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Ask a Fed – Part 2, Verification and More

November 20, 2015

Federal Training Officer David Bartnicki recently shared updates on a variety of topics. To ease your reading process, we have split his update into two blog posts. You can see part one here.

Verificationbartnicki

The October 2, 2015 Electronic Announcement provided the long-awaited guidance allowing schools to accept alternative documentation for tax filers who (after the requisite processing time) have been unable to obtain a tax transcript. Please note that this verification documentation exception is for 2015-2016.

The alternative documentation includes the following:

  • A signed copy of the relevant (i.e., applicant, spouse, or parent) 2014 IRS tax return that was filed with the IRS.
  • A statement from the tax filer, on or attached to the tax return, which certifies that the tax return submitted to the institution includes the same information that was submitted to the IRS (NEW)
  • Documentation from the IRS that the transcript request was unsuccessful.
    • For tax filers who requested a transcript using the IRS online transcript request process, a signed and dated copy of the screen shot from the official IRS Web page that displays a message indicating that the transcript request was unsuccessful.
    • For tax filers who requested a transcript using IRS Form 4506T-EZ or Form 4506-T, a copy of the IRS response that was mailed to the tax filer stating that the IRS could not provide the transcript. The copy of the IRS response must be signed and dated by the tax filer.
  • A completed and signed IRS Form 4506T-EZ or Form 4506-T that includes on line 5 the name, address, and telephone number of the institution as the third party to whom the IRS is to mail the 2014 IRS transcript. (to be used by the school ONLY if the school questions the accuracy of the information on the signed copy of the paper tax return).

For more information, please see the 10/2/15 EA – http://ifap.ed.gov/eannouncements/100215AcceptableDocUpdateFor1516AwardYrVerification.html.

2016-2017 ISIRs

On November 12, 2015 we posted an electronic announcement indicating that in response to concerns that some institutions have been using the list of colleges that a student includes on their FAFSA for purposes unrelated to the awarding of student financial assistance, beginning with the 2016-2017 FAFSA, the Department will only provide the Federal School code and corresponding housing code for the institution receiving the student’s ISIR.

Information about all of the colleges listed by the student will continue to be included on ISIRs provided to state grant agencies, as well as on the Student Aid Report (SAR) provided to the student. Institutions may not require students to submit SARs to the institution.

Gainful Employment

Unfortunately, some of my schools received emails and phone calls from the Department indicating that they had not reported any GE data or certain GE program data was missing over the last few months. In response to our inquiries, schools were asking me at what point would the schools be considered GE compliant. I am happy to say that on October 8, 2015, ED posted and electronic announcement summarizing how a school could determine when they have met ED’s GE reporting requirements.

The 10/8/15 EA indicated the following:

An institution has met its reporting requirement for a GE program that is included on the Department’s NSLDS GE Program Tracker List for a year –

  • If the word ‘Yes’ is in the ‘Source GE’ column for the program. A ‘Yes’ indicates that the institution has reported students for that program for that year;

OR

  • If any value other than ‘A1’ is in the ‘Status Reason’ column for the program for that year. A value other than ‘A1’ means that the institution annotated the tracker to indicate that the program does not need GE reporting for that year. [See GE Electronic Announcement #53 for information on which of an institution’s academic programs are GE programs and therefore must be reported on.]

If neither of the above conditions is met, the institution must either report for the program/year or make a substantiated and documented annotation to the ‘Status Reason’ value in the NSLDS GE Program Tracker List for the program/year.

We also reminded schools that they must report or annotate every program included on the school’s NSLDS GE Program Tracker List for each award year (2008-2009 through 2013-2014), even if the program was not offered for a year or if there were no Title IV aid recipients enrolled in the program for a year. In addition, it is important that schools ensure that all students who received Title IV aid for a program have been reported. Schools must report all students who received Title IV aid to attend the GE program for that year or for any of the reporting award years.

Also, as a reminder, we recently posted the Updated GE Disclosure Template. Schools must, no later than January 31, 2016, update disclosures for each of their GE programs to reflect information from the 2014-2015 award year using this updated Disclosure Template to meet their disclosure requirements under 34 CFR 668.6(b). The updated template can be found at http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/negreg-summerfall.html. If you have questions about the template please contact our help desk toll-free at 855.359.3697 or gedt@inovas.net. Please see the October 23, 2015 Electronic Announcement for more information.

Finally, one of the most common areas I get questions about is gainful employment and I just want to remind everyone that there is a GE website on the right-hand side of IFAP dedicated to all things GE – http://ifap.ed.gov/GainfulEmploymentInfo/indexV2.html. It contains updated EAs, DCLs, federal registers, training materials, GE Operations Manual, etc. It also contains an extensive Q&A section that is periodically updated with new Q&A’s (a lot of them our questions that you asked GE-Questions@ed.gov). Recent new additions include:

  • 11/17/15 GE EA #69 (updated NSLDS GE User Guide)
  • 11/10/15 GE EA #68 (new chapters in GE Operations Manual)
  • 10/23/15 GE EA #66 (programmatic accreditation and program eligibility regarding GE certification Q&A’s)

Data Challenges and Appeals Solution (DCAS) system

Also related to GE is the new DCAS system. This new system will allow schools to submit challenges to data elements from the Draft GE Completers List. Future releases of DCAS related to GE will include functionality for challenging the information used to calculate the debt-to-earnings (D/E) rates.

In addition, we will expand DCAS functionality in phases to include all appeals, requests for adjustments and challenges related to institutional cohort default rates (CDRs), and other student-level data initiatives. After we fully implement all phases of DCAS, we will retire the eCDR Appeals system.

In preparation for the launch of the new system later this year, we encourage all authorized users that will be working with DCAS to enroll in the DCAS Online Service. Authorized users can enroll in DCAS by a school’s (or organization’s) Primary Destination Point Administrator (Primary DPA) via the Student Aid Internet Gateway (SAIG) Enrollment Website. In the attachment to the 10/26/15 Electronic Announcement we provided detailed instructions for the Primary DPA to complete the process.

For more information about the new DCAS system please review the 10/22/15 and 10/26/15 Electronic Announcements.

Web Surveys

A few schools have called me concerned about an electronic survey they received on behalf of FSA and were wondering if it was legitimate. On November 12, 2015, FSA launched a school partner survey that is being conducted by an independent vendor, CFI Group, via the web. The survey is an effort on ED’s part to ensure that Federal Student Aid and the Department of Education provide the best services possible to our school partners. The notification emails will be sent from “Federal Student Aid, through CFI Group [surveyhelp@cfigroup.com].” The web survey has been designed to take approximately five minutes to complete and will be conducted in a manner that ensures strict confidentiality of all responses.

If you receive the survey, we hope you will help us help you by taking the time to provide meaningful feedback that, in the end, will help all of us administer the Federal Student Aid programs as effectively and efficiently as possible. For more information about the FSA survey, please see the November 10, 2015 Electronic Announcement.

NSLDS

For those working with NSLDS enrollment, I am pleased to announce we posted a new updated NSLDS Enrollment Reporting Guide on IFAP (October 2015). The new enrollment guide includes clarification on how to report enrollment data and how to add students to rosters, as well as information regarding the new Enrollment Statistics page and the new Enrollment Statistics report. The new guide can be found at http://ifap.ed.gov/ifap/byNSLDSType.jsp?type=NSLDS%20User%20Documentation or under the “Processing Resources” Box on IFAP.

If your office does not directly work with NSLDS Enrollment Reporting, please make sure your school offices that do work with enrollment reporting (Registrar, etc.) are made aware of and working with our latest guide.

Career Pathway Programs

For those schools considering developing eligible career pathway programs for ability-to-benefit (ATB) students or who are already offering eligible career pathway programs, I strongly encourage you to review the series of Q&A’s ED recently posted to IFAP in the 10/22/15 Electronic Announcement. The announcement includes 12 Q&A’s that discuss various key areas associated with offering eligible career pathway programs. The questions focus on definitions, documentation, program requirements, program approval, coursework, TIV eligibility and ATB criteria. One question provided addresses a common issue that many schools have been asking me about in reference to the new career pathway program process:

Question 9: Is each ATB student required to take coursework from both the adult education component and from the Title IV eligible post-secondary program component in each payment period in order to receive Title IV aid?

Answer 9: For a student to be eligible for Title IV aid after successfully completing one of the ATB alternatives, the student must be concurrently enrolled in both the adult education and the Title IV eligible post-secondary components of the eligible career pathway program and that enrollment must be documented by the institution (see Answers 2 and 8).

However, that does not preclude a student from occasionally being enrolled in just one component of the eligible career pathway program for any particular payment period as long as the institution has evidence that the student has taken coursework in both components throughout the student’s enrollment in the eligible career pathway program.

For example, consider a student who took classes in both the adult education component and the Title IV eligible post-secondary program component for the first and second payment periods (e.g., Fall and Spring semesters) of the student’s enrollment in the career pathway program, but only classes in the Title IV eligible post-secondary program component for the summer (the third payment period) because no adult education program was offered in the summer term. This student would be eligible to receive Title IV aid for all three payment periods for enrollment in the Title IV eligible postsecondary program component.

Note that as discussed in Dear Colleague Letter GEN-15-09, a student is only eligible for Title IV aid for coursework that is part of the Title IV eligible post-secondary program component. Therefore, a student solely enrolled in adult education coursework during a payment period would not be Title IV eligible for that payment period.

As noted in Dear Colleague Letter GEN-15-09, all Title IV awards are calculated using only the costs and enrollment status related to the post-secondary coursework.

For more information and a detailed discussion regarding all of the Q&A’s, please see the October 22, 2015 Electronic Announcement – http://ifap.ed.gov/eannouncements/102215EligibleCareerPathwayProgQandA.html.

150% Subsidized Direct Loan Limitations

On October 19, 2015, ED published an electronic announcement providing additional guidance on how a school determines whether a student is eligible for a Direct Subsidized Loan when the student’s Remaining Eligibility Period is less than one year, and, if the student is eligible, for what period and in what amount. This has been a common area of confusion and concern and we hope the EA helps schools and students in these situations.

An otherwise eligible student can receive a Direct Subsidized Loan when that student has a Remaining Eligibility Period that is one year or greater. However, there are special considerations if the student’s Remaining Eligibility Period is greater than zero years, but less than one year. These students can receive a Direct Subsidized Loan if:

  • The school can originate a Direct Subsidized Loan in compliance with all Direct Loan origination rules as provided in the regulations at 34 CFR 685.301, with particular attention to the applicable minimum loan period rules, as discussed below; and
  • The loan’s loan period, academic year, enrollment status, and loan amount results in a Subsidized Usage Period that is equal to or less than the student’s Remaining Eligibility Period.

The EA discusses differences between credit term programs and non-term programs, academic year and loan period considerations, enrollment status adjustments and loan amount issues. In fact we remind schools that if awarding a full annual Direct subsidized loan for a period shorter than an academic year, the subsidized usage period is generally set to one year (unless adjusted for enrollment status). In such instances, the school should give the student the most in Direct Subsidized Loan funds that the student is eligible to receive but keeping this limitation in mind. For some students, that could be just one dollar less than the annual loan limit.

For a detailed discussion regarding awarding Direct Subsidized Loans during eligibility periods less than one year, please see the October 19, 2015 EA – http://ifap.ed.gov/eannouncements/10191515DirectSubsidizedLoanLimitEA20determiningEligibitityPeriodislessthan1yea.html.

Again, I hope everyone has a safe and happy Thanksgiving and that I will see many of my SASFAA colleagues at the FSA Training Conference in Las Vegas. And remember – any questions asked in Vegas, stay in Vegas.

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