The Catholic University of America

Responsibilities of the Associate Vice President for Enrollment Services and University Registrar

Higher Education Opportunity Act of 2008 (HEOA)

To the maximum extent feasible, the University must provide the International Standard Book Number ("ISBN") and retail price for required and recommended textbooks and supplemental materials for each course listed on the schedule (posted on the web or print course schedule). If no ISBN is available, the institution may provide the textbook's author, title, publisher, and copyright date. If the disclosure is not practical for a certain text, a designation of *to be determined* can be noted. Written course schedules should indicate where on the University web page this information will be posted. The Act encourages Universities to disseminate information regarding book rentals, used textbooks, buy-back programs, and alternative delivery programs or other cost saving strategies. Universities shall make available to the college bookstore, upon request, the most accurate information regarding the course schedule for the next academic period and for each course offered, including the information described above as well as the number of students enrolled in such course and the maximum enrollment for each class. The Registrar is responsible for the following:

Ensuring that the ISBN and retail price for required and recommend textbooks and other supplemental materials for each course (where available) is posted on the internet along with the Course Schedule

Providing to the college bookstore, upon request, the information detailed above

Family Educational Rights and Privacy Act (FERPA)

This law regulates the keeping and dissemination of student education records. Subject to several exceptions, “student education records” include any records (regardless of format or medium) maintained by the University or an agent of the University which are directly related to a student.   Policies and procedures for release of student education records and information must meet the following requirements:

Release of information without consent: Release of student educational records and information without student consent is permitted in the following circumstances:  1) directory information (e.g. name, address, phone, major, participation in officially recognized activities/sports, date and place of birth, weight/height of athletic team members, dates of attendance, awards/degrees received, most recent educational institution attended) provided that the student has not exercised an opt out in this regard;  2) to school officials w/in the institution with need to know;  3) to other postsecondary education institutions for purposes related to enrollment or transfer; 4) to administer financial aid; 5) to organizations conducting studies to develop, validate, or administer predictive tests, administer student aid, or improve instruction; 6) to accrediting organizations to carry out their functions; 7) per judicial order or lawful subpoena; 8) in connection with a health or safety emergency; 9) to give the victim of a crime of violence or a sex offense the final results of the disciplinary proceeding against the alleged perpetrator re that alleged offense; 10) to a parent if the student violates law or institutional policy re use or possession of alcohol or controlled substances if the institution determines the student committed a disciplinary violation and the student is under 21 at the time of the disclosure. 

Disclosure in Emergency: The University may disclose personally identifiable information from a student’s education records without consent to address a health or safety emergency if: 1) The emergency is actual or imminent and poses an articulable and significant threat, such as bodily harm, to the health or safety of the student or others; 2) disclosure is limited to the period of the emergency and is made only to appropriate parties (law enforcement, public health officials, trained medical personnel, parents) who need the information to protect health and/or safety; and 3) the institution records in the student’s education records the articulable and significant threat that formed the basis for the disclosure.

Release of Information requiring consent: Release of student educational records and information not listed in the above categories requires that the University have written permission from the student to release information from a student's education record.  Consent must be in writing by the student and specify which records may be disclosed, to whom, and the time frame for disclosure.  If appropriate consent is obtained, the authority of the requestor to receive the information, and authentication as to the requestor’s identify, is required.

The Registrar is the primary institutional official responsible for compliance with FERPA and is responsible for the following:

 

Implementation of policies and procedures to prevent unauthorized access to or disclosure of student education records (per the requirements set forth above)

 

Implementing and overseeing procedures to allow students to view their records as required under FERPA

 

Implementing and overseeing procedures for requiring waivers prior to dissemination of records to employers

 

Distribution of the Annual Notification of Student Rights to students, as well as the notification to students of their right to place a hold on the release of directory information

 

Gramm Leach Bliley Act

This law regulates the disclosure of non-public personal information by financial institutions. Specifically, the law protects consumers or customers who are "individuals obtaining financial products or services to be used primarily for personal, family or other household purposes." The responsibilities of the Associate Vice President of Enrollment Services and University Registrar (Registrar) with respect to the Act are as follows:

Data Security:

Appropriately safeguard all covered data, including social security number data and student financial information such as credit card information

Ensure sensitive customer information is transmitted over encrypted networks, and not request that customers send credit card numbers or Social Security Numbers over non-encrypted networks

Oversee any service providers who will have access to customer information, and request inclusion of an information security clause in relevant contracts with vendors

 

Payment Card Industry Data Security Standard (E-Commerce)

The  PCI DSS standards are contractual obligations imposed by credit card companies and require that the University protect consumers and cardholders against identity theft by enforcing best practice security standards.  The Registrar oversees and works with the Director of Enrollment Services, Business Systems, who is responsible for accepting credit card payments only in accordance with approved, PCI-compliant methods as determined by Technology Services and Treasury Management.

Bankruptcy Reform Act of 1978 as amended, Title 11 U.S.C. § 523(a)(8),

The Act and amendments prohibits the discharge of most student loans in bankruptcy when the loans were obtained from the government or non-profit higher educational institutions. There is an exception for undue hardship and for loans that became due more seven years before the filing of the petition. The seven-year exception was eliminated for cases commenced after October 1, 1998, the effective date of the Higher Education Amendments of 1998, and thus borrowers will not be able to discharge their debts to educational institutions under the seven-year exception. An institution may be affected by the automatic stay (11 U.S.C. § 362(d)(1)), while the bankruptcy action is proceeding, and this prohibits the withholding of student transcripts to obtain payment. This action is also prohibited if the debt is actually discharged. For more on the issue of debt collection and student loans, go to the U.S. Department of Education Web site at http://www.ed.gov/offices/OSFAP/DCS/ that contains a guide to defaulted student loans.  The Registrar oversees and works with the Director of Enrollment Services, Business Systems, who is responsible for ensuring that accounts of students who have filed for bankruptcy are not sent out for collections.

Tuition Payment Credit Reporting Requirements (26 U.S.C. § 6050S; 26 CFR 1.6050S-1 et seq.)

As an educational institution that receives payments of qualified tuition and related expenses, the University must furnish a statement to each individual for whom it is required to file an information return on or before January 31st of the year following the calendar year in which payments were received, or amounts billed, for qualified tuition and related expenses, or reimbursements, refunds, or reductions of such amounts were made.  The statements returns are intended to assist taxpayers and the Internal Revenue Service (IRS) in determining any education tax credit allowable as well as other tax benefits for higher education expenses. The reporting to both students and the IRS is accomplished by using Form 1098-T "Tuition Payments Statement". This form is filed with the IRS for each individual with respect to whom payments of qualified tuition and related expenses were received, or reimbursements or refunds of such expenses were made. The University does not have to file a 1098-T on a student when a refund is issued in an amount equal to or greater than the amount the student paid. The information reporting requirements of this section do not apply with respect to any individual who is a nonresident alien during the calendar year, unless the individual requests the institution or insurer to report. The institution is also not required to file a report for an individual who receives no academic credit, for students whose tuition and related expenses are covered by a formal billing arrangement between the institution and the student's employer, or for students whose tuition and related expenses are entirely waived or paid entirely with scholarships.

Colleges and universities that participate in the Perkins Loan Program, or operate their own institutional loan programs, must report student loan interest payments to the IRS. This is done on Form 1098-E which must be filed on or before February 28th or March 31st if filed electronically. The person making the payment must receive their statement by January 31st.

The Registrar oversees and works with the Director of Enrollment Services, Business Systems, who is responsible for collecting all necessary information from students for completion of the Forms 1098-T and 1098-E, and for sending the forms to both students and the IRS. Detailed guidance and specifics for this process are set forth in Tuition Payment Credit Reporting Requirements.

Voter Registration (Higher Education Amendments of 1998 as amended by the Higher Education Opportunity Act of 2008)

As part of its Program Participation Agreement, the University must make a good faith effort to distribute voter registration forms to each student in attendance, and may transmit the form electronically in order to meet the requirement. The Registrar is responsible for overseeing distributing of the forms.

Veterans Educational Assistance Act of 2008

Effective August 1, 2009, the Act expands educational benefits for military veterans.  The main provisions of the Act include funding 100% of a public four-year undergraduate education to a veteran who has served three years on active duty since September 11, 2001. The Act also provides the ability for the veteran to transfer benefits to a spouse or children after serving (or agreeing to serve) ten years.


Resources

Family Policy Compliance Office (FCPO), Department of Education

FERPA Awareness Training Modules

FERPA Publications, Videos and Web Tutorials (Office of General Counsel)

FERPA Q and A (Office of General Counsel)

FERPA Resources, Forms and Checklists (Office of General Counsel)

National Mail Voter Registration Form

Voter Registration Page (DC)

Related Policies

Collection of Student Address Information

Final Exam

Information Security and Assurance

Records and Transcripts

Registration: Undergraduate

Student Records