Skip to content

Ask a Fed

October 2, 2015

Federal Training Officer David Bartnicki recently shared these updates:bartnicki

Federal Perkins Loan Program

I have been getting a lot of questions from schools about the fate of Perkins and just wanted to share that Congress did not take action to extend the Perkins Loan Program beyond September 30, 2015. Therefore, as we provided in Gen-15-03, schools may not make Federal Perkins Loans to new borrowers after September 30, 2015. Schools must follow the guidance provided in GEN-15-03, particularly as it relates to disbursements made on or after October 1, 2015, and the provisions about “grandfathered borrowers.” Please see GEN-15-03 and the Perkins Loan Q & As in the upper-right hand side of IFAP for more information.

In addition, we published GEN-15-19 reminding institutions that participate in Perkins they must return to the Department (ED) the Federal portion of any Excess Liquid Capital in their Perkins Loan Revolving Fund (this is separate from and not because of the ending of the Perkins program). GEN-15-19 contains interactive worksheets to help institutions determine their Excess Liquid Capital (ELC) that must be returned to ED and to the school. Remember that ELC is the amount of the Fund’s “Cash On Hand” that is in excess of the institution’s estimated immediate needs. The Federal share of the institution’s ELC must be returned to ED via G5 no later than December 31, 2015.

Finally, ED posted an electronic announcement on September 21, 2015 regarding the new Perkins Loan Assignment System (PLAS). I am happy to announce that the new PLAS system is now available at Perkins electronic processing will include the following:

  • Submit multiple loans as a “batch file” or submit individual loans
  • Securely upload supporting documentation (prom notes, etc.)
  • Search, view, and edit submitted loan assignment information
  • View Perkins reports of accepted/rejected loans for assignment

The PLAS User Access Form and instructions, along with a PLAS User Guide, are available at An overview of the PLAS user access process is attached to the 9/21/15 electronic announcement.

Clery Act – Campus Security

On September 8, 2015, the Department published an electronic announcement indicting that we have become aware that certain third parties are offering “certifications” to Campus Security Authorities (CSAs) and other institutional officials. We want to make it clear that the Department does not issue certifications and does not recognize or place any value on any certification offered by a third party. An institution is not required or expected to have any such certification to comply with the Clery Act or the Department’s implementing regulations.

If you have questions about compliance with the Clery Act, please direct them to the Campus Safety Help Desk. The Help Desk can be reached by phone at 800.435.5985 or by email at


WOW. It really is happening. After talking about prior, prior year income information for almost a decade on the FAFSA, it finally is going to happen.

An electronic announcement was issued on September 14, 2015 outlining two major processing changes for the FAFSA form in 2017-2018. First, beginning with the 2017-2018 financial aid application cycle, the FAFSA will be available on October 1st of the year prior to the upcoming award year. Thus, 2017-2018 FAFSA filing will begin on October 1, 2016.  We hope this will provide families more time to submit data, review information and assist schools in the packaging process.

And secondly, beginning with 2017-2018, FAFSA income information from one tax year earlier – the so-called “prior-prior year” – will be collected. This means that the 2017-2018 FAFSA will collect tax year 2015 income information. We hope this will reduce the use of estimated income and greatly increase the ability of families to use the IRS DRT process.

Now with anything new, many of you have been calling and sending emails with tons of questions. At this time we are currently reviewing the impact of these changes for 17-18 and developing guidance to assist schools and families as we transition to an earlier processing cycle with the use of prior, prior income information. We promise to share guidance as quickly and efficiently as possible as you prepare office policies, procedures and systems to work with these changes. Stay tuned to IFAP!

Cohort Default Rates

On September 28, 2015, the Department of Education distributed the FY 2012 3-Year official cohort default rate (CDR) notification packages to all eligible domestic and foreign schools.

The FY 2012 3-year national cohort default rate went down to 11.8%. If you review the CDR data provided in our briefing report attached to the September 30, 2015 electronic announcement, you will see that the default rates in all school sectors went down. A lot of that is a result of your hard work and efforts to work with your students to keep them out of default.

Please, please remember that the time period for appealing the FY 2012 3-Year Official Cohort Default Rates under 34 C.F.R Part 668, Subpart N begins on Tuesday, October 6, 2015 for all schools. For specific information regarding eCDR Appeals, visit the eCDR Appeals website, where you will find user guides for each of the challenge and adjustment processes, as well as a user guide for the registration process. Additionally, you will find links to recordings of eCDR Appeals demonstration sessions to assist first-time users.

If you have additional questions, please contact or call the Operations Performance Division’s hotline at 202.377.4259.

150% Subsidized Direct Loan Limitations

On September 25, ED published an electronic announcement reminding schools to properly update a borrower’s Direct Loan (Direct Subsidized Loans, Direct Unsubsidized Loans, and Direct PLUS Loans) information in the COD System and enrollment information in NSLDS to ensure that Subsidized Usage and interest subsidy status can be calculated correctly.

If accurate information is not reported (or corrections are not made when information changes), a borrower may incorrectly lose the interest subsidy on his or her Direct Subsidized Loans. In addition, schools may be subject to sanctions, including possible administrative action pursuant to 34 CFR 668, Subpart G – Fine, Limitation, Suspension, and Termination Proceedings.

Note: A school must be aware of its Direct Loan reporting even if its loan processing or enrollment reporting is handled by a third party servicer. It is the school’s responsibility to ensure that reporting is being completed timely and correctly.

We are still seeing many instances of incorrect data being reported and/or not being fixed. Please make every effort to ensure that your COD and NSLDS data is accurate and updated timely. For steps on properly reporting DL data in COD and enrollment information in NSLDS, please see the September 25, 2015 electronic announcement.

If you have questions about the COD System, contact the COD School Relations Center at 800.848.0978. You may also e-mail If you have questions about NSLDS, contact the NSLDS Customer Support Center at 800.999.8219. You may also e-mail For questions about the 150% limit, visit the 150% Direct Subsidized Loan Limit Information page on the IFAP website or email questions to

Gainful Employment

I hope all schools have properly reported their 2014-2015 GE data as required by October 1, 2015 (not to mention all of the data required to be submitted by July 31, 2015). If you have not, please note that the Department has been sending out letters to schools reminding them of their reporting requirements and possible consequences if not done.

Any specific concerns of noncompliance should be addressed to the contacts outlined in your school letters. The sooner NSLDS has all of your GE data (or updated information), the sooner a resolution can be reached. This data is extremely important to our overall administration of the GE programs and we need your support and information in order to properly and effectively manage these programs.

I hope to see many of you during my fall travels throughout the region to various workshops and conferences. And remember I am just the messenger.

No comments yet

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s

%d bloggers like this: