student might have got the loan outside -- in an outside process where the institution was not involved, although there is less and less of that because there are some changes in the law. And then the third category is the institutional financing. So there are three separate ones you will be reporting on, the private loans that you know about and the institutional financing which of course you would have to know about, and will pick up the Title IV loan separately.

Cynthia Hammond: If all our Title IV programs have median loan debts at $0, are we still required to submit reports?

Jeff Baker: You are always required to submit reports if you have a Gainful Employment Program as we have defined in the regulations and clarified in our guidance what a Gainful Employment Program is, you have to report students. You have to report if there are any students enrolled in that Gainful Employment Program in the appropriate award year and first time through it's of course six different award years. Whether the student got loans or not, whether there is a median because you could have very few students who got loans and a whole lot more who didn't, so the median could be zero. By the way, that's the difference between median and mean and I hope you understand the difference. If not we have included a frequently asked question to describe the difference between median and mean, but in any event it doesn't matter you would report for each student because they have enrolled and then what loans they had and we will calculate the median and if it turns to be zero, then it's zero.

Cynthia Hammond: Is there a minimum number of students for reporting as there is for disclosures?

Jeff Baker: There is no minimum for reporting any number of students if they are enrolled during the award year. The only difference is, and you report all the information about that, the questioner seem to understand that for disclosures because the privacy concerns, you still have to disclose information about the Gainful Employment Program. But when you have to calculate median loan debt and disclose that, you do not calculate it if there were fewer than 10 students who completed the program. And that's because it is possible to get real close to what an individual student's debt was if there are fewer than 10. But reporting, you report even if there was just one student enrolled -- take an extreme case, there was a program, a student was enrolled for one day during the award year, you report that student.

Melissa Rosade: Can we use our own Excel spreadsheet or do we have to use the provided Department of Education upload template and if so, why?

Valerie Sherrer: The question again is, you can't use your own Excel spreadsheet, you must use our template because what we've done is built in, that you can't see, headers and trailers are in our pre-formatted and we also have some edits built into the pre-formatted. So there are codes hidden in our template and we need that code in order to upload the data into the database. So you have to use our template. But you can cut and paste from your Excel spreadsheets right into ours and then upload it into NSLDS.

Melissa Rosade: Can you restate when you expect the NSLDS batch process to be ready to accept files?

Valerie Sherrer: The date for us to be ready for accepting will be September 26.

Cynthia Hammond: If a student begins in a GE program, withdraws and then starts a different non-GE program, how do I report that student? Do I report them as registered in another program that equals "Y" even if the second program is not a GE Program?

Jeff Baker: What you are required to do in this scenario within the award year is report the student because she was enrolled during the award year in a particular GE program that you have identified in the reporting. You'll be asked the beginning date of that enrollment and the ending date of that enrollment during the award year. And that's the end of that reporting.

I am going to expand the question a little bit. If the student during the same award year enrolled in a different GE Program -- that's one of the examples -- where the same student would be reported twice in the same award year. In that case, after you get done reporting that the student withdrew from GE Program XYZ, you would then in a separate -- as a separate record -- report that the student enrolled in GE program ABC beginning on this date and then whatever happened during the award year. If the subsequent program is not a Gainful Employment Program, there is no requirement to report. So you would just have the beginning and ending date of the student's enrollment in the GE Program.

Cynthia Hammond: If a school does not participate in a loan program, do we still need to do the GE reporting?

Jeff Baker: Yes. This goes back to the statute which says that the only eligible programs are Gainful Employment Programs or degree programs. So if you have a program that meets the definition of a Gainful Employment Program, you have to report information about your students. I would add to that that just because the school -- I am taking from the question, the school does not participate in the Title IV loan programs, does not mean necessarily that the students didn't receive private loans or there might even be institutional financing. But even if all of those are no, you still report the student -- students.

Melissa Rosade: If we choose to report batch, can we report that to NSLDS with our normal EDconnect method?

Valerie Sherrer: Yes. Yes, as long as they download the message classes for GE, they can use EDconnect to upload.

Cynthia Hammond: Our certificate programs that are fully transferable to an AA degree, still need to be reported as a GE program?

Jeff Baker: Yes. This is something that we're going to get a couple of frequently asked questions, hopefully before the end of the week on this and let me see if I provide just a little clarity on this. In the information we put out in the Dear Colleague Letters and in subsequent electronic announcements, we did -- and particularly the one we just posted GE, Electronic Announcement Number 11. We wanted to make the case clear that if the program results in a certificate or other credential awarded by the institution, it is a Gainful Employment Program at all types of institutions. If it's not a program that leads to a credential or certificate awarded by the institution, but simply a course of study or series of courses that are eligible for Title IV Aid because they are preparatory to entering a degree program then they are not programs and therefore cannot be Gainful Employment Programs.

It's an important distinction and you have to make sure that your academics at your institution have made those determinations, that's not a determination that gets to be made by Financial Aid Administrator or by a systems coordinator or a data provider. We're talking about academic decision that this set of course work, leads to a credential -- certificate even if the purpose of the program was to allow the students to have the basics or the preparatory work or the prerequisites to enter into a higher program, it is still a credential program or a certificate program and it’s GE. If on the other hand, it's a series of course work that does not lead to any credential but it is preparatory for entering a degree program then it is not a Gainful Employment Program.

Cynthia Hammond: How do I report a program when I don't have a CIP code?

Jeff Baker: You're supposed to have a CIP code for every program. This is required by your IPEDS reporting which is both statutory and regulatory required. Our National Center for Education Statistics has the whole taxonomy of CIP codes. Your institution should have, a long time ago, but certainly should now review that taxonomy on the appropriate CIP code. Perhaps get a little advice from colleagues or other institutions or from professional associations or NCES and assign a CIP code. Frankly speaking, there is no such thing as an academic program that doesn't have a CIP code.

Melissa Rosade: Which version of the User Guide should be used?

Valerie Sherrer: Right now there is the version that was posted on June 3 that is the current guide. The final guide will have the online screens will be posted around July 30 and that will be the guide that has the online screens and everything complete. But the record layout is complete in the current version, all the requirements are there, the only thing missing from the guide at this point is the online screens that we are still coding and developing.

Cynthia Hammond: My school ended a program on our ECAR in 2009. Do we still need to report for 2006-07, 07-08, and 08-09?

Jeff Baker: You only need to report on programs -- Gainful Employment Programs that are Title IV eligible. So in this example they ended their Title IV eligibility a couple of years ago. And so it's a good question, even though they were Title IV eligible back in the earlier year there is no need to report. And the reason for this is -- I hope you would seem pretty logical -- the reason for the reporting is so that we can do the metrics to determine if the program is -- meets the definition of statutory requirement of gainful. So to result in -- Gainful Employment should be Title IV eligible. Well, if the school is already decided, if it doesn't want the program to be Title IV eligible there is no need to do that. Cynthia I want to ask you, did we put a frequently asked question out about this -- about programs that have ended?

Cynthia Hammond: I believe so.

Jeff Baker: Yeah. I think there is one out there on this and hopefully I was consistent with that answer.

Cynthia Hammond: I have a few students' names who are misspelled on a social security card. When we enter the name in NSLDS, should we correct the spelling or to use what is printed their social security card?

Jeff Baker: I don't know. No, the -- first of all, you should direct the student and I know you can't make them do this, but you should direct student to correct the information with the Social Security Administration. It's possible that the Social Security Administration has it corrected, it's just the card wasn't updated. But assuming that's not the case, they should correct it with the Social Security Administration. We will not be running matches with Social Security Administration for several more months. And I don't know how long SSA takes but presumably if you have some of those as you're putting files together now and throughout the summer, there will still be an opportunity for you to contact the student and have them correct their social security number. You should correct -- you should use the social security -- you should use the student's -- assuming it's a spelling error or they just got the name wrong, you should use the student's real name. But for example, even though Valerie mentioned about Robert and Bobby and so on, if there are some reason, the Social Security Administration has it as Bob then that's how you should report it unless the student's going to change it in both places.

Cynthia Hammond: Will NSLDS provide a testing environment and a testing cycle?

Valerie Sherrer: No.

Jeff Baker: Let me -- we're though working with a group of schools that will help us do a beta testing to make sure that the system works and also to get their advice of tweaks and little changes that we can make. But a generalized testing we just do not have the time to do all of that.

Cynthia Hammond: Some of our GE programs have both secondary and post-secondary students enrolled. Will we be required to report on the high school, in other words, on the secondary students?

Jeff Baker: Yeah, students in high school that are enrolled in the same program, that post-secondary students are, you only report on the post-secondary students. No, I got it wrong. And we put this one out on FAQ I think.

Cynthia Hammond: I believe we did, it's all students with social security numbers enrolled in the program.

Jeff Baker: Right. Right. That will be -- yes, because we want to keep track of those because many of those students not in all case who understand that will transition to be post-secondary students, so we need the information. Any student -- if the program is a Title IV eligible program anyone who is enrolled in that they have a social security number for, you need to report.

We have gotten some questions about the use of third party servicers for reporting, whether it would the National Student Clearinghouse or any others. As Valerie mentioned, you certainly can use servicers. But as in any requirement -- any provision of our programs where a school has chosen to use a third party servicer, the institution is responsible for making sure that the reporting is done and done properly and done correctly. So, we have provisions within the User Guide and the discussion that Valerie went through about servicers how they can use multiple TG numbers and all of that, and so you should review that. If there are additional questions particularly from servicers who are planning on rolling this out for large numbers of institutions, they can contact us and we'll help them through the process, as we do for the enrollment.

Melissa Rosade: Do we submit one big file covering the first five financial aid years or five files, one for each year?

Valerie Sherrer: It's up to you. It's either way. One file or multiple files is your choice, whatever you can best manage.

Jeff Baker: And the reason why that works is if you've had a chance to look at the record layout, one of the fields in the record is the award year. So, if they are next to each other but they are five different years, we can sort that out. Similarly, if I may, we talk a couple of times about the possibility that you will be submitting the same student more than once, because they came in or not of a program or they were in multiple GE Programs -- that's fine. You can send them all together because part of the record layout, in addition to award year and the student identifiers (name, social security number, date of birth) is the GE Program identified by CIP code and credential level.

Cynthia Hammond: If we have no GE programs, do we need to tell you through the missing data mailbox?

Jeff Baker: At this point, the answer would be no. I only give a little caveat to that because we need to think about that whether that's a good way for us to not bother you. Said differently if we get past October 1, if we have institutions that have not sent anything in, we may give them a call or shoot him an email or something asking them if there was a mistake or something. And if you really don't have any Gainful Employment Programs maybe we can avoid a little bit of a hassle.

I do want to caution though, it is a very, very, very rare situation where an institution does not have a Gainful Employment Program. As this process began, there were institutions who believed frankly that this only applied to for-profit institutions. And once they got through that a little bit, they understood that, well it may apply to publics and not-for-profits, it didn't applied to them because their certificate program is offered by the extension service or it's a post-baccalaureate or a post-graduate. It turns out that somewhere north of 85% of our institutions we believe have at least one Gainful Employment Program, but it's possible you don't have any. And so for now there is no need to report, nor is there any need to use the missing data mailbox. But stay on top of that a little bit because we might find it helpful for both us and the institutions to have you tell us that.

Melissa Rosade: Is the TG mailbox tied to individual user ID or an online account for data submission?

Valerie Sherrer: That's the choice -- your choice at your school. If your school uses one TG mailbox for all of your online data submissions, it can be that TG mailbox. But if you choose to use a TG mailbox associated with your user ID, for example, because you are responsible for GE reporting -- that's your choice. It's up to you to decide whether or not your institution will support individual TG mailboxes or if you want to use to one that your institution uses for batch processes.

Melissa Rosade: Will GE utilize the SSCR system or is this different?

Valerie Sherrer: It's totally different.

Melissa Rosade: So can one employee do regular NSLDS reporting and another do the GE reporting?

Valerie Sherrer: Yes. As long as the -- your user at the school has an NSLDS ID and have their Primary Destination Point Administrator have given them the rights to do enrollment updating, one can do normal enrollment and the other can do GE reporting.

Cynthia Hammond: Are all errors supposed to be corrected before October 1 as well as initial reporting?

Jeff Baker: Well, they should be. But obviously, even we're not going to require that when we're not going to bring the system up until September 26. So what we would -- you have to take care of it as quickly as possible hopefully you're using technology that we're providing or your own technology to do some editing before you even upload the information that's one advantage of using the online screens and to a little lesser extent but also the template as Valerie mentioned there is some editing in there. Batch users it's up to you to do the best you can. Obviously, we can't hold you to that. But we would not be pleased if -- in a couple of cases, if we receive batch files, where virtually all of them errored out, that would be something we wonder how seriously you were taking the responsibility. And secondly, even it's just a few errored out but they weren't fixed in relatively short order. And we'll leave that open because of course it depends upon the reason. So, we'll leave it at that. Now, if we get into the subsequent years, we may be in a different mode but certainly this is first time around.

Cynthia Hammond: I have a program that only became Title IV eligible in 2009. Do I need to report the previous years?

Jeff Baker: I think we already answered that one, that -- well I am sorry that was a program that ended the earlier one.

Cynthia Hammond: That was ended. This one became Title IV eligible.

Jeff Baker: Yes, you have to report for the prior period because we're looking to measure the set -- do I have that wrong again? Again, a little help here.

Cynthia Hammond: I think if your program became Title IV eligible, you report from the award year you became Title IV eligible going forward.

Jeff Baker: Okay. Thank you. Okay, right. So yes, it's actually the flipside of the question. So you report from the award year, the entire award year from when the program was created or actually was Title IV eligible. We will make sure that's on our frequently asked question, if it's not already, at least I will read it and then I will know the right answer the next time I am asked.

Melissa Rosade: If we submit it back through SAIG Mailbox and there are errors is the whole batch rejected or just the records with errors?

Valerie Sherrer: Just the records with errors.

Melissa Rosade: Can these errors be corrected online or do I have to correct them through batch?

Valerie Sherrer: You have to correct them either through batch or enter the records individually online or put them in an Excel spreadsheet.

Jeff Baker: They are busily reading your questions.

Cynthia Hammond: Yeah. We have a lot of duplicate questions. Can you review one more time what's due July 1 versus what's due October 1?

Jeff Baker: July 1, 2011, the disclosure requirements of the October 29, 2010 regulation, schools must be in compliance with. Again, we covered that in the webinar that we did at the end of May. It's in a Dear Colleague Letters and there is at least two maybe three or four Gainful Employment Electronic Announcements that dealt with disclosures and there is a whole bunch of questions and answers on Gainful Employment. Disclosures are -- you're to be -- implement those and your website should be updated with the required information in three days, by July 1.

Secondly, if you're adding a new Gainful Employment -- a new program that's a Gainful Employment program because it meets the definition and classes are scheduled to begin in that program on or after July 1, this coming Friday, then you either should have or must immediately on July 1 follow the Gainful Employment regulations about informing us about that program. The reporting is due October 1, 2011 for those five or six award years that we've been talking about here in this webinar and after that it will be every October 1.

Melissa Rosade: Is the Excel file option available for more than 50 students per sheet or only 50 students?

Valerie Sherrer: We are limited to 50 per sheet. So you'll have to do multiple sheets, if you have more than 50 students.

Cynthia Hammond: Jeff, in adding to your question, I would like to mention that both this -- that the webinars that you did in the end of May are available now on our website, if people would like to see them. We posted both of them even though the content is the same; the questions and answers were different, so we went ahead and posted both of them. If you go the Gainful Employment Information page at the bottom of the page it says Resources and there is a link there. This webinar will also be posted there in the coming days.

Jeff Baker. Right, thanks Cynthia. And that's important I keep forgetting that. There's lots of information on our website. Again to repeat, the regulations are there. The Dear Colleague Letter is there. The 11 and growing numbers of Electronic Announcements that are topical, the Frequently Asked Questions and these webinars. And this one, as Cynthia mentioned, will be posted within a few days. Actually, since we're doing this again tomorrow, there will be two of them posted for the same reason, while the screens are the same, we use different words as we go through them, Valerie and I, but more importantly the questions are slightly different and so you'll have all the information whether you listened in on one both or for folks who didn't listen in any of the webinars.

Melissa Rosade: When if ever do we deactivate a student?

Valerie Sherrer: If you've loaded duplicate records or you found that you entered the wrong award year and you have to -- well you can correct an award year. So it's only if the record was loaded in error that shouldn't have been a GE student, you put him there, you put the wrong person there you would deactivate the record.

Cynthia Hammond: Does an institution have to have an NSLDS user ID no matter which way they do reporting?

Valerie Sherrer: Yes. Well, yes, they need to see the data that they have reported, so they need an NSLDS user ID. And more importantly, they have to be able to set up for us to receive their files from SAIG and they have to do it online.

Jeff Baker: Are we -- got just about all? I think a lot of the questions that were duplicates are very slight variations of what we've discussed. Just hold on a second we will see any last minute questions -- we're close to the end of our time anyway, but I don't want to shortchange anybody if there is some question there. We'll wrap it up giving Angela an opportunity to remind you about the survey. Valerie wants to repeat the information.

Valerie Sherrer: Yes, I want to make sure give you the NSLDS customer service support telephone numbers at 800-999-8219.

Jeff Baker: Anything else ladies?

Cynthia Hammond: As October 1 is a Saturday then we have till Monday, October 3 to do reporting?

Jeff Baker: The regulation says October 1, so I'll leave it at that. If you think I'm going to be at work checking your files on Saturday, probably not but they are dated I don't want to be too frivolous about it, so October 1. If we -- we will have to see how -- if we can give a little flexibility, but it's a good question. We'll check that out. We do have similar deadlines for FISAPs and COD reporting and so on. And we will have to be as flexible as we can. It's a good question.

Cynthia Hammond: We do have a handful of questions that came in later that we -- are good questions that we don't have time to report today. We will -- just to let folks on the phone know, we will review these and add more to our Frequently Asked Questions page on the Gainful Employment info page and you might want to put the link to that back on.

Jeff Baker: Can we get that slide?

Valerie Sherrer: Sorry.

Jeff Baker: Yeah, we're going to go back to that slide there. Well, we thank you very much for your time and your questions are very good. I think they provide clarity in a lot of places. Please pay attention to the information on the website and please check it on a regular basis. This is really important we want to make sure everybody does it right and of course that we do it right. Angela you want to remind them about the survey please?

Angela Smith: Yes. What we are about to do is we are going to put up on our screen a link to our Zoomerang survey. Please take a few minutes to complete the survey. We greatly appreciate it. Just as a reminder, clinking on this link will open a new browser window, so you want to make sure that your pop-up blockers are turned off, so that you can get the new window and complete our Zoomerang survey. This concludes our Reporting Gainful Employment Data to NSLDS webinar. And thank you so much for your participation.

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