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2011 Final Rule (without repayment rate) vs. 2013 Draft Regulation

DRAFT FOR DISCUSSION PURPOSES – 08/29/2013
| Final Rule (2011)      | Draft Regulation (2013)                                                     |
|------------------------|-----------------------------------------------------------------------------|
| Applicable students    | Title IV & non-Title IV                                                 | Title IV only |
| Accountability Metrics | annual DTEdiscretionary DTE                                                 | annual DTEdiscretionary DTE |
| Passing                | aDTE ≤ 12% OR dDTE ≤ 30%                                                    | aDTE ≤ 8% OR dDTE ≤ 20% |
| Zone                   | No equivalent provision                                                     | Not passing &8% < aDTE ≤ 12% OR 20% < dDTE ≤ 30% |
| Failing                | aDTE > 12% & dDTE > 30%                                           | aDTE>12% & dDTE>30% |
| Ineligibility rules    | T4 ineligible for 3yrs if 3 fails out of 4 yrs                              | T4 ineligible for 3yrs if:2 fail out of 3yrs ORNot passing in any 1 out of 4yrs (time limit for zone programs) |
| Zone consequences      | No equivalent provision                                                     | Debt warnings to students if program could become ineligible at the end of the yr |
| Fail consequences      | After 1st & 2nd fail: Debt warnings to students                         | After 1st fail: Debt warnings to studentsT4 enrollment limited to previous yr level |
| New programs           | All new programs notify, the Department decides whether to formally approve | For discussion at negotiations |

DRAFT FOR DISCUSSION PURPOSES – 08/29/2013

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DRAFT FOR DISCUSSION PUROSES – 08/29/2013

2011 Final Rule (without repayment rate) vs. 2013 Draft Regulation, cont.
| Final Rule (2011)                              | Draft Regulation (2013)                                                                                             |
|------------------------------------------------|---------------------------------------------------------------------------------------------------------------------|
| Min Program Size                               | 30 completers                                                                                                       | 10 completers |
| Debt amortization schedule for DTE calculation | Debt amortized over 10, 15 and 20 years for certificate/associate’s, bachelors and graduate programs respectively   | Debt amortized over 10 years for all credential/degree levels |
| Tuition & fees  cap in DTE calculation     | Median debt capped at program tuition and fees (if reported by institution)                                         | No tuition and fees cap for median debt |

DRAFT FOR DISCUSSION PUROSES – 08/29/2013

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DRAFT FOR DISCUSSION PURPOSES – 08/29/2013

2011 Final Rule (without repayment rate) vs. 2013 Draft Regulation, cont.
| Final Rule (2011)                                | Draft Regulation (2013)                                                                                                                                                         |
|--------------------------------------------------|---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Students excluded from DTE calculation           | Loans in military deferment status (no min time requirement)Loan discharged for disabilityEnrolled at an eligible institution (no time min time requirement)Student died        | Loans in military deferment status for at least 60 daysLoan discharged for disabilityEnrolled on at least half-time basis at an eligible institution for at least 60 daysStudent died Completed a higher credentialed GE program at the institution |
| Alternate earnings challenge for DTE calculation | For failing program, institution may submit alternate earnings information using:Data from survey conducted by institution in accordance with NCES standardsState earnings data | For failing program, institution may submit alternate earnings information using:Data from survey conducted by institution in accordance with NCES standards |
| Alternate DTE calculation in first 3yrs          | In first 3yrs of rule, alternate DTE calculation may be applied that uses BLS data for earnings                                                                                 | In first 3yrs of rule, alternate DTE calculation may be applied that uses the median loan debt  of students completing in the most recent year (decouples debt and earnings) |
| Cap of ineligible programs in first year of rule | For each institutional category (public, private non-profit, proprietary), ineligible programs capped at number accounting for 5% of that year’s completers                     | No equivalent provision |

DRAFT FOR DISCUSSION PURPOSES – 08/29/2013

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DRAFT FOR DISCUSSION PURPOSES – 08/29/2013

2011 Final Rule (without repayment rate) vs. 2013 Draft Regulation, cont.
| Final Rule (2011) | Draft Regulation (2013)                                                                                                                                                                                                                                                                                                              |
|-------------------|--------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------|
| Disclosures       | OccupationCost of tuition, fees, books, supplies, room & board On-time completion ratePlacement rateMedian loan debt Repayment rate (dollar-based)Calculation adjusted to account for loans in negative amortization                                                                                                             | OccupationCost of tuition, fees, books, suppliesCompletion rate (100 & 150% of program time)Placement rateMedian loan debt Repayment rate (borrower-based)Generally, payment of $1 of principal over course of year counts as positive repayment, but for loans in negative amortization, full payments must be made for entire year Median earningsWhether program meets requirements for licensure (if applicable) |
| Reporting         | For each student:Student identifiers linked to institutionName and CIP code of programDate of completionPrivate and institutional loan amountsWhether student matriculated to higher credential program Total number of students enrolled in each program at institution and identifying informationExplanation for any missing data | For each student:Student identifiers linked to institutionName, CIP code, credential level, and normal time of programDate of completion or withdrawalPrivate and institutional loan amountsDate of initial attendanceAttendance dates and enrollment status during the award yearExplanation for any missing data |

DRAFT FOR DISCUSSION PURPOSES – 08/29/2013

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