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Latest from FSA: Ask a FED

November 6, 2014

bartnickiFederal Training Officer David Bartnicki recently shared these updates:


On October 17, 2014, ED published an electronic announcement that outlined the alternative documentation tax filers could use to complete verification when they were unable to obtain an IRS tax return transcript for 2014-2015. The alternative documentation is similar to what was allowed last year and includes – a signed 2013 tax return, signed and dated documentation supporting that transcripts were unavailable (screen shots from the IRS web page or written IRS responses) and a 4506T-EZ or 4506-T on file with the school listed as the third party to receive a transcript if necessary. Please note that this announcement provides guidance only for the remainder of the 2014-2015 award year. This does NOT pertain to the upcoming 2015-2016 award year.

Please note that this alternative approach can be used for a tax filer who, though they have already had their tax returns processed by the IRS, was unable to secure a transcript when they recently attempted to obtain an IRS tax return transcript. This does not apply to situations where the tax filer just filed their tax return and is unable to obtain a transcript simply due to the normal IRS processing times. For specific details please review the 10/17/14 electronic announcement.

In addition, ED recently published a new verification Q & A under the program integrity Q & A website updating guidance on the REAL ID Act when trying to confirm a student’s identity under V4 or V5. We state:

DOC-Q26. Is a government-issued photo identification that is not compliant with the REAL ID Act of 2005, e.g., one marked “not for federal identification,” acceptable documentation for an applicant selected to verify his or her identity?

DOC-A26. Yes. The REAL ID Act of 2005 currently affects individuals seeking access to restricted areas where identification is required e.g. Federal facilities or boarding Federally regulated commercial airplanes. Because there are currently no restrictions under the REAL ID Act on Federal agencies from accepting non-compliant identification for other purposes, such identification is acceptable to complete verification for an applicant required to verify his or her identity if that identification has not expired and includes the applicant’s photo and name. [Guidance issued 10/29/2014]



Please don’t forget to submit all FISAP edits and corrections by Monday, December 15, 2014. Please note that if a school has drawn down more than the amounts reported on the FISAP, a negative balance will be created in G5. When this happens, we will reduce the school’s authorization in G5 to the expended amounts reported on the FISAP, and the school will be required to return the amount of the negative balance.

Also, any changes made to Part II, Section A (Request for Funds 2015-2016) after December 15th may result in reductions in funding for the application year and/or the reporting year. Changes that increase eligibility will be considered to ensure accurate reporting, but the corresponding increases in funding will not be approved.

Please see electronic announcement dated October 29, 2014 for more information (


Final Federal Register – Direct PLUS loans

ED recently published a final Federal Register dealing with the adverse credit history process for Direct PLUS Loans on October 23, 2014.  Highlights include:

  • Amending the adverse credit history regulations to include situations where a borrower has one or more debts with a total outstanding balance greater than $2,085 and that are 90 or more days delinquent as of date of credit report or have been placed in collection or charged off during the two years preceding the date of the credit report
  • PLUS loan counseling (provided by ED) will be required for borrowers who have an adverse credit history and successfully document extenuating circumstances or obtain an endorser
  • Credit checks indicating no adverse credit history will remain valid for 180 days instead of 90 days
  • ED will enhance the consumer information provided for PLUS applicants and will make all voluntary PLUS loan counseling information easily accessible to borrowers who are seeking PLUS loans
  • ED will collect and publish the performance of PLUS loans, including default rate information

Though the new regulations are effective July 1, 2015, the Department will be exercising the right for early implementation and will publish a separate Federal Register announcing the implementation date in the near future. For more information, please see the 10/23/14 final Federal Register –


Final Federal Register – Violence Against Women Act

ED recently published a final Federal Register dealing with the regulatory changes brought about by the Violence Against Women Act on October 20, 2014.  Highlights include:

  • Maintaining 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
  • 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
  • Developing 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
  • Process to remove and maintain documentation for “unfounded” crimes
  • Clear procedures for handling institutional disciplinary actions in cases of alleged dating violence, domestic violence, sexual assault or stalking which includes that 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

Though the new regulations are effective July 1, 2015, please remember that the statute required institutions to include this new information in their annual security reports (ASR) beginning with the ASR provided to students, employees, and prospective students and employees by October 1, 2014. For a complete description of the new regulations, please see the 10/20/14 final Federal Register –


Final Federal Register – Gainful Employment

Just today, October 31, 2014, ED has published the final Federal Register outlining the new gainful employment regulations. These new regulations are effective July 1, 2015. I can honestly say that I have not had time today to read the 215 page document and therefore, I am not able to provide any specific guidance at this time except to say that for more information about the new GE regulations, please see the 10/31/14 Federal Register (

Please note that the Department will be providing lots of guidance (in different formats) around the new GE requirements throughout the coming weeks and months to ensure that all of our schools are properly informed, trained and updated with the most accurate and up-to-date information as possible. Stay tuned to IFAP.

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