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Ask a Fed: GE, Modules, State Authorization, and More

December 21, 2016

Federal Training Officer David Bartnicki recently provided these updates:

Student Transfers from Closed Schools

We continue to receive lots of questions from schools accepting students who have transferred from a closed school especially around the topic of closed school loan discharges. ED recently posted some additional guidance around some of the specific criteria that we review when considering whether or not to approve a closed school discharge. Some of the highlights include –bartnicki

A number of factors may be relevant in making a determination of comparability of a program of study, including:

  • The academic or professional nature of the two programs;
  • The similarity in course requirements;
  • The treatment of transfer credits by the institution accepting the credits (for example: as general education credits or electives, or as credits toward completion of the core program);
  • The disposition of a state approving agency or accrediting agency on the comparability of the programs.

Factors that indicate a borrower is completing a comparable educational program “by any other comparable means” include, but are not limited to, the receiving school evaluating the borrower’s competencies through testing or interviews that translate to credit or steps toward completion of core credits for the comparable program.

For more information please review the December 7, 2016 electronic announcement.  

Accrediting Council for Independent Colleges and Schools (ACICS)

On December 12, 2016, the Secretary upheld the Senior Department Official decision and the recommendations of NACIQI and ED staff to cease recognition of ACICS. His decision is considered final and officially starts an 18-month timeframe for institutions to find another accreditor in order to continue participating in federal student aid programs.

For schools currently accredited by ACICS, please review the December 13, 2016 electronic announcement and information located at There are several adjustments automatically happening to ACICS schools from a Title IV perspective and many steps a school must take to ultimately remain TIV eligible in the future. Any specific Title IV eligibility questions should be directed to your regional school participation team.

Gainful Employment

In a recent electronic announcement dated December 16, 2016, the Department indicated that the 2017 GE Template is not expected to be released until the latter part of this coming January. Once the Department releases the 2017 GE Disclosure Template, institutions will have at least 60 days to be in compliance with the regulatory posting and dissemination requirements. In a future Electronic Announcement, we will provide notification that the 2017 GE Disclosure Template is available for use and indicate the deadline date by which institutions will be expected to post the new template to the GE Program’s website, provide the template in all promotional materials for the program, and provide prospective students with the template (via hand-delivery or email).

Please note that separate from the disclosures, once a school has received a Notice of Determination from ED (due to final GE rates) that a program could become ineligible, the school must provide a warning to its GE program students and prospective students no later than 30 days after the institution received the Secretary’s Notice of Determination.

In addition, ED is clarifying that the 2017 GE Disclosure Template must also be distributed to prospective students as a separate document (once available) before the student signs an enrollment agreement, completes registration, or makes any financial commitment to the institution. The disclosure template may be provided by hand-delivering (individually or as part of a group presentation) it to the prospective student, or by sending it to the primary email address used by the institution for communicating with that student, ensuring that the disclosure template is the only substantive content in the email.

For more detailed information please read the December 16, 2016 electronic announcement.

State Authorizations

Final regulations for state authorizations were posted in a final federal register dated December 19, 2016. Please note that these regulations become effective July 1, 2018. Highlights include:

  • Multiple Routes to State Authorization for Distance Education: The final regulations require institutions offering distance education or correspondence courses to be authorized by each State in which the institution enrolls students, if such authorization is required by the State. The regulation recognizes authorization through a state’s participation in a State authorization reciprocity agreement, as long as the agreement does not prevent a state from enforcing its own laws.
  • State Complaint Process Documentation: The final regulations require institutions to document the state process for resolving student complaints regarding distance education or correspondence courses in States in which the institution enrolls students.
  • Disclosure Requirements: The final regulations mandate certain public and individualized disclosures to enrolled and prospective students in distance education or correspondence courses, including the disclosure of adverse actions taken against the institution, the institution’s refund policies, and whether each program meets applicable state licensure or certification requirements. The regulation also requires institutions’ to explain to students the consequences of the student moving to a state where the institution is not authorized, which could include loss of eligibility for federal student aid.
  • Branch Campuses or Additional Locations in a Foreign Location Authorization: The final regulations make clear that foreign branch campuses or additional locations be authorized by the appropriate foreign government agency and, if at least half of a program can be completed at the foreign location or branch campus, be approved by the accrediting agency and reported to the state where the main campus is located.

Please review the 12/19/16 federal register for the complete regulations, along with school comments and ED discussions in the preamble –

R2T4 and Modules

Policy has recently clarified some guidance for the training officers based upon some school questions that I wanted to share with my SASFAA colleagues.

Once a student attends a module within a term, they are considered to be in a module setting throughout the entire term even if they later drop the module and are only enrolled in full-term courses.

In a case where a student is only enrolled in module 1 and completes that module, then during the time between modules adds and then drops a course in a subsequent module before ever attending it, the student would be considered to have simply completed the period and no R2T4 calculation would be required. If the student had actually started the second module and then dropped the course, R2T4 would apply and it would include all days in modules 1 and 2.

Abbreviated Loan Periods

I have gotten a few questions on awarding loans during an abbreviated loan period (occurs with certain nonterm and nonstandard term programs with overlapping AYs between schools) and wanted to clarify that the COA used to determine the loan amounts for the abbreviated loan period is based on the costs and time period associated with the abbreviated loan period.

Beware: New Scam Aimed at Student Borrowers

December 13, 2016

Leadership in Washington will soon change, and, unfortunately, some third-party companies are attempting to profit because of it.

Recently, a third-party debt relief company, claiming to be the Department of Education, has been leaving voicemail messages for student borrowers claiming that they must act immediately to qualify for student loan forgiveness before the program is eliminated. A transcript of the voicemail follows.

This message is from the Department of Education. In regards to Donald Trump becoming President, all programs for student loan forgiveness will be stopped immediately as soon as he takes office in January. In order for you to qualify, you must apply within the next 24 hours or you will not be able to have your student loan payment reduced. Please contact us at 888.307.0680. The number again is 888.307.3680. Once again you must get enrolled within the next 24 hours.

Please be aware that these calls do not originate from the Department of Education. We appreciate you making your student borrowers aware of this scam.

Latest from FSA: 5 Questions to Ask Yourself Before Postponing Your Federal Student Loan Payments

December 8, 2016


FSA recently tweeted out a link to a blog post at HomeRoom, the official blog of the Department of Education. The post offers students advice on questions they should consider prior to postponing their federal student loan payments.

The five questions the blog post delves into include:

  1. Should I choose a deferment or forbearance?
  2. Can I postpone my payments with deferment or forbearance?
  3. How could a deferment or forbearance cause my loan balance to increase?
  4. Should I postpone my payments with a deferment or forbearance?
  5. What are my other options?

In addition to these questions, the post advises students to always proceed with caution and to consider asking their servicers for advice. We encourage you to share this post with your students.

Check out the original blog post.

Building the Leaders of Tomorrow

December 7, 2016


At Nelnet, we believe in our youth as the future of America. That’s why we are so invested in their success and education. From involvement with TeamMates to participating in Junior Achievement events, mentoring the future leaders of tomorrow is a key component of who we are.

Nelnet has been a long-time partner of TeamMates, a one-on-one, school-based mentoring program.

Through TeamMates, mentors are paired with a young person who they meet with one hour per week. The goal of the program is for mentors to be a positive figure in a child’s life and to help guide them toward achieving their educational goals.

Executive sponsor for TeamMates at Nelnet, Jim Kruger, said it’s an incredibly rewarding opportunity for both the mentor and student.

“Not only is it a great program because it allows Nelnet to give back to the communities we live and work in,” Kruger said. “But it also fits directly with our business model to promote education.”

Nelnet associate Grant Rogers learned about the opportunity to mentor in an informational session in the fall. For Rogers, being a Teammate during his first year at Nelnet has become one of his favorite parts of the week.

From playing basketball to board games with his 7th grade TeamMate, Rogers says he looks forward to their Wednesdays together as much as, if not more than, his TeamMate.

“For some kids it’s hard for them to find an adult to look up to as a role model that’s not a parent,” Rogers said. “I think it’s really important for kids to have another stable person in their life.”

Not only do Nelnet employees volunteer one-on-one as mentors, but they also teach classrooms of students through Junior Achievement.

JA is the nation’s largest nonprofit that helps students build skills to achieve future economic and academic success. To educate students on these skills, outside volunteers come into classrooms and teach students about the community and business.

Nelnet associates are always encouraged to volunteer. In October, many Colorado associates spent time in classrooms during Nelnet’s second annual Service Day.

Scott Hollon, the Nelnet representative on the JA board, said that the volunteer model of teaching real-world skills take some of the pressure off teachers.

“Last year more than 34 Nelnet associates volunteered their time to teach 46 classrooms,” Hollon said. “Junior Achievement’s mission to inspire and prepare young people to succeed in a global economy is a great complement to our education focus.”

Chelsea Larkins, a Training and Development Supervisor at Nelnet, has earned membership in the Gold Apple Society. JA volunteers who have taught at least 20 classes receive this distinction.

“The most rewarding part of JA is seeing students I’ve taught succeed,” Larkins said. “Many of them go on to high school and beyond with an entrepreneurial spirit, and I enjoy watching them bring their business ideas to life.”

Whether it is one-on-one or in a classroom, Nelnet associates are working to educate and inspire tomorrow’s leaders.





Ask a Fed: Verification, Early FAFSA, Program Eligibility, and More

November 22, 2016

Federal Training Officer David Bartnicki recently provided these updates:bartnicki

Early FAFSA/Prior, Prior Year

I have gotten lots of questions from schools regarding their inability to view 17/18 ISIRs due to system upgrades/issues. ED recently posted an electronic announcement on 11/18/16 that addresses these concerns. Please note that we assume this is a temporary situation and that once the ISIRs are available for viewing, schools will start reviewing them (especially for the 399 code). Here is an excerpt from the EA:

“…we are providing special consideration for instances when an institution is not yet ready to move 2017-2018 ISIRs from its designated SAIG mailbox into a “production database”. Only in instances where the institution’s systems are not yet ready for 2017-2018 ISIRs (and not simply because the institution chooses to delay its start-up or loading of 2017-2018 ISIRs) the institution may continue to make 2016-2017 Title IV disbursements to otherwise eligible students, notwithstanding that there could be a 2017-2018 ISIR for a student with a Comment Code 399. Once the institution is able to load its 2017-2018 ISIRs, it must promptly do so and then determine which have a Comment Code 399. The institution should not make any additional 2016-2017 disbursements until it determines if corrections need to be made to the 2016-2017 record…”


On October 31, 2016 ED posted an electronic announcement that discusses several key scenarios where an applicant’s Verification Tracking Group can change and when Title IV funds may have to be returned. A chart is attached that covers situations where an applicant was disbursed Title IV aid and was later selected for verification or their verification tracking group changed or filed an income tax return extension. The guidance in this Electronic Announcement and the attached chart applies to both the 2016-2017 FAFSA processing year and to all subsequent years, including the 2017-2018 FAFSA processing year.

Please review the announcement and chart for more information:

Also, please do not forget to update your V4 and V5 students in FAA Access to CPS Online for 2016-2017 and 2017-2018. Our November 18, 2016 electronic announcement reminds schools that the V4/V5 tracking process will continue in 2017-2018 and that we have added a new value 6 as a possible outcome when reporting students – problems with both identity and high school completion.

In addition, we recently updated several verification Q&As on the program integrity website:

General Questions (VER)


Acceptable Documentation for FAFSA Information Selected for Verification (DOC)


To access all of the Program Integrity Q&As, please visit: (upper right-hand side of IFAP).

Borrower Defense

A final federal register was posted on November 1, 2016 regarding the much talked about borrower defense regulations. Aside from a few areas, the regulations become effective July 1, 2017. A few highlights include:

  • Clarify that borrowers with loans first disbursed prior to July 1, 2017, may assert a defense to repayment under the current borrower defense State law standard
  • Establish a new Federal standard for borrower defenses, and limitation periods applicable to the claims asserted under that standard, for borrowers with loans first disbursed on or after July 1, 2017
  • Establish a process for the assertion and resolution of borrower defense claims made by individuals
  • Establish a process for group borrower defense claims with respect to both open and closed schools, including the conditions under which the Secretary may allow a claim to proceed without receiving an application
  • Provide for remedial actions the Secretary may take to collect losses arising out of successful borrower defense claims for which an institution is liable
  • Add provisions to schools’ Direct Loan Program participation agreements (PPAs) that, for claims that may form the basis for borrower defenses, prohibit participating schools from using certain contractual provisions regarding dispute resolution processes and require certain school notifications /disclosures regarding arbitration
  • Clarify that a limitation may include a change in an institution’s participation status in title IV, HEA programs from fully certified to provisionally certified
  • Amend the financial responsibility standards to include actions and events that would trigger a requirement that a school provide financial protection, such as a letter of credit, to insure against future borrower defense claims and other liabilities to the Department
  • Require proprietary schools at which the median borrower has not repaid in full, or paid down by at least one dollar the outstanding balance of, the borrower’s loans to provide a Department-issued plain language warning in promotional materials and advertisements
  • Require a school to disclose on its Web site and to prospective and enrolled students if it is required to provide financial protection, such as a letter of credit, to the Department

For a detailed discussion and the actual regulations, please review the 11/1/16 federal register –

2017-2018 Shopping Sheet

Due to the early FAFSA process for 2017-2018, I am happy to announce that for those schools using the shopping sheet, the 2017-2018 shopping sheet is now available. On November 14, 2016, we posted an electronic announcement that contained the new 2017-2018 shopping sheet template, file layouts, data file schema and HTML specifications. Please see the 11/14/16 EA for more information –

Gainful Employment

As noted in the GE EA #98 dated 11/18/16, please do not forget that if you plan to challenge any draft GE Debt-to-Earning Rates you need to do so by December 7, 2016. It is important to note that all draft GE D/E rates challenges must be submitted and confirmed on the NSLDS Professional Access website by 11:59 P.M. (ET) on December 7, 2016 in order to be considered by the Department. For all challenges, both the “Submit” and “Confirm” buttons must be clicked to complete the challenge submission process; otherwise, the corrections will be lost.

For specific information on how to properly submit challenges and for additional resources, please see the November 18, 2016 electronic announcement –

Campus-Based Funding

On November 18, 2016, ED provided an electronic announcement outlining the Title III and Title V waiver process for the non-federal share of earned compensation paid to students under the FWS Program and of FSEOG funds awarded to students for the 2017-2018 award year.

OPE/IS has automated its designation process by using existing data to determine an institution’s eligibility for Title III and Title V Programs.

Once the 2017 OPE/IS process is complete, institutions may verify their Title III and Title V eligibility status by going to the Application on the OPE/IS website (

A notice will be published in the Federal Register on or around December 1, 2016, announcing the availability of the 2017 Title III and Title V eligibility designations and the waiver application deadline.

Note: Historically Black Colleges and Universities (HBCUs), Tribally Controlled Colleges and Universities (TCCUs), and institutions with an active Title III or Title V grant (current throughout Federal Fiscal Year 2017) automatically qualify for the waiver of the Campus-Based non-federal share requirement. These waivers are granted unless Federal Student Aid’s Grants and Campus-Based Programs Division receives information from OPE/IS that the institution has lost its grant funding and/or HBCU or TCCU status.

For questions about Title III or Title V eligibility, contact:

Christopher Smith
Tel: (202) 453-7946
Jason Cottrell
Tel: (202) 453-7530

Pre-Majors or Pre-Programs

We have had lots of questions of late around “pre” programs (pre-biology, pre-nursing, etc.) and how Title IV aid is affected.

Policy recently provided some guidance to NASFAA that I wanted to share with my SASFAA schools.

  • An otherwise eligible student enrolled in a “pre-program” (includes pre-majors) may be considered a regular student enrolled in an eligible program if, provided the appropriate academic requirements are met, enrollment in the pre-program assures the student admission to the full program at a later point. If this is the case, we would consider the “pre-program” to be the first part of the formal program in which the student will ultimately matriculate. This is similar to how we treat “undeclared” students enrolled in degree programs.
  • However, if admission to the “pre-program” does NOT (presuming the student has met all applicable academic requirements) guarantee admission to the actual or formal program, then we treat the “pre-program” as not considered leading to a credential, and therefore not an eligible program. For example, a pre-nursing program consists entirely of coursework acceptable toward completion of a BSN program at the institution. Students must successfully complete all of these courses with a grade of “B” or higher, and pass a written exam in order to transition into the BSN program. However, admission of even those pre-nursing students who have met all academic requirements is contingent on the availability of clinical slots, with the result that not all of them will matriculate into the BSN program. Accordingly, students who successfully complete the pre-nursing requirements must apply to the BSN program with no guarantee of acceptance. Those students who are not admitted to the BSN program will have effectively been “parked” in a program that does not lead to a degree or other credential and is therefore not an eligible program.
  • This guidance does not, in any way, obviate the requirement that, to be eligible, a student must be enrolled as a regular student in an eligible program. In this regard you could draw an equivalency to undeclared students in a BA/BS program. That is, with a few exceptions (teacher certification, preparatory coursework etc.) a student must always be enrolled in an eligible program. Hence the reason for requiring that, provided the student meets all of the academic requirements while in the pre-major, he or she is admitted into the full program. In that way the student really can be considered to have been enrolled in the eligible program throughout. As stated in our response, the pre-program then becomes part of the formal program. It has always been permissible for a program to have associated with it, enrollment which is conditional to the extent that certain academic standards must be achieved in order to remain in that program-perhaps an exam at a certain point. However, if a student meets all academic requirements and is then told she will not be admitted to the full program, that student is considered to have not been enrolled in an eligible program while in the pre-major.

I hope everyone has a wonderful Thanksgiving. We have lots to be thankful for and it is nice to take a moment and remember all the good things in our lives…even if that good thing is a FED!

Student Loan Servicing Leaders Combine Forces to Create Servicing Platform of the Future

November 16, 2016


Great Lakes and Nelnet have formed a joint venture to create the servicing solution of the future and compete in the U.S. Department of Education’s (ED) ongoing procurement.

Great Lakes + Nelnet = GreatNet

Inspired by changes called for by ED to simplify the student loan borrower experience, GreatNet is a collaboration of the best from our two organizations in our response to the procurement.

GreatNet has been announced as one of three finalists. If selected, we can help ED fulfill their vision for a streamlined student loan borrower experience, with simplified communications and easy-to-use technology on a single platform. The goal is for each student loan borrower to benefit from the same high quality service across all touch points.

For More Information

We’re excited about the future with GreatNet, and we’re here to help in all the usual ways.

At Great Lakes, contact your Great Lakes representative or Client Services team with any questions, or for help with your Great Lakes-serviced loans. At Nelnet, contact School Ombudsman Dawn Knight with questions, or your School Service Center for daily assistance with Nelnet-serviced loans.

Five Great Resources for Prospective and Current College Students

November 11, 2016


When a student who needs financial assistance for college does a Google search for “financial aid,” they encounter about 30.8 million search results. If that student decided to devote one minute of his or her time to reviewing each result, they would finish in a breezy 58 ½ years.


While the Information Age has made it easier than ever to dig up details on any subject imaginable, it has also made it easier than ever to be so intimidated by the masses of resources available that you hide behind your couch for days at a time.

Federal Student Aid (FSA) is always the best place to start when it comes to financial aid resources. However, to help sort through the troves of information available, we identified five resources that we think are great for prospective and current college students.


High school students considering college can receive a lot of financial assistance through scholarships. Unfortunately, many students think less-than-extraordinary academic records disqualify them from any scholarship consideration. Not so, says The “C” Students Guide to Scholarships. This book offers tips, secrets, and techniques for applying for hundreds of thousands of dollars in scholarships and grants. The guide’s step-by-step direction is designed to help “’C students” turn hidden talents and unique strengths into cash for college.

More details on The “C” Students Guide to Scholarships.

Financial Aid

When high school and college students need financial assistance, many turn to Federal Student Aid (FSA). While completing the Free Application for Federal Student Aid (FAFSA) provides an excellent opportunity for students everywhere to earn financial assistance, many find the application daunting. Many communities have local nonprofits that have worked to simplify the process by putting together a FAFSA Checklist. A quick search should turn up local resources in your area. This easy-to-follow document contains details on all of the information the FAFSA requires, as well as where to find it.

Review and print the FAFSA Checklist.

Avoiding Scams

As students search for money to support their education, they will encounter a lot of information. Unfortunately, some of these “opportunities” are designed to pull money from students’ pockets. FSA offers a library of tips and resources designed to help students and parents spot swindlers and keep their money – as well as their identities – safe.

Check out FSA’s resources for avoiding scams.

Online Research

There was a time when college papers required research that bordered on physical labor. Students scoured card catalogs, seemingly endless reference numbers were scribbled, racks of books were hiked through, and then… the book was not on its shelf. With hordes of information at their fingertips, students now have to ensure that they properly organize, vet, and cite online sources. makes this process easy with an extensive Guide to Online Research. This resource covers everything from properly evaluating academic sources to accessing scholarly databases and citing academic sources.

Review’s Guide to Online Research.

Resume Guidelines

As graduation nears and students begin focusing on life beyond their undergraduate degrees, resumes earn more scrutiny than most acts of Congress. How long should they be? What should they emphasize? Is the font okay? Resume Guidelines and Standards from ResumeEdge, a Nelnet company, offers advice on these questions and more. With dos and don’ts for every resume, this printable guide helps students build a resume that emphasizes their strengths to every potential employer.

Please feel free to share all of these resources with your current and/or prospective students. And remember, while hiding behind your couch may seem like a great way to avoid your search engine’s spewings, closing a browser window works pretty well, too.