Conference Date Federal Update TRAINER U.S. Department of Education.

Conference

Date

Federal Update

TRAINERU.S. Department of Education

2

Breaking News! • 2017-2018 Processing Announcements

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

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

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

• 2017-2018 FAFSA will collect tax year 2015 income data• Reduces the use of estimated income and increases the use

of the Data Retrieval Tool (DRT)

More information coming soon. Stay tuned to IFAP!

3 9/14/15 Elec. Ann.

2016-2017 Processing Updates

PLACE HOLDER for 16/17 Updates

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5

FY 2012 3-Year Official National Cohort Default Rates

# of Schools

Borrower Default

Rate (%)

# of Borrowers Defaulted

# of Borrowers

Entered Repayment

# of Schools

Borrower Default

Rate (%)


# of Borrowers

Entered Repayment

# of Schools

Borrower Default

Rate (%)


# of Borrowers

Entered Repayment

Public 1,667 11.7% 301,453 2,563,157 1,637 12.9% 292,012 2,252,334 1,619 13.0% 250,661 1,922,773 Less than 2 yrs 148 12.2% 1,241 10,151 146 13.6% 1,196 8,750 139 16.5% 1,315 7,963 2-3 yrs 854 19.1% 173,628 905,058 841 20.6% 158,104 767,073 840 20.9% 125,764 599,467 4yrs(+) 665 7.6% 126,584 1,647,948 650 8.9% 132,712 1,476,511 640 9.3% 123,582 1,315,343Private 1,727 6.8% 73,747 1,083,328 1,712 7.2% 70,186 969,156 1,712 8.2% 72,347 879,269 Less than 2 yrs 49 22.4% 2,318 10,336 43 25.0% 1,644 6,567 41 21.8% 1,097 5,020 2-3 yrs 161 14.6% 6,193 42,274 161 12.0% 2,026 16,861 168 14.2% 2,305 16,217 4yrs(+) 1,517 6.3% 65,236 1,030,718 1,508 7.0% 66,516 945,728 1,503 8.0% 68,945 858,032Proprietary 2,294 15.8% 235,384 1,486,162 2,277 19.1% 288,126 1,500,812 2,187 21.8% 277,088 1,270,965 Less than 2 yrs 1,199 17.7% 33,393 188,549 1,177 20.6% 38,686 187,209 1117 20.9% 34,811 165,921 2-3 yrs 747 17.7% 62,650 353,777 762 19.8% 77,441 390,649 743 21.4% 71,853 334,459 4 yrs(+) 348 14.7% 139,341 943,836 338 18.6% 171,999 922,954 327 22.1% 170,424 770,585Foreign 431 3.3% 372 11,266 428 3.8% 403 10,488 432 4.6% 449 9,562Unclassified 2 0.0% 0 5 1 0.0% 0 3 1 0.0% 0 1TOTAL 6,121 11.8% 610,956 5,143,918 6,055 13.7% 650,727 4,732,793 5,951 14.7% 600,545 4,082,570

Fiscal Year 2010 OfficialFiscal Year 2011 OfficialFiscal Year 2012 Official

National Default Rates – FY 2012

• On September 28, 2015, the Department electronically distributed FY 2012 3-Year official cohort default rates to all eligible schools

• Please don’t forget to review your CDR data and appeal as appropriate within the required time frames– Time period for appeals begins on Tuesday, October 6, 2015

• Questions about default rates - contact [email protected] or call the Operations Performance Division Hotline at (202) 377-4259

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10

Counseling type Required for: When:

Entrance

First time subsidized or unsubsidized loan borrowers

First time graduate/professional student PLUS borrowers

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

Financial Awareness Counseling (FAC)

Not required

PLUS

PLUS Borrowers (graduate/ professional students and parents) who have an adverse credit history but whoObtain an endorserSatisfactorily document extenuating circumstances to the Department of Education

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

ExitStudent borrowers

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

TEACH Initial and Subsequent Counseling

TEACH Grant recipients Each year a student receives a TEACH Grant

TEACH Exit Counseling TEACH Grant recipients

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

11

12

Sequestration

13

Sequestration

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Sequestration

15

Interest Rates

• New rate structure applies to all loans first disbursed after June 30, 2013

• Annual fixed rates based on 10 Year T-Bill plus add-on

• Applies to loans first disbursed between July 1 and June 30

• Rate applies for the life of the loan

16

Interest Rates 2015-2016Effective for loans first disbursed on or after July 1, 2015:

Undergraduate Students - Sub and Unsub• 4.29% (last year’s Sub and Unsub was 4.66%)• Add-on of 2.05% with cap of 8.25%

•Graduate students – Unsubsidized Loans only• 5.84% (last year’s Grad Unsub – 6.21%)• Add-on of 3.60% with cap of 9.5%

•PLUS Loans (parent and grad/professional)• 6.84% (last year’s – 7.21%)• Add-on of 4.60% with cap of 10.5%

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

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

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

2015-16 Verification

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• The V4 and V5 tracking process in FAA Access that began in the 2014-15 processing year WILL CONTINUE for 2015-16.

• Schools need to select the proper award year for which they are providing results– 2014-15; 2015-16, etc.

V4/V5 Tracking Results – 2015-2016

https://faaaccess.ed.gov

V4/V5 Tracking Results – 2015-16

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

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

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

• changes to previously submitted Identity Verification Results must be updated within 30 days

2016-17 Verification – Overview

7

• Same data elements as for 2015-2016 award year

• Some modifications and clarifications to acceptable documentation

• In limited circumstances, an applicant’s Verification Tracking Group could change

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


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Verification Tracking Group changes:•Verification Tracking Group V3 (Child Support Paid) has been removed

• Applicants placed in V1, V4, V5, and V6 must still verify child support paid if reported on ISIR


24

Verification Tracking Group changes:•Applicants may be moved from previously assigned Groups V1, V4, and V6 to Verification Tracking Group V5

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

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


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

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

– The institution is not liable


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

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


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

– a copy of their Wage and Tax Statement (or equivalent documentation) for each source of employment income and

– a signed statement identifying all of the individual’s income and taxes

Verification Policy Updates

10

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

• Copy of all relevant W-2s• Signed statement that individual did not retain a copy

of his or her tax account information, and• Documentation from the IRS that indicates that the

individual’s tax account information cannot be located

• Child support paid• Removed a separation agreement or divorce decree

from acceptable documentation


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High School Completion Status •For V4 and V5, if institution successfully verified and documented applicant’s high school completion status for a prior award year, verification of high school completion status is not required for subsequent years•An institution may not accept as alternative documentation an applicant’s self-certification, nor a DD Form 214 Certificate

Identity/Statement of Educational Purpose •The valid government-issued photo identification used to verify an applicant’s identity must not have expired


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Victims of IRS tax-related identity theft must submit:

•Statement signed and dated by tax filer indicating they were victims of IRS tax-related identity theft and the IRS has been made aware of the tax-related identity theft; and

•A Tax Return DataBase View (TRDBV) transcript obtained from the IRS

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

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


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Individuals who filed an amended tax return must submit the following documents to the institution:

•an IRS Tax Return Transcript, or any other IRS tax transcript(s) that include all of the income and tax information required to be verified; and•a signed copy of the IRS Form 1040X that was filed with the IRS

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

October 2, 2015 Electronic Announcement

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

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

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

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For 2015-2016 award year

2015-2016 – Transcripts Unavailable Alternative documentation includes:

• Signed copy of relevant 2014 IRS tax return

AND

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

AND

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

AND

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

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NSLDS: Future Enhancements

Enrollment Reporting

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Display of historical Program-Level enrollment information on NSLDSFAP

Enrollment Submittal File Tracking

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Displays information regarding enrollment rosters and error acknowledgment files received by NSLDS

Enrollment Reporting

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• Enrollment Reporting Compliance Letters– Letters will be sent to schools not meeting

Enrollment Reporting requirements

– Based on Enrollment Statistics data

• Updated Enrollment Reporting Guide– Available late Summer 2015

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New Income-Driven Repayment Plan

• Revised Pay As You Earn (REPAYE) – Repayment plan with monthly payments that are equal to 10% of discretionary income, divided by 12.

Disclaimer: This information is subject to change as the regulation is under negotiation

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• Repayment Plans:– I5 = Borrowers in REPAYE – J5 = Borrowers that have been removed from REPAYE

and currently under a Post-REPAYE-Alternative-Fixed repayment plan

• Forgiveness Types:– R8 = Borrowers eligible for forgiveness under REPAYE

for undergrad loans after 20 yrs– R9 = Borrowers eligible for forgiveness under REPAYE

for undergrad and graduate loans, or just graduate loans after 25 yrs

REPAYE

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Payments from Federal Loan Servicers

• Late in 2015, NSLDS will begin to collect individual payment information made to federal loan servicers:

• NSLDS will collect and display payment information from federal loan servicers (includes Direct Loans and federally-serviced FFELP loans)

• NSLDS will also display the number of payments made that count toward Public Service Loan Forgiveness (PSLF) on NSLDS FAP and Student Access

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• Borrower Defense– Borrowers may be eligible for a Direct Loan

discharge if a school commits fraud or violates state law related to their loans or the educational service paid for.

– New discharge types coming soon

42

Changes in the Law

43

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

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

• Any type of institution may offer eligible career pathway programs

• No requirement to offer eligible career pathway programs

Guidance - GEN-15-09

“Grandfathered Students” Exception

44

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

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

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

Eligible Students

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

Education approved ATB test

• Completes at least 6 credit hours or 225 clock hours that are applicable toward a degree or certificate offered by the postsecondary institution

• Completes a State process approved by the Secretary• No State process has ever been sent for ED approval

Approved ATB Tests

46

Electronic Announcement – June 24, 2015•Newly approved ATB tests – effective July 1, 2015

– Wonderlic Basic Skills Test Verbal Forms VS-1/VS-2, Quantitative Forms QS-1/QS-2 – both paper and online

– Spanish Wonderlic Basic Skills Test Verbal Forms VS-1/VS-2, Quantitative Forms QS-1/QS-2 – both paper and online

• Effective November 1, 2015, only these two Spanish ATB tests are permitted for ATB purposes for Spanish speaking students

Approved ATB Tests

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Electronic Announcement – June 24, 2015

•Continuing ATB tests– CELSA Forms 1 and 2 & ACCUPLACER – ASSET, COMPASS AND COMPASS ESL

• eligible through 10/31/15

Please see the 6/24/15 EA for ATB passing scores, publisher contact information and a list of ATB tests

no longer approved.

Eligible Career Pathway Program

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• An eligible career pathway program (484 (d)(2)) must:• Concurrently enroll students in connected adult education and

eligible postsecondary programs;

• Provide students with counseling and supportive services to identify and attain academic and career goals;

• Provide structured course sequences that—

• Are articulated and contextualized; and

• Allow students to advance to higher levels of education and employment;

• Provide opportunities for acceleration for students to attain recognized postsecondary credentials, including degrees, industry relevant certifications, and certificates of completion of apprenticeship programs;


49

• An eligible career pathway program (484 (d)(2)) must:• Be organized to meet the needs of adults;• Be aligned with the education and skill needs of

the regional economy; and• Have been developed and implemented in

collaboration with partners in business, workforce development, and economic development


50

• Eligible career pathway programs contains 2 components: • an adult education component, and

• a Title IV eligible postsecondary program component


51

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

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

• Transition to postsecondary education and training; • Obtain employment

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


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

academic program


53

• An eligible career pathway program, as defined in section 484(d)(2) of the HEA, is not itself a TIV eligible program under 34 CFR 668.8 because it contains an adult education component that includes, by definition, coursework that is below the postsecondary level• An eligible career pathway program will never be submitted

to ED for approval• Will never appear on your ECAR

• The school must determine if a career pathway program meets the criteria as outlined in the law and GEN-15-09

• If necessary, must provide documentation to auditors and reviewers


54

Restrictions• May not include cost of the adult education

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

• May not pay for the cost of the adult education component using Title IV aid• only costs that can be included in COA are those

associated with the Title IV eligible postsecondary program component


55

Restrictions• Credit or clock hours associated with adult

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

eligible postsecondary program component is eligible for TIV aid within normal remedial limits

– 30 semester hours; 45 quarter hours; 900 clock hours


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• Career Pathway Program Definitions:• The definition of an eligible career pathway program under

section 484(d)(2) of the HEA may differ from definitions under the Workforce Innovation and Opportunity Act, and in other laws, including State and local laws

• A program that qualifies for funding under the Workforce Innovation and Opportunity Act or another law may not meet the definition of an eligible career pathway program in section 484(d)(2) of the HEA

• To provide Title IV aid to students under the ATB alternatives under the new law, an institution must ensure that its eligible career pathway program(s) meets the requirements under section 484(d)(2) of the HEA as described in GEN-15-09

Eligibility Timeframes

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• Student enrolled in an eligible career pathway program as of July 1, 2014, and who meets one of the ATB alternatives prior to July 1, 2014, may be awarded:

• Pell Grant, TEACH Grant, and Campus-Based aid beginning with 1st payment period of 14/15 in which student was enrolled

• DL can be awarded for entire loan period that includes 7/1/14

Eligibility Timeframes

58

• Student enrolled in an eligible career pathway program as of July 1, 2014, and who meets one of the ATB alternatives on or after July 1, 2014, may be awarded:

• Pell Grant, TEACH Grant, and Campus-Based aid beginning with payment period in which student meets ATB alternative

• DL can be awarded for the entire loan period that includes the date when student meets the ATB alternative

Regular Pell Grants

59

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

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

Limited Pell Grants

60

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

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

is $5,775 (non-ATB)

Limited Pell Grants

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

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

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

Limited Pell Grants

62

• IMPORTANT: Schools are responsible for determining student eligibility and the correct award amount for students who receive a Federal Pell Grant award under the Career Pathway Alternative Pell Grant Disbursement Schedules• At this time, COD does not contain these

schedules and there are no system edits on the Pell Grant award amount related to these schedules

7/9/15 Electronic Announcement

Pell Grant Determination

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• An institution must document its determination of whether a student qualifies for a Limited Pell Grant award or a Regular Pell Grant award for 15/16 and beyond• Could include documentation from NSLDS

showing receipt of TIV aid or a transcript from a previous school demonstrating student enrolled in an eligible program at a Title IV institution

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Additional Programs

65

• If a student completes a career pathway program and then enrolls in a regular TIV eligible academic program, the student will not be eligible for additional TIV funds UNLESS they now have a high school diploma or equivalent

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Gainful Employment - Regulations

67

• Notice of Proposed Rulemaking (NPRM)• Federal Register - March 25, 2014• OPE Website with discussions and materials

associated with GE negotiated rulemaking:• http://www2.ed.gov/policy/highered/reg/hearule

making/2012/gainfulemployment.html

• Final Federal Register - October 31, 2014• Effective date - July 1, 2015• http://ifap.ed.gov/fregisters/attachments/FR103114Final.pdf

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The HEA provides that to be Title IV eligible an educational program must be offered by:

Generally, all non-degree programs must lead to gainful employment

A public or non-profit postsecondary educational institution and leads to a degree; or

Any institution and “to prepare students for gainful employment in a recognized occupation”

Generally, all programs at for-profit institutions must lead to gainful employment

GE Programs

69

• At proprietary institutions, ALL programs (degree and nondegree) are GE Programs except for –• Preparatory coursework necessary for enrollment in

a Title IV eligible program

• Approved Comprehensive Transition and Postsecondary Programs for students with intellectual disabilities; and

• A limited number of bachelor degree programs in liberal arts if the institution has been regionally accredited since October 2007 and the program has been offered by the institution since January 2009

GE Programs

70

• At public institutions and not-for-profit institutions, all NONDEGREE programs are GE Programs except for:• Programs of at least two years in length designed to be fully

transferable to a bachelor’s degree program where the institution does not confer a credential upon completion of the coursework

• Approved Comprehensive Transition and Postsecondary Programs for students with intellectual disabilities

• Preparatory coursework necessary for enrollment in an eligible program; and

• Teacher certification programs where the institution does not award a credential

Gainful Employment Measure

71

• Debt-to-earnings (D/E) rates• Annual Earnings D/E rate• Discretionary Income D/E rate• Passing: Annual D/E < = 8% or Discretionary D/E < =

20%• Failing: Annual D/E > 12% or Discretionary > 30%• Zone: Annual D/E > 8% and < = 12% or

Discretionary D/E > 20% and <= 30%

71

Gainful Employment Results

72

• Program’s loses Title IV eligibility if:

• D/E measures – Fails in two out of three years

OR

• D/E measures - Fails or in the zone for four consecutive years

72

GE Reporting

73

• Reported all Title IV students by July 31, 2015• Report 2008-09 through 2013-14 award years• Programs with Medical and Dental Residencies

report 2007-08 through 2013-14 award years

• Report future award years by October after end of the award year• Report 2014 – 2015 Award Year by October 1,

2015

GE Data to Report

74

• Institutional, Program, Student Enrollment, and Student Financial Data – ONLY submit data on students enrolled in a GE

program

– ONLY submit data on Title IV aid recipients

– ONLY submit data for programs that exist as of 7/1/12• Schools must report data for GE programs that were

discontinued on or after July 1, 2012 and before July 1, 2015 for any of the award years 2008-2009 through 2013-2014, in which students received Title IV aid for enrollment in the programs

• 8/10/15 Electronic Announcement

Reporting – Students to include

10

• All Title IV students enrolled in GE Programs • A student enrolled in more than one GE

Program must be reported separately for each program

• A student who ‘stopped out’ and re-entered the same GE Program during the same award year must be reported separately for each enrollment

• A student who was enrolled in the same GE Program during multiple award years must be reported separately for each award year

GE Program Tracking

76

• Gainful Employment Program Tracking Web page (NSLDS)• Listed under the ORG Tab• Provides a listing of the GE programs ED records show the

institution offers• Shows whether the institution has reported to NSLDS the GE

information for any required programs

• Resources– NSLDS Gainful Employment User Guide, Chapter 4– “GE Program Detail Response Status Report” - provides GE data

institution has reported to NSLDS

GE Program Tracking List

• Displays a unique list of GE programs, from the various sources, for an institution

• Institutions can update• Available in August 2015

77

GE Program Tracking - Corrections

78

• GE EA #60 – September 4, 2015• GE programs listed were based in part on COD origination

information for 14-15 which indicated a program was GE• Many errors are program credential level code errors

• Errors must be corrected in NSLDS and COD accordingly• If Program Credential Level code in GE Program Tracking List

is not correct due to inaccurate COD reporting, select ‘I2’ (Program Was Not Title IV Eligible) for a status code

• Program Credential Level Code errors in COD can be corrected by sending maintenance record that contains updated values or by making appropriate updates to Program Credential Level codes online using COD Web site

Debt- to-Earnings Rate Calculation Process

Note: FSA Calculates & Validates each step before sending to schools

79

Certifications

80

GE electronic announcement #54 – June 11, 2015New PPAs executed on or after July 1, 2015 will have the new certifications incorporated into the PPA languageTIV schools that won’t execute a PPA between July 1, 2015 and December 31, 2015 must provide a Transitional Certification signed by CEO/President to [email protected]

Certifying each GE program meets all TIV eligibility criteria

Certifications

81

GE electronic announcement #54 – June 11, 2015After transitional certification provided, adding/revising GE program data on E-App that does not result in a new PPA, will need to provide a new certification each time E-App is updatedCertification processing instructions and sample certification language are attached to the GE EA #54Questions/concerns, please email - [email protected]

Disclosures Under New Final Rules

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• Through December 31, 2016, current disclosure requirements remain in effect• Occupations; Normal time to complete program; On-time

graduation rate for completers; Tuition & fees, books & supplies, room & board; Placement rate for completers (as determined by State or Accreditor methodology); and Median loan debt

• Institutions must comply with new disclosure requirements (October 31, 2014 Final Rules) beginning January 1, 2017•ED to conduct consumer testing and hold focus groups to determine new disclosure requirements and prepare new disclosure template

GE Disclosure Resources

28

• GE Disclosure Template http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/negreg-summerfall.html– Requirement– Template application– Quick start guides – Bulk data file upload tool– Help desk: (855) 359-3697, [email protected]

Important Dates

84

GE Resources

85

• GE Information Page on IFAP – Federal Register Notices; DCLs; Electronic Announcements;

FAQs; Webinars; Presentations; Resources

http://www.ifap.ed.gov/GainfulEmploymentInfo/indexV2.html

• NSLDS Gainful Employment User Guide• GEN-15-12 – GE regulatory overview • ANN-15-01 - Recorded Webinar – GE Reporting

send questions to [email protected]

86

Negotiated Rulemaking

87

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

– Procedures for a borrower to establish defense to repayment– Criteria the Department will use to identify acts/omissions of an institution that constitute defenses to

repayment– Standards and procedures that ED will use to determine school liability for amounts based on borrower

defenses– Effect of borrower defenses on school capability assessments

•Two public Hearings– 9/10/15 – Washington D.C.– 9/16/15 – San Francisco

Experimental Site Initiative

88

• Federal Register Notice – 8/3/15– Provide Pell Grant funding to otherwise eligible students who are incarcerated

in Federal or State penal institutions

– Partner with Federal/State correctional facilities to offer TIV eligible programs to incarcerated students

– Prisoners must be eligible for release and priority given to prisoners who likely to be released within five years of enrollment in the educational program

– Must apply to participate by October 2, 2015 to receive priority consideration

Experimental Sites Initiative

89

Federal Register Notice – to be published Dual Enrollment

Permits otherwise-eligible high school students to receive Pell Grants while concurrently enrolled in Title IV-eligible postsecondary programs.

Watch for more information coming Fall, 2015

Program Integrity “Proposed” Rules

90

• Notice of Proposed Rule-Making (NPRM) published on May 18, 2015

• Comments must have been received by July 2, 2015

• Main Topics:– Cash Management– Repeat Coursework– Clock-to-Credit Conversion (“clock hour program

definition”)


91

• Cash Management• Establish two different types of arrangements between institutions and financial

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

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

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

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

• Mitigate fees incurred by student aid recipients


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• Repeat Coursework• Allow institution offering term-based programs to count, for enrollment,

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

• Clock-to-Credit Hour Conversion • Streamline conversion by removing provisions where a State/Federal

approval or licensure action cause a program to be measured in clock hours

Final Rules – Direct PLUS Loans

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• NPRM published 08/08/14

• Final Rule published 10/23/14

• Federal Register Notice published 1/14/15 – New PLUS loan regulations

will be early implemented early as of March 29, 2015

“Charged Off” and “In Collection”

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• Charged off – a debt that a creditor has written off as a loss, but that is still subject to collection action

• In collection – a debt that has been placed with a collection agency by a creditor or that is subject to more intensive efforts by a creditor to recover amounts owed from a borrower who has not responded satisfactorily to the demands routinely made as part of the creditor’s billing procedures

Adverse Credit History

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• One or more debts with total outstanding balance greater than $2,085 that are - – 90 or more days delinquent as of date of credit report; OR– have been placed in collection or charged off during two

years preceding date of credit report

OR• Subject of default, bankruptcy discharge, foreclosure,

repossession, tax lien, wage garnishment or write-off of a debt under title IV during the five years preceding date of credit report

Required PLUS Loan Counseling

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• PLUS loan counseling required for borrowers who have adverse credit history and successfully:– document extenuating circumstances; OR– obtain an endorser (cannot have an adverse credit history)

• Counseling will include:– information on borrowers’ current loan indebtedness– provide estimated loan repayment amounts– describe ways to avoid delinquency and default– provide additional financial aid literacy information– effective March 29, 2015 in StudentLoans.gov

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Voluntary PLUS Loan Counseling

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• Enhance consumer information for PLUS applicants

• Items included:– Calculator to allow borrowers to estimate future requirement

monthly payment amount under various repayment plans

– Tools to assist borrowers in determining how factors such as taking out additional PLUS loans or deferring repayment affect required monthly repayment and total amount repaid

– Available repayment plans for student/parent PLUS borrowers

– Budgeting information for minimum amounts needed

– Strategies for avoiding delinquency and default

• Studentloans.gov (same link as required counseling)

Validity of Credit Check

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• Credit check indicating no adverse credit history will remain valid for 180 days

• Any action that would normally trigger a credit check will not do so if prior credit check with no adverse credit obtained within past 180 days

• Effective March 29, 2015

Performance of PLUS Loans

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• Will collect and publish (where appropriate) information about performance of parent and student PLUS loans, including – default rate information based on credit

history characteristics of PLUS loan applicants and

– individual institutional default rates

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Dear Colleague Letters

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

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

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

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

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

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


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• GEN-15-18 – Protecting Student Information• Reminds institutions of higher education and their third-party

servicers of continuing obligations to protect data used in all aspects of administering Title IV FSA programs

• Ensure that all FSA applicant information is protected from access by or disclosure to unauthorized personnel according to several state and federal laws.

• Provides list of Industry standards and best practices

• Gramm-Leach-Bliley Act requires schools to ensure the security and confidentiality of customer records and information

• Institution remains liable for any action by its third-party servicers


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• GEN-15-16 – Unaccompanied Homeless Youth Decisions• Reviews basic definitions, the application process, FAA

protocols and possible documentation • Remind institutions that they should limit any inquiry to whether

the applicant has been determined to be an unaccompanied youth who is homeless, or at risk of being homeless, rather than the reasons for the applicant’s homelessness (why)

• If student unable to answer “yes” to the homeless youth dependency questions, is determined to be an unaccompanied youth who is homeless or at risk of being homeless by the FAA, then the FAA must submit a FAFSA “correction” using the “Homeless Youth Determination” flag


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• GEN-15-15 – Annual Security Report Changes– Provides summary of significant changes including:• Maintain statistics about the number of incidents of dating

violence, domestic violence, sexual assault, and stalking • “Clery geography” includes areas within the patrol

jurisdiction of the campus police or the campus security department

• Definitions of dating violence, domestic violence, sexual assault and stalking

• Updated crime definitions under the FBI’s Uniform Crime Reporting program


106

• GEN-15-15 – Annual Security Report Changes• Provides summary of significant changes including:

• Revised categories of bias for the purposes of Clery Act hate crime reporting to add gender identity and to separate ethnicity and national origin into separate categories

• Develop primary educational programs and on-going campaigns to promote the awareness of dating violence, domestic violence, sexual assaults and stalking

• Develop descriptions of safe bystander intervention options, risk reduction information and the definition of consent in reference to sexual activity


107

• GEN-15-15 – Annual Security Report Changes• Provides summary of significant changes including:

• Process to remove and document “unfounded” crimes

• Clear procedures for handling institutional disciplinary actions in cases of alleged dating violence, domestic violence, sexual assault or stalking which include:

– proceedings be conducted by officials who receive at least annual training on issues related to dating violence, domestic violence, sexual assault and stalking and on how to conduct investigations and hearings that protect the safety of the victims and promote accountability


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• GEN-15-15 – Annual Security Report Changes• To ease the burden on institutions and to help ensure

accuracy, the Department will NOT collect data on incidents of dating violence, domestic violence, sexual assault, and stalking for the 2013 calendar year

• Required to report contact information of their lead Title IX coordinator in 2015 Campus Safety and Security Survey

• Nothing in the Clery Act, as amended by VAWA, alters or changes an institution’s obligations or duties under Title IX


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• GEN-15-10 – State Authorization• Final regulations were effective July 1, 2011

• ED provided for delays of implementation date (34 CFR 600.9(a) and (b)) so long as the State was establishing an acceptable authorization process effective by July 1, 2015

• The stay of these regulations ended June 30, 2015

• These regulations do not apply to distance programs, only to physical locations of an institution of higher education • If state officials have concerns - contact Sophia McArdle - (202)

219-7078; [email protected]• If school officials have concerns - contact your school participation

division


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GEN-15-08 – Citizenship and Immigration Documentation•Process through which a school and student can confirm student’s citizenship or immigration status when student is unable to appear in person at school

– Confirmation of Eligible Noncitizen Status• If unable to provide original documentation (e.g. distance

education), school policy may permit students to photocopy, scan, or image immigration documents, and submit electronic images or paper copies to school

• Subsequently, the school must initiate paper-based secondary confirmation process using the G-845 form once documents received from noncitizen student


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GEN-15-08 – Citizenship and Immigration Documentation

• Confirmation of U.S. Citizenship or U.S. National Status

• If unable to provide original documentation (e.g. distance education), school policy may permit students to photocopy, scan, or image citizenship documents, and submit electronic images or paper copies to school for confirmation

• NOTE: the G-845 secondary confirmation form is never used to confirm a student’s status as a U.S. citizen or national


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GEN-15-08 – Citizenship and Immigration Documentation• Photocopying or Imaging

• Reproduction of these documents is lawful for limited purpose of applying for Title IV aid

• A school may provide additional guidance on how (e.g. time, place, and media) student should submit photocopies or other images of his or her documentation

• If the school chooses to allow a student to submit a hard copy or electronic image of an original document, school should have a process in place to ensure that a student is submitting an exact copy, such as an affidavit

– a sample copy of an affidavit is attached to the DCL


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GEN-15-06 – Loan Counseling Requirements/Flexibilities

•Series of Q & As designed to discuss the statutory and regulatory requirements for entrance counseling as well as institutions’ flexibility to augment that counseling

•Two main regulatory premises:– Once borrower has completed required entrance counseling,

either at current institution or at previous institution, borrower cannot be required to participate in any subsequent counseling as a condition of receiving Direct Loans

– Borrower makes the decision of whether to borrow and how much to borrow (up to annual and aggregate limits), not the institution - except an institution may, on a case-by-case basis, deny or reduce a Direct Loan (34 CFR 685.301(a)(8))


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GEN-15-06 – Loan Counseling Requirements/Flexibilities

•For 1st-time borrowers required to go through entrance counseling, a school may:

– Add additional content, including tests or worksheets– Require attendance at workshops/presentations

•However, the additional information or steps cannot unreasonably impede the student from obtaining their loan in a timely manner

•A school may, on a voluntary basis, provide additional information beyond entrance counseling to certain groups of students as long as not discriminatory


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GEN-15-05 – 2015-16 Unusual Enrollment History Flag•2015-2016 UEH Flag has expanded to consider–

– An applicant’s prior receipt of, in addition to a Federal Pell Grant, a Federal Direct Loan (not including Direct Consolidation Loans or parent PLUS Loans)

– The prior four, instead of three, award years • For 2015-2016, UEH Flag evaluation includes 2011-2012,

2012-2013, 2013-2014, and 2014-2015 award years

•A school may self-select a student for UEH (not selected by ED) if suspect enrollment problems

– Self-selected students treated as if have UEH 3 flag

GEN-13-09 provides full institutional resolution guidance


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GEN-15-03 – Federal Perkins Program•Barring any Congressional action, the authority to make Perkins loans to new borrowers will end September 30, 2015

– If prior to October 1, 2015, school makes the first disbursement of a Federal Perkins Loan to a student for the 2015-2016 award year, school may make any remaining disbursements of that 2015-2016 loan after September 30, 2015

Series of Perkins wind-down Q & As available under the “Hot Topics” area of IFAP.ed.gov (upper right-hand corner)


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GEN-15-03 – Federal Perkins Program•Narrow “grandfathering” provision allows schools to make Perkins Loans to certain students through 9/30/2020, if:

– Student received at least one Perkins Loan disbursement on or before 6/30/15 (2014-2015 award year or earlier)

– Student enrolled at same institution where the last Perkins Loan disbursement was received

– Student enrolled in same academic program for which student received his or her last Perkins Loan disbursement

• first four digits of the program’s CIP code are identical• Applies to undeclared once academic program chosen

– Perkins Loan can be made only after student awarded all Direct Subsidized Loan aid for which student is eligible


118

GEN-14-23 – Title IV aid and competency-based education (CBE) with current statutory/regulatory rules

• Distinction between competency-based education in direct assessment programs and regular credit-hour programs

•ED established e-mail address for competency-based education questions: [email protected]•Currently have 3 experiments related to competency-based education and direct assessment programs

• For more information contact - [email protected]

•Schools interested in developing a direct assessment program should also review DCL GEN-13-10


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GEN-14-23 – Title IV aid and CBE•16 Q & As to help address school questions about -

• Distinction between credit hour CBE and direct assessment; • Requirements for establishing credit hour equivalencies in

direct assessment programs; • Requirements for regular and substantive interaction between

students and faculty; • Prohibitions on paying Title IV aid for credit earned through

prior learning assessments; • Satisfactory academic progress; • Return of Title IV Funds provisions; and • Accrediting agencies’ roles in reviewing CBE programs


120

GEN-14-22 –Title IV aid and apprenticeship programs•Apprenticeship is a training system that combines job-related instruction with structured on-the-job learning experiences•If apprenticeship is part of academic program that participates in Title IV programs, school may provide aid to an eligible student, including the apprenticeship portion of the program•An institution may use its Federal Work-Study (FWS) Program funds to pay the training wages for otherwise eligible FWS students employed as apprentices, even when apprenticeship is not part of the student’s eligible academic program•Under FWS JLD program, an institution, or group of institutions, may use a portion of FWS Federal allocation to locate and develop off-campus apprenticeship opportunities for students


121

GEN-14-22 –Title IV aid and apprenticeship programs• Unless restricted by accreditation or state, there are no limits

on the percentage of the program that may consist of on-the-job training, as long as the training is provided by the institution

• Report to ED locations where 50% or more of an academic program is provided, including on-the-job training component

• If entity other than institution provides on-the-job training, that component must be 25% of the program or less, or, with specific permission of institution's accrediting agency, over 25% but less than 50% of the program

• In "contracting-out" situations, institution must enter into a written arrangement with entity providing on-the-job training


122

GEN-14-21 – Pell Grant eligibility for incarcerated students • Clarifies students confined/incarcerated in locations not

Federal or State penal institutions, like juvenile justice facilities, and meet eligibility criteria, are eligible for Pell

• Juvenile justice facilities are NOT Federal or State penal institutions for Pell purposes regardless of what gov’t entity operates or has jurisdiction over the facility, including Federal or State government

• Students confined in juvenile justice facilities after being adjudicated delinquent are considered to be “incarcerated”

• Pell eligibility applies to students in juvenile justice facilities regardless of age, type of sentence, length of sentence, and whether adjudicated as a juvenile or convicted as an adult

Electronic Announcements

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9/21/15 – New Perkins Loan Assignment System (PLAS)– PLAS is now available at https://efpls.com

•Perkins electronic processing:– Submit multiple loans as a “batch file” or submit individual

loans

– Securely upload supporting documentation (prom notes, etc.)

– Search, view, and edit submitted loan assignment information

– View Perkins reports of accepted/rejected loans for assignment

•PLAS User Access Form and instructions, along with a PLAS User Guide is available at https://efpls.com

•An overview of the PLAS user access process is attached to the 9/21/15 EA


124

9/8/15 – Clery Act 3rd Party Certifications•An institution is not required or expected to have any kind of Clery Act certification to comply with the Clery Act or the Department’s implementing regulations

•Moreover, we do not give any weight to any such certification if we review an institution’s compliance with the Clery Act


125

7/9/15 – Student Eligibility Codes in COD•Provided a chart that outlined which eligibility codes to use in COD for students with high school diplomas or equivalents and which codes to use for students qualifying for Title IV aid under ability-to-benefit (ATB)

•IMPORTANT: Schools are responsible for determining student eligibility and the correct award amount for students who receive a Federal Pell Grant award under the Career Pathway Alternative Pell Grant Disbursement Schedules

– COD does not contain these schedules and there are no system edits on the Pell Grant award amount related to these schedules


126

7/1/15 – Blue Book•ED no longer publishing The Blue Book (manual of Title IV administrative guidance for fiscal officers)

•All essential guidance from The Blue Book will be placed in the FSA Handbook

6/29/15 – G-845 Form•A new G-845 Form with an expiration date of 5/31/18 must now be used to request verification from DHS-USCIS of an applicant's eligible non-citizenship status

•The new G-845 Form and application instructions have been updated in the 15/16 FSA HDBK Vol. 1, Chapter 2

127

Training

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• 2015 FSA Training Conference • Tuesday, December 1 –

Friday, December 4, 2015• Mandalay Bay, Las Vegas,

Nevada• Conference and lodging

registration is open!• fsaconferences.ed.gov

(right-hand side of IFAP website)

Training

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• FSA E-Training Website - fsatraining.info– Online training modules (e.g., Institutional Eligibility;

Completing FISAP; Consumer Information, R2T4)

• 2014 FSA Training and 2015 ED NASFAA Conference presentations• fsaconferences.ed.gov

• Past FSA presentations in audio and video format• http://ifap.ed.gov/ifap/ifapMedia.jsp

• Topics include – GE, NSLDS Enrollment Reporting and PLUS Loan Adverse Credit History changes

Contacts

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• “City” School Participation Division• Main Number: phone number• IIS – phone number• IIS - phone number

• “City” Training Officers• NAME – phone number• NAME – phone number

• Email – [email protected]

Department of Education Contacts

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Research and Customer Care [email protected]

Reach FSA855.FSA.4FAA -- 1 number to reach 10 contact centers!

Campus Based Call Center eZ-AuditCOD School Eligibility Service GroupCPS/SAIG Foreign Schools Participation DivisionNSLDS Research and Customer Care CenterG5 Nelnet Total & Permanent Disability

Team

Questions?

Contact me with follow-up questions about this session:Trainer Name- Federal Training Officer

[email protected]; phone number

132

Training Feedback

133

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

•Go to insert individual TO survey link– Evaluation form is specific to Trainer Name

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

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

Conference Date Federal Update TRAINER U.S. Department of Education.

Documents

sequestration slide

department of education

eligible program slide

student borrowers graduate

prior year

national default rates

default rates contact

time subsidized