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Federal Update Anita Olivencia U.S. Department of Education.

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Federal Update Anita Olivencia U.S. Department of Education
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Page 1: Federal Update Anita Olivencia U.S. Department of Education.

Federal Update

Anita OlivenciaU.S. Department of Education

Page 2: Federal Update Anita Olivencia U.S. Department of Education.

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ApplicationProcessing

Page 3: Federal Update Anita Olivencia U.S. Department of Education.

2017-2018 Processing Announcement!

Beginning with 2017-2018, the FAFSA cycle will begin October 1 instead of January 1

2017-2018 FAFSA filing will begin October 1, 2016Gives more time to review, submit & update FAFSA data

Beginning with 2017-2018, FAFSA income information will come from the “prior, prior year”

2017-2018 FAFSA will collect tax year 2015 income dataReduces the use of estimated income and increases the use of the Data Retrieval Tool (DRT)

3 9/14/15 Elec. Ann.

Page 4: Federal Update Anita Olivencia U.S. Department of Education.

Questions?

FAFSA CHANGES FOR 2017-18

Page 5: Federal Update Anita Olivencia U.S. Department of Education.

Entrance/Exit Counseling Reminders

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Page 6: Federal Update Anita Olivencia U.S. Department of Education.

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Counseling type Required for: When:

Entrance

First time subsidized or unsubsidized loan borrowers

First time graduate/professional student PLUS borrowers

Prior to receiving funds the first time a student borrows as an undergraduate or graduate/professional student

Financial Awareness Counseling (FAC)

Not required

PLUS

PLUS Borrowers (graduate/ professional students and parents) who have an adverse credit history but who Obtain an endorser Satisfactorily document

extenuating circumstances to the Department of Education

Each year the borrower requests a PLUS loan and has an adverse credit history.

ExitStudent borrowers

When student borrowers graduate, leave school, or drop below half-time enrollment

TEACH Initial and Subsequent Counseling

TEACH Grant recipients Each year a student receives a TEACH Grant

TEACH Exit Counseling TEACH Grant recipients

When TEACH Grant recipient leaves school, drops below half-time enrollment, or leaves the TEACH eligible program

Page 7: Federal Update Anita Olivencia U.S. Department of Education.

Sequestration

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GEN-15-07

Page 8: Federal Update Anita Olivencia U.S. Department of Education.

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Sequestration

Page 9: Federal Update Anita Olivencia U.S. Department of Education.

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Sequestration

Page 10: Federal Update Anita Olivencia U.S. Department of Education.

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Sequestration

Page 11: Federal Update Anita Olivencia U.S. Department of Education.

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Verification

Page 12: Federal Update Anita Olivencia U.S. Department of Education.

• Same verification items and Verification Tracking Groups to be verified as 2014-2015

• Applicant will remain in original 2015–2016 Verification Tracking Group for the entire 2015–2016 award year record

Federal Register published June 25, 2014GEN-14-11 published June 30, 2014EA November 24, 2014 – Suggested Text

2015-16 Verification

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Page 13: Federal Update Anita Olivencia U.S. Department of Education.

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The V4 and V5 tracking process in FAA Access that began in the 2014-15 processing year WILL CONTINUE for 2015-16.Schools need to select the proper award year for which they are providing results

2014-15; 2015-16, etc.

V4/V5 Tracking Results – 2015-2016

https://faaaccess.ed.gov

Page 14: Federal Update Anita Olivencia U.S. Department of Education.

V4/V5 Tracking Results – 2015-16

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Whom to report: student for whom school received an ISIR with a Verification Tracking Group of V4 or V5 AND for whom school requested verification documentation

• Do NOT include students the school selected for verification of identity or high school completion status

When to report: 60 days following the institution's firstrequest to the student to submit the required V4 or V5 identity and high school completion documentation • changes to previously submitted Identity Verification

Results must be updated within 30 days

Page 15: Federal Update Anita Olivencia U.S. Department of Education.

2016-17 Verification – Overview

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Same data elements as for 2015-2016 award yearSome modifications and clarifications to acceptable documentationIn limited circumstances, an applicant’s Verification Tracking Group could changeResources

GEN-15-11Federal Register Notice – June 26, 2015Suggested Text – Coming soon!

Page 16: Federal Update Anita Olivencia U.S. Department of Education.

2016-17 Verification

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Verification Tracking Group changes:• Verification Tracking Group V3 (Child

Support Paid) has been removed• Applicants placed in V1, V4, V5, and

V6 must still verify child support paid if reported on ISIR

Page 17: Federal Update Anita Olivencia U.S. Department of Education.

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2016-17 VerificationVerification Tracking Group changes:Applicants may be moved from previously assigned Groups V1, V4, and V6 to Tracking Group V5

Applicant is only required to verify the additional items in V5 that were not previously verified

if verification not completed for previously assigned Verification Tracking Group (V1, V4, and V6) prior to student moving to V5, institution is only required to verify the FAFSA information in Verification Tracking Group V5

If applicant is moved to Verification Tracking Group V5, no additional disbursements of any Title IV aid may be made until verification is completed

Page 18: Federal Update Anita Olivencia U.S. Department of Education.

2016-17 Verification

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Verification Tracking Group changes:Applicants moved to Verification Tracking Group V5

If Title IV aid had been disbursed prior to receiving an ISIR with the new V5, and the applicant does not complete verification, the applicant is liable for the full amount of TIV aid disbursed for 2016-2017The institution is not liable

Page 19: Federal Update Anita Olivencia U.S. Department of Education.

2016-17 Verification

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Income Information for Non-IRS Tax Filers Tax filers who filed an income tax return with a taxing authority in a U.S. territory (Guam, American Samoa, the U.S. Virgin Islands) or commonwealth (Puerto Rico and the Northern Mariana Islands) or with a foreign central government, must submit a copy of a transcript of their tax information

A signed copy of the applicable 2015 income tax return that was filed with the taxing authority is only acceptable if tax filers are unable to obtain a free copy of a transcript of their tax information

Page 20: Federal Update Anita Olivencia U.S. Department of Education.

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2016-17 Verification

Question from MASFAA: Can a student self-certify that they are unable to get a free copy of a non-IRS tax transcript?

Answer: Still waiting on a policy answer.

Page 21: Federal Update Anita Olivencia U.S. Department of Education.

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2016-17 Verification

Question from MASFAA: Does the school have to seek the services of an translator or tax expert on foreign tax returns to officially translate a non-IRS tax transcript or does the school use their best guesstimate to figure out AGI, taxes paid, U.S dollars equivalents, as they do with tax returns from Puerto Rico?

Answer: Still waiting on a policy answer.

Page 22: Federal Update Anita Olivencia U.S. Department of Education.

2016-17 Verification

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Income Information for Non-IRS Nontax Filers Residents of the Freely Associated States (Republic of the Marshall Islands, the Republic of Palau, the Federated States of Micronesia), and a U.S. territory or commonwealth or a foreign central government who are not required to file an income tax return under that taxing authority’s rules must submit:

a copy of their Wage and Tax Statement (or equivalent documentation) for each source of employment income anda signed statement identifying all of the individual’s income and taxes

Page 23: Federal Update Anita Olivencia U.S. Department of Education.

Verification Policy Updates

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Tax filers and Nontax filers—if a copy of the tax return was not retained and cannot be located by the IRS must submit:

Copy of all relevant W-2sSigned statement that individual did not retain a copy of his or her tax account information, andDocumentation from the IRS that indicates that the individual’s tax account information cannot be locatedChild support paidRemoved a separation agreement or divorce decree from acceptable documentation

Page 24: Federal Update Anita Olivencia U.S. Department of Education.

Verification Policy Updates

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High School Completion Status For V4 and V5, if institution successfully verified and documented applicant’s high school completion status for a prior award year, verification of high school completion status is not required for subsequent yearsAn institution may not accept as alternative documentation an applicant’s self-certification, nor a DD Form 214 CertificateIdentity/Statement of Educational Purpose The valid government-issued photo identification used to verify an applicant’s identity must not have expired

Page 25: Federal Update Anita Olivencia U.S. Department of Education.

Verification Policy Updates

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Victims of IRS tax-related identity theft must submit:Statement signed and dated by tax filer indicating they were victims of IRS tax-related identity theft and the IRS has been made aware of the tax-related identity theft; and A Tax Return DataBase View (TRDBV) transcript obtained from the IRS

Tax filers who cannot obtain a TRDBV transcript may instead submit another official IRS transcript or equivalent document provided by the IRS if it includes all of the income and tax information required to be verified

Guidance applies to 15/16 and subsequent years • Posted in 6/26/15 Federal Register Notice

Page 26: Federal Update Anita Olivencia U.S. Department of Education.

Verification Policy Updates

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Individuals who filed an amended tax return must submit the following documents to the institution:an IRS Tax Return Transcript, or any other IRS tax transcript(s) that include all of the income and tax information required to be verified; anda signed copy of the IRS Form 1040X that was filed with the IRS

Guidance effective 8/13/15 for 15/16 and subsequent years • Posted on Program Integrity Q & A website

Page 27: Federal Update Anita Olivencia U.S. Department of Education.

October 2, 2015 Electronic Announcement

• Alternative documentation allowed when tax filer RECENTLY requested but unable to obtain an IRS Tax Return Transcript using the IRS paper or on-line request process • No alternative documents for telephone requests • Exception not permitted for –

– transcripts unable to be obtained simply because the IRS has not had time to process the data due to a recent filing

– saying the "Get Transcript Online" tool is not available

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For 2015-2016 award year

Page 28: Federal Update Anita Olivencia U.S. Department of Education.

2015-2016 – Transcripts Unavailable Alternative documentation includes:

• Signed copy of relevant 2014 IRS tax return

AND

• Statement from tax filer, on or attached to the return, certifying same data submitted to the IRS

AND

• Communication from IRS stating request unsuccessful – Letter from IRS (signed and dated by tax filer); or– Screen shot print (signed and dated by tax filer)

AND

• Completed and signed IRS Form 4506 T-EZ or 4506-T listing institution as third party – only send to IRS if doubt accuracy

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Page 29: Federal Update Anita Olivencia U.S. Department of Education.

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Perkins Loan Program

DCL GEN-15-03

Page 30: Federal Update Anita Olivencia U.S. Department of Education.

Perkins Loan Program

Dear Colleague Letter GEN-15-03 Congress did not act and the program ended on

September 30, 2015Schools may not make Federal Perkins Loans to

new borrowers after September 30, 2015. If prior to October 1, 2015, a school makes the

first disbursement of a Federal Perkins Loan to a student for the 2015-2016 award year, the school may make any remaining disbursements of that 2015-2016 loan after September 30, 2015.

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Page 31: Federal Update Anita Olivencia U.S. Department of Education.

Perkins Loan Program

Narrow “grandfathering” provision Allows schools to make Perkins Loans to certain

students for up to five additional years (through September 30, 2020) to enable students who received loans for award years “to continue or complete courses of study.

Loans can be made only if all of the following conditions are met:

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Page 32: Federal Update Anita Olivencia U.S. Department of Education.

Perkins Loan Program

The school made at least one loan disbursement to the student on or before June 30, 2015.

The student is enrolled at the same institution where the last Perkins Loan disbursement was received.

The student is enrolled in the same academic program (same CIP Code) for which the student received his or her last Perkins Loan disbursement.

Loan used to meet unmet need only after student has been awarded all Direct Subsidized Loan for which the student is eligible.

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Page 33: Federal Update Anita Olivencia U.S. Department of Education.

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Perkins Loan Program

Question from MASFAA: Student signed an MPN in 2014. The MPN is now expired. Can I continue to award and disburse Perkins to grandfathered students on the last MPN even though it is expired?

Answer: Yes. Under the multi-year functionality of the Perkins MPN schools are allowed to continue to disburse loans. See GEN 12-19 for past guidance on expired Perkins MPNs.

http://ifap.ed.gov/dpcletters/GEN1219.html

Page 34: Federal Update Anita Olivencia U.S. Department of Education.

Dear Colleague Letters

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GEN-15-19 – Perkins Excess Liquid Capital• Reminds institutions that participate in Perkins they must

return to the Department (ED) the Federal portion of any Excess Liquid Capital in their Perkins Loan Revolving Fund

• Includes interactive worksheets to determine Excess Liquid Capital (ELC) that must be returned

ELC is the amount of the Fund’s “Cash On Hand” that is in excess of the institution’s estimated immediate needs

• ED allows the institution to calculate the Federal share to be returned to ED and the institutional share that must be removed from the Fund and returned to the institution

• The Federal share of the institution’s ELC must be returned to ED via G5 no later than December 31, 2015

Page 35: Federal Update Anita Olivencia U.S. Department of Education.

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Career Pathway Programs &

Title IV Eligibility

GEN 15-0910.22.15 Electronic Announcement

Page 36: Federal Update Anita Olivencia U.S. Department of Education.

Changes in the Law

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Consolidated and Further Continuing Appropriations Act of 2015 (Pub. L. 113-235) enacted 12/16/14• Changed section 484(d) HEA to allow a student who does

not have a high school diploma (or recognized equivalent), or who was not properly homeschooled, to be eligible for Title IV aid through ability to benefit (ATB) alternatives, but ONLY if the student is enrolled in an "eligible career pathway program”

Any type of institution may offer eligible career pathway programsNo requirement to offer eligible career pathway programs

Guidance - GEN-15-09

Page 37: Federal Update Anita Olivencia U.S. Department of Education.

“Grandfathered Students” Exception

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The Consolidated Appropriations Act of 2012 amended section 484(d) of the HEA to allow a student without a high school diploma (or recognized equivalent), and who attended an eligible program at a Title IV institution prior to July 1, 2012, to be eligible for Title IV aid under the previous ATB alternatives (GEN-12-09)• Eligible students were referred to as having been

“grandfathered” • The new ATB provision in Pub. L. 113-235 (career

pathway programs) does NOT affect the eligibility of students grandfathered under the 2012 provision

Page 38: Federal Update Anita Olivencia U.S. Department of Education.

Eligible Students

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Students enrolled in an eligible career pathway program, on or after July 1, 2014, (who are not HS graduates, properly homeschooled, or do not meet HS equivalent conditions) may be eligible to receive Title IV aid if meet one of the following ATB alternatives (484(d)(1)):• Passes an independently administered Department of

Education approved ATB test• Completes at least 6 credit hours or 225 clock hours that are

applicable toward a degree or certificate offered by the postsecondary institution

• Completes a State process approved by the SecretaryNo State process has ever been sent for ED approval

Page 39: Federal Update Anita Olivencia U.S. Department of Education.

Eligible Career Pathway Program

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Eligible career pathway programs contains 2 components: • an adult education component, and • a Title IV eligible postsecondary

program component

Page 40: Federal Update Anita Olivencia U.S. Department of Education.

Eligible Career Pathway Program

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Adult Education Component: academic instruction and education services below the postsecondary level that increase individual’s ability to:• Read, write, and speak in English and perform

mathematics or other activities necessary for the attainment of a secondary school diploma or its recognized equivalent;

• Transition to postsecondary education and training; • Obtain employment

Same definition as Adult Education and Family Literacy Act, Title II of the Workforce Innovation and Opportunity Act

Page 41: Federal Update Anita Olivencia U.S. Department of Education.

Eligible Career Pathway Program

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Title IV eligible postsecondary program component: must meet definition of an eligible program under 34 CFR 668.8 in order for students enrolled in the eligible career pathway program to be eligible for Title IV aid• Includes all coursework of the TIV

eligible academic program

Page 42: Federal Update Anita Olivencia U.S. Department of Education.

Eligible Career Pathway Program

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Restrictions• May not include cost of the adult education

component of an eligible career pathway program in student’s Cost of Attendance (COA)

• May not pay for the cost of the adult education component using Title IV aid

only costs that can be included in COA are those associated with the Title IV eligible postsecondary program component

Page 43: Federal Update Anita Olivencia U.S. Department of Education.

Eligible Career Pathway Program

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Restrictions• Credit or clock hours associated with adult

education coursework cannot be incorporated into a student’s Title IV enrollment status, regardless of whether the institution considers the adult education coursework to be remedial

Remedial coursework associated with the Title IV eligible postsecondary program component is eligible for TIV aid within normal remedial limits

30 semester hours; 45 quarter hours; 900 clock hours

Page 44: Federal Update Anita Olivencia U.S. Department of Education.

Regular Pell Grants

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Eligible student whose first enrollment in ANY Title IV eligible postsecondary program was before July 1, 2015, and who is enrolled in an eligible career pathway program in or subsequent to the 2015–2016 award year, is eligible for a Regular Pell Grant award

• Regular Pell Grant Payment and Disbursement Schedules for 15/16 published in GEN-15-02

Page 45: Federal Update Anita Olivencia U.S. Department of Education.

Limited Pell Grants

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Any student whose first enrollment in ANY Title IV eligible postsecondary program was on or after July 1, 2015, and is eligible under one of the ATB alternatives for enrollment in an eligible career pathway program, will ONLY be eligible for a Limited Pell Grant award

• Maximum limited Pell Grant amount for 15/16 is $4,860

Maximum regular Pell Grant amount for 15/16 is $5,775 (non-ATB)

Page 46: Federal Update Anita Olivencia U.S. Department of Education.

Limited Pell Grants

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• Calculation of the percentage of the annual Scheduled Award used (Pell Lifetime Eligibility Used – LEU) will be based on the student’s full Scheduled Award under the Regular Pell Grant Payment Schedule

A student only eligible for Limited Pell Grant with 0 EFC for 15/16 used 84.1558 percent ($4,860 / $5,775) of 15/16 Scheduled Award

Career Pathway Alternative Pell Grant Disbursement Schedules is attached to GEN-15-09

Page 47: Federal Update Anita Olivencia U.S. Department of Education.

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Page 48: Federal Update Anita Olivencia U.S. Department of Education.

Additional Programs and ATB

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If a student completes a career pathway program and then enrolls in a regular TIV eligible academic program, the student will not be eligible for additional TIV funds UNLESS they have a high school diploma or equivalentAlso, once a student obtains a HS diploma or equivalent they are no longer subject to the restrictions placed on ATB students

Page 49: Federal Update Anita Olivencia U.S. Department of Education.

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Regulatory Activity

Page 50: Federal Update Anita Olivencia U.S. Department of Education.

Negotiated Rulemaking

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Federal Register Notice – 8/20/15Proposed regulation discussion:

Procedures for a borrower to establish defense to repaymentCriteria the Department will use to identify acts/omissions of an institution that constitute defenses to repaymentStandards and procedures that ED will use to determine school liability for amounts based on borrower defensesEffect of borrower defenses on school capability assessmentsTwo public Hearings9/10/15 – Washington D.C.9/16/15 – San Francisco

Page 51: Federal Update Anita Olivencia U.S. Department of Education.

Program Integrity “Proposed” Rules

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Notice of Proposed Rule-Making (NPRM) published on May 18, 2015Comments must have been received by July 2, 2015Main Topics:

Cash ManagementRepeat CourseworkClock-to-Credit Conversion (“clock hour program definition”)

Page 52: Federal Update Anita Olivencia U.S. Department of Education.

Program Integrity “Proposed” Rules

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Cash Management• Establish two different types of arrangements between

institutions and financial account providers (Tier 1 and 2) and publically disclose these contracts and costs

• Cannot require student/parent to open a certain type of account in order to receive TIV credit balance funds

Provide a list of account options in a neutral manner with the student’s preexisting bank account listed first

• Obtain student/parent consent prior to sharing PII data or sending access devices from account providers

• Mitigate fees incurred by student aid recipients

Page 53: Federal Update Anita Olivencia U.S. Department of Education.

Program Integrity “Proposed” Rules

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Repeat Coursework• Allow institution offering term-based programs

to count, for enrollment, courses a student is retaking that they previously passed, up to one repetition per course, including when student is retaking a previously passed course due to the student failing other coursework

Clock-to-Credit Hour Conversion • Streamline conversion by removing provisions

where a State/Federal approval or licensure action cause a program to be measured in clock hours

Page 54: Federal Update Anita Olivencia U.S. Department of Education.

Questions?

Contact me with follow-up questions about this session:

[email protected](617) 289-0130

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Page 55: Federal Update Anita Olivencia U.S. Department of Education.

Training Feedback

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To ensure quality training we ask all participants to please fill out an online session evaluation

Go to http://s.zoomerang.com/s/AnitaOlivenciaEvaluation form is specific to Anita Olivencia

This feedback tool will provide a means to educate and inform areas for improvement and support an effective process for “listening” to our customers

Additional feedback about training can be directed to [email protected]


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