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March 9, 2015

bartnickiFederal Training Officer David Bartnicki recently shared these updates:

DRAFT FY 2012 CDRs
On Monday, February 23, 2015, we distributed the FY 2012 Draft Cohort Default Rate notification packages to all eligible domestic and foreign schools, guaranty agencies, and lenders. This information was sent to the SAIG mailbox for the destination point administrator designated by the school.

To ensure that your FY12 rate is correct, please remember that the time period for challenging a school’s FY 2012 3-Year Draft Cohort Default Rate under 34 C.F.R Part 668, Subpart N begins on Tuesday, March 3, 2015 for all schools.
Any questions or concerns about your draft FY12 CDRs can be directed to fsa.schools.default.management@ed.gov or by calling the Operations Performance Division Hotline at 202-377-4259.

Ability to Benefit (ATB)
I have been getting lots of questions about the reinstatement of Ability to Benefit (ATB) alternatives that were recently put in place by the Consolidated and Further Continuing Appropriations Act of 2015. Please note that our Offices of General Counsel and Policy are busy reviewing the changes outlined in the law to ensure that any modifications to our current ATB rules are properly and accurately updated. Once ED has had a chance to review, discuss and finalize our new guidance around ATB alternatives, we will provide the information to our schools as soon as possible. Please stay tuned to IFAP.

Consortium Agreements and NSLDS Enrollment Reporting
I have received several inquiries as to which school must report a student through the NSLDS enrollment reporting process when a student is taking classes at a host school through a consortium agreement. Policy has clearly indicated that it is the “home” school, the school where the student is enrolled for the purposes of seeking a degree or certificate, which must report the enrollment status of the student. Remember that the only reason the student is able to receive Title IV aid at the host school is because of their enrollment in a program of study at the home school.

2015-2016 Shopping Sheet
On February 24, 2015 ED posted an electronic announcement containing the 15/16 Shopping Sheet Template, XML file layout, HTML specifications, and the Institutional Metric Data File. Please note that we only made one addition to the 2015-2016 Shopping Sheet, the addition of an “American Opportunity Tax Credit” bullet under the “Other options” section.

For more information please see the 2/24/15 electronic announcement.

FSA Handbook
The 2015-2016 FSA HDBK AVG section has been posted to IFAP.ed.gov. Additional volumes and sections will be posted over the next several weeks and months. Stay tuned to IFAP.

In addition, a new appendix F has been added to the 2014-2015 FSA HDBK Appendix section. Appendix F covers Institutional Reporting and Disclosure Requirements for Federal Student Assistance Programs. This is a great resource when reviewing your school’s reporting requirements and consumer information responsibilities. This appendix contains a chart that outlines the required information, methods of delivery, due dates, and applicable citations.

Federal Perkins Loan Program
ED recently posted DCL GEN-15-03 on the status of the Federal Perkins Loan Program. It states that absent Congressional action, schools may not make Federal Perkins Loans to new borrowers after September 30, 2015. If prior to October 1, 2015, a school makes the first disbursement of a Federal Perkins Loan to a student for the 2015-2016 award year, the school may make any remaining disbursements of that 2015-2016 loan after September 30, 2015.
In addition, the DCL describes a narrow “grandfathering” provision that allows schools to make Federal Perkins Loans to certain students for up to five additional years (through September 30, 2020) to enable students who received loans for award years that end prior to October 1, 2015 “to continue or complete courses of study.” To be grandfathered the following must be true –

  1. School made at least one Perkins Loan disbursement to the student on or before June 30, 2015.
  2. Student is enrolled at the same institution where the last Perkins Loan disbursement was received.
  3. Student is enrolled in the same academic program for which the student received his or her last Perkins Loan disbursement. (first four digits of the program’s CIP code are identical)
  4. Perkins Loan can be made to an otherwise eligible grandfathered student to meet all or some of the student’s unmet need only after the student has been awarded all Direct Subsidized Loan aid for which the student is eligible.

Note that because the grandfathering provision applies only to students who received a Perkins Loan for award years 2014-2015 or earlier, a student who received his or her first Perkins Loan for the 2015-2016 final award year of the program, (e.g., an incoming first-year student) will not be an eligible grandfathered student for purposes of receiving loans beyond that 2015-2016 award year.

For more information please review GEN-15-03. Additional communications about the wind-down of the Perkins program will be coming out over the next few months.

R2T4 and Snow Days
Due to recent weather conditions I have received numerous questions about what to do with R2T4 when the school is closed for several days (including up to 5 days or more) due to weather conditions. Policy has indicated that unless the school is closed due to normal vacation periods (scheduled breaks) or due to a federal declared disaster (as outlined in GEN-10-16), the school would not exclude the days missed due to unscheduled breaks.

If schools have questions or concerns around administering Title IV aid due to a local disaster/problem (meeting timeframes, reporting deadlines, etc.), schools should contact their local regional school participation team for guidance.

Training – Webinars
Dear Colleague Letter ANN-15-04 announced the rescheduling of a webinar that will discuss COD System operational changes resulting from the new Direct PLUS Loan adverse credit history regulatory provisions. The rescheduled webinar will take place Thursday, March 12, 2015 at 2:00 P.M. (ET). For information on how to properly register for the upcoming webinar please review ANN-15-04 for links and contact information – http://ifap.ed.gov/dpcletters/ANN1504.html.

In addition, DCL ANN-15-05 announced an upcoming webinar to discuss changes and enhancements to the Common Origination and Disbursement (COD) System for the 2015-2016 Award Year. This webinar has been scheduled for Tuesday, March 17th, 2015 at 3:00 P.M. (ET), and again on Thursday, March 19th, 2015, at 9:00 A.M. (ET). For information on how to properly register for the upcoming webinar please review ANN-15-05 for links and contact information – http://ifap.ed.gov/dpcletters/ANN1505.html.

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