Saskatchewan Designation Policy Manual...Saskatchewan Designation Policy Manual - May 2019 5 (iii)...

Saskatchewan Designation Policy ManualMay 2019

saskatchewan.ca/informationforinstitutions

Table of Contents

Introduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1Designation Process . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2

Designation Criteria - Institutions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .2Designation Criteria - Programs . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .5

Transfer of Ownership of Saskatchewan Private Vocational Schools . . . . . . . . . . . . 6Maintaining Status as a Designated Institution . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6

Portfolio Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .7Institution Performance . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10Student Performance. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .15

Revocation of Designation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 16Appeal of a Decision to De-Designate. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16Reinstatement of Designation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16

Appendix A - National Designation Policy Framework . . . . . . . . . . . . . . . . . . . . . . . . 17Attachment A - Common Elements . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 21Attachment B - Designation Criteria for International Educational Institutions . . . . . . .23Attachment C - Designation Criteria for E-learning Educational Institutions . . . . . . . . .24Attachment D - Administrative Compliance Indicator . . . . . . . . . . . . . . . . . . . . . . . . .25Attachment E - Repayment Rate Indicator . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .28Terms and Definitions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .33

Appendix B - Sample Saskatchewan Memorandum of Agreement (MOA) . . . . . . 35Appendix C - Designation Policy Framework Compliance Form . . . . . . . . . . . . . . . 38Appendix D - Repayment Rate Methodology . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 40Appendix E - Sample Improvement Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 42

1Saskatchewan Designation Policy Manual - May 2019

Introduction

Designation is the process by which post-secondary institutions are deemed eligible to receive students who qualify for federal and provincial/territorial student financial assistance. The Canada Student Financial Assistance Act and the Canada Student Loans Act, along with associated regulations, delegate the authority to carry out the designation of post-secondary institutions to provinces and territories. Each jurisdiction is responsible for developing and implementing designation policies that support federal, provincial and territorial (F/P/T) student financial assistance programs. In Saskatchewan, the province agreed, through the Canada-Saskatchewan Integration Agreement for the Harmonization and Administration of Federal and Provincial Student Loans Programs, to incorporate the core elements of a pan-Canadian designation framework into its designation policies. Saskatchewan has worked collaboratively with F/P/T jurisdictions to develop and implement a pan-Canadian policy framework and process for the implementation of reciprocal designation policies.

In April 2003 the Council of Ministers of Education, Canada approved the National Designation Policy Framework (the Framework). The Framework is a pan-Canadian approach intended to guide jurisdictions in the development of their designation policies. The Framework supports provincial and territorial governments as well as the Government of Canada in working with educational institutions to improve the performance of the student loans portfolio and to improve accountability to students and taxpayers through stewardship of the portfolio.

The Framework reiterates the fundamental purpose of government student loan programs - that of increasing access to opportunities for post-secondary education. The Framework document itself signals to institutions that student success is a key element in successfully managing financial risk. Institutions play the central role in retaining students, ensuring students succeed, and ensuring students improve their overall employability. These are key factors contributing to students’ success in repaying their student loans. Institutions, therefore, are central to any effort by government to effectively manage the financial risks inherent in a student loan program.

Four principles are identified in the Framework including taxpayer protection; accountability and informed choice; consumer protection; and complementarity to other post-secondary education policies. The Framework is designed to establish a common approach to the designation policies implemented in each jurisdiction across Canada. It is also recognized that jurisdictions will have flexibility in the specific measures implemented to address these principles.

Each jurisdiction will implement designation policies that are responsive to their own particular needs while being consistent with the Framework. A balanced approach to measuring these common elements uses a set of agreed-upon indicators that are organized into three categories of performance: portfolio, institution and student (see Appendix A).

2 saskatchewan.ca/informationforinstitutions

Designation Process

If an educational institution wishes to become designated for Canada-Saskatchewan Integrated Student Loans for full-time students and Canada Student Loans for part-time students, they must contact the Saskatchewan Ministry of Advanced Education, which designates educational institutions, to discuss their eligibility. If an educational institution meets the designation criteria set out below, the educational institution will sign a Memorandum of Agreement (MOA) with the Saskatchewan Ministry of Advanced Education to become designated. A sample of the MOA can be found in Appendix B.

Designation Criteria - InstitutionsTo be eligible for student loan designation, educational institutions must provide full-time programming. Students, however, can choose to study on a part-time basis.

Section 18 of The Saskatchewan Student Direct Loans Regulations sets the general criteria for the designation of educational institutions as follows:

For the purposes of approving an educational institution as a designated educational institution or revoking the designation of an educational institution and for the purposes of efficiently administering student loan programs jointly administered by the ministry and the Government of Canada, the minister may take into consideration:

(a) whether or not the educational institution is designated as an educational institution for the purposes of Canada direct loans pursuant to sections 3 and 4 of the Canada Student Financial Assistance Act; and

(b) whether or not the educational institution:

(i) offers a program of studies that:

(A) leads to a degree, diploma or certificate; and

(B) lasts at least 12 weeks within a period of 15 consecutive weeks;

(ii) in the case of vocational or technical programs, provides a minimum of 20 hours per week of student activity or participation;

(iii) has been in operation for at least 18 months and has graduated at least one class of students;

(iv) is authorized to operate pursuant to the appropriate legislation for that class of educational institution; and

(v) has entered into an agreement with the minister that establishes the terms and conditions with respect to maintaining its status as a designated educational institution pursuant to sections 3 and 4 of the Canada Student Financial Assistance Act.


The following provides additional detail for different types of educational institutions.

All Educational Institutions

The educational institution must meet all of the following criteria:

• Offer post-secondary programs that lead to a certificate, diploma or degree;

• Offer a program that is at least 12 weeks in length within a period of 15 consecutive weeks;

• Offer full-time programs. For career/vocational/technical institutions full-time is a minimum of 20 hours per week of student activity or participation;

• Be in existence for at least 18 months and have graduated at least one class of students;

• Be constituted under appropriate legislation;

• In Saskatchewan, be registered for at least 18 months under The Private Vocational Schools Act, 1995; be governed by The Education Act, by any other Act or by any Act of the Parliament of Canada; be constituted under its own legislation; or be affiliated or federated with a Saskatchewan university; and

• Enter into an agreement with the minister that establishes the terms and conditions with respect to maintaining its status as a designated educational institution.

Educational Institutions in Other Canadian Provinces or Territories

An institution must be designated in its own province or territory and therefore meet all current requirements for designation in Canada.

International Institutions

International institutions will only be reviewed for designation status if a Saskatchewan resident has applied for student loan funding to attend the educational institution.

In addition to the criteria set out in the Designation Policy Framework, the following criteria applies for international educational institutions seeking designation status.

1. Designation of Educational Institutions in the United States:

A post-secondary educational institution located inside the United States must be approved for Title IV funding by the US Department of Education (https://fafsa.ed.gov/FAFSA/app/schoolSearch?locale=en_EN).

2. Designation of Educational Institutions outside the United States:

An international post-secondary educational institution located outside the United States must meet the following criteria:

• Be approved for the purpose of student financial assistance or be accredited in its home country; and

• Demonstrate stability by having been in continuous operation for a minimum of two years prior to designation.

https://fafsa.ed.gov/FAFSA/app/schoolSearch?locale=en_EN

https://fafsa.ed.gov/FAFSA/app/schoolSearch?locale=en_EN


An international post-secondary educational institution must also be listed in one of the following publications:

• International Handbook of Universities (International Association of Universities, Stockton Press)

• World of Learning (Europa Publications)

• Commonwealth Universities website at www.acu.ac.uk

• International Association of Universities website at www.whed.net/home.php

• Federal school look up for FAFSA, (US Department of Education) www.fafsa.ed.gov/FAFSA/app/schoolSearch?locale=en_EN

International post-secondary educational institutions located outside of the United States offering medical programs must meet the following criteria in addition to the criteria listed above:

• Be listed on the International Medical Education Directory maintained by the Foundation for Advancement of International Medical Education and Research (FAIMER) at https://imed.faimer.org/;

• Be approved by a member of the Federation of Medical Regulatory Authorities of Canada; and

• Be in continuous operation for at least ten years.

E-learning Institutions

E-learning Institutions must meet the following additional criteria:

1. (a) A Canadian e-learning post-secondary educational institution must meet one of the following criteria:

(i) The institution has programs that meet the eligibility criteria as defined by federal, provincial, and territorial legislation with respect to post-secondary education;

(ii) Be approved by one of the Canadian quality assurance bodies;1

(iii) Have an equivalent on-site offering of the course or program of study; or

(iv) Demonstrates that academic credits, or credit hours earned through the course or program of study are transferable to a designated public post-secondary educational institution located within the same province/territory.

• The transferability of credits must be outlined in either articulation agreements between the two post-secondary educational institutions, or in provincial transfer guides.

(b) An international e-learning post-secondary educational institution must meet one of the following criteria:

(i) Be approved for Title IV funding by the US Department of Education;

(ii) Be approved by one of the Canadian quality assurance bodies1; or

1 A complete listing of quality assurance bodies is available at: www.univcan.ca.

http://www.acu.ac.uk

http://www.whed.net/home.php

http://www.fafsa.ed.gov/FAFSA/app/schoolSearch?locale=en_EN

https://imed.faimer.org/

http://www.univcan.ca/


(iii) Be in receipt of an acceptable rating in a full institutional audit conducted by the United Kingdom Quality Assurance Agency for Higher Education within the last five years.

And all e-learning post-secondary educational institutions must:

2. Require a minimum of 20 hours per week of student activity or participation, in the case of career/vocational/technical programs of study;

3. Actively monitor student participation and maintain contact with students in order to ensure that minimum course load requirements are maintained;

4. Demonstrate that its courses or programs of study and monitoring activities meet these guidelines; and

5. Provide specific program of study/course start and end dates.

Designation Criteria - ProgramsThe educational institution is responsible for ensuring that all courses/programs for which student loans are issued meet basic eligibility criteria as outlined in the Educational Institution Manual for the Canada-Saskatchewan Integrated Student Loans Program and Other Financial Assistance.

Eligible programs must:

• Lead to a certificate, diploma or degree;

• Be at least 12 weeks in length within a period of 15 consecutive weeks; and

• Require a minimum of 20 hours per week of student participation activity for career/vocational/technical institutions.

The following provides clarification on certain types of programs:

• Students in correspondence, distance education, or other programs with a non-traditional form of delivery may be considered full-time students if they meet all eligibility criteria and the educational institution is designated for student loan purposes.

• Practicums/internships which are a requirement of a program before the diploma/degree/certificate is granted, and which are an essential element of the program, are eligible for assistance provided the practicum/internship is considered by the educational institution as full-time post-secondary study and the student earns full-time equivalent credit hours.

• Individuals in periods of practical training required for acceptance in a professional corporation or for the practice of any trade or profession (such as medical internship/residency, dietetic internship or legal articling) are not full-time students for student loan funding purposes.

• The educational institution makes the determination as to whether or not a co-op student is in full time study but credit hours/units need not be the benchmark for this determination.

http://publications.gov.sk.ca/documents/139/79342-Educational%20Institution%20Manual.pdf




Transfer of Ownership of Saskatchewan Private Vocational Schools

Saskatchewan Private Vocational Schools that are designated for Canada-Saskatchewan Integrated Student Loans and are sold to a new owner will maintain their designated status if the following conditions are met:

• The institution continues to be registered as a Private Vocational School with the Saskatchewan Ministry of Advanced Education and is in full compliance with all legislative and regulatory requirements;

• The new owner has completed all requirements in the Private Vocational Schools Change of Ownership Checklist;

• The programs offered by the institution do not change significantly when the institution is sold;

• The new owner signs a Memorandum of Agreement with the Government of Saskatchewan;

• The new owner develops a Saskatchewan Designation Policy Improvement Plan where necessary; and

• The new owner assumes responsibility for the institutions repayment rate history and any conditions or sanctions the Ministry has placed on the institution pursuant to requirements set out in this Manual.

Maintaining Status as a Designated Institution

As part of Saskatchewan’s designation policy, performance measures that are consistent with the pan-Canadian Framework will be used to assess and monitor performance of an educational institution. There are three performance measures:

1. Portfolio Performance: repayment rate data.

2. Institution Performance: administrative compliance and student support services.

3. Student Performance: student retention and completion rates.

Every loan year, institutions will be required to voluntarily declare their compliance with the Designation Policy as outlined in the Designation Policy Framework Compliance Form (Appendix C). Ministry officials will randomly audit institution compliance and will identify any corrective actions required by institutions.

The Framework provides for corrective action up to and including de-designation should an educational institution not comply with the criteria outlined in this manual. Failure to maintain an educational institution’s repayment rate in the acceptable range will result in the educational institution’s designation being placed under review and could lead to de-designation, if repayment targets are not met.


Portfolio PerformanceTo assess and monitor the performance of education institutions with respect to portfolio performance, repayment rate data will be used.

Repayment Rates

Repayment rates indicate the performance of the educational institution with respect to whether students who attend the institution are able to repay their debt. The National Designation Policy Framework provides for a three year assessment cycle. Educational institutions will be provided with a repayment rate in the first year of each cycle along with any improvement targets and will be evaluated at the beginning of the next assessment cycle in terms of improvement.

The repayment rate is calculated by tracking consolidated loans over a two year repayment period and is determined by dividing the “federal principal amount paid” plus the “federal principal amount remaining in ‘good standing’” by the total “federal principal amount consolidated.” Appendix D provides a detailed example of the methodology used to determine an educational institution’s repayment rate.

There are three institutional risk zones used in the assessment of educational institutions: Green, Yellow, and Red. Institutions are assigned one of these three risk zones based on the repayment rate indicator. The risk zone ranges are determined using the national average to define the boundary of the Green zone, while the Red zone is fixed at 60 per cent. The table below shows an example of the risk zone parameters based on the national average repayment rate for the second assessment cycle of 85.2 per cent:

Risk Zone Repayment RateGreen Greater than 85.2%Yellow 60% to 85.2%

Red Less than 60%

Repayment rates are provided annually by the Canada Student Loan Program to the Ministry of Advanced Education (the Ministry) by December of each year. The Ministry will then advise each educational institution of their repayment rates in writing.

In instances where repayment rates are below the national average (Yellow and Red zones), educational institutions will be required to develop or revise an Improvement Plan that includes a focus on student performance.

The table on the following page identifies performance improvement targets and associated interventions for each risk zone related to Portfolio Performance.


Risk Zone Performance Improvement Target Intervention

Implications/Response to

Non-Performing Institution

Green Exempt Exempt Exempt

Yellow Three percentage points over three years.

The Ministry will provide written notification to the educational institution that identifies repayment rate improvement targets and timelines in which to achieve the improvement targets.

The educational institution will ensure that they obtain assistance from a third party, the Ministry, or both, in diagnosing issues and assessing steps to be taken to improve performance.

Educational institutions will have 30 calendar days from receipt of written notification to develop or revise an Improvement Plan and submit the Improvement Plan to the Ministry for approval.

In the event that an Improvement Plan is not acceptable by the Ministry, the Ministry will work with the educational institution to negotiate an agreed upon Plan.

Educational institutions must implement the agreed upon Improvement Plan immediately.

Educational institutions that fail to implement an Improvement Plan within the prescribed time will have their designation status revoked.


Risk Zone Performance Improvement Target Intervention



Red Educational institutions must improve performance to meet the Yellow zone threshold within three years and show year over year improvement during this three year period.

The Yellow zone threshold is currently a repayment rate of 60%.

Year over year improvement is defined as: 60% minus the educational institution’s repayment rate at the start of the three year period divided by three years.

For example, if an educational institution’s repayment rate is 30% they would need to improve by 10% each year: (60% - 30%)/3 =10%.

The Ministry will provide written notification to the educational institution that identifies repayment rate improvement targets and timelines in which to achieve the improvement targets.

The educational institution and Ministry may obtain assistance from a third party to diagnose issues and take steps to improve performance.

Educational institutions that fail to meet the performance improvement targets prescribed by the Ministry or are three years in the Red zone without improvement to the Yellow zone may have their designation status revoked.

At any time within the three years the Ministry may exercise its authority to de-designate an educational institution.


Institution PerformanceThe Ministry monitors compliance to the requirements in the Designation Memorandum of Agreement and to the administrative procedures outlined in the Educational Institutional Manual for the Canada - Saskatchewan Integrated Student Loans Program and Other Financial Assistance to assess an institution’s performance. Failure to comply with all administrative compliance requirements will prompt an immediate review of designation status.

The following table identifies administrative compliance requirements and the associated intervention activities related to institution performance.

Administrative Compliance

RequirementsIntervention Implications/Response to


Formalized Communication:

• The educational institution must enter into a Memorandum of Agreement (MOA) with the Province (see Appendix B).

The Ministry develops and issues MOA with each educational institution.

This is a requirement for designation. Educational institutions will be required to sign a MOA before being designated.

Appointed Financial Aid Officer:

• The educational institution must have an officially appointed officer for the purpose of administering loans via the Electronic Confirmation of Enrolment (ECE) Portal.

The Ministry confirms educational institution staff are registered on the ECE Portal.

Educational institutions will be given 30 calendar days to appoint an appropriate official in the event that one isn’t already acting in this capacity.








Advertising:

• Educational institutions must not use their designation status for recruitment but for information purposes only.

Advertising is monitored annually by the Ministry through a review of the educational institution’s publications.

Educational institutions will be given five business days to correct any deficiencies in advertising.

The Ministry will provide educational institutions with written notification of the results of administrative compliance reviews, identify corrective measures, improvement requirements and/or implications in the event that the educational institution fails to adhere to administrative compliance requirements.

Subsequent infractions will result in revocation of designation status by the Ministry.

Published Tuition Refund Policy:

• Educational institutions must have a published tuition refund policy.

Publication of tuition refund policies is monitored annually by the Ministry through a review of the educational institution’s publications.

Educational institutions will be given five business days to correct any deficiencies in publishing tuition refunds.

The Ministry will provide educational institutions with formal notification of the results of administrative compliance reviews, any improvement requirements and/or implications in the event that the educational institution fails to adhere to administrative compliance requirements.





Program Eligibility:

• Programs at educational institutions must meet the eligibility criteria as defined by federal and provincial legislation.

Program eligibility is monitored on an ongoing basis as new programs are submitted for approval or changes are made to existing programs.

Ministry officials will work with educational institutions through administrative compliance reviews to identify and correct any non-compliance issues.


Financial Stability:

• Educational institutions must have measures including but not limited to:

¾ Being covered under applicable legislation; and/or

¾ Providing a surety bond or other suitable security guarantee; and/or

¾ Participating in a train-out insurance fund.

Requirements for surety bonds and participation in a train-out fund are monitored by the Ministry.

The Ministry ensures that educational institutions demonstrate financial stability.

If an educational institution cannot demonstrate financial stability at any time the Minister can revoke designation status of the educational institution immediately.





Reporting Change in Student Status:

• Educational institutions must report, within 30 calendar days, the following changes in student status:

¾ Withdrawal from the program; and

¾ Change from full-time to part-time.

• Educational institutions must maintain student attendance records in a manner acceptable to the Ministry and comply with attendance policies as set out in the Educational Institution Manual for the Canada-Saskatchewan Integrated Student Loans Program and Other Financial Assistance.

The Ministry reviews educational institution student loans records annually through on-site visits. Information on student files will be cross-referenced to discontinuation information reported via the Electronic Confirmation of Enrolment (ECE) Portal.

Educational institutions will be required to correct any deficiencies in reporting changes to a student status immediately.

The Ministry will provide educational institutions with formal notification of the results of administrative compliance reviews and any improvement requirements and/or implications in the event that the educational institution fails to adhere to administrative compliance requirements.

Subsequent failures to report changes in student status within the prescribed time period will result in revocation of designation status by the Ministry.













Tuition Refunds

• In instances where tuition refunds are due, educational institutions must forward refunds to the National Student Loan Services Center within 30 calendar days of the student withdrawing.

The Ministry reviews educational institution student loans records annually through on-site visits. Information on student files will be cross-referenced to discontinuation information reported via the ECE Portal.

Educational institutions will be required to correct any tuition refund deficiencies immediately.


Subsequent failures to provide tuition refunds within the prescribed time period will result in revocations of designation status by the Ministry.


Student PerformanceEducational institutions with repayment rates that fall within the Red and Yellow zones will be required to develop an Improvement Plan. The Ministry will work collaboratively with educational institutions in the development of an Improvement Plan. Improvement Plans will focus on student success and should include actions that promote student retention. A sample Improvement Plan is located in Appendix E.

The following table identifies Improvement Plan requirements and the associated intervention activities related to student performance.

Improvement Plan Requirements Intervention



Improvement Plans must contain information on the following factors related to student success:

• Successful completion of programs within the established program length;

• Rigorous assessment tools for admission of non-grade twelve graduates;

• Tutorial services;

• Extended class room hours;

• Alumni services; and

• Student loan repayment information material or sessions.

The Ministry will provide formal notification to the educational institution regarding the need for an Improvement Plan.

The educational institution will ensure that they obtain assistance from a third party, the Ministry, or both, in diagnosing issues and assessing steps to be taken to improve performance.

Educational institutions will have 30 calendar days from receipt of written notification to develop or revise an Improvement Plan and submit the Improvement Plan to the Ministry for approval.

In the event that an Improvement Plan is not acceptable by the Ministry, the Ministry will work with the educational institution to negotiate an agreed upon Improvement Plan.

Failure to develop and implement an Improvement Plan will result in revocation of designation status at the end of the 30 day period.

Educational institutions that fail to act upon the activities described in their Improvement Plan will have their designation status revoked.


Revocation of Designation

Failure of an educational institution to comply with the terms of the signed Memorandum of Agreement, meet performance improvement targets in any of the performance measures (portfolio, institution, and student), or if the Ministry has identified deficiencies after a compliance review, any or all of the following actions may be taken:

• Consult with the educational institution;

• Require compliance within a specific period of time and provide evidence of compliance;

• Require additional or more frequent monitoring or reporting; and/or

• Recommend to the Minister responsible that the educational institution’s designation be removed.

Appeal of a Decision to De-DesignateIf the Minister decides to revoke the status of a designated educational institution, the decision will be communicated in a letter sent by registered mail.

Any person who is aggrieved by a decision by the Minister or that person’s designate has the right to request a review of the decision. The request for a review respecting a decision may be made, in writing, within 10 days from the acceptance of the registered letter to:

Deputy Minister’s Office, Ministry of Advanced Education 1120-2010 12th Avenue Regina, Saskatchewan S4P 0M3

The Deputy Minister’s Office may select an independent adjudicator to hear the appeal.

The aggrieved will have 30 days from the request for review to provide written submissions pertaining to the designation status to be considered in the appeal. An opportunity to make an oral submission and/or an extension of time to prepare documentation may be considered upon request.

During the period of appeal, the post-secondary educational institution will maintain its designation status.

Within 30 days from receiving written and/or oral submissions, the Ministry/adjudicator shall:

a) Confirm, reverse, or vary the decision; and

b) Mail a copy of the decision together with written reasons for the decision to the aggrieved.

The decision made by the Ministry/adjudicator is final.

Reinstatement of DesignationIf an educational institution has its designated status removed, the institution must serve an 18 month waiting period and meet all other designation requirements as stated in the Designation Process before being eligible to re-apply for designation status.


Appendix A - National Designation Policy Framework

Intergovernmental Consultative Committee on Student Financial Assistance

April 2003 (Updated February 2008)Preamble

In 2001, provincial/territorial and federal governments, through the Intergovernmental Consultative Committee on Student Financial Assistance (ICCSFA) agreed to the development of a Designation Policy Framework (Framework) with common elements to be applied in all jurisdictions for the designation of institutions.1

Four principles were identified and confirmed by Advisory Committee of Deputy Ministers of Education. to be reflected in the Framework:

• Taxpayer protection

• Accountability and informed choice

• Consumer protection

• Complementarity to other post-secondary education policies

The goal was to develop a framework that encompasses these principles and can be used by provinces and territories to establish designation policies and criteria for institutions operating within their jurisdiction. The Framework will give assurance that a suitable basis exists for the provinces/territories to also designate institutions that have already been designated by the home province/territory and that students and taxpayers will receive an appropriate return on their education investment.

Objective

The Designation Policy Framework is a pan-Canadian approach intended to guide jurisdictions in the development of their designation policies.

The Framework will support provincial and territorial governments as well as the Government of Canada in working with educational institutions to improve the performance of the student loans portfolio and to improve accountability to students and taxpayers through stewardship of the portfolio.

The Framework reiterates the fundamental purpose of government student loan programs - that of increasing access to opportunities for post-secondary education. The Framework document itself signals to institutions that student success is a key element in successfully managing financial risk. They play the central role in retaining students, ensuring students succeed, and ensuring students improve their overall employability. These are key factors

1 Jurisdictions (except Quebec, Northwest Territories, and Nunavut), participating in the Canada Student Loan Program, as well as the Government of Canada.


contributing to students’ success in repaying their student loans. Institutions, therefore, are central to any effort by government to effectively manage the financial risks inherent in a student loan program.

Scope

The Framework is designed to establish a common approach to the designation policies implemented in each jurisdiction across Canada. Within the shared Framework, it is recognized that jurisdictions will have flexibility in the specific measures implemented to address these principles. Each jurisdiction will implement designation policies that are responsive to their own particular needs while being consistent with the Framework.

Approach

This Framework encourages and emphasizes the establishment of criteria to be used when determining whether an institution should be designated in the first instance and on an ongoing basis. These initial criteria are to be supported by a set of performance standards tied to those aspects of student and portfolio performance over which the institution can have some influence.

All jurisdictions commit to encouraging improved performance so that institutions can maintain designation. It is recognized that all designated institutions have the ability to influence the overall financial exposure of the federal and provincial/territorial student loan programs. However, the Framework also recognizes that there is a range of factors that influence financial exposure and some of these factors are beyond the control of institutions.

It is also recognized that funding under student financial assistance programs is provided to assist students, not schools. While the withdrawal of designation status could potentially affect a school’s revenue, protecting the interests of students and taxpayers is the paramount consideration under this Framework.

Common Elements

All jurisdictions agree to the development of common elements for designation criteria in order to enhance accountability to taxpayers and students, enhance customer service, and protect the student’s investment by supporting the student in making informed choices. A balanced approach to measuring these common elements will use a set of agreed-upon indicators that are organized into three categories of performance: portfolio, institutional, and student. For an institution to be designated, it would have to reach certain benchmarks on each of these elements, and maintain that level.

All jurisdictions commit to including the following common elements in their designation policies:

• That the institution has programs that meet the eligibility criteria as defined by federal, provincial, and territorial legislation with respect to post-secondary education.

• That the institution be capable of appropriate administration of the student loan program and be accountable for this administration.


• That institutions provide students with adequate consumer protection and information upon which to make an informed choice about their post-secondary options. Designated educational institutions are also expected to focus on student success, improve ways to retain students, and ensure students improve their overall employability.

• That the level of financial risk of designated institutions is monitored and addressed.

Attachment A of this Framework provides more details about the aspects and activities that further define each element.

All jurisdictions are committed to working together with educational institutions to increase repayment performance in the portfolio. As a part of designation, educational institutions accept an active role in managing student financial assistance.

Risk Management

Using performance criteria, all jurisdictions will be able to identify the level of financial risk associated with attending each particular institution. All jurisdictions agree to mitigate financial exposure by focusing audit and/or review resources on working with institutions whose students represent the highest financial risk.

To determine the risk posed at a given institution, each performance criterion will be taken into consideration. Benchmarks for each category will be set, against which improved performance will be measured over a period of time.

If an institution has been assessed and placed in the high risk category, jurisdictions commit to the following minimum actions:

• Formal notification to the institution;

• Ensure that the institution obtains assistance from a third party, the provincial/territorial government, or both, in diagnosing issues and assessing steps to be taken to improve performance; and

• Ensure that an Improvement Plan is prepared and submitted to the jurisdiction.

Jurisdictions may determine that the role the institution plays in fulfilling regional, socio-economic, or cultural provincial policy priorities will be taken into account when determining the impact of a high-risk assessment on the institution’s designation status.

Risk Indicators

Risk to student assistance programs would be assessed through a measurement of three types of performance:

1. Portfolio Performance: e.g., repayment data, default data.

2. Institution Performance: e.g., administrative compliance, student support services.

3. Student Performance: e.g., completion data, employment data, withdrawal data.


Other Indicators

It is recognized that limited data are currently available for the set of indicators. These indicators are intended as an initial set for use in assessing the risk profile of institutions. Over time, as further data become available, jurisdictions will review the list of indicators with a view to modifying the initial set, if necessary.

Federal and Provincial/Territorial Responsibilities

Consistent with the Common Elements and Risk Management practices, the following responsibilities are identified for provincial, territorial, and federal levels of government in the implementation and maintenance of this Framework. The Framework recognizes the responsibility shared among all jurisdictions to support and maintain the Framework and share information with each other, as appropriate.

Provincial/Territorial Responsibilities

• Adhere to the provisions of the Designation Policy Framework.

• Implement a process for the initial designation of institutions and the ongoing monitoring of them, including an appeal process for those institutions that are not successful in attaining or maintaining designation.

• Implement formal agreements governing institutional designation. Such agreements would specify the terms of and conditions for designation and the requirements for the administration of student financial assistance.

Federal Responsibilities

• Adhere to the provisions of the Designation Policy Framework.

• Assist provinces/territories to implement designation policies that are consistent with the Framework.

• Maintain the master designation list.


Attachment A - Common ElementsActivities responsive to each element listed in the body of the Framework are provided below. This attachment should not be seen as an exhaustive list, as provinces/territories are encouraged to develop and consider further measures that reflect the common elements.

Institutions have programs that meet the eligibility criteria as defined by federal, provincial, and territorial legislation with respect to post-secondary education .

Required

• With respect to program eligibility, institutions would be assessed based on the eligibility requirement described by provincial, territorial, and federal legislation.

• Institutions must provide independent assurance of institutional integrity, such as being licensed or registered by a recognized accrediting body, or equivalent. Provincial/ territorial governments would determine the appropriate requirements for the various types of institutions operating in their jurisdiction.

The institution is capable of appropriate administration of the student loan program and is accountable for this administration .

Required

• All jurisdictions will enter into a formal agreement with domestic institutions, covering the institution’s participation in the student financial assistance program, including requirements for the provision of information by the institution pertaining to the operation of the student financial assistance program. All jurisdictions will also ensure that domestic institutions continue to meet the requirements outlined in the formal agreement.

Optional

• Require institutions to submit a description of the procedures to be implemented to properly administer a financial aid office, including provisions for appropriately trained staff.

• Institutions must demonstrate sound operational and financial viability and stability for a specified prior period in order to be eligible for designation.

Institutions provide students with adequate consumer protection and information upon which to make an informed choice about their post-secondary options . Designated educational institutions are also expected to focus on student success, improve ways to retain students, and ensure students improve their overall employability .

Required

• Require institutions to establish and publish tuition and fee policies and refund policies and ensure that the refund policies relate in a fair and equitable manner to the student’s date of withdrawal in relation to the full course of study for which tuition and fees have been paid.


• Require institutions to provide a financial guarantee, such that if an institution is closed, the students’ investment receives appropriate protection.

• Require institutions to collect and report information to students and to governments, where appropriate, in support of agreed indicators such as completion, employment, and withdrawal.

Optional

• Require institutions to provide information on program outcomes to students and to governments during the waiting period for designation.

• Ensure that information on loan default (or repayment) rates is provided to students.

The level of financial risk of designated institutions is monitored and addressed .

Required

• Jurisdictions will ensure that institutions maintain an acceptable level of risk as defined by the provincial and territorial governments in consultation with the federal government.

• Institutions cooperate with the efforts of provinces/territories to identify and mitigate financial risk as appropriate.

• Institutions will provide student financial assistance information and counselling.

Optional

• Require institutions to have a withdrawal/exit management plan to assist students.

• Require institutions to meet specific requirements for student retention prior to designation.

• Require institutions to contract with an independent auditor to report on institutional compliance with the administrative requirements under the jurisdiction’s designation policy. The level of risk would determine the frequency of these audits.


Attachment B - Designation Criteria for International Educational InstitutionsIn addition to the criteria set out in the Designation Policy Framework, the following criteria would apply for international educational institutions seeking designation status.

1. A post-secondary educational institution located inside the United States must be approved for Title IV funding by the US Department of Education.

2. (a) An international post-secondary educational institution located outside the United States must meet the following criteria:

(i) Be approved for the purpose of student financial assistance or be accredited in its home country; and

(ii) Demonstrate stability by having been in continuous operation for a minimum of two years prior to designation.

(b) An international post-secondary educational institution must also be listed in one of the following references:

(i) International Handbook of Universities (International Association of Universities, Stockton Press);

(ii) The World of Learning (Europa Publications);

(iii) The Commonwealth Universities website at www.acu.ac.uk/home;

(iv) The International Association of Universities website at www.unesco.org/iau/members_friends/mem_membinst1.html;

(v) The federal school look up for FAFSA, (US Department of Education) www.fafsa.ed.gov/index.htm; or

(vi) Accredited Institutions of Postsecondary Education (Greenwood Publishing Group).

3. International post-secondary educational institutions located outside of the United States offering medical programs must meet the following criteria in addition to the criteria listed above in section 2:

(i) Be listed on the International Medical Education Directory maintained by the Foundation for Advancement of International Medical Education and Research (FAIMER) imed.ecfmg.org or the World Directory of Medical Schools maintained by the World Health Organization www.who.int/hrh/wdms/en/;

(ii) Be approved by a member of the Federation of Medical Regulatory Authorities of Canada; and

(iii) Be in continuous operation for at least ten years.

4. Maintaining the Master Designation List:

(i) An institution’s designation status will be reviewed if no students receiving a Canada Student Loan or a provincial student loan has attended the institution in the past two years; and

(ii) The list of international educational institutions will be reviewed by jurisdictions once every five years.

http://www.acu.ac.uk/home

http://www.unesco.org/iau/members_friends/mem_membinst1.html

http://www.fafsa.ed.gov/index.htm

http://imed.ecfmg.org

http://www.who.int/hrh/wdms/en/


Attachment C - Designation Criteria for E-learning Educational InstitutionsIn addition to the criteria set out in the Designation Policy Framework, the following criteria would apply for e-learning educational institutions seeking designation status.

1. (a) A Canadian e-learning post-secondary educational institution must meet one of the following criteria:

(i) The institution has programs that meet the eligibility criteria as defined by federal, provincial, and territorial legislation with respect to post-secondary education;

(ii) Be approved by one of the Canadian quality assurance bodies;

(iii) Has an equivalent on-site offering of the course or program of study; and

(iv) Demonstrates that academic credits, or credit hours earned through the course or program of study are transferable to a designated public post-secondary educational institution located within the same province/territory.

• The transferability of credits must be outlined in either articulation agreements between the two post-secondary educational institutions, or in provincial transfer guides.

(b) An international e-learning post-secondary educational institution must meet one of the following criteria:

(i) Be approved for Title IV funding by the US Department of Education;

(ii) Be approved by one of the Canadian quality assurance bodies;

(iii) In receipt of an acceptable rating in a full institutional audit conducted by the United Kingdom Quality Assurance Agency for Higher Education within the last five years;

AND all e-learning post-secondary educational institutions must:

2. Require a minimum of 20 hours per week of student activity or participation, in the case of career/vocational/technical programs of study;

3. Actively monitor student participation and maintain contact with students in order to ensure that minimum course load requirements are maintained;

4. Demonstrate that its courses or programs of study and monitoring activities meet these guidelines; and

5. Provide specific program of study/course start and end dates.


Attachment D - Administrative Compliance IndicatorThe Administrative Compliance Indicator is one of the two initial indicators approved to assess and monitor the performance of education institutions for the purpose of becoming designated, and maintaining their designation status. The Administrative Compliance Indicator has seven criteria, further defined below:

1 . Formalized Communication

The key elements of a letter of understanding or MOU granting or renewing designation status must include:

• Acknowledgement of designation status being gained and/or maintained.

• A reminder that having a designation status is a serious responsibility and involves both serving the clients (students) appropriately and maintaining the highest levels of fiscal integrity with public funds.

• The institution’s responsibilities, which at a minimum meet those outlined in the Designation Policy Framework.

• The institution and program adheres to any further applicable legislation, regulations, and policies in place.

• That the jurisdiction may audit the institution with respect to the compliance of these responsibilities.

• That any evidence of non-compliance will be followed up.

• An attachment of the Administrative Compliance section of the pan-Canadian Designation Policy Framework.

• That the (department, government) is there to provide advice and logistical assistance in the administering of student financial assistance.

• Agreement in writing of the above conditions from the institution must be received by the jurisdiction.

2 . Appointed Financial Aid Officer

• That the institution must have an officially appointed officer for the purpose of signing student financial assistance documents, and it must inform the jurisdiction of who the officer(s) is/are, along with a sample of their signature.

• That the institution informs the jurisdiction immediately if the signing authority of an officer is revoked, and on what day it was revoked.


3 . Advertising

• Designated institutions are not permitted to use their designation status for recruitment but for information purposes only. Jurisdictions may develop/determine general statements for institutions to use in official material.

• Designated institutions may refer to government student financial assistance eligibility in course calendars and provide a reference to the jurisdiction’s student financial assistance program for more detailed information.

• Jurisdictions may request an institution to provide advertising material and publications to ensure compliance with the above criteria.

4 . Published Tuition Refund Policy

• To obtain and or maintain designation status, an institution must have a published tuition refund policy. This policy should be placed in applicable official school materials, such as school calendar, student handbook, student contract, and application package.

¾ If the institution’s policy is that tuition is 100 pre cent non-refundable, there must be a clear statement to that effect in official school materials.

• That the tuition refund policy meets the minimum standards established by the jurisdiction in which it resides.

• That if a student becomes eligible for a tuition refund, but due to loans and grants already disbursed may fall into an over award situation, the jurisdiction has first claim on the tuition refund until the student’s over award is cleared.

• That the jurisdiction may at any time request a copy of the published tuition refund policy for the purpose of ensuring compliance with both the Framework and any applicable Acts and Regulations.

5 . Program Eligibility

• Institutions have programs that meet the eligibility criteria as defined by federal, provincial, and territorial legislation with respect to post-secondary education.

6 . Financial Stability

Institutions will have measures including but not limited to:

• Being covered under applicable legislation or providing a surety bond or other suitable security guarantee, (such as a letter of credit), payable to the appropriate authority, at least equal to a specified percentage of the tuition and other fees paid by all students receiving student loans; and/or participating in a train-out insurance fund.

• Insure the prompt issuance of tuition refunds to students.


7 . Reporting Change in Student Status

The definition for “change in student status” is:

• Withdrawal from the program;

• Change from full-time to part-time; or

• Failure to maintain satisfactory scholastic standing.

Criteria include:

• The school must report a student’s name, social insurance number and date that the student ceased to meet student loan eligibility criteria to the appropriate government body within four weeks.

• The institution must advise the appropriate government body of a student’s name, social insurance number and date he/she dropped to part-time status or withdrew from school completely within four weeks.

• An applicant must maintain a satisfactory scholastic standard, defined as successful completion of at least 40 per cent of a full course load leading to a degree, diploma or certificate at the post-secondary level for permanently disabled students and 60 per cent for all other applicants to continue to be eligible for Canada student loans.


Attachment E - Repayment Rate IndicatorCalculation Methodology

Under the current repayment rate calculation methodology used for the first evaluation cycle (2004-08), all loan dollars associated with a given borrower are linked to the most recent post-secondary educational institution for which the borrower received either a loan (Certificate of Eligibility) or interest free status (Confirmation of Enrolment). Therefore only the last post-secondary education institution associated with the borrower was attributed with the borrower’s student loan performance.

At the beginning of the second evaluation cycle (2008–12), a revised methodology will replace the initial methodology to calculate repayment rates. The revised repayment rate calculator distributes loan dollars proportionately to every institution attended by a given borrower prior to consolidation. Loan dollar proportions are calculated based on the amount of disbursement allotted to a given borrower while attending each institution. More specifically, at the point of consolidation, if a borrower had received a loan for an amount of p, while enrolled with institution X, and then had received another loan for an amount q, while attending institution Y, institution X will receive p/(p+q) of the total share of the loan dollars while institution Y will receive q/(p+q) of the total share of the loan dollars. (See TABLE 1 for how loan dollars can be distributed where a given borrower has attended more than one institution while receiving student loans.)

For the first evaluation cycle, initial targets were determined as at July 31, 2004 based on the combined repayment rate performance of all borrowers who consolidated in the 2002-03 loan year. Similarly, for the second evaluation cycle (2008-12), targets were determined as at July 31, 2008 based on the combined repayment rate performance of all borrowers who consolidated in the 2006-07 loan year. The reason for this was to ensure that the repayment period was sufficiently long enough to provide an accurate representation of the risk that particular institutions represent before determining the target rates for the cycle. For example, loans that consolidated in August 2006 (the first month of consolidated loans included in this cohort) provided 24 months of repayment data, while loans that consolidated in July 2007 (the last month of consolidated loans included in this cohort) provided 13 months of repayment data.

**Approximately 80 per cent of loans consolidate between November and March (21 and 17 months of repayment data, respectively).

Note: For simplicity, the amount consolidated (both principal and capitalized grace period interest) will be treated as the amount of money at risk. As such, only payments against this amount will be registered. Payments made against accrued interest after the consolidation date are not considered.


Notes:

• To minimize the impact of provincial grant and/or bursary payments made prior to the consolidation date, all payment types made in ‘study’ or in ‘grace’ (Class A) are not included in the proposed repayment rate calculations. The data suggests that Class A payments account for just three per cent of all payments made in a given loan year. Based on further investigation, it was identified that these payments had a minimal impact on institutional repayment rates.

• The repayment rate risk methodology relies on new consolidations in a given loan cohort. As such, there may be instances of new educational institutions that have not recorded new consolidations and would not appear in the repayment tables and subsequent annual report. However, these institutions will most likely have low volumes of loans, and therefore do not represent significant risk.

• Provinces may choose to use provincial data in conjunction with federal data when examining repayment rates. However, there may be considerable grant and/or bursary payments against the provincial principal amount after the consolidation date. To be consistent and comparable with the federal repayment methodology, provinces should not count grant/bursaries paid after consolidation as payments. These amounts should be excluded from both the numerator and denominator (from payments and from consolidations).

Example:

How loan dollars are distributed to all institutions from which a borrower received loan disbursement:

TABLE 1: Example - Loan disbursements by institution

Institution Disbursements Total Disbursement by Institution

ACME D1: $5,000 $5,000BDPX D2: $8,000 D3: $8,000 $16,000BVDY D4: $6,000 $6,000

Borrower Disbursement Total: $27,000

In Table 1, John Smith received four disbursements (D1, D2, D3, and D4) while attending three different institutions (ACME, BDPX, and BVDY).

The proportions of loans allocated to each institution are then calculated by dividing the Total Disbursement by Institution by the Total Borrower Disbursement:

ACME: $5,000 / $27,000 = 0.18519 = 18.519%

BDPX: $16,000 / $27,000 = 0.59259 = 59.259%

BVDY: $6,000 / $27,000 = 0.22222 = 22.222%

The borrower’s current principal is then multiplied by each institution’s loan dollar proportion to determine the principal to be applied to each institution. Table 2 summarizes this calculation.


TABLE 2: Example - Linking principal to institutions

Institution Percent Applied Current Principal Principal Applied

Principal at Consolidation

ACME 18.52% $27,000 $5,000.13BDPX 59.26% $27,000 $15,999.93BVDY 22.22% $27,000 $5,999.14

Principal PaidACME 18.52% $1,600 $296.30BDPX 59.26% $1,600 $948.14BVDY 22.22% $1,600 $355.55

Principal Outstanding

ACME 18.52% $25,400 $4,703.83BDPX 59.26% $25,400 $15,051.79BVDY 22.22% $25,400 $5,644.39

Note: The loan disbursement proportions are used as a basis to calculate the proportion of Principal at Consolidation, Principal Outstanding, and Principal Paid to each institution attended by John Smith.

To determine the overall repayment rate for an institution, proportions of Principal at Consolidation, Principal Paid and Principal Outstanding (including Principal in Good Standing and Principal Delinquent) from each borrower at a given institution are then aggregated.


TABLE 3: Sample Institutional Repayment Rate Calculations to Determine Risk ZonesConsolidation

Month Repayment Period Consolidation Principal Paid

Principal in Good Standing

Principal Delinquent

August 2002Aug 1, 02 - Jul 31, 04 (24 months)

$175,000 $20,930 $140,070 $14,000

September 2002Sept 1, 02 - Jul 31, 04 (23 months)

$89,000 $10,200 $74,800 $4,000

October 2002Oct 1, 02 - Jul 31, 04 (22 months)

$279,000 $23,760 $192,240 $63,000

November 2002Nov 1, 02 - Jul 31, 04 (21 months)

$3,779,000 $348,600 $3,137,400 $293,000

December 2002Dec 1, 02 - Jul 31, 04 (20 months)

$1,433,000 $121,680 $1,230,320 $81,000

January 2003Jan 1, 03 - Jul 31, 04 (19 months)

$1,645,000 $119,200 $1,370,800 $155,000

February 2003Feb 1, 03 - Jul 31, 04 (18 months)

$382,000 $23,104 $280,890 $78,000

March 2003Mar 1, 03 - Jul 31, 04 (17 months)

$1,021,000 $53,940 $845,060 $122,000

April 2003Apr 1, 03 - Jul 31, 04 (16 months)

$306,000 $12,900 $245,100 $48,000

May 2003May 1, 03 - Jul 31, 04 (15 months)

$208,000 $6,960 $167,040 $34,000

June 2003Jun 1, 03 - Jul 31, 04 (14 months)

$280,000 $7,290 $235,710 $37,000

July 2003Jul 1, 03 - Jul 31, 04 (13 months)

$852,000 $16,160 $791,840 $44,000

Grand Totals $10,449,000 $764,720 $8,711,270 $973,00

Repayment Rate=(Paid + Good Standing) *100 ($764,724 + $8,711,270) *100 = 90.7% Consolidation $10,449,000

Target and Assessment Cycle

The repayment rate of the first consolidation cohort (i.e. the 2002-03 consolidations) will be tracked for a period of two years (i.e. until July 31, 2004), at which point a four year target will be set. Starting in Fall 2004, institutions in the Yellow and Red risk zones will have three assessment periods on which to improve their repayment rates. Since each of the three consolidation cohorts are tracked for a period of two years, the first assessment year data will be available for Fall 2006 and the last assessment year data will be available for Fall 2008. After which, a new target will be set at the end of the third assessment period.

Note: The 2003-04 consolidation cohort will have graduated prior to the Fall 2004 target set date, and therefore, cannot be used for assessment as this consolidation cohort will not be affected by any institutional Improvement Plan implemented after Fall 2004 (refer to Chart 1).


CHART 1: Repayment Rate Evaluation Period

Risk Zones

There will be three institutional risk zones: Green, Yellow, and Red. Institutions will be assigned one of these three risk zones based on their students’ repayment performance as calculated by repayment rate indicator. Green zone institutions (i.e. institutions with a repayment rate which is above the national average) will be exempt from any intervention assessment. Yellow zone institutions (i.e. institutions with a repayment rate from the national average to one standard deviation below) and Red zone institutions (i.e. institutions with a repayment rate below one standard deviation from the national average) will be targeted to improve their repayment rates.


Zones For Institutions

Performance Level

Performance Improvement

TargetIntervention Sanctions/Response to non-

performing Institutions

Green Good Exempt Exempt Exempt

Yellow Average Three percentage points over three assessment periods.

Formal notification of status.

Identification of improvement targets.

Jurisdictions may initiate additional interventions as deemed appropriate.

If institutions meet the following criteria, jurisdictions will intervene during and at the end of the assessment cycle:

1. Institutions with non-improving performance, and

2. Highest amount of dollars at risk

Jurisdictions will decide on the type of interventions based on a case by case.

If a Yellow zone institution fails to meet its target by the end of the assessment cycle, further action may be required.

Red Poor Institutions must improve performance to meet Yellow zone threshold within three assessment periods.

Formal notification to the institution.

Ensure that the institution obtains assistance from a third party, the provincial/territorial government, or both, in diagnosing issues and assessing steps to be taken to improve performance.

Ensure that an Improvement Plan is prepared and submitted to the jurisdiction.

If the institution fails to meet the performance improvement target/plan approved by the jurisdiction within three years, it will be de-designated unless it is determined by the jurisdiction that significant improvement has occurred and a re-consideration of de-designation is warranted.*

At any time within the three years, jurisdictions may exercise their authority to de-designate an institution as they deem appropriate.

* Jurisdictions may determine that the role the institution plays in fulfilling regional, socio-economic, or cultural provincial policy priorities will be taken into account when determining the impact of a high-risk assessment on the institution’s designation status.


Terms and DefinitionsConsolidation Month: First month of loan repayment (i.e. seven months after end of study date.)

Repayment Period: The period extending from the Consolidation Month to the end of the assessment period.

Consolidation ($): Initial federal principal (and capitalized grace period interest) dollar amount that was consolidated in a given loan year.

Principal Paid ($): Federal principal dollar amount that was paid (in full or in part) as at the end of the assessment period.

Principal in Good Standing ($): Federal principal dollar amount that remains in Good Standing as at the end of the assessment period. Note: Good Standing is defined as being up-to-date with required monthly payments or on Interest Relief.

Delinquent Principal ($): Federal principal dollar amount in delinquency as at the end of the assessment period. Note: Delinquency is defined as not being up-to-date with required monthly payments (i.e. one or more missed payments that remain outstanding)

Loan Dollar Proportion ($): If a borrower received a loan for an amount of p while enrolled with institution X, and then received another loan for an amount q while attending institution Y, institution X will receive p/(p+q) of the total share of the loan dollars while institution Y will receive q/(p+q) of the total share of the loan dollars.

Repayment Rate: Sum of ‘Principal Paid ($)’ plus sum of ‘Principal in Good Standing ($)’, divided by sum of ‘Consolidation ($)’, multiplied by 100.

35Saskatchewan Designation Policy Manual

SAMPLE

Appendix B - Sample Saskatchewan Memorandum of Agreement (MOA)

DESIGNATION MEMORANDUM OF AGREEMENT (MOA) BETWEEN

THE GOVERNMENT OF SASKATCHEWAN

as represented by the Minister of

Advanced Education,

AND

Name of Legal Owner and Name of Institution

(Institution)

A . Introduction:Saskatchewan’s Minister of Advanced Education is responsible under federal and provincial legislation for designating educational institutions. Designation ensures students attending designated institutions are eligible to receive student loans under Saskatchewan’s and Canada’s student loans programs. Canada requires Saskatchewan to enter into agreements with educational institutions to outline the terms and conditions respecting the conditions the Institution must meet before any student who attends the Institution will be eligible for student loans.

The Designation Policy of the Ministry of Advanced Education (the Ministry) is designed to strengthen consumer and taxpayer protection, to ensure accountability and informed choice, and to work complementarily with other post-secondary educational policies. Designation status is the responsibility of an institution to maintain. It involves both serving the students appropriately and maintaining the highest levels of fiscal integrity with public funds.

The Ministry is committed to working in a collaborative manner with post-secondary institutions to improve performance and increase student success both while in study and in repayment. The Ministry will provide support to institutions that promote student success, including personnel for consultation and support in the development and evaluation of administrative processes. This includes distributing both materials that outline students’ rights and responsibilities in repayment and administrative materials for institutions, and offering programs that are available to students who are experiencing financial difficulties.

Post-secondary institutions and personnel are expected to focus on student success, including strategies to retain students and supports that improve their overall employability.

B . Institution’s Acknowledgements and Covenants:The institution acknowledges that the Ministry of Advanced Education does not grant designation status as a right, designation status must be earned, and Advanced Education retains the sole discretion to determine designation status.


SAMPLE

In consideration of the Ministry of Advanced Education providing loans to certain students attending the Institution, and with a view to encouraging Advanced Education to grant or continue to grant the Institution designation status:

1. The Institution agrees to comply with:

a) The Canada Student Financial Assistance Act and the Canada Student Loans Act and accompanying regulations;

b) The Student Assistance and Student Aid Fund Act, 1985, and all regulations thereunder;

c) All other legislation that applies to the Institution;

d) The Saskatchewan Designation Policy Manual; and

e) Educational Institution Manual for the Canada-Saskatchewan Integrated Student Loans Program and Other Financial Assistance.

2. Not so as to restrict the generality of the forgoing, and as more particularly described in the aforesaid websites, the Institution shall:

a) Co-operate fully with any audit that Advanced Education chooses to undertake to determine or ensure compliance with any of the Institution’s obligations under this memorandum, including allowing Advanced Education employees reasonable access to and copies of all relevant documents and records upon request;

b) Advise Advanced Education of the name of the Institution’s financial aid officer who has authority to sign student financial assistance documents;

c) Not use its designation status for recruitment of students or staff;

d) Publish the Institution’s tuition refund policy in all applicable school materials, including calendars, books, contracts, and applications;

e) Be authorized to operate under the applicable legislation; and

f) Promptly report to Advanced Education a student’s name and social insurance number where the student withdraws from a program, changes from full-time to part-time, or fails to maintain satisfactory scholastic standing.

C . Advanced Education’s Agreements: Advanced Education agrees to:

1. Consider the Institution’s compliance with this memorandum when determining whether to designate the Institution or suspend or cancel the Institution’s designation.

2. Provide such logistical advice in the administration of student financial assistance as Advanced Education deems appropriate and feasible.




SAMPLE

Termination:Either party may terminate this MOA immediately by written notice mailed to the last known address of the other.

X____________________________________Executive DirectorStudent Services and Program DevelopmentMinistry of Advanced Education

_____________________________________Date

X____________________________________

Signature

Name: ________________________________ Please Print

Title: __________________________________ Please Print

_____________________________________Date


Appendix C

Educational Institution: ______________________________________________________________________

Mailing Address: ____________________________________________________________________________ Street/apartment number City/Town

_____________________________________________________________________________ Province Country Postal Code

Daytime Telephone (with area code): __________________________________________________________

Other Telephone (with area code): _____________________________________________________________

Email Address: _____________________________________________________________________________

Institutional Contact Name: __________________________________________________________________

Administrative Compliance Requirements Checklist VerifiedAppointed Financial Aid Officer

Please indicate the appointed officer for the purpose of administering loans via the Electronic Confirmation of Enrolment (ECE) Portal.

Name: ____________________

____________________Advertising

Please verify that the institution does not use their designation status for recruitment but for information purposes only. (Please attach a copy of the link to your webpage)

Published Tuition Refund Policy

Please verify that the institution has a published tuition refund policy. (Please attach a copy of the link to your webpage)

Attendance Reporting

Please verify that the institution maintains student attendance records in a manner acceptable to the Ministry and comply with attendance policies as set out in the Educational Institution Manual: Canada-Saskatchewan Integrated Student Loans Program and Other Financial Assistance.

Designation Policy Framework Compliance Form

Student Service Centre1120 - 2010 12th AvenueRegina, Canada S4P 0M3 306-787-56201-800-597-8278Fax: 306-787-1608




Administrative Compliance Requirements Checklist VerifiedReporting Change in Student Status

Please verify that the institution has reported to the National Student Loan Service Centre, within 30 calendar days, the following changes in students’ statuses:

• Withdrawals from the program

• Changes from full-time to part-time

Tuition Refunds

Where tuition refunds are due, please verify that the institution forwards refunds to the National Student Loan Services Centre within 30 calendar days of the student withdrawing.

I __________________________________________________ submit this form to the Ministry of Advanced (Name of Institution Official)Education and can attest that __________________________________________ is in compliance with the (Name of Institution)educational institution’s obligations as outlined in the Designation Policy Framework and as agreed to in the Memorandum of Agreement for designation under the Canada-Saskatchewan Integrated Student Loan Program.

X ____________________________________________ _______________________________Signature of Institution Official Date


Appendix D - Repayment Rate Methodology

The following table provides an example of how an educational institution’s Repayment Rate is determined:

Sample Institutional Repayment Rate CalculationConsolidation

Month Repayment Period Consolidation Principal Paid

Principal in Good Standing

Principal Delinquent

August 2002Aug 1, 02 - Jul 31, 04 (24 months)

$175,000 $20,930 $140,070 $14,000

September 2002Sept 1, 02 - Jul 31, 04 (23 months)

$89,000 $10,200 $74,800 $4,000

October 2002Oct 1, 02 - Jul 31, 04 (22 months)

$279,000 $23,760 $192,240 $63,000

November 2002Nov 1, 02 - Jul 31, 04 (21 months)

$3,779,000 $348,600 $3,137,400 $293,000

December 2002Dec 1, 02 - Jul 31, 04 (20 months)

$1,433,000 $121,680 $1,230,320 $81,000

January 2003Jan 1, 03 - Jul 31, 04 (19 months)

$1,645,000 $119,200 $1,370,800 $155,000

February 2003Feb 1, 03 - Jul 31, 04 (18 months)

$382,000 $23,104 $280,890 $78,000

March 2003Mar 1, 03 - Jul 31, 04 (17 months)

$1,021,000 $53,940 $845,060 $122,000

April 2003Apr 1, 03 - Jul 31, 04 (16 months)

$306,000 $12,900 $245,100 $48,000

May 2003May 1, 03 - Jul 31, 04 (15 months)

$208,000 $6,960 $167,040 $34,000

June 2003Jun 1, 03 - Jul 31, 04 (14 months)

$280,000 $7,290 $235,710 $37,000

July 2003Jul 1, 03 - Jul 31, 04 (13 months)

$852,000 $16,160 $791,840 $44,000

Grand Totals $10,449,000 $764,720 $8,711,270 $973,00

Repayment Rate=(Paid + Good Standing) *100 ($764,724 + $8,711,270) *100 = 90.7% Consolidation $10,449,000

Definitions for Repayment Rate Calculation:

Consolidation ($): Initial federal principal (and capitalized grace period interest) dollar amount that was consolidated in a given loan year.

Consolidation Month: First month of loan repayment (i.e. seven months after end of study date.)


Delinquent Principal ($): Federal principal dollar amount in delinquency as at the end of the evaluation period. Note: Delinquency is defined as not being up-todate with required monthly payments (i.e. one or more missed payments that remain outstanding).

Principal Paid ($): Federal principal dollar amount that was paid (in full or in part) as at the end of the evaluation period.

Principal in Good Standing ($): Federal principal dollar amount that remains in Good Standing as at the end of the evaluation period. Note: Good Standing is defined as being up-to-date with required monthly payments or on the Repayment Assistance Plan.

Repayment Period: The period extending from the Consolidation Month to the end of the evaluation period.

Repayment Rate: Sum of ‘Principal Paid ($)’ plus sum of ‘Principal in Good Standing ($)’, divided by sum of ‘Consolidation ($)’, multiplied by 100.

Note: Repayment rate calculations are tied to an educational institution, not the individuals attending the educational institution.


SAMPLE

Appendix E - Sample Improvement Plan

Saskatchewan Designation Policy Sample Improvement Plan

Institution NameThe Saskatchewan Ministry of Advanced Education and the Institution agree that the following activities will be undertaken and that these activities form the Improvement Plan. This Improvement Plan can be changed, by mutual consent, at anytime.

The Ministry of Advanced Education commits to undertaking the following activities with the Institution.

Key Area Function Activities

Borrower Education

Enhanced Entrance Counselling

• Ministry of Advanced Education staff will present information on the Canada-Saskatchewan Integrated Student Loans Program including students’ repayment obligations and debt management tools to at least one group intake session annually.

• Ministry of Advanced Education staff will develop materials containing loan information for borrowers future reference that will be distributed by the institution and posted on the Saskatchewan Student Loans Website including but not limited to:

¾ The Canada-Saskatchewan Integrated Student Loans Handbook and the Educational Institution Manual: Canada-Saskatchewan Integrated Student Loans Program and Other Financial Assistance.

Enhanced Exit Counselling

• Ministry of Advanced Education staff will present information on the Canada-Saskatchewan Integrated Student Loans Program focusing on students’ repayment obligations, consequences of default and debt management tools to at least one graduating group annually.

• Ministry of Advanced Education staff will develop materials containing loan repayment information for borrowers’ future reference that will be distributed by the institution and posted on the Saskatchewan Student Loans website.

http://publications.gov.sk.ca/documents/139/100898-Student%20Loan%20Handbook%202017-18.pdf

http://publications.gov.sk.ca/documents/139/100898-Student%20Loan%20Handbook%202017-18.pdf





SAMPLE


Leveraging Technology

Internet Access

• Ministry of Advanced Education will continue to expand the student loan website for students to view and use as a reference on an ongoing basis by:

¾ Providing online access to the application process;

¾ Providing links to other appropriate websites that will assist students with financial aid and repayment;

¾ Providing updates to program information in a complete and timely manner.

The Ministry of Advanced Education also commits to broader activities that will impact all Institutions including:

• Continuing to work on the National Designation Working Group to refine the Repayment Rate Methodology to address issues such as the inclusion of prior student loan debt and student in arrears for less then 90 days being included as delinquent.

• Continuing to work with the government of Canada to improve the Canada-Saskatchewan Integrated Student Loans Program particularly with respect to repayment policies, procedures and debt management programs.


SAMPLE

Educational institutions commit to undertaking the following activities.


Borrower Education

Enhanced Entrance Counselling

• Invite the Ministry of Advanced Education to present at student information sessions as required.

• Distribute materials containing loan information to the borrowers for future reference.

• Provide access to information, where available, on graduation rates, graduate employment rates and default rates by institution and program.

• Offer sessions intermittently throughout the semester to promote attendance at counseling sessions.

• Offer one-on-one entrance counselling to students who cannot attend group sessions.

• Meet with borrowers at the end of the semester/program to identify students who may need additional counseling.

Review Sessions

• Discuss with students information about their loans including cumulative amount borrowed, estimated interest and estimated monthly payment.

• Confirm with students that they have received a recent loan summary and/or refer students to National Student Loan Service Centre’s online account services.

• Update students on changes in financial aid office procedures.

• Remind students of their rights and responsibilities.

• Relay to students the consequences of discontinuing their studies and defaulting on their loans.

• Remind students to send updated student information to the lender and service providers and direct students to where they can update their information online.

• Counsel excessive borrowers (to be defined by individual institutions) on a one-on-one basis about responsible borrowing, budgeting, debt management plans, repayment options and salary expectations.

Enhanced Exit Counselling

• Invite the Ministry of Advanced Education, lenders and service providers to present at information sessions.

• Include and emphasize the correct procedures transfer students should follow when notifying their lenders that they have transferred and in applying for interest free status.

• Provide students with the most up-to-date information on the names and phone numbers of lenders and service providers.

• Offer one-on-one exit counselling to students who cannot attend group sessions.

• Develop exit interview forms and ensure that they are completed in full.

• Send borrowers a letter or brochure if they were unable to attend an exit counselling session during their grace period reminding them of their rights and responsibilities and listing phone numbers to call for assistance.


SAMPLE


Alliance Building

Work with Other Campus Departments to Promote Positive Repayment Behaviour

• Stress the importance of default prevention to upper administration and request their assistance in helping secure resources.

• Enlist the assistance of alumni organizations and the registrar’s office to provide updated address information to service providers.

• Make default prevention a priority for the entire financial aid office by educating front counter staff and advisors on default prevention measures.

Work Closely with Outside Agencies to Promote Default Prevention

• Take advantage of services where offered by lenders and service providers, such as entrance and exit counselling via the web.

• Invite industry experts to train financial aid office staff on default prevention methods.

Leveraging Technology

Internet Access

• Create/link to a financial aid web page for students to view and use as a reference.

• Refer students to National Student Loan Service Centre’s online account information services.

• Provide computers for students to use, either in the lobby of the financial aid office or in a lab setting, to access financial aid information online.

Student Retention

Academic Advising

• Academic advisors should strongly encourage their advisees to make efforts to establish memberships in the social communities of their collegiate institution.

Administrative Policies and Procedures

• Have effective methods for the communication of rules and regulations important to students.

Withdrawal Management Plan

• Develop a withdrawal management plan to ensure that those students who do leave the institution before completing their program are informed of their responsibilities with respect to their student loans.

• Establish formal withdrawal procedures that require “sign off” by the financial aid office before a student is allowed to withdraw. This will ensure proper counselling on loan repayment obligations.

Monitoring of Graduation Rates by Program

• Institutions that monitor program graduation rates will be in a better position to identify, rectify and/or eliminate programs that have low repayment rates improving overall institutional performance.

Employment Initiatives/ Services

To connect students with the labour market.

• Conduct regular education and training needs assessment to ensure ongoing relevancy of education/training program(s) and the employability of graduates in the local/regional/provincial economy.

• Establish/enhance an employment resource centre which includes job postings, job search websites, resources on resume writing and interview skills.

• Monitor the performance of programs with respect to graduate employment rates and graduate’s other labour market outcomes (e.g. post-study income) through graduate employment surveys.

• Enhance relationships with employers of former graduates and other potential employers.




Student Success Plan

Students are ready to begin their post-secondary program and have the tools to successfully complete their program.

• Develop a set of procedures to ensure that students are successful including:

¾ Pre-screening for program suitability to ensure successful program completion;

¾ Tutorial services;

¾ Academic counseling; and

¾ Providing opportunities to attach students to the labour market.

• Student success is defined as:

¾ Successfully completing the program of study within the approved program length;

¾ Obtaining employment in the field of study; and

¾ Repayment of financial obligations arising from student loan debt.

Need more information?Telephone: Outside Regina call toll-free: 1-800-597-8278 Regina area (or outside Canada): 306-787-5620

Fax: 306-787-1608

Business Hours: 8:00 a.m. to 5:00 p.m. Monday to Friday

Mailing Address: Student Service Centre, Ministry of Advanced Education 1120 - 2010 12th Avenue Regina, Saskatchewan S4P 0M3

saskatchewan.ca/studentloans saskatchewan.ca/informationforinstitutions


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