1. No category

Federal
Update
Conference
Date
TRAINER
U.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
4
5
FY 2012 3-Year Official National Cohort Default Rates
Fiscal Year 2012 Official
Fiscal Year 2011 Official
Fiscal Year 2010 Official
# of
Borrower
# of
# of
# of Borrower
# of
# of
# of Borrower
# of
Schools Default Borrowers Borrowers Schools Default Borrowers Borrowers Schools Default Borrowers
Rate
Defaulted Entered
Rate
Defaulted
Entered
Rate
Defaulted
(%)
Repayment
(%)
Repayment
(%)
Public
Less than 2 yrs
2-3 yrs
4yrs(+)
Private
Less than 2 yrs
2-3 yrs
4yrs(+)
Proprietary
Less than 2 yrs
2-3 yrs
4 yrs(+)
Foreign
Unclassified
TOTAL
1,667
148
854
665
1,727
49
161
1,517
2,294
1,199
747
348
431
2
6,121
11.7%
12.2%
19.1%
7.6%
6.8%
22.4%
14.6%
6.3%
15.8%
17.7%
17.7%
14.7%
3.3%
0.0%
11.8%
301,453
1,241
173,628
126,584
73,747
2,318
6,193
65,236
235,384
33,393
62,650
139,341
372
0
610,956
2,563,157
10,151
905,058
1,647,948
1,083,328
10,336
42,274
1,030,718
1,486,162
188,549
353,777
943,836
11,266
5
5,143,918
1,637
146
841
650
1,712
43
161
1,508
2,277
1,177
762
338
428
1
6,055
12.9%
13.6%
20.6%
8.9%
7.2%
25.0%
12.0%
7.0%
19.1%
20.6%
19.8%
18.6%
3.8%
0.0%
13.7%
292,012
1,196
158,104
132,712
70,186
1,644
2,026
66,516
288,126
38,686
77,441
171,999
403
0
650,727
2,252,334
8,750
767,073
1,476,511
969,156
6,567
16,861
945,728
1,500,812
187,209
390,649
922,954
10,488
3
4,732,793
1,619
139
840
640
1,712
41
168
1,503
2,187
1117
743
327
432
1
5,951
13.0%
16.5%
20.9%
9.3%
8.2%
21.8%
14.2%
8.0%
21.8%
20.9%
21.4%
22.1%
4.6%
0.0%
14.7%
250,661
1,315
125,764
123,582
72,347
1,097
2,305
68,945
277,088
34,811
71,853
170,424
449
0
600,545
# of
Borrowers
Entered
Repayment
1,922,773
7,963
599,467
1,315,343
879,269
5,020
16,217
858,032
1,270,965
165,921
334,459
770,585
9,562
1
4,082,570
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) 3774259
9
Counseling type
Entrance
Financial Awareness
Counseling (FAC)


Required for:
First time subsidized or
unsubsidized loan borrowers
First time graduate/professional
student PLUS borrowers
Not required
PLUS Borrowers (graduate/
professional students and parents)
who have an adverse credit history
but who
 Obtain an endorser
 Satisfactorily document
extenuating circumstances to the
Department of Education
PLUS
Exit
Student borrowers
TEACH Initial and
Subsequent
Counseling
TEACH Exit
Counseling
10
When:
Prior to receiving funds the first
time a student borrows as an
undergraduate or
graduate/professional student
Each year the borrower requests
a PLUS loan and has an adverse
credit history.
When student borrowers
graduate, leave school, or drop
below half-time enrollment
TEACH Grant recipients
Each year a student receives a
TEACH Grant
TEACH Grant recipients
When TEACH Grant recipient
leaves school, drops below halftime enrollment, or leaves the
11
Sequestration
12
Sequestration
13
Sequestration
14
15
Interest Rates
• New rate structure applies to all loans
first disbursed after June 30, 2013
• Annual fixed rates based on 10 Year TBill 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 2015-2016
Effective 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%
17
18
2015-16 Verification
• 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, 2014
GEN-14-11 published June 30, 2014
EA November 24, 2014 – Suggested Text
19
V4/V5 Tracking Results – 2015-2016
• 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.
https://faaaccess.ed.gov
20
V4/V5 Tracking Results – 2015-16
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 first
request to the student to submit the required V4 or V5
identity and high school completion documentation
•
21
changes to previously submitted Identity Verification
Results must be updated within 30 days
2016-17 Verification – Overview
• 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!
7
2016-17 Verification
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
23
2016-17 Verification
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
24
2016-17 Verification
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
25
2016-17 Verification
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
26
2016-17 Verification
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
27
Verification Policy Updates
• 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
10
Verification Policy Updates
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
29
Verification Policy Updates
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
30
Verification Policy Updates
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
31
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
For 2015-2016 award year
32
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
•
33
Completed and signed IRS Form 4506 T-EZ or 4506-T listing
institution as third party – only send to IRS if doubt accuracy
NSLDS:
Future Enhancements
Enrollment Reporting
Display of
historical
Program-Level
enrollment
information on
NSLDSFAP
35
Enrollment Submittal File Tracking
Displays
information
regarding
enrollment rosters
and error
acknowledgment
files received by
NSLDS
36
Enrollment Reporting
• 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
37
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.
Eligible Loans
Non-Eligible Loans
• Direct Loan
• Defaulted Loans
• Direct/Federal Parent PLUS
• Consolidation Loan that repaid:
• Direct/Federal Parent PLUS Loan
Disclaimer: This information is subject to change
as the regulation is under negotiation
38
REPAYE
• 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
39
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
40
New Discharge
• 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
41
42
Changes in the Law
• 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
43
“Grandfathered Students” Exception
• 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
44
Eligible Students
• 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
45
Approved ATB Tests
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 VS1/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
46
Approved ATB Tests
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.
47
Eligible Career Pathway Program
• 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;
48
Eligible Career Pathway Program
• 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
49
Eligible Career Pathway Program
• Eligible career pathway programs
contains 2 components:
• an adult education component, and
• a Title IV eligible postsecondary
program component
50
Eligible Career Pathway Program
• 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
51
Eligible Career Pathway Program
• 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
52
Eligible Career Pathway Program
• 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
53
Eligible Career Pathway Program
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
54
Eligible Career Pathway Program
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
55
Eligible Career Pathway Program
• 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
56
Eligibility Timeframes
• 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
57
Eligibility Timeframes
• 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
58
Regular Pell Grants
• 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
59
Limited Pell Grants
• 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)
60
Limited Pell Grants
• 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
61
Limited Pell Grants
• 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
62
7/9/15 Electronic Announcement
Pell Grant Determination
• 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
63
64
Additional Programs
• 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
65
66
Gainful Employment - Regulations
• 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
67
The HEA provides that to be Title IV eligible
an educational program must be offered by:
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”
68

Generally, all nondegree programs
must lead to gainful
employment

Generally, all
programs at for-profit
institutions must lead
to gainful employment
GE Programs
• 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
69
GE Programs
• 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
70
Gainful Employment Measure
• 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
71
Gainful Employment Results
• 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 72
GE Reporting
• 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
73
GE Data to Report
• 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 20132014, in which students received Title IV aid for
enrollment in the programs
• 8/10/15 Electronic Announcement
74
Reporting – Students to include
• 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
10
GE Program Tracking
• 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
76
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
• 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
78
Debt- to-Earnings Rate Calculation Process
Note: FSA Calculates & Validates each step before sending to schools
79
Certifications
GE electronic announcement #54 – June 11, 2015
 New PPAs executed on or after July 1, 2015 will
have the new certifications incorporated into the PPA
language
 TIV 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
80
Certifications
GE electronic announcement #54 – June 11, 2015
 After 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 updated
 Certification processing instructions and sample
certification language are attached to the GE EA
#54
 Questions/concerns, please email [email protected]
81
Disclosures Under New Final Rules
• 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
82
GE Disclosure Resources
• GE Disclosure Template
http://www2.ed.gov/policy/highered/reg/he
arulemaking/2009/negreg-summerfall.html
– Requirement
– Template application
– Quick start guides
– Bulk data file upload tool
– Help desk: (855) 359-3697, [email protected]
28
Important Dates
84
GE Resources
• 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]
85
86
Negotiated Rulemaking
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
87
Experimental Site Initiative
• 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
88
Experimental Sites Initiative
 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
89
Program Integrity “Proposed” Rules
• 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”)
90
Program Integrity “Proposed” Rules
• 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
91
Program Integrity “Proposed” Rules
• 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
92
Final Rules – Direct PLUS Loans
• 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
93
“Charged Off” and “In Collection”
• 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
94
Adverse Credit History
• 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
95
Required PLUS Loan Counseling
• 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:
–
–
–
–
–
96
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
97
Voluntary PLUS Loan Counseling
• 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)
98
Validity of Credit Check
• 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
99
Performance of PLUS Loans
• 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
100
101
Dear Colleague Letters
• 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
102
Dear Colleague Letters
• 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
103
Dear Colleague Letters
• 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
104
Dear Colleague Letters
• GEN-15-15 – Annual Security Report Changes
– Provides summary of significant changes including:
•
•
•
•
105
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
Dear Colleague Letters
• 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
106
Dear Colleague Letters
• 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
107
Dear Colleague Letters
• 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
108
Dear Colleague Letters
• 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
109
Dear Colleague Letters
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
110
Dear Colleague Letters
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
111
Dear Colleague Letters
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
112
Dear Colleague Letters
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))
113
Dear Colleague Letters
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
114
Dear Colleague Letters
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
115
Dear Colleague Letters
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)
116
Dear Colleague Letters
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
117
Dear Colleague Letters
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 competencybased 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
118
Dear Colleague Letters
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
119
Dear Colleague Letters
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
120
Dear Colleague Letters
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-thejob 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
121
Dear Colleague Letters
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
122
Electronic Announcements
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
123
Electronic Announcements
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
124
Electronic Announcements
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
125
Electronic Announcements
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
126
127
Training
• 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)
128
Training
• 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
129
Contacts
• “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]
130
Department of Education Contacts
Research and Customer Care Center
800.433.7327
[email protected]
Reach FSA
855.FSA.4FAA -- 1 number to reach 10 contact centers!
Campus Based Call Center
COD
CPS/SAIG
NSLDS
G5
131
eZ-Audit
School Eligibility Service Group
Foreign Schools Participation Division
Research and Customer Care Center
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
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]
133