Reporting and Disclosure Requirements for Institutions of Higher Education to Participate in Federal Student Aid Programs Under Title IV of the Higher Education Act
Released: 2009-08-31T00:00:00

Summary:
The Higher Education Act of 1965 (HEA; P.L. 89-329), as amended, authorizes a broad array of federal student aid programs that assist students and their families with paying for or financing the costs of obtaining a postsecondary education. These federal student aid programs are authorized under Title IV of the HEA. Requirements applicable to the administration of Title IV federal student aid programs are specified in Title I of the HEA, as well as in Title IV. The HEA also authorizes many other types of programs, including programs that make federal aid and support available to institutions of higher education (IHEs). The Department of Education administers programs authorized under the HEA. In 2008, the HEA was reauthorized under the Higher Education Opportunity Act (HEOA; P.L. 110-315); and in 2009 technical amendments to the HEA were made under P.L. 111-39.
Institutions that participate in one or more Title IV programs, or that seek to begin participating in these programs, are subject to a wide range of requirements under the act to report or disclose information to the Secretary of Education, to students, to the public, or to other entities. As part of the amendments made to the HEA, the HEOA added numerous additional requirements for the reporting and disclosure of information, many of which are applicable to IHEs. This has resulted in a sizable expansion of the reporting and disclosure requirements with which IHEs must comply as a condition of their participation in HEA, Title IV federal student aid programs.
This report responds to requests by Members of Congress for an in-depth examination of the reporting and disclosure requirements applicable to IHEs that participate in Title IV federal student aid programs. Specifically, it identifies and describes the reporting and disclosure requirements specified under Title I and Title IV of the HEA that applied to institutions prior to the enactment of the HEOA and those that were amended or newly established by the HEOA. It has been prepared to serve as a resource to assist Members of Congress and their staff in overseeing the Department of Education's implementation of amendments to the HEA made by the HEOA. It is designed to be comprehensive, though not necessarily exhaustive, in scope. It will not be updated.

paragraphs: The Higher Education Act of 1965 (HEA; P.L. 89-329), as amended, authorizes a broad array of federal student aid programs that assist students and their families with paying for or financing the costs of obtaining a postsecondary education. These federal student aid programs are authorized under Title IV of the HEA. Requirements applicable to the administration of Title IV federal student aid programs are specified in Title I of the HEA, as well as in Title IV. The HEA also authorizes many other types of programs, including programs that make federal aid and support available to institutions of higher education (IHEs). The Department of Education (ED) administers programs authorized under the HEA. In 2008, the HEA was reauthorized under the Higher Education Opportunity Act (HEOA; P.L. 110-315 ); and in 2009 technical amendments to the HEA were made under P.L. 111-39 .
Institutions that participate in one or more Title IV programs, or that seek to begin participating in these programs, are subject to a wide range of requirements under the act to report or disclose information to the Secretary of Education (the Secretary), to students, to the public, or to other entities. As part of the amendments made to the HEA, the HEOA added numerous additional requirements for the reporting and disclosure of information, many of which are applicable to IHEs. This has resulted in a sizable expansion of reporting and disclosure requirements with which IHEs must comply as a condition of their participation in HEA, Title IV federal student aid programs.
This report responds to requests by Members of Congress for an in-depth examination of the reporting and disclosure requirements applicable to IHEs that participate in Title IV federal student aid programs. Specifically, it identifies and describes the reporting and disclosure requirements specified under Title I and Title IV of the HEA that applied to institutions prior to the enactment of the HEOA and those that were amended or newly established by the HEOA. It has been prepared to serve as a resource to assist Members of Congress and their staff in overseeing the Department of Education's implementation of amendments to the HEA made by the HEOA. 
This report is designed to provide a thorough presentation of provisions in the HEA that require IHEs to report or disclose information, while also highlighting those provisions that were added or amended by the HEOA. In general, the organization of this report follows the statutory framework of the HEA. With respect to a number of subject areas, substantially similar requirements for the reporting or disclosure of information are specified in more than one part or section of the HEA. For example, similar requirements for the disclosure of information about student loans are specified in several areas of the HEA; and certain requirements for the reporting or disclosure of information may be specified in the Program Participation Agreement, as well as in other sections of the HEA. While the Secretary has latitude to streamline similar requirements in implementation, in this report, such requirements are generally identified as they appear in the act.
This report attempts to be comprehensive, but not necessarily exhaustive, in its scope. It is designed to identify and describe requirements in the HEA for IHEs to report or disclose information. It does not attempt to identify every instance in which an IHE may be required to respond to a federal statutory or regulatory requirement. For example, it does not examine all requirements that are primarily operational in nature for IHEs to provide information related to federal student aid programs, such as the exchange of information through ED's Common Origination and Disbursement (COD) system, nor the requirement of IHEs to verify student aid application information. It also does not examine requirements for IHEs to retain documentation of their compliance with HEA or regulatory provisions that have no associated requirement for them to report or disclose information. 
This report also does not address response burden, nor non-HEA requirements and regulations that may impact IHEs. The HEOA requires the Secretary to enter into an agreement with the National Research Council to conduct a study to determine the number and scope of all the federal regulations and reporting requirements applicable to IHEs, and the associated response burden. The HEOA also requires the Government Accountability Office (GAO) to conduct a study on IHEs' time and cost burdens associated with completing the Integrated Postsecondary Education Data System (IPEDS) surveys. Both of these studies are required to be completed by August 2010.
The Secretary of Education ultimately is responsible for determining which HEA reporting and disclosure requirements are applicable to IHEs that participate in Title IV and for promulgating regulations to implement those requirements. In July and August, 2009, ED published proposed regulations to implement the HEOA amendments to the HEA in the Federal Register . 
The HEOA also amended the HEA, effective July 1, 2010, to require the Secretary to provide IHEs with a list of all the reports and disclosures required under the act. The list that must be prepared by the Department of Education must include the following:
the date the report or disclosure is required to be completed and submitted, made available, or disseminated; the required recipients; any required methods for transmittal or dissemination; a description of the content of each report or disclosure sufficient to allow the IHE to assign responsibility to staff; references to applicable statutes, regulations, and guidance; and any other pertinent information relating to the reporting or disclosure requirement.
The remainder of this report identifies and describes requirements for institutions to report or disclose information to the Secretary, to students, to the public, or to other entities, such as lenders, guaranty agencies, and consumer reporting agencies, as specified in the HEA and Department of Education regulations. It begins with generally applicable requirements as specified in HEA, Title I—General Provisions; Title IV, Title G—General Provisions; and Title IV, Part H—Program Integrity, and concludes with Title IV program-specific requirements for the federal student loan and campus-based programs. Information on requirements to report or disclose information as part of the IPEDS surveys is presented in the Appendix .
The report generally follows the statutory framework of the HEA, and is organized by Title and Part. Brief general descriptions are provided for each of the major requirements for IHEs to report or disclose information. These descriptions are followed by tables which present the pre-HEOA requirements for IHEs to report or disclose information, a statutory or regulatory citation for the requirement, and the designated recipient of the information. The tables also show any corresponding changes made by the HEOA to these requirements. For instance, the tables highlight additional new requirements, as well as changes to the content of what was required to be reported under previously exiting requirements.
subsections: section_title: Title I—General Provisions
paragraphs: Prior to the reauthorization of the HEA in 2008, Title I of the HEA included four parts, which established general provisions for the remainder of the HEA: (1) Part A: Definition of an Institution of Higher Education, (2) Part B: Additional General Provisions, (3) Part C: Cost of Higher Education, and (4) Part D: Administrative Provisions for Delivery of Student Financial Assistance. Several of the provisions included in Title I specifically affected IHEs' participation in the Title IV federal student aid programs. Only Part B, however, included specific reporting requirements for institutions. Part C included implicit reporting requirements such as those related to IPEDS, which is an annual series of surveys administered by ED. The requirement for institutions to participate in IPEDS was and continues to be included in the Program Participation Agreement (PPA) requirements included in HEA, § 487.
The HEOA amends the institutional reporting requirements included in Part A, Part B, and Part C. The HEOA adds a new set of institutional reporting requirements to Part C with a focus on transparency in college costs for consumers and textbook information. The HEOA also adds a new Part E: Lender and Institution Requirements Relating to Education Loans, which contains a series of requirements for IHEs to disclose information about student loans, which are in addition to requirements specified separately under Title IV, Part B—the Federal Family Education Loan (FFEL) program; Title IV, Part D—the William D. Ford Federal Direct Loan (DL) program; and Title IV, Part E—the Federal Perkins Loan program.
This section of the report examines the reporting requirements specified in Title I, Part A, Part B, and Part C of the HEA prior to and after enactment of the HEOA. It also examines requirements specified in Title I, Part E of the HEA that were enacted by the HEOA amendments.
subsections: section_title: Definition of Institution of Higher Education (Title I, Part A)
paragraphs: The HEA includes two definitions of IHEs. The first definition, specified in § 101, applies for institutional participation in programs other than those authorized under Title IV. The second definition, specified in § 102, applies for institutional participation in Title IV programs, the focus of this report. The § 101 definition recognizes as IHEs those institutions that are legally authorized by the state, are accredited or pre-accredited by an agency or association recognized by ED, are nonprofit institutions, award a bachelor's degree or provide at least a two-year program that is accepted as credit toward the completion of a bachelor's degree, and enroll as regular students only individuals who have graduated from a secondary institution or hold the equivalent of a high school diploma. The § 101 definition also recognizes institutions offering not less than a one-year program of training in preparation for employment and institutions admitting students beyond the age of compulsory secondary school attendance.
subsections: section_title: Definition of IHE for Participation in Title IV Programs (HEA, § 102)
paragraphs: The HEA, § 102 definition of an IHE, which applies for participation in Title IV programs, includes all institutions recognized as IHEs under HEA, § 101, and also proprietary institutions, postsecondary vocational institutions, and institutions located outside of the United States (i.e., foreign institutions). Proprietary institutions are defined as those institutions that provide training in preparation for gainful employment in a recognized occupation; are legally authorized by the state; are accredited by an agency or association recognized by ED; admit as regular students only individuals who have graduated from a secondary institution or hold the equivalent of a high school diploma, or who are past the age of compulsory attendance in the state in which the institution is located; and have been in existence for at least two years. In addition, until enactment of the HEOA, proprietary institutions were required to derive at least 10% of school revenue from non-Title IV funds. Under the HEOA, this requirement—commonly referred to as the 90/10 rule—was removed from the § 102 definition of an IHE and made part of the requirements for institutional program participation agreements, specified under HEA, Title IV, Part G (described below). Postsecondary vocational institutions must meet criteria similar to those applicable to proprietary institutions with two exceptions: (1) they must be nonprofit institutions, and (2) they are not subject to the 90/10 rule. 
In addition, to be eligible to participate in Title IV programs, institutions must meet certain requirements based on course of study or enrollment. Institutions are required to report compliance with the following four requirements as part of their Application for Approval to Participate in Federal Student Financial Aid Programs (E-App) (described below under Title IV, Part H).
1. No more than 50% of an institution's courses, other than a postsecondary career and technical institution, may be correspondence courses (excluding courses offered by telecommunications) (§ 102(a)(3)(A)). 2. No more than 50% of an institution's students may be enrolled in correspondence courses (excluding courses offered by telecommunications) (§ 102(a)(3)(B)). 3. No more than 25% of an institution's enrollment may be comprised of students who are incarcerated (§ 102(a)(3)(C)). 4. No more than 50% of enrollment at an institution that does not provide a two-year or four-year course of study (or both) leading to an associate's or bachelor's degree may be comprised of students who do not possess a high school diploma or its equivalent (§ 102(a)(3)(D)).
subsections: section_title: Foreign Institutions
paragraphs: In general, foreign institutions are currently eligible to participate in the Federal Family Education Loan (FFEL) program if they meet the same requirements as an IHE under § 101 and have been approved by ED to participate in the FFEL program. Foreign medical and veterinary institutions, however, must meet additional requirements to participate in the FFEL program. Foreign institutions must report information demonstrating that they meet the terms of these requirements on the E-App. (see below). Foreign medical institutions must meet one of the following two sets of additional criteria (§ 102(a)(2)(A)). 
1. At least 60% of the students, and at least 60% of the graduates of a graduate medical school located outside of the United States, must not be U.S. citizens or permanent residents; and at least 60% of the students or graduates of a graduate medical school located outside of the United States or Canada taking examinations administered by the Educational Commission for Foreign Medical Graduates must receive a passing score. 2. The graduate medical school must have a clinical training program that was approved by a state as of January 1, 1991.
For foreign for-profit veterinary institutions to be eligible to participate in the FFEL program, they must require their students to complete their clinical training at an approved veterinary school located in the United States.
The HEOA amended eligibility requirements for foreign medical institutions and veterinary institutions, and added eligibility requirements for foreign nursing schools to participate in the FFEL program, effective July 1, 2010. It is expected that when these new requirements become effective, foreign institutions would be required to report information demonstrating that they meet these requirements on the E-App. 
Foreign for-profit graduate medical institutions. Effective July 1, 2010, foreign medical institutions will be required to meet one of the following two sets of additional criteria to participate in the FFEL program. 
1. At least 60% of the students, and at least 60% of the graduates of a graduate medical school located outside of the United States, must not be U.S. citizens or permanent residents; and at least 75% of the students or graduates of a graduate medical school located outside of the United States or Canada taking examinations administered by the Educational Commission for Foreign Medical Graduates must receive a passing score. 2. The graduate medical school must have a clinical training program that was approved by a state as of January 1, 1991; and must continue to operate a clinical training program in at least one state that is approved by that state.
Foreign veterinary institutions . The HEOA made no changes to the requirements for these institutions to participate in the FFEL program.
Fore ign nursing schools. In accordance with amendments enacted in the HEOA and P.L. 111-39 , effective July 1, 2012, foreign nursing schools can become eligible to participate in the FFEL program, but will be required to meet the following five eligibility requirements.
1. The school must have an agreement with either a hospital or accredited school of nursing located in the United States at which the school's students are required to complete their clinical training. 2. The school must have an agreement with an accredited school of nursing located in the United States which provides that its students will also receive a degree from the school in the United States upon graduation. 3. The school may certify only FFEL program loans for its students. 4. The school must reimburse the Secretary for the costs of any loan defaults for current and former students included in the calculation of its cohort default rate for the preceding fiscal year. 5. At least 75% of students or graduates from the school who, during the preceding year, took the National Council Licensure Examination for Registered Nurses must have received a passing score.
section_title: Disclosures of Foreign Gifts (Title I, Part B)
paragraphs: In accordance with HEA, § 117, institutions that are owned or controlled by a foreign source or that receive a gift from or enter into a contract with a foreign source valued at $250,000 or more, when considered alone or in combination with other gifts from or contracts with that foreign source within a calendar year, must file a disclosure report with the Secretary. The report must be filed on January 31 or July 31, whichever date is closest following receipt of the gift. Institutions that are required to publicly disclose gifts from or contracts with foreign sources under state laws that are substantially similar to the requirements of HEA, § 117, or that are required by any executive branch agency to prepare a report on gifts from or contracts with foreign sources according to requirements that are substantially similar to the requirements of HEA, § 117, may file a copy of such disclosure report in lieu of separately filing a disclosure report with the Secretary. 
If an institution fails to comply with these requirements, the Secretary may request the Attorney General to bring a civil action to request the court to compel compliance. Institutions that knowingly or willfully fail to comply with the requirements of this section must repay the United States for the full costs of obtaining compliance. The HEOA did not amend the HEA requirements for the disclosure of foreign gifts. Reporting requirements for IHEs relating to the disclosure of foreign gifts are presented in Table 1 .
section_title: Drug and Alcohol Abuse Prevention (Title I, Part B)
paragraphs: The HEA includes several institutional reporting requirements related to the prevention of drug and alcohol abuse, most of which had been incorporated into the HEA prior to the enactment of the HEOA. As a condition of eligibility to receive funds or any form of financial assistance under any federal program, institutions are required to certify to the Secretary that they have adopted and implemented a program to prevent the use of illicit drugs and the abuse of alcohol. An institution failing to provide this certification is not eligible to receive funds or any other form of financial assistance under any federal program. Institutions must distribute information about drug and alcohol abuse and prevention to students and employees on an annual basis. This includes standards of conduct, applicable legal sanctions, a description of health risks, a description of available counseling, treatment, or rehabilitation programs, and a description of institutional sanctions. Institutions must also make this information available to the Secretary and the public upon request. In addition, institutions are required to conduct a biennial review of the effectiveness of their programs, to implement changes to the programs if necessary, and to ensure that required sanctions are consistently enforced. (HEA, §§ 120 and 487(a); and 34 CFR § 668.14).
Part B of the HEA, as amended by § 107 of the HEOA, retains all of the aforementioned reporting requirements. However, the requirements for the biennial review have been expanded to include a determination of the number of drug and alcohol-related violations and fatalities that occur on campus or as part of the institution's activities that are reported to campus officials, and the number and types of sanctions imposed by the institution in response to these violations and fatalities. Reporting requirements for IHEs relating to drug and alcohol abuse prevention are presented in Table 2 .
section_title: Participation in Data Collection by ED (Title I, Part C)
paragraphs: Under Title I, Part C, the Department of Education collects a broad array of information about institutions. On an annual basis, the Commissioner of Education Statistics is required to collect information from (at least) all institutions participating in Title IV programs. Examples of information collected include data on tuition and fees, costs of attendance (COA), and the average amount of financial assistance received by undergraduate students by type of assistance required to be collected under HEA, § 131(a). These data are annually collected by ED through IPEDS. Institutions must participate in IPEDS to retain their Title IV eligibility. Institutions are also required to participate in any other federal postsecondary institution data collection in a timely manner (e.g., the National Postsecondary Student Aid Survey (NPSAS)). Under the HEOA amendments to the HEA, these reporting requirements were retained and expanded to reflect the addition of new data elements to IPEDS (see Title IV, Part G, and Table 16 , below), and a new requirement that NPSAS data be representative for each state. Reporting requirements that relate to college affordability and transparency, IPEDS, NPSAS, and college textbook information are summarized below.
subsections: section_title: Reporting Requirements Relating to College Affordability and Transparency
paragraphs: Under HEA, § 131(a), IHEs are required to annually report information on undergraduate tuition and fees, cost of attendance, the number of undergraduate students receiving specified forms of financial assistance, and the average amount of financial assistance received. Institutions have been required to report this information through IPEDS. 
The HEOA amended the HEA by establishing a requirement for ED to annually publish six lists relating to college affordability by sector (e.g., public four-year institutions):
1. the 5% of institutions with the highest tuition and fees; 2. the 5% of institutions with the highest net price; 3. the 5% of institutions with the largest percentage increase in tuition and fees over the last three academic years; 4. the 5% of institutions with the largest percentage increase in net price over the last three academic years; 5. the 10% of institutions with the lowest tuition and fees; and 6. the 10% of institutions with the lowest net price. 
Institutions listed on the third or fourth lists are also subject to reporting requirements related to the reasons for cost increases and steps being taken to reduce costs, unless their increase in tuition and fees or net price over the three-year period was less than $600. Reporting requirements for IHEs relating to the cost of higher education are presented in Table 3 .
section_title: Consumer Information Reporting Requirements
paragraphs: The HEOA amended the HEA to require ED to make available various information about institutions, such as data concerning student enrollment, graduation rates, cost of attendance, student aid, and specific services offered by the institution. Many of these items were already collected in some form through IPEDS or other data collection efforts maintained by ED. As discussed later in the Title IV, Part G section of this report, the Program Participation Agreement requires all institutions to participate in IPEDS, and other postsecondary education data collection efforts as designated by the Secretary, in a timely manner and "to the satisfaction of the Secretary."
The HEOA amended the HEA by adding new requirements relating to transparency in college tuition for consumers (HEA, § 132(i)). This amendment requires the Secretary to make an array of consumer information publicly available on the College Navigator website. It may be presumed that much of this information will be collected through IPEDS if it is not already being collected through another data collection effort. Table 4 presents an analysis of the new consumer information reporting requirements and identifies for each data element, whether it was being collected through IPEDS or another source prior to the enactment of the HEOA, or whether it is a new data collection requirement. Prior to enactment of the HEOA, the HEA generally did not specify data elements on which the Secretary must publicly report—with the exception of data related to tuition and fees and cost of attendance (§ 131(a) and (b), discussed above)—and, for the most part, the HEA did not specify data elements that institutions must provide to the Secretary. Thus, the comparisons made in Table 4 primarily focus on the differences between specific requirements included in § 132(i) and IPEDS data collection requirements in effect prior to the enactment of the HEOA.
The HEOA also amended the HEA by adding a new requirement for the Secretary to develop a multi-year tuition calculator for use by current and prospective students, their families, and others in estimating prices for tuition and fees in future years for each year during the normal duration of a program of study (HEA, § 132(j)). The multi-year tuition calculator will use tuition and fee information reported by IHEs as required under HEA, § 132(i). For institutions that offer multi-year tuition guarantee programs, the calculator must also allow individuals to obtain estimates of tuition and fees in future years based on the provisions of the tuition guarantee program.
section_title: State-by-State Student Aid Recipient Survey (NPSAS)
paragraphs: Prior to the enactment of the HEOA, § 131(d) of the HEA required the Secretary to conduct a triennial, nationally representative survey of individuals who receive federal student aid under Title IV. The survey was required to be representative of students from all types of institutions, as well as full-time students, part-time students, undergraduate students, graduate students, professional students, current students, and former students. The specified purposes of the survey were to identify the population of federal student aid recipients; to determine their income distribution and socioeconomic characteristics; to describe the combinations of federal, state, and private aid received by students; and to describe loan recipients' debt burden and their capacity to repay their education debts. This information has been collected through the National Postsecondary Student Aid Study (NPSAS), authorized under the Education Sciences Reform Act of 2002, Title I, Part D, §153(a)(1)(E).
The HEOA amends the HEA at § 132(k) to require ED to conduct a quadrennial survey, on a state-by-state basis, of individuals who receive federal student financial aid under Title IV. The state-by-state survey must be representative of students from all types of institutions, as well as full-time students, part-time students, undergraduate students, graduate students, professional students, current students, and former students. The specified purposes of the survey were expanded to also include describing the impact of students' education debt burden on their courses of study and post-graduation plans, and describing how the costs of textbooks and other instructional materials affect the costs of postsecondary education. It appears that the new state-by-state representative sample of students and former students may be implemented as a modification to the NPSAS, through which similar information on students is currently collected.
While NPSAS respondents are students or former students, institutions are required to provide ED with certain information about sampled students through a two-stage process. In the 2008 NSPAS, about 1,900 IHEs were included in the sample of institutions. These IHEs were asked to provide ED with enrollment lists that included the names of all students enrolled at a certain date, as well as information including date of birth, social security number, education level, major, and contact information. From the enrollment lists, ED then selected approximately 140,000 students to include in their survey sample. ED also requested additional information from the IHEs on sampled students, including demographic information, admission information (for undergraduates), enrollment status, the degree the student is working toward, and tuition, financial aid, and scholarship information. 
The HEOA did not change the types of information to be collected from IHEs for the NPSAS. However, the new requirement for data to be representative by state will increase the number of students and IHEs required to be included in the NPSAS sample. The increase will be especially acute in states with a relatively small number of students, as a large portion of these students will have to be included in a sample to ensure it is representative of the state. 
section_title: Textbook Information Program
paragraphs: The HEOA prospectively amends Title I, Part C of the HEA by adding a new § 133, which establishes new requirements concerning information about textbooks. Under the new requirements, information provided by publishers to faculty members who are in charge of selecting course materials at Title IV participating institutions must include certain price information and copyright dates of previous editions. The new provision also will require textbook publishers to "unbundle" materials, except under certain circumstances, and to make textbooks and each supplement to a textbook available as separate items. 
In accordance with the new provision, IHEs that receive federal financial assistance will be required, to the maximum extent possible, to publish as part of online course pre-registration and registration materials, the International Standard Book Number (ISBN) for all materials that will be used in each class, as well as the retail price of required and recommended course materials for each course listed in the institution's course schedule. Institutions will also be required to make available to the college bookstores they operate, or with which they are affiliated, upon request, their course schedule for the subsequent academic period, the aforementioned information about course materials, and enrollment information for each class. In addition, under the new provision, IHEs will be encouraged to disseminate information to students regarding the availability of renting textbooks, purchasing used textbooks, guaranteed textbook buy-back programs, and alternative ways to obtain course content. Requirements for IHEs that receive federal financial assistance to disclose certain information about college textbooks are presented below in Table 5 . 
section_title: Institution Requirements Relating to Education Loans (Title I, Part E)
paragraphs: The HEOA adds a new Part E to Title I which establishes new requirements for lenders and institutions with respect to federal student loans made under Title IV, as well as private student loans. For institutions that participate in preferred lender arrangements—in which the IHE recommends, promotes, or endorses the student loan products (e.g., FFEL program loans and private student loans) of certain lenders—new requirements specify that IHEs must disclose or report certain information, including the maximum amount of Title IV grant and loan aid available to students; detailed information about the terms and conditions of loans; that under the FFEL program, the institution is required to process applications to obtain a loan from any eligible lender; and a detailed explanation of why the IHE entered into a preferred lender arrangement with the lender. 
Institutions that participate in preferred lender arrangements also must inform prospective borrowers of private student loans that they may qualify for federal student aid under Title IV, and that the terms and conditions of federal student loans may be more favorable than the terms and conditions of private student loans. Institutions may make the required disclosures about student loans and preferred lender arrangements on model disclosure forms developed by the Secretary and the Board of Governors of the Federal Reserve System, or on forms developed by the institution. 
Institutions that participate in the DL program must make publicly available a completed model disclosure form for DL program loans containing information comparable to what must be disclosed by IHEs with respect to FFEL program loans. The Secretary will be required to provide completed model disclosure forms for DL program loans to IHEs that participate in the DL program. Institutions will be required to post this information on their websites and to include it in informational materials about financial aid that are distributed to prospective students and their families.
The HEOA also amended the HEA to establish a requirement for borrowers of private student loans to self-certify their eligibility for these loans. The provisions for self-certification require institutions to disclose to prospective borrowers of private student loans certain information necessary for completion of the form, including their cost of attendance, their expected family contribution, and the estimated financial assistance they will receive. Detailed information on reporting requirements for institutions with respect to student loans is presented in Table 6 . 
section_title: Title IV, Part G—General Provisions
paragraphs: Title IV, Part G includes a broad array of requirements and other provisions applicable to institutions that participate in Title IV programs. Part G provisions which establish requirements for IHEs to report or disclose information may be categorized into the following major areas.
Student eligibility requirements applicable to the receipt of federal student aid, including determination of eligibility and need, and verification of immigration status. Information about the institution and its programs; the availability of, procedures to apply for, and descriptions of federal student aid programs; the institution's transfer of credit policies; and penalties for drug-related offenses. Entrance and exit counseling for borrowers of FFEL and DL program loans; and verification of borrower information in the National Student Loan Data System (NSLDS). Information on athletic programs and students who receive athletically related student aid; and completion or graduation rates, both for recipients of athletically related aid and for all students. Information on campus security, campus crime, fire safety, and missing persons procedures. Information required as part of program participation agreements, including the reporting or disclosure of institutional and financial assistance information, information collected as part of the IPEDS surveys, information on student loan codes of conduct, and information on student loan preferred lender lists.
This part of this report identifies and describes provisions specified in Title IV, Part G that require the reporting or disclosure of information by institutions that participate in Title IV programs.
subsections: section_title: Student Eligibility
paragraphs: Under Title IV, Part G, institutions are required to provide students with a determination of eligibility and need for federal aid. They are also required to provide information concerning individuals who are determined to be ineligible for federal student aid due to their immigration status to the U.S. Citizenship and Immigration Services (USCIS); and information concerning individuals determined to be ineligible for federal student loans to applicable lenders and guaranty agencies. Reporting requirements for IHEs relating to student eligibility are presented below in Table 7 .
section_title: General Institutional Information and Financial Assistance
paragraphs: Prior to enactment of the HEOA, HEA, § 485 required each institution whose students participate in HEA Title IV programs to disseminate multiple pieces of information through various means, upon request, to enrolled students and to prospective students. In addition, compliance with the requirements of § 485 has been a component of the Program Participation Agreement into which IHEs must enter with the Secretary for initial and continuing eligibility to participate in Title IV programs. (Program Participation Agreements are discussed below.) All enrolled students must be provided an annual notification about what information is available and how it may be obtained. The types of information that institutions must provide include information about available financial assistance programs, how to obtain financial aid, and conditions for receiving aid; costs of attendance; specific program costs; the institution's academic program; facilities and services available to individuals with disabilities; the institution's accreditation; standards for satisfactory student progress; completion or graduation rates; the ability of students to enroll in a study-abroad program that may still qualify them for federal student aid; and campus crime. An institution whose mission includes the preparation of students to enroll in another eligible institution also must provide the transfer-out rate of its certificate- or degree-seeking, full-time undergraduate students. 
The HEOA added several disclosure and regulatory requirements to the HEA. As previously mentioned, institutions are required, upon request, to disclose various information to current and prospective students. The HEOA expanded on these requirements to include additional information that must be disclosed, such as institutional policies and sanctions related to copyright infringement, information about student body diversity, and the placement in employment of the institution's graduates. Additional requirements were added related to the disaggregation of completion and graduation rates, emergency response and fire safety, transfer of credit, missing person procedures, drug policy notifications, and reimbursements paid to any employees for service on advisory boards. For example, under the new transfer of credit policies, institutions must publicly disclose any criteria used to make transfer of credit determinations, and the institutions with which it has established an articulation agreement. Under the new policies relating to drug-related offenses, institutions must notify students about penalties for drug violations, including notifying students who have lost their eligibility for federal student aid due to a drug violation of the options to regain eligibility. Previously existing and new reporting requirements are detailed below in Table 8 .
section_title: Entrance Counseling and Exit Counseling
paragraphs: According to statutory and regulatory provisions in effect prior to the enactment of the HEOA, IHEs are required to ensure that student borrowers of FFEL and DL program loans receive initial counseling and exit counseling. Department of Education regulations specify requirements for initial counseling, while statutory provisions specify requirements for exit counseling. 
Initial counseling, or entrance counseling, must be provided before the first disbursement of the loan. The counseling must include an explanation of the Master Promissory Note (MPN), the significance of the borrower assuming an obligation to repay a student loan, the consequences of default, sample repayment schedules, the borrower's rights and responsibilities with respect to the loan, and the terms and conditions of the loan. 
Exit counseling must be provided before a student who has borrowed a FFEL or DL program loan leaves school. Exit counseling includes a review of the information provided during entrance counseling; an estimate of average anticipated monthly payments based on the borrower's actual student loan debt or the average student loan debt of borrowers in the same program at the same school; available repayment options; debt management strategies; options for deferment, forbearance, forgiveness, and discharge; notification that the borrower's loan history is available through NSLDS; and information about whom the borrower may contact regarding questions about the terms and conditions of his or her loan (i.e., the Department of Education Student Loan Ombudsman).
The HEOA amended the HEA to specify statutory requirements for entrance counseling and to add additional statutory requirements for exit counseling. New requirements for exit counseling include the provision of information about the option to pay the interest as it accrues on Unsubsidized Stafford Loans and PLUS Loans while the borrower is in school; the importance of contacting the IHE in the case of early withdrawal so that exit counseling can be provided; the effects of consolidating one or more FFEL, DL, or Perkins Loans into a Consolidation Loan on the terms and conditions of the underlying loan or loans; and a description of tax benefits available to borrowers.
The HEOA also amended the HEA by adding a requirement that institutions inform borrowers of loans made under the FFEL, DL, and Perkins Loan programs that information about their loans will be submitted to NSLDS and will be accessible to guaranty agencies, lenders, and institutions that are determined by the Secretary to be authorized users of NSLDS.
Information on requirements applicable to institutions with respect to the disclosure of information as part of entrance counseling, exit counseling, and NSLDS is presented in Table 9 . 
section_title: Athletically Related Student Aid and Athletic Programs
paragraphs: Institutions at which students receive athletically related student aid are required to annually report to the Secretary by July 1 on the number of participating students by sport, race, and sex; completion or graduation rates by race and sex in specific sports for the current year and average of the four most recent years; and the completion or graduation rate for all students by race and sex for the current year and average of the four most recent years. The information must also be provided to prospective athletically related aid recipients and their parents, guidance counselors, and coaches. These requirements may be waived by the Secretary for an institution that is a member of an athletic association or conference that voluntarily publishes completion or graduation rate data (or has agreed to publish such data), if the Secretary determines the published information is comparable to the aforementioned information (HEA § 485(e); and 34 CFR §§ 668.41 and 668.48).
Any coeducational institution participating in Title IV programs and that has an intercollegiate athletic program must annually report information on team composition, operating expenses, coaches, the ratio of athletically related aid for men versus women, revenues for men's and women's teams, and related data. A report on athletic program participation rates and financial support data must be made available to students and potential students, upon request, and to the public. Enrolled students must be informed of their right to request the information. The report must be provided to ED within 15 days of the institution making the report available to students and the public. (HEA § 485(g); and 34 CFR 668.14, 668.41, and 668.47; OMB No. 1845-0010).) Reporting requirements for IHEs with respect to athletically related student aid and athletic programs are presented in Table 10 .
section_title: Campus Security, Campus Crime, Fire Safety, and Missing Person Procedures
paragraphs: Statutory requirements related to campus crime and security are specified in HEA, § 485(f). Institutions must certify that they have established a campus security policy and have complied with the disclosure of campus security policy and campus crime statistics requirements. Institutions must provide detailed information about campus security policies and crime statistics, including statistics on the types of crimes committed by category, a description of programs to inform current and prospective students and employees about the prevention of crimes, crime statistics, and various policy statements. Institutions must distribute an annual security report to enrolled students and current employees by October 1 of each year. Statistics about the number of criminal offenses by category also must be reported annually to ED. In addition, institutions are required to make timely reports to the campus community about any crimes considered to be a threat to students or employees. Institutions also are required to develop and distribute materials about their sex offense policies, prevention measures, reporting procedures, and penalties. Any institution with a police or security department must maintain a daily crime log that includes the nature, date, time, and general location of each crime, as well as the disposition of the complaint, if known. Institutions that substantially misrepresent the number, location, or nature of crimes may be subject to civil penalties under HEA § 487(c)—Audits; Financial Responsibility; Enforcement of Standards. (HEA §§ 485(f) and 487(a); and 34 CFR 668.14, 668.41, and 668.46.)
subsections: section_title: Campus Security and Campus Crime Measures
paragraphs: The HEOA adds several requirements related to campus crime and security. For example, it expands the list of crimes for which institutions must indicate whether the crime committed was a "hate crime" to include crimes such as simple assault and intimidation. It also modifies current reporting requirements related to the relationship between campus law enforcement and other security personnel. The HEOA requires institutions to inform current and prospective students and employees about campus policies related to immediate emergency response and evacuation procedures, including the use of electronic or cellular communication. (HEA, § 485(f).)
section_title: Fire Safety Standards and Measures
paragraphs: The HEOA amends the HEA by establishing a requirement that institutions publish an annual fire safety report, to be available to the public and submitted to the Secretary, that contains information about fire safety practices and standards at the institution and provides data on fires that occurred in on-campus housing facilities. (HEA, § 485(i).)
section_title: Missing Person Procedures
paragraphs: The HEOA amends the HEA by establishing requirements related to missing student notification. Each institution is required to have a policy for students residing in on-campus housing that informs them that they each have the option to identify someone to be contacted if they are determined to be missing. The policy must also specify contact requirements for students under the age of 18 who are determined to be missing, and indicate that law enforcement will be contacted within 24 hours of a student being determined to be missing (§485(j)(1)). Prior to the enactment of the HEOA, the HEA did not include reporting requirements related to missing person procedures. (HEA, § 485(j).)
Reporting requirements applicable to institutions with respect to campus security, campus crime, fire safety, and missing persons procedures are presented in Table 11 .
section_title: Program Participation Agreement
paragraphs: The Program Participation Agreement (PPA) is a document that each institution is required to sign in order to participate in federal student aid programs, and which also contains general reporting requirements for institutions. In some instances, these requirements may be redundant with those specified in other sections of the HEA, while in other instances they may add new requirements, or provide clarification of or additional information about a requirement that is mentioned elsewhere in the HEA. For example, the PPA requires that if an institution uses job placement rates as a means of attracting students, it must make the most recent employment statistics, graduation statistics, and other information available to substantiate the advertised rates, as well as relevant state licensing requirements for the state in which the institution is located related to any jobs for which the program is designed to prepare students. This requirement is not stated clearly elsewhere in the HEA, although this is information that accrediting agencies are required to review. (HEA § 487(a); and 34 CFR § 668.14.) Provisions of PPAs that require the reporting or disclosure of information are presented in Table 12 . 
section_title: Title IV, Part H—Program Integrity
paragraphs: Part H of Title IV specifies the roles and responsibilities for the three aspects of the program integrity triad: (1) state authorization, (2) accreditation by an accrediting organization recognized by the Secretary of Education, and (3) eligibility and certification by ED. The triad is intended to provide balance in assuring the eligibility of institutions for Title IV programs. The state role is primarily one of consumer protection, while the accrediting agencies are intended to function as a quality assurance mechanism. These two legs of the triad were developed independently of the federal government. The federal government has historically relied on them to avoid generating concerns about federal interference in educational decision-making. ED is responsible for the third leg of the triad, oversight of compliance; that is, protecting the administrative and fiscal integrity of the federal student aid programs. Most of the reporting requirements in Part H are imposed in response to the third leg of the triad. These requirements, however, are generally specified in regulations rather than statutory language.
subsections: section_title: State Authorization
paragraphs: The state role in the triad is to provide legal authority for postsecondary institutions to operate in the state in which they are located. The state provides legal authorization to an institution through a charter, license, or other written document issued by the appropriate state agency or state official. Each institution is required to provide evidence to the Secretary that the institution has authority to operate within a state at the time it is certified as eligible for the Title IV federal student aid programs (see discussion below). The HEOA did not amend this requirement. (HEA § 495.)
section_title: Accreditation
paragraphs: The second aspect of the triad focuses on accreditation. Institutions that want to participate in the federal student financial aid programs must be accredited by an accrediting agency or organization recognized by the Secretary. The HEA, both prior to and after the enactment of the HEOA, includes numerous requirements that accrediting agencies must meet to gain recognition from the Secretary. These provisions require the accreditors to assess specific aspects of an institution, such as its success with respect to student achievement, curricula, faculty, and student support services. While these provisions apply directly to accrediting agencies, they have an indirect effect on institutions in so far as institutions must provide information and data that accrediting agencies must examine in order to gain recognition from the Secretary. Therefore, this section examines potential reporting requirements that may be placed on institutions by accrediting agencies in response to the requirements accrediting agencies must meet to be recognized by the Secretary. It is unclear to what extent these requirements are actually reporting requirements that are placed on institutions. In addition, this section focuses only on potential institutional reporting in response to the requirements in the HEA. Accrediting agencies may have their own institutional reporting requirements that are not addressed in the HEA.
Accrediting agencies must consistently apply and enforce standards that ensure that the education programs, training, or courses of study offered by an IHE are of sufficient quality to meet the stated objectives for which the programs, training, or courses are offered. The standards used by the accrediting agency or association must assess student achievement, in relation to the institution's mission, including, as applicable, course completion, passage of state licensing examinations, and job placement rates. The accrediting organization must also consider the institution's curricula, faculty, facilities, fiscal and administrative capacity, student support services, recruiting and admissions practices, measures of program length, objectives of the credentials offered, and student complaints received directly by the agency or association or those that are available to the agency or association. The institution's record of compliance with the institutional requirements of Title IV must also be examined with respect to the most recent student loan default rate data provided by ED, the results of financial or compliance audits, program reviews, and other information provided to the agency or association by ED. (HEA §496(a).)
The HEOA amended the HEA by modifying and adding requirements related to accreditors' assessments of institutions. When consistently applying and enforcing standards, an accrediting agency must do so in a manner that respects the stated mission of the institution, including religious missions. The HEOA also requires accrediting agencies to require institutions that offer distance education or correspondence education to have a process by which the institution is able to determine that the student who registers for a course is the student who participates in, completes, and receives credit for the course. When accrediting agencies evaluate the institution's success with respect to student achievement, their evaluation may include different standards for different institutions or programs, as established by the institution. Finally, as part of an accrediting agency's review of an institution for accreditation or reaccreditation, the accrediting agency must confirm that the institution has transfer of credit policies that are publicly disclosed and include a statement of the criteria used to make transfer-of-credit decisions.
As previously mentioned, this overview of HEA reporting requirements does not focus on the accreditation process. However, there are two sets of special circumstances in which an institution must report information directly to the Secretary with respect to a change in accreditation. Institutions seeking a change in accreditation must provide all materials related to its prior accreditation or preaccreditation, and materials substantiating the need for the change, to the Secretary. In addition, institutions seeking multiple accreditations must provide the Secretary and each accrediting agency with the reasons they seek to do so. (34 CFR § 600.11.) The HEOA did not amend these requirements.
 Table 13 details potential reporting requirements that may be placed on institutions by accrediting agencies in response to the requirements accrediting agencies must meet to be recognized by the Secretary. Unlike previous reporting requirements discussed in this report, it is unclear to what extent these are actually reporting requirements with which institutions must comply.
section_title: Eligibility and Certification
paragraphs: ED is responsible for the eligibility and certification portion of the triad. In this capacity, ED is responsible for verifying the institution's legal authority to operate in a state and its accreditation status, and for evaluating its administrative capability and financial responsibility. ED has developed an Application for Approval to Participate in Federal Student Financial Aid Programs (E-App) that all institutions must complete in order to be eligible to participate in Title IV programs. Through the application, ED requests information and documentation related to educational programs, telecommunications and correspondence courses, changes in ownership or structure, third-party servicers that perform functions related to the federal student aid programs, administrative capability, and financial responsibility. Eligibility to participate in Title IV programs is authorized for up to six years.
The HEOA did not amend requirements related to eligibility and certification procedures. All institutional reporting requirements discussed in this section were included in the HEA prior to the enactment of the HEAO.
The form used to establish institutional eligibility to participate in Title IV programs is also used for a variety of other purposes. The form is used by an institution that wants to be designated as an "eligible" institution (but not participate in Title IV programs), so that its students may receive deferments on Title IV loans or be eligible to receive the HOPE or Lifetime Learning Scholarship tax credits, or so the institution may apply to participate in non-Title IV HEA programs. Thus, complying with the reporting requirements on the application affects not only an institution's Title IV eligibility but also its eligibility for certain non-Title IV programs. The form must also be completed by an institution that wants to receive initial certification, be recertified, or be reinstated to participate in the federal student aid programs. Institutions that undergo a change of ownership, convert from a for-profit institution to a nonprofit institution or vice versa, or merge with another institution must also complete the form. Finally, institutions that want to expand their federal student aid program eligibility or certification or need to update previously reported information must complete the form.
The application form is developed by the Secretary and is designed to collect enough information from each institution to determine whether the institution meets the requirements of eligibility, accreditation, financial responsibility, and administrative capability. In completing the application, institutions must also describe the relationship between a main campus and all branch campuses and any third-party servicers. In addition, information relating to the institution's administrative capability and fiscal responsibility must be provided, upon request, to the Secretary, the appropriate guaranty agency, and the appropriate accrediting agency. The information must also be provided to the state agency that legally authorizes the institution to operate and to the state agency that approves public postsecondary vocational education, if the institution is a public postsecondary vocational educational institution. (HEA §§ 487(a) and 498(b); CFR § 668.14; and OMB No. 1845-0012.)
The institution must indicate on the application if it wants to participate in Title IV programs, and it must submit the required documentation to be considered for certification. For example, each institution must provide evidence that it has the authority to operate within a state at the time it is certified by ED. Institutions currently certified to participate in Title IV programs must apply for recertification periodically. An institution currently certified to participate in at least one Title IV program that wants to participate in one or more additional Title IV programs must submit an application to the Secretary. (HEA § 495(b); and 34 CFR § 600.20 (a).)
Foreign institutions are permitted to participate in the Federal Family Education Loan (FFEL) program authorized under Title IV, Part B. A foreign institution that wants to participate in the FFEL program or continue its eligibility for this program must submit an application to the Secretary with all required information and documentation. Foreign institutions failing to provide this information are not eligible to participate in FFEL. (34 CFR § 600.53.)
 Table 14 summarizes the types of information collected on the E-App. 
In addition to the information collected on the E-App, institutions are required to submit various documents depending on their specific circumstances. These documents are listed below.
All applicants: Current letter of accreditation and any attachments, valid state license or other state authorization, 501(c)(3) designation from the IRS (for nonprofit institutions only), and a copy of approval from the institution's accrediting agency if the institution contracts with an organization or an ineligible institution to provide more than 25% of any educational program. Initial applicants: Audited financial statements for the two most recently completed fiscal years and a default management plan (unless exempt from providing the latter). Institutions with a change in ownership or structure: Audited financial statements for the two most recently completed fiscal years, audited financial statements of the new owner of the institution's two most recently completed fiscal years, audited same-day balance sheet showing the financial condition of the institution after the change in ownership, and a default management plan (unless exempt from providing the latter). Institutions seeking reinstatement: Audited financial statements for the two most recently completed fiscal years and a default management plan (unless exempt from providing the latter). Foreign institutions: Certified English translation of nonprofit designation status (for nonprofit institutions only), most recent catalog and its certified English translation of all sections dealing with degrees and programs provided, legal authorization and its certified English translation to provide an educational program beyond the secondary school level in the country in which the institution is located, legal authorization and its certified English translation to award a degree that is equivalent to a degree in the United States, legal authorization and its certified English translation to provide graduate medical education (if applicable), audited financial statements for the two most recent years (if an initial applicant), and a default management plan (unless exempt from providing the latter).
Once an institution is determined to be eligible and certified to participate in Title IV programs, the institution must complete a Program Participation Agreement (described earlier). The PPA applies to all Title IV programs with the exception of the Leveraging Educational Assistance Partnership (LEAP) program. Under the PPA, an institution acknowledges that it is bound by the requirements of the Title IV programs and the laws, regulations, and policies governing these programs. 
section_title: Financial and Compliance Issues
paragraphs: Some financial and compliance reports are required to be submitted on a periodic basis. These reports are often used to determine an institution's initial or continuing eligibility to participate in Title IV programs. They are submitted directly to the Secretary and are made available to guaranty agencies, eligible lenders, and state agencies. In applying for certification or recertification, an institution must submit to the Secretary a financial statement audited by an independent certified public accountant. In addition, to be considered financially responsible, a public institution must notify the Secretary that it is designated as a public institution in a specific state and must provide a letter from that state or other government entity confirming its designation as a public institution and that it is not in violation of a past performance requirement. (HEA §498(c) and 34 CFR 668.171.)
An institution must comply with requirements for both financial and compliance audits, and the results must be submitted to the Secretary and made available to relevant guaranty agencies, eligible lenders, and state agencies. The financial audit must consider the overall financial condition of the institution, while the compliance audit focuses on funds obtained by the institution under HEA, Title IV or obtained from a student or parent who has a Title IV loan insured or guaranteed by ED. The compliance audit and audited financial statements must be submitted no later than six months after the last day of the institution's fiscal year. In addition, a public institution must submit to the Secretary a statement from the State Auditor General that the institution met all of its financial obligations for the past year and that it continues to have sufficient resources to meet all of its financial obligations. (HEA §487(c); and 34 CFR §§ 668.15 and 668.23.)
If an institution offers more than 50% of its courses by correspondence, has 50% or more of its regular students enrolled in correspondence courses, has more than 25% of its regular students in incarceration, or fails to meet requirements regarding the percentage of students with a high school diploma, the school is ineligible for Title IV. The institution must report this information to the Secretary by July 31 following the end of an award year. If an institution files for bankruptcy or its owner or chief executive officer has committed fraud involving Title IV funds, the institution must report the violation to the Secretary within 10 days. (HEA, § 102; 34 CFR § 600.7.)
Noncompliance with standards for participation in Title IV programs may result in an emergency action; imposition of a fine; limitation, suspension, or termination of participation in a Title IV program; and the limitation, suspension, or termination of the servicer (if an institution uses a third-party servicer) to contract with any institution to administer any aspect of its participation in Title IV programs. Further, if an institution is determined to be not financially responsible or fails to submit its financial and compliance audits by the date required and in the manner required, the institution may be fined or have its participation in Title IV programs limited, suspended, or terminated. If the institution is provisionally certified, its certification may be revoked. The specific reporting requirements that may be associated with an institution's failure to comply with standards for participation are beyond the scope of this report. (34 CFR §§ 668.11, 668.81 through 668.86, 668.92 through 668.95, and 668.171.)
section_title: End of Participation in Title IV Programs
paragraphs: If an institution's participation in Title IV programs ends, the institution must notify the Secretary and submit various documents to the Secretary, including a letter of engagement for an independent audit, plans for collection of outstanding loans, and financial and performance reports. The specific reporting requirements that may be associated with the end of an institution's participation in Title IV federal student aid programs are beyond the scope of this report. (34 § CFR 668.26.)
section_title: Title IV Program-Specific Requirements
paragraphs: While most requirements for the reporting or disclosure of information, as specified in Title I, or Part G and Part H of Title IV, are applicable to IHEs as a condition of their participation in one or more Title IV programs, several Title IV programs contain specific requirements for IHEs to report or disclose certain program-specific information to the Secretary, to students or borrowers, or to other entities. Some of these requirements are substantially similar to requirements specified elsewhere in the HEA. Also, in some instances, these requirements are operational in nature; for example, calculating financial need for borrowers and forwarding this information to lenders, or notifying lenders of a change in the status of a borrower. In other instances, these requirements pertain to the application to participate in a program and the use of funds for that program, as with the Fiscal Operations Report and Application to Participate (FISAP) for the campus-based programs. 
This part of this report examines program-specific reporting and disclosure requirements applicable to IHEs that participate in the FFEL program, the DL program, and the three campus-based programs—the FSEOG program, the FWS program, and the Federal Perkins Loan program.
subsections: section_title: Federal Student Loan Programs (FFEL and DL Programs)
paragraphs: Most requirements for institutions to report or disclose information with respect to the FFEL and DL programs are specified in the HEA under Title I or Part G—General Provisions, and Part H—Program Integrity of Title IV (see above), and in regulations implementing these provisions. However, the HEA also specifies several institutional requirements for the reporting or disclosure of information in statutory language authorizing the FFEL and DL programs.
subsections: section_title: Federal Family Education Loan Program (Part B)
paragraphs: In accordance with FFEL program requirements specified in Title IV, Part B, institutions are required to comply with several reporting and disclosure requirements which are primarily operational in nature. For each borrower of a Stafford Loan, institutions must provide eligible FFEL program lenders with a statement showing relevant need analysis data used in determining the borrower's eligibility for the loan (e.g., EFC, COA, and EFA, as applicable), the loan amount, and a disbursement schedule. Institutions must also provide information on changes in a borrower's permanent address, when the student ceases to be enrolled at least half-time, and any other change in status to the lender or the guaranty agency. The HEOA did not amend these FFEL program requirements. These requirements are presented in Table 15 .
section_title: William D. Ford Federal Direct Loan Program (Part D)
paragraphs: In accordance with DL program requirements specified in Title IV, Part D, institutions are required to provide timely and accurate information to the Secretary concerning the status of student borrowers while in attendance and after they leave school, for purposes of servicing and collecting on loans. This requirement is similar to the FFEL program requirements described above. The HEOA amended the HEA to establish requirements for institutions that participate in the DL program to comply with the student loan disclosure requirements specified in HEA, § 433 that are applicable to lenders of FFEL program loans, including disclosures before disbursement and before repayment. DL program reporting and disclosure requirements are presented in Table 16 .
section_title: Campus-Based Programs (FSEOG, FWS, & Federal Perkins Loans)
paragraphs: The Federal Supplemental Educational Opportunity Grant program, the Federal Work-Study program, and the Federal Perkins Loan program are collectively referred to as the campus-based programs. These programs are authorized under Title IV, Part A, Subpart 2; Part C; and Part E, respectively. They are need-based federal student aid programs under which students may receive aid made available through the institution they attend. Campus-based aid is funded through a combination of federal allocations to institutions and institutional matching funds. Institutions that participate in the campus-based programs are subject to a number of program-specific reporting requirements specified in the statute or regulations.
subsections: section_title: Fiscal Operations Report and Application to Participate (FISAP).
paragraphs: As its name implies, the FISAP is a data collection instrument used to gather program and fiscal information from institutions that have participated in one or more of the campus-based programs in a prior award year, and to gather information used in the allocation of funds to institutions that intend to participate in one or more of the campus-based programs in the subsequent award year. The FISAP is intended to ensure the proper and efficient administration of funds that institutions receive from the Secretary. Information reported on the FISAP includes identifying information and characteristics of the IHE, the IHE's request for funds to participate in each applicable program, enrollment information for undergraduate and graduate students arrayed according to income level, fiscal and program data for each applicable program (e.g., allotment of funds, aggregate student financial need, Perkins Loan cohort default rate data, employment in FWS community service, transfer of funds between programs, etc.), the distribution of campus-based program aid recipients by student type and income level, and administrative costs. The FISAP form contains more than 200 line items, and many of these line items have multiple data elements. FISAP forms are made available by July 1 of each year and completed FISAPs are due to ED by October 1 of each year. Institutions submit completed FISAPs to ED electronically via the Student Aid Internet Gateway. 
Requirements specified in the HEA for the reporting of information that is collected via the FISAP for the FSEOG, FWS, and Federal Perkins Loan programs are presented in Table 17 , Table 18 , and Table 19 , respectively. The HEOA made relatively few changes to the campus-based programs and these tables show the additional information that IHEs will likely be required to report on the FISAP.
section_title: FWS—Job Location and Development Program.
paragraphs: Institutions or groups of institutions may use FWS funds to operate job location and development programs for currently enrolled students. Each institution that operates a job location and development program must enter into an agreement with the Secretary stating that the institution will submit an annual report on the use of the funds under the program and an annual evaluation of the effectiveness of the program in benefitting the institution's students. (HEA, § 446(b)(6)).
section_title: Requirements for IHEs as Lenders of Federal Perkins Loans
paragraphs: Under the Federal Perkins Loan program, institutions make loans directly to students. In their capacity as lenders, institutions are required to disclose certain information about the terms and conditions of Perkins Loans to borrowers prior to making a loan, as part of the loan agreement, and also prior to the commencement of repayment. In addition, institutions must disclose information about borrower's Perkins Loans to consumer reporting agencies, including information about the disbursement and repayment of loans, loan defaults, and the rehabilitation of defaulted loans. Requirements for institutions to report or disclose information about the terms and conditions of Perkins Loans to borrowers, and the repayment of loans to consumer reporting agencies is presented in Table 20 . In addition, as a requirement of program participation agreements (see previous discussion), institutions must report information on Perkins Loans to the National Student Loan Data System (NSLDS).
subsections: section_title: Appendix. IPEDS and Other Postsecondary Education Data Collections
paragraphs: Under Title IV, Part G, as part of Program Participation Agreements, IHEs are required to respond to IPEDS or any other federal postsecondary institution data collection effort, as specified by the Secretary, in a timely manner and to the satisfaction of the Secretary. There are multiple postsecondary data collections that are conducted by ED on either an annual basis (e.g., IPEDS) or every few years (e.g., NPSAS). For some of these data collection efforts the participation of all IHEs is required (e.g., IPEDS), while for others a sample of IHEs are selected for participation (e.g., the National Postsecondary Student Aid Study (NPSAS)). Because IPEDS is an annual, mandated reporting requirement for all IHEs, this appendix provides a detailed depiction of the IPEDS reporting requirements. A review of other postsecondary data collections is beyond the scope of this report.
Integrated Postsecondary Education Data System
IPEDS is the primary postsecondary education data collection program for the National Center of Education Statistics at ED. Through IPEDS, data are collected from all primary providers of postsecondary education in the U.S. through surveys. Data are collected from academic, vocational, and continuing professional education programs that are provided by institutions open to the general public. All IHEs that participate, or are authorized to participate, in any of the federal student aid programs authorized by Title IV of the HEA are required to respond to IPEDS. Other institutions may choose to participate in IPEDS. Selected data for any institution that responds to IPEDS are included in the College Navigator website.
IPEDS data are collected through a series of eight survey components: institutional characteristics, degree completions, 12-month enrollment, human resources (including fall staff and salaries), fall enrollment, finance, financial aid, and graduation rates. Most surveys are conducted annually. Examples of data collected on each of these surveys are provided below.
Institutional characteristics: institutional contact information, educational offerings, mission statement, control, affiliation, admissions requirements, and student charges. Degree completions: level or type of degree (degree programs) and length of program (non-degree programs). 12-month enrollment: unduplicated headcounts and instructional activity, and full-time equivalent (FTE) enrollment. Human resources: employees assigned by position, including full- or part-time status, function, or occupational category; and faculty status and tenure status; as well as data on fall staff and salaries. Fall staff: full-time faculty by contract length and salary intervals, non-faculty employed full time by primary occupational activity and salary class intervals, tenure of full-time faculty, and number of new hires by primary occupational activity (data collected biennially in odd-numbered years from IHEs with 15 or more full-time employees). Salaries: number of full-time instructional staff by rank, gender, and length of contract; total salary outlay; and fringe benefit information (data are collected from degree-granting institutions only). Fall enrollment: number of full- and part-time students enrolled in the fall, students in courses creditable toward a degree, and students enrolled in courses that are part of a vocational or occupational program; residence of students; and age of students. Finance: revenues by source, expenses by function, physical plant assets and indebtedness, and endowment investment. Financial aid: number of students receiving federal grants, state and local government grants, institutional grants, and loans; and average amount of aid received by type of aid. Graduation rates: number of students entering the institution, number of students completing their program within 150% of the normal period of time, number of students who transferred, and number of students who received athletically related student aid.
It should be noted that not every survey is administered to every institution each year, and that not every student is included in various data elements. For example, the fall staff survey component is conducted only in odd years. The salaries survey component is required to be completed only by degree-granting institutions. Financial aid data are collected for full-time, first-time, and degree- and certificate-seeking students only. In calculating graduation rates, only full-time, first-time, and degree- or certificate-seeking students are counted in the initial calculation of the number of students entering an institution during a particular year. In addition, different versions of various surveys are administered to IHEs depending on whether the IHE is a four-year, two-year, or less-than-two-year institution; on whether the IHE is a public, private nonprofit, or private for-profit institution; and on other institutional factors such as the institution's number of full-time employees.
The individual survey components are administered in either the fall, spring, or winter. For the 2008-2009 academic year, the following components were administered in each of these time periods.
Fall 2008: Institutional Characteristics, Completions, and 12-Month Enrollment Winter 2008-2009: Human Resources, Fall Enrollment, and Finance Spring 2009: Graduation Rates and Student Financial Aid, as well as Fall Enrollment and Finance (for IHEs that did not finalize these data during the winter data collection)
 Table A-1 provides an overview of the survey items to which a public, four-year institution would be required to respond. As previously discussed, the specific survey components, survey items, and number of survey items varies based on institutional characteristics, such as institutional level and control.