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April 17, 2015

bartnickiFederal Training Officer David Bartnicki recently shared these updates:

2015-2016 UEH Flag Updates

On March 16, 2015 ED posted the long awaited Dear Colleague Letter GEN-15-05 that discusses the expanded criteria when reviewing Unusual Enrollment History (UEH) for selected students in the 2015-2016 processing year. The new changes include: (1) an applicant’s prior receipt of, in addition to a Federal Pell Grant, a Federal Direct Loan (not including a Direct Consolidation Loan or parent PLUS Loan) and (2) reviewing the prior four, instead of three, award years (15-16 UEH review includes the 2011-2012, 2012-2013, 2013-2014 and 2014-2015 award years).

Though GEN-15-05 provides a summary of how to review and resolve UEH selected students, we remind schools to review GEN-13-09 for a more detailed and thorough discussion. This resolution process applies to any student, including graduate students, who get selected for review under the UEH flag.

Please note that it may take some time for the SAR comments and ISIR Guide to be updated with these new requirements so schools should resolve 15/16 UEH flags as outlined in the Dear Colleague Letters mentioned above.

Ability to Benefit (ATB)

The number one question I am still getting is about the reinstatement of Ability to Benefit (ATB) alternatives that were put in place by the Consolidated and Further Continuing Appropriations Act of 2015. I have been told that a Dear Colleague Letter has been written and is currently going through the final clearance process. I hope to see the new DCL posted to IFAP very soon.

Educational Tax Benefits for Students and Families

Though there are a number of tax provisions, including the American Opportunity Tax Credit (AOTC) and the Lifetime Learning Tax Credit, designed to reduce or partially offset the costs of higher education for students and families, we believe many students and their families do not take advantage of these tax credits that could save them thousands of dollars.

To help address this problem, the IRS has prepared a flyer to alert students of these potential tax benefits called, “Students and Parents – Why Form 1098-T is important to you?” We have provided a copy of the flyer as a ‘PDF’ attachment to a March 17, 2015 electronic announcement.

We are asking all high school and college counselors, advisors, and financial aid administrators to make these flyers as widely available to student and families as is possible. This could include posting the flyers to websites, using other social media, or for postsecondary schools and colleges, including them in students’ admissions letters, registration materials, and financial aid award packets.

National Student Clearinghouse (NSC)

I have been getting a few questions around whether schools can still use the NSC to submit student enrollment data to NSLDS. The answer is yes, schools may still use NSC to submit student enrollment data to NSLDS. These questions appear to have been generated due to recent comments in a March 12, 2015 electronic announcement where we indicated that FSA had recently terminated an enrollment reporting contract with NSC. Please note that this was a separate and distinct contract between FSA and NSC and had nothing to do with individual school contracts with NSC.

Aggregate Loan Limits and Dependent Students whose Parents are denied a PLUS

I have talked about this topic in the past but since I have recently received several questions around aggregate loan limits for dependent students whose parents are denied a PLUS loan I thought we could revisit this topic.

If a dependent student’s parent is denied a PLUS, the dependent student can now borrow up to the annual independent student loan levels. In this limited instance, we are now treating a dependent student as an independent student. In fact, if you review the loan limit charts in the 14/15 FSA Handbook, Volume 3, Chapter 5 page 97 you will note that the aggregate limits for an independent student also includes dependent students whose parents are denied a PLUS loan.

It can be a little confusing to figure out what a student can borrower if the dependent student’s parent is denied a PLUS one year but not in other years. Remember, that whatever additional amounts they were able to borrow because they were considered an independent student does not count against their dependent aggregate loan limits (of course they can never exceed the overall undergrad aggregate totals). However, whatever amounts they would be able to borrow as a dependent student (i.e. 1st year dependent student can borrow $3500 – base sub/unsub and $2000 additional unsub) would still count against their dependent aggregate loan limits.

One good example a school asked was how much could a 4th year dependent student whose parent was denied a PLUS loan borrow if they had reached their dependent undergrad aggregate loan limits of $31,000 (including $23,000 in sub). The student in this case as a 4th year student (and assuming the COA and EFA supported the loan amounts), could borrow up to $12,500 since they are treated as an independent student for DL purposes and can borrow against the independent aggregate loan amount of $57,500. Remember that the $12,500 is made up of $5500 base sub/unsub and $7000 additional unsub. If the student has used up all of his sub eligibility (as in my example) then the entire amount would be unsub aid.

And of course no undergraduate student can borrow above the independent aggregate loan limit of $57,500.


A lot of schools have been asking me if the Department plans on sharing any information with schools about the FSA ID process that they can then share with their students. The answer is yes. The Department plans on sharing a step-by-step guide on the FSA ID registration process that you can then share with students, parents and borrowers.

Remember that we are not providing information to students on the new FSA ID process until shortly before implementation to hopefully reduce any potential confusion. In fact, until we actually transition to the new FSA ID, there is nothing for a student, parent or borrower to do. In addition, I have been informed that the FSA ID implementation date is now May 10, 2015.

Third Party Servicers

On February 12, 2015, the Department posted an electronic announcement requiring all third party servicers as defined under 34 C.F.R § 668.2 and GEN-15-01 to submit a Third Party Servicer Data Form (attached to the announcement) within 30 days of the date of the announcement or within 30 days of receiving notification of the requirement from the Department. In addition, third party servicers are required to update information within 10 days of the date, if:

  • The servicer changes its name;
  • The servicer changes the address or contact information for its primary location or additional location;
  • The servicer adds or terminates a contract with an eligible Title IV institution; or
  • The servicer buys, sells, or merges with another third party servicer. 34 C.F.R. § 668.25(e)(1)(i).

Any questions about the 2/12/15 electronic announcement or the Third Party Servicer Data Form, should be directed to the Third Party Servicer Oversight Group (816) 268-0543;


For those that may have missed it, I am happy to report that we announced in a March 3, 2015 electronic announcement that FSA will be hosting a FSA Training Conference in 2015. The 2015 FSA Training Conference will be held from December 1 – December 4, 2015 at the Mandalay Bay Hotel, 3950 Las Vegas Blvd. South, Las Vegas, Nevada, 89119.

Conference and lodging registration will open this summer. Additional information regarding the 2015 FSA Training Conference will be posted at as it becomes available.


A couple of our colleagues in the Department have or will be retiring shortly and I just wanted to pass on their information in case some of you have had the chance to work with them directly.

Pam Moran, manager and program specialist, in the Office of Postsecondary Education recently retired. Pam worked closely on all ED policy matters that dealt with the FFEL and DL programs. Her knowledge and experience will be greatly missed.

Barbara Mroz, manager over our QA program and experimental sites, will be retiring shortly. I know many of our schools in the Southeast have had an opportunity to talk to and work with Barbara either through the QA program or by volunteering in our experimental sites initiatives.

We wish them both a fun and relaxing retirement (with no regulations to worry about).

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