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July 31, 2015

bartnickiGainful Employment

Well, today is the big day. All schools with GE programs should be putting any final touches on their GE program reports and sending them into NSLDS by the end of today. Institutions must report, no later than July 31, 2015, information from the 2008-2009 award year through the 2013-2014 award year and for certain medical and dental GE programs, institutions will also report for the 2007-2008 award year.  Following this initial reporting, institutions must report GE data annually by October 1 following the end of the award year (e.g., October 1, 2015, for the 2014-2015 award year), unless the Secretary establishes a different reporting date.

Please note that if reporting errors occur or information needs to be updated, schools will be given an opportunity to provide additional data.  In the meantime, however, please make every effort to send in your GE data within our prescribed timeframes.

For those wanting a good overview of the regulatory requirements schools must adhere to with regards to GE programs, please see Dear Colleague Letter(DCL) GEN-15-12 (  This is a nice summary of the overall GE process, along with various GE contact and resource information.

Annual Security Report

GEN-15-15 ( provides a summary of  the final regulations (effective  July 1, 2015) that were implemented due to statutory changes to the Clery Act under the  Violence Against Women Reauthorization Act of 2013 (VAWA).

It is important to stress that the preamble to the NPRM noted that the changes made to the Clery Act by VAWA did not affect in any way Title IX of the Education Amendments of 1972 (Title IX), its implementing regulations, or associated guidance issued by the Department’s Office for Civil Rights (OCR). Nothing in the Clery Act, as amended by VAWA, alters or changes an institution’s obligations or duties under Title IX as interpreted by OCR.

GEN-15-15 provides an overview of the major changes to the Clery Act which includes the following –

  • Require institutions to collect and report information regarding incidents of dating violence, domestic violence, sexual assault, and stalking that occur on an institution’s Clery Geography and are reported to a Campus Security Authority or to local law enforcement agencies;
  • Revise the categories of bias for the purposes of Clery Act hate crime reporting to add gender identity and to separate ethnicity and national origin into different categories;
  • Require institutions to provide information on culturally relevant, inclusive prevention awareness programs to incoming students and new employees, as well as describe these programs in their ASRs and require institutions to provide, and describe in their ASRs, ongoing prevention and awareness campaigns for students and employees. These campaigns must include the same information as the institution’s primary prevention and awareness program;
  • Require institutions to provide for a prompt, fair, and impartial disciplinary proceeding in cases of alleged dating violence, domestic violence, sexual assault, or stalking

For a complete summary of all major changes please see GEN-15-15.

I also want to point out that the DCL indicated that 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.  However, institutions must still report three years of statistics for all other crime categories and will be required to report the contact information of their lead Title IX coordinator in the 2015 Campus Safety and Security Survey.

Please ensure that your appropriate offices on campus are aware of these new campus security updates and that all changes are properly implemented.

Unaccompanied Homeless Youth Determinations

In an effort to help address questions the Department has been receiving around unaccompanied homeless youth determinations on the FAFSA form, ED recently posted GEN-15-16 to help clarify institutional and applicants’ roles and responsibilities related to Title IV dependency determinations for unaccompanied homeless youth.

The DCL ( reviews basic definitions, the application process, FAA protocols and possible documentation.  We do stress that we are aware that some institutions are unnecessarily restricting applicants’ access to aid by asking applicants to provide justification as to why they are homeless or unaccompanied rather than evidence that they have been determined to be homeless or at risk of being homeless. We 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.

For additional information please see GEN-15-16.

Data Security

GEN-15-18 reminds institutions of higher education and their third-party servicers of their continuing obligations to protect data used in all aspects of the administration of the Title IV Federal student financial aid programs.  With recent high-level data breaches across different organizations being publicized in the news, it is important for schools (and third-party servicers) to remember that they must ensure that all Federal Student Aid applicant information is protected from access by or disclosure to unauthorized personnel according to several state and federal laws.

Industry standards and best practices include:

  • Assessing the risk and magnitude of harm that could result from unauthorized access, use, disclosure, disruption, modification or destruction of information or information systems;
  • Determining the levels of information security appropriate to protect information and information systems;
  • Implementing policies and procedures to cost-effectively reduce risks to an acceptable level; and
  • Regularly testing and evaluation of information security controls and techniques to ensure effective implementation and improvement of such controls and techniques.

For information related to protecting student information please see GEN-15-18 (

G-845 Form

Please note that the G-845 form used by Title IV postsecondary institutions to request verification from DHS-USCIS of an applicant’s eligible non-citizenship status has been updated. The revised form has an expiration date of 05/31/2018 and replaces the prior version that has an expiration date of 01/31/2015.  Institutions are encouraged to begin using the revised G-845 form immediately. The previous version of the G-845 form may no longer be submitted to DHS-USCIS after August 14, 2015.

The new G-845 Form and application instructions have been updated in the 15/16 FSA HDBK Vol. 1, Chapter 2.  For a summary of the G-845 changes, along with contact information for individual student eligibility questions, please see the June 29, 2015 electronic announcement (

Student Eligibility Codes in COD

On July 9, 2015, ED provided an electronic announcement (, along with an attached chart, that outlined which eligibility codes to use in COD for students with high school diplomas or equivalents and which codes to use for student s qualifying for Title IV aid under ability-to-benefit (ATB).  Please refer to the 7/9/15 EA for specific COD operational guidance.

In addition, we reminded schools that as noted in Dear Colleague Letter GEN-15-09, a student who is enrolled in an eligible career pathway program and is eligible through one of the ATB alternatives, and who first enrolled in any Title IV eligible postsecondary program on or after July 1, 2015 is subject to a reduced Pell Grant amount. The Pell Grant award amount for these students must be based on the 2015-2016 Career Pathway Alternative Pell Grant Disbursement Schedules.

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. The COD System does not contain these schedules and there are no system edits on the Pell Grant award amount related to these schedules.  We urge schools to take special care when awarding Pell Grant funds to students who are eligible as a result of one of the ATB criteria in order to avoid overpayments for which the school is liable.


I have gotten a few questions from schools around student and parents having issues with their FSA IDs.  On July 17, 2015 ED posted an electronic announcement ( reminding schools that the creation of an FSA ID must only be accomplished by the individual who owns the FSA ID and only that person may use the FSA ID.  Many of the problems our service centers are addressing are coming from individuals experiencing difficulty logging in because their FSA IDs were created by someone else, such as a parent creating an FSA ID for a child, or vice versa. In addition to this being contrary to the legal certifications provided by the person creating the FSA ID, when an individual’s FSA ID is created by someone else, it is likely that the FSA ID owner will not know the information necessary to log in.

For more information and FSA ID contact information please review the 7/17/15 EA.

The Blue Book

ED announced in an electronic announcement on July 1, 2015 that we would no longer be publishing The Blue Book.  The Blue Book was a Department of Education manual used to provide Title IV administrative guidance to fiscal officers.  Please let your fiscal and business offices know that even though The Blue Book will no longer be provided, we are incorporating all essential guidance from The Blue Book into the Federal Student Aid Handbook which is updated on an annual basis.

2015 FSA Training Conference

In case you missed it, the lodging and registration site is now open for the 2015 FSA Training conference (  Rooms fill up fast so make your reservation today.

This year’s FSA conference program will focus on topics related to changes in Title IV legislation and corresponding regulations such as protecting students’ privacy and their loan data, Gainful Employment rules, the 150% Subsidized Direct Loan limitation and student loan repayment options. We will also discuss changes to the Clery Act, which includes revisions to the Violence Against Women Act (VAWA) that require schools to implement changes to further help protect their students. Financial aid professionals will learn how to implement these changes at their schools and will be able to utilize face-to-face, hands-on sessions using the Department’s data systems, such as COD and NSLDS.

We will also include the essential sessions such as the new changes to the FAFSA® and verification as well as sessions on cash management and loan reconciliation, among others. Schools will also have the opportunity to provide feedback to FSA through the open forums.


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