Information Required to Be Disclosed Under the Higher Education Act of 1965: Suggestions for Dissemination A Supplemental Report

Transcription

1 RepRt f the NatiNal pstsecndary educatin cperative Infrmatin Required t Be Disclsed Under the Higher Educatin Act f 1965: Suggestins fr Disseminatin A Supplemental Reprt

2 InfrmatIn required t Be disclsed under the higher educatin act f 1965: suggestins fr disseminatin a supplemental reprt Authr: Andrea Sykes Cnsultant Laurium Evaluatin Grup Nvember 2011 This prject has been funded, either whlly r in part, with federal funds frm the U.S. Department f Educatin under Cffey Cnsulting, LLC s Cntract N ED-04-CO The cntents f this publicatin d nt necessarily reflect the views r plicies f the U.S. Department f Educatin, nr des mentin f trade names, cmmercial prducts, r rganizatins imply endrsement f same by the U.S. Gvernment.

3 Natinal Pstsecndary Educatin Cperative The Natinal Pstsecndary Educatin Cperative (NPEC) was established by the Natinal Center fr Educatin Statistics (NCES) in 1995 as a vluntary rganizatin that encmpasses all sectrs f the pstsecndary educatin cmmunity including federal agencies, pstsecndary institutins, assciatins, and ther rganizatins with a majr interest in pstsecndary educatin data cllectin. In 2007, NCES assigned NPEC the respnsibility fr develping a research and develpment agenda fr the Integrated Pstsecndary Educatin Data System (IPEDS). IPEDS is the cre pstsecndary educatin data cllectin prgram fr NCES. NPEC als ccasinally prduces prducts f value t pstsecndary data prviders, users, and institutinal representatives. NPEC publicatins d nt underg the frmal review required fr standard NCES prducts. The infrmatin and pinins published in them are the prducts f NPEC and d nt necessarily represent the plicy r views f the U.S. Department f Educatin r NCES. Nvember 2011 The NCES Hme Page address is The NCES Publicatins and Prducts address is The NPEC Hme Page address is This publicatin is nly available nline. T dwnlad, view, and print the reprt as a PDF file, g t the NCES Publicatins and Prducts address shwn abve. This reprt was prepared in part under Cntract N. ED-04-CO with Cffey Cnsulting, LLC. The cntents f this publicatin d nt necessarily reflect the views r plicies f the U.S. Department f Educatin, nr des mentin f trade names, cmmercial prducts, r rganizatins imply endrsement f same by the U.S. Gvernment. Suggested Citatin Sykes, A. (2011). Infrmatin Required t Be Disclsed Under the Higher Educatin Act f 1965: Suggestins fr Disseminatin A Supplemental Reprt (NPEC ). U.S. Department f Educatin. Washingtn, DC: Natinal Pstsecndary Educatin Cperative. Retrieved [date] frm Cntent Cntact Elise Miller (202) Elise.Miller@ed.gv

4 Cntents Intrductin... 1 Findings... 2 Cnclusins... 9 References...10 Appendix A: Suggested Titles fr HEA Student Cnsumer Infrmatin n Institutinal Web Prtal Page...11 Appendix B: Methdlgy...13 iii

5 Intrductin In 2009, the Natinal Pstsecndary Educatin Cperative (NPEC) issued a reprt, Infrmatin Required t Be Disclsed Under the Higher Educatin Act f 1965: Suggestins fr Disseminatin (2009 NPEC reprt), that prvided suggestins n hw pstsecndary institutins culd meet disclsure requirements under the Higher Educatin Act f 1965 (HEA), as amended by the Higher Educatin Opprtunity Act (HEOA) f 2008 (Natinal Pstsecndary Educatin Cperative 2009). Disclsure requirements are infrmatin that a pstsecndary educatin institutin is required t distribute r make available t anther party, such as students r emplyees. The purpse f the 2009 NPEC reprt was t help clleges and universities successfully identify and meet their bligatin t disclse infrmatin as required under HEA, as amended by the HEOA. It included suggestins t help institutins make the required disclsures mre accessible and understandable t cnsumers and mre cmparable acrss institutins. There are abut 40 cnsumer infrmatin disclsures with which pstsecndary institutins must cmply under federal law (see appendix A fr a list f required disclsures as f Nvember 2009). The disclsures range frm prviding infrmatin n campus crime t ensuring that students have received and understand their brrwing rights. Sme f the required infrmatin must be made available t students, while thers must be prvided t students. Given the prminent rle that the Internet plays in prviding students and families with infrmatin abut clleges and universities, the 2009 NPEC reprt prvided suggestins n hw best t rganize and present disclsure requirements n an institutin s web site. Specifically, the reprt included the fllwing five suggestins: 1. Fcus bth n cmpliance and cmmunicatin. 2. Develp a single web page n the institutin s website that prvides hyperlinks t the HEA disclsure infrmatin. 3. Adpt a three-click apprach. 4. Use cnsumer-friendly labels and language whenever pssible, and avid institutinal/technical jargn. 5. Use a cmmn set f cntent titles. This paper was cmmissined by NPEC t determine if institutins were implementing the suggestins in its 2009 reprt. This paper identifies hw institutins have implemented the NPEC s 2009 reprt suggestins n presenting disclsure requirements. Additinally, this reprt identifies ther resurces and tls that culd be used by institutins t present disclsure requirements in a cnsumer-friendly manner. Specifically, the reprt addresses the fllwing questins: 1. T what extent did institutins develp a single web page t present HEA disclsure requirements? 2. T what extent did institutins develp web pages that used a cmmn set f cntent titles and presented HEA disclsure infrmatin in a cnsumer-friendly manner? 1

6 3. In what ways did institutins cllabrate n their campus t develp cnsumer infrmatin websites? Findings 1. T what extent did institutins develp a single web page t present HEA disclsure requirements? Each f the 40 institutins reviewed fr this study had a single prtal web page that includes many f the HEA disclsure requirements. Hwever, there were incnsistencies in hw each institutin s web page was labeled. Institutins did nt use the same terms t label r title the web page, a similar finding frm the 2009 NPEC reprt. Several institutins labeled the web page Cnsumer Infrmatin. Sme web pages were titled Student Cnsumer Infrmatin ; Disclsure f Cnsumer Infrmatin ; HEOA Student Cnsumer Infrmatin ; and Student Right t Knw Infrmatin. The University f Delaware develped anther title fr its web page Yur Right t Knw. Accrding t a university fficial, the university wanted t be sure that the link was accessible frm the university s hme page and that the link wuld lk appealing t a student. The institutinal research ffice was leading the effrt t design the University f Delaware s web page and cntacted the marketing and public relatins ffice. Thse ffices created a lg and used the wrds Yur Right t Knw fr the web page. The lg is lcated at the bttm f the University f Delaware s main hme page ( as shwn in exhibit 1. Exhibit 1. University f Delaware s website with Yur Right t Knw lg that links t cnsumer infrmatin 2

7 There were als incnsistencies in hw easily cnsumer infrmatin web pages culd be accessed r lcated. Amng the 40 institutins reviewed, 14 had placed a link t their cnsumer infrmatin web page n the institutin s hme page. Several institutins had the link at the bttm f the main hme page in a small fnt. Fr example, Prince Gerge s Cmmunity Cllege placed the link t its cnsumer infrmatin page at the bttm f its hme page with the title f HEA Disclsure, shwn in exhibit 2. Exhibit 2. Prince Gerge s Cmmunity Cllege hme page with link t cnsumer infrmatin HEA Disclsure Cnsumer infrmatin link Other institutins prminently displayed the link t the cnsumer infrmatin web page. As shwn in exhibit 3, Brwn Mackie Cllege, a 2-year private fr-prfit institutin, placed the wrds Cnsumer Infrmatin in a large fnt as well as a descriptin f what that meant at the bttm f the cllege s hme page. 3

8 Exhibit 3. Brwn Mackie Cllege hme page with link t cnsumer infrmatin Once a student clicks n the Learn Mre buttn, they are then asked t select a campus lcatin and then directed t the cnsumer infrmatin web page fr that campus. 4

9 By placing a link t the cnsumer infrmatin web page directly n the institutin s hme page, students can find the infrmatin in three-clicks, as suggested in the 2009 NPEC reprt. Other institutins placed a link t the cnsumer infrmatin web page under the Abut Us sectin r the A-Z Index. Thus, if a student knew t lk fr the wrds cnsumer infrmatin r student cnsumer infrmatin, they wuld be able t find the cnsumer infrmatin web page within three clicks. Tw institutins, Califrnia State University-San Bernardin and Natinal American University, placed a link t their cnsumer infrmatin page web n all f the main university web pages. Althugh a student culd feasibly access the disclsure infrmatin frm multiple sites n these tw institutins web pages, the language used t identify the web page is HEOA r disclsure f cnsumer infrmatin terms that may nt be meaningful fr a student. Althugh mst institutins reviewed implemented the three-click apprach, thers did nt place links t the cnsumer infrmatin web page in an easily accessible r shallw lcatin as suggested in the 2009 NPEC reprt. Accrding t fficials at tw institutins, the cnsumer infrmatin web pages d nt align with hw their institutin presents infrmatin t prspective r current students. The fficials reprted that they have created a web page that is cmpliant with the HEA disclsure requirements, but they did nt necessarily want t draw attentin t the page. These fficials als raised cncerns that students and parents wuld nt actually use the infrmatin. One f these fficials had cnducted a web analysis f visitrs t the cnsumer infrmatin web page and nted that all hits had cme frm internal campus ffices. 2. T what extent did institutins develp web pages that used a cmmn set f cntent titles and presented HEA disclsure infrmatin in a cnsumer-friendly manner? Many f the web pages created by institutins were cnsumer-friendly and ften used the cmmn set f cntent titles suggested in the 2009 NPEC reprt. The cnsumer infrmatin web pages used a variety f frmats t rganize and present the HEA disclsure infrmatin. Sme institutins had an verview page that included several categries that a cnsumer culd select in rder t find mre infrmatin. Fr example, Black Hawk Technical Cllege gruped disclsure infrmatin under the fllwing five headings: 1 Cllege Life, includes health and campus safety infrmatin; Financial Aid, includes refund plicy and cunseling infrmatin; Academic Plicies, transfer plicies and graduatin data; Cllege Navigatr Website; and Textbk Cst Infrmatin. Althugh Black Hawk Technical Cllege had rganized cnsumer infrmatin in a visually appealing frmat, nt all HEA disclsure infrmatin was lcated n this web page. Ball State University als used a table f cntents frmat fr its web page and used the fllwing seven categries fr rganizing disclsure requirements: 2 1 Fr mre infrmatin, see 2 Fr mre infrmatin, see 5

10 General Infrmatin, includes price f attendance, privacy plicies, and transfer plicies Teacher Preparatin Prgram Reprt Student Financial Assistance/Availability/Cntact Infrmatin Health and Safety Student Outcmes, includes retentin and graduatin rates Intercllegiate Athletic Prgram Vter Registratin Accrding t the Ball State University fficial respnsible fr develping the cnsumer infrmatin web page, she used the 2009 NPEC reprt t create an utline fr all the disclsures required and rganized her web page based n the suggestins frm the NPEC reprt. All eight fficials wh were interviewed reprted that the 2009 NPEC reprt was extremely helpful in rganizing the infrmatin that needed t be presented. Other web pages reviewed als reflected the influence f the 2009 NPEC reprt. As shwn in exhibit 4, Blmsburg University als used the suggested titles and utline presented in the NPEC reprt t rganize its student cnsumer infrmatin web page. Exhibit 4. Partial view f Blmsburg University s cnsumer infrmatin web page 6

11 Althugh all 40 institutins had created web pages with cnsumer-friendly language, several f the web pages did nt include all the required disclsure infrmatin. In many cases, a disclsure requirement was listed, hwever the link t the infrmatin was nt wrking, r there was n link t click n t access the infrmatin. Accrding t sme fficials, they were still wrking n cllecting infrmatin n their campus. At ne university, during the prcess f develping the web page, they learned that the alumni ffice had nt cnducted its annual survey f graduates in 5 years. As a result, the university did nt have jb placement data n its web page. Anther fficial stated that her ffice had nt cllected transfer-ut data, and she had recently begun wrking with the Natinal Student Clearinghuse s that her university culd reprt a transferut rate. Acrss the 40 cnsumer infrmatin web pages, there was a wide range f frmats fr presenting disclsure infrmatin related t price f attendance, jb placement, graduatin and transfer-ut rates, and retentin rates. Several institutins presented the data in a visually appealing and easily understd frmat by using tables, charts, and graphs. Exhibit 5 shws hw Dickinsn Cllege created a simple table t present retentin and graduatin infrmatin n its cnsumer infrmatin web page. Exhibit 5. Dickinsn Cllege cnsumer infrmatin web page disclsure f retentin and graduatin rates Other institutins did nt use such frmats, making it challenging fr a cnsumer t digest a large amunt f infrmatin. Sme institutins linked t the frm they used t reprt data t the Integrated Pstsecndary Educatin Data System (IPEDS) t shw retentin r graduatin data. 3 3 Fr mre infrmatin, see 7

12 Anther institutin shwed jb placement rate data by linking directly t a 37-page alumni survey reprt. 4 The reprt included the respnses fr each questin in the survey, and it was challenging t lcate the actual jb placement fr graduates f the cllege. Fr student bdy diversity, graduatin rates, and retentin rates, several institutins linked t the Cllege Navigatr website, and then the cnsumer needed t search fr the institutin t find the infrmatin. 3. In what ways did institutins cllabrate n their campus t develp cnsumer infrmatin web pages? Acrss the eight institutins interviewed, there was extensive cllabratin acrss campus ffices in rder t develp the cnsumer infrmatin web pages. One f the first steps was determining wh was respnsible fr leading the develpment f the web page and ultimately mnitring its accuracy ver time. Fr the mst part, the institutinal research ffice was in charge f develping and mnitring the web page. Institutinal research staff were ften the lead because they were the mst aware f the requirements thrugh their attendance at institutinal research cnferences and their respnsibilities fr IPEDS data reprting. Hwever, at ne institutin the prcess was led by the public relatins ffice, and at a fr-prfit institutin it was led by a prject manager frm the cmmunicatins department. The primary respnsibility f the lead staff persn was t identify the required disclsures, the ffice respnsible fr the infrmatin, and a cntact persn. Several fficials reprted that they tk a systematic apprach t cllecting the necessary infrmatin, creating spreadsheets with the disclsure requirements listed in the 2009 NPEC reprt and then adding infrmatin abut the respnsible campus ffice and whether there was already a web page that included the infrmatin. Accrding t several fficials, almst all f the infrmatin was available either n a campus web page r in the institutin s fact bk. If the infrmatin was nt already available, the lead staff persn wuld create a web page r a PDF dcument fr the infrmatin. At ne institutin, an fficial reprted creating PDF dcuments fr mst f the disclsure requirements, thus making the prcess mre time cnsuming. The cnsumer infrmatin web pages that were created encmpassed infrmatin frm an array f campus ffices, such as Campus Safety, Student Services, Athletics, Public Relatins, Academic Affairs, Alumni Services, Financial Aid, Webmaster, Facilities, and Registrar, amng thers. At each f the eight institutins, the fficials wh led the develpment f the cnsumer infrmatin web page reprted that ther campus ffices were generally agreeable and readily prvided the infrmatin that was needed t create the web page. At tw institutins, the develpment f the web page ccurred at the same time as an accreditatin site visit, which heightened awareness f the disclsure requirements because the accreditrs were asking fr the same infrmatin. At anther institutin, the cnsumer infrmatin web page was develped during a university-wide web redesign, thus making the prcess mre seamless. Accrding t campus fficials, there were sme disagreements that ccurred between campus ffices. Mst f the disagreements invlved interpreting the disclsure requirements and determining what infrmatin was exactly required t be disclsed. Accrding t a few fficials, 4 Fr mre infrmatin, see 8

13 the disagreements ften ccurred with the financial aid and campus safety ffices. Bth f these campus ffices had prfessinal assciatins that were actively prviding guidance and interpretatins f HEA disclsure requirements. Smetimes the advice prvided by prfessinal assciatins cnflicted with the infrmatin that was in the 2009 NPEC reprt, and the persn respnsible fr develping the web page had t reslve thse differences. In additin t the n-campus cllabratin, many institutins cllabrated with ther clleges and universities. Several reprted that they had learned hw ther institutins were implementing the suggestins in the 2009 NPEC reprt at cnferences and IPEDS training sessins. Sharing web page templates and rganizatinal tls was cmmn amng clleges and universities. Fr example, ne fficial ften used ther university and cllege web pages as a guide when creating his wn cnsumer infrmatin web page. Despite the widespread disseminatin f infrmatin abut disclsure requirements, several fficials reprted that there are institutins that are still nt aware f the 2009 NPEC reprt and suggestins fr develping a single web page. Based n the Internet search cnducted fr this study, there are institutins that d nt have a single cnsumer infrmatin web page fr presenting HEA cnsumer infrmatin. Cnclusins Almst 3 years after the HEA was amended by the HEOA, institutins are still wrking t meet the disclsure requirements included in the law. Many institutins frm acrss all sectrs have develped single cnsumer infrmatin web pages t present federal disclsure requirements that are easily accessible, use cnsumer-friendly terms, and use cmmn titles t allw fr cmparisns acrss institutins. The guidance prvided in the 2009 NPEC reprt has been instrumental in helping many institutins create a single cnsumer infrmatin web page t present federal disclsure requirements. Mrever, sharing f the reprt and infrmatin abut disclsure requirements at cnferences and trainings als prvided institutins and their staff with resurces they needed t create their cnsumer infrmatin web page. Despite such prgress, there is mre wrk that needs t be dne t present HEA disclsure infrmatin in a clear and cnsistent manner that can be cmpared acrss institutins. The 2009 NPEC reprt prvided a summary f the disclsure infrmatin that shuld be included n institutins cnsumer infrmatin web pages; hwever mre guidance culd be prvided n hw t rganize the disclsure requirements and t present data in a visually appealing way. Fr example, many institutins cnsumer infrmatin web pages simply list all the disclsure requirements rather than gruping them in similar categries. The web pages that utilized verview pages with a table f cntents r with headings that gruped disclsure requirements were much simpler t navigate. In additin, institutins that used graphs r tables t present data n graduatin r retentin rates, jb placement, r student diversity were easy t cmprehend. Other institutins presented the raw data they submitted t IPEDS r all the data cllected in a survey, making it difficult fr a cnsumer t interpret the infrmatin. Fr disclsure requirements that include data, such as graduatin rates, jb placement, student bdy diversity, r retentin rates, NCES culd assist institutins by creating tables r graph templates that an institutin culd use in rder t present data in a clearer manner. The templates culd be based n thse currently in use at sme institutins. 9

14 References Natinal Pstsecndary Educatin Cperative. (2009). Infrmatin Required t Be Disclsed Under the Higher Educatin Act f 1965: Suggestins fr Disseminatin (Updated) (NPEC v2), prepared by Carl Fuller and Carl Salern, Cffey Cnsulting. Washingtn, DC. 10

15 Appendix A: Suggested Titles fr HEA Student Cnsumer Infrmatin n Institutinal Web Prtal Page Ntice f Availability f Institutinal and Financial Aid Infrmatin Cntact Infrmatin fr Assistance in Obtaining Institutinal r Financial Aid Infrmatin General Institutinal Infrmatin Privacy f Student Recrds Family Educatinal Rights and Privacy Act (FERPA) Facilities and Services fr Students with Disabilities Student Diversity Price f Attendance Net Price Calculatr Refund Plicy and Requirements fr Withdrawal and Return f Federal Financial Aid Textbk Infrmatin Educatinal Prgrams Instructinal Facilities Faculty Transfer f Credit Plicies and Articulatin Agreements Accreditatin, Apprval, and Licensure f Institutin and Prgrams Cpyright Infringement Plicies and Sanctins Cmputer Use and File Sharing Student Activities Career and Jb Placement Services Teacher Preparatin Prgram Reprt Student Financial Assistance Student Lan Infrmatin Assistance Available Frm Federal, State, Lcal, and Institutinal Prgrams Federal Student Financial Aid Penalties fr Drug Law Vilatins Health and Safety Student Outcmes Initial Lan Cunseling fr Student Brrwers Exit Cunseling fr Student Brrwers Institutinal Cde f Cnduct fr Educatin Lans Preferred Lender Lists Preferred Lender Arrangements Drug and Alchl Abuse Preventin Prgram Vaccinatin Plicies Campus Security Plicies, Crime Statistics and Crime Lg Fire Safety Plicies, Fire Statistics and Fire Lg (On-Campus Husing Facilities) Retentin Rate Graduatin Rates (Student Right-t-Knw Act) Transfer-ut Rates (Student Right-t-Knw Act) Graduatin Rates fr Students Receiving Athletically Related Student Aid (Student Right-t-Knw Act) 11

16 Transfer-ut Rates fr Students Receiving Athletically Related Student Aid (Student Right-t-Knw Act) Jb Placement fr Graduates Jb Placement Rates fr Graduates Graduate and Prfessinal Educatin Placement fr Graduates Intercllegiate Athletic Prgram Participatin Rates and Financial Supprt Data (Equity in Athletics Disclsure Act) Vter Registratin This list was used in the 2009 NPEC Reprt, Infrmatin Required t Be Disclsed Under the Higher Educatin Act f 1965: Suggestins fr Disseminatin, which was prepared by Carl Fuller and Carl Salern f Cffey Cnsulting fr the Natinal Pstsecndary Educatin Cperative. 12

17 Appendix B: Methdlgy Frty pstsecndary institutins in five sectrs were identified fr this study using nnstatistical sampling. The number f institutins reviewed by sectr is as fllws: Eleven 4-year public institutins Ten 4-year private, nt-fr-prfit institutins Fur 4-year private, fr-prfit institutins Twelve 2-year public institutins Three 2-year private, fr-prfit institutins The cnsultant identified institutins cnsumer infrmatin web pages by using an Internet search engine and entering terms such as cnsumer infrmatin, cllege ; student infrmatin, university ; and HEOA disclsure, cllege. It was challenging t identify 2-year fr-prfit institutins thrugh these search terms, s the cnsultant used IPEDS data t identify institutins in this sectr and went directly t their websites t lcate their cnsumer infrmatin web pages. T identify the extent t which institutins utilized suggestins included in the 2009 NPEC reprt, the cnsultant reviewed each institutin s cnsumer infrmatin web page. During the review, the cnsultant nted whether suggestins frm the 2009 NPEC reprt were implemented, the specific disclsure infrmatin that was included n the cnsumer infrmatin web page, and hw students wuld be able t lcate r access the web page. T learn abut the cllabratin that ccurred n campuses, the cnsultant interviewed fficials at the fllwing eight institutins: Chesapeake Cllege (2-year public) Tufts University (4-year private, nt-fr-prfit) University f Delaware (4-year public) Capella University (4-year private, fr-prfit) Xavier University (4-year private, nt-fr-prfit) Dickinsn Cllege (4-year private, nt-fr-prfit) Blmsburg University (4-year public) Ball State University (4-year public) During the interview, the cnsultant gathered infrmatin n each institutin s prcess fr develping the cnsumer infrmatin web page, including campus resurces and staff invlved; the rles and respnsibilities f campus staff in develping and mnitring the web page; the extent t which the institutin used suggestins utlined in the 2009 NPEC reprt; and any challenges encuntered when develping the web page. 13