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Ask a Fed: Perkins, Verification, and FSA ID

December 16, 2015

Federal Training Officer David Bartnicki recently shared these updatesbartnicki:

Title IV Updates:

October 30, 2015 Federal Register – Final Rules (Program Integrity)

A lot of schools are excited about some of the changes in the new cash management regulations and other changes in the final federal register notice posted October 30, 2015.  Please note that at this time most regulations under the 10/30/15 federal register are effective July 1, 2016. A few regulations are effective later including: posting of contracts for T1 and required T2 arrangements (September 1, 2016); contract cost information for T1 and required T2 arrangements (September 1, 2017); and financial account costs associated with T1 and required T2 arrangements in an established format (July 1, 2017). ED is currently considering early implementation for certain regulations and if approved, any new timeframes will be shared on IFAP.


Policy mentioned at the 2015 FSA Training Conference that DD Forms 214 Certificate of Release or Discharge from Active Duty can be used to verify high school completion status. GEN-15-11 indicated that the DD Form 214 could not be used to verify high school completion; however, new information shared with the Department from the military has allowed us to reconsider our position. Formal written guidance should be posted to IFAP soon.

In addition, on November 18, 2015, ED posted the suggested text language schools can use with their 2016-2017 verification process. Of course schools must use the exact language provided in the “Statement of Educational Purpose” in APPENDIX A for students who are placed in Verification Tracking Groups V4 or V5. Do not forget that the November 18, 2015 EA also contains several additional appendices including appendix D which provides a good overview of the IRS time frames to process transcripts depending on how the tax payer files, when they file and whether they owe money or not to the IRS. On December 9, 2015 ED posted a few updates to the original November 18, 2015 EA –

Gainful Employment

On November 20, 2015, ED published an electronic announcement reminding schools of the upcoming deadline for submission to the Department of their “Gainful Employment (GE) Program Transitional Certification” no later than December 31, 2015. Under the regulations at 34 CFR 668.414, an institution’s most senior executive officer must sign a certification that each of the institution’s currently eligible GE programs listed on its Eligibility and Certification Approval Report (ECAR) meets the requirements of 34 CFR 668.414(d). If an institution has submitted an E-App that resulted, or will result, in a new Program Participation Agreement (PPA) issued to the institution after July 1, 2015 and before December 31, 2015, those PPAs will have the required GE program certification included; therefore no Transitional Certification will be required.

Please see the June 11, 2015 Electronic Announcement for transitional certification language and more detailed instructions –

In addition, later this winter, NSLDS will be sending Draft Gainful Employment (GE) Completers Lists to each institution that has one or more GE Programs. Institutions should review the data for accuracy and where appropriate, challenge the draft data. For an overview of timeframes, request for data corrections, challenges and recent webinar information, please see the December 11, 2015 Electronic Announcement –


To further assist schools in their outreach efforts with the FSA ID, particularly with the start of the 2016–17 FAFSA application cycle approaching, ED created a number of FSA ID resources for school use:

  • What’s an FSA ID and Why Do I Need One?: A two-page fact sheet providing an overview of the FSA ID, where it can be used, how to create one, and some important tips.
  • Creating and Using Your FSA ID: An Overview: A PowerPoint presentation covering what an FSA ID is and who needs one, how to create an FSA ID, and how to troubleshoot common issues such as forgetting a username or password.
  • FSA ID Digital and Social Outreach: A document providing sample Facebook posts, tweets, blog content, and other digital resources that you can use in your online and social outreach.
  • How to Create an FSA ID: A tutorial video introducing the FSA ID and walking through the process of creating one. (Coming December 18.)

Please visit for a link to the outreach materials and see the December 9, 2015 Electronic Announcement for more specific guidance.

Deadline to Apply for Designation as a Title III or Title V Institution and Request a Waiver of the Non-Federal Share Requirement for the Campus-Based Programs for the 2016-2017 Award Year

I have been receiving many questions around the waiver process for the non-federal portion of FSEOG and FWS. To receive a waiver of the FWS and FSEOG non-federal share requirement, an institution must be designated by the Department of Education’s Office of Postsecondary Education Institutional Service (OPE/IS) as an eligible Title III or Title V institution under the Higher Education Act (the HEA).

OPE/IS has streamlined its Title III and Title V designation process by automatically determining an institution’s designation as an eligible institution for Title III and Title V Programs using information already available. OPE/IS will post the results on those streamlined determinations on an Eligibility Matrix on its website at Institutions that are listed on the OPE/IS Eligibility Matrix as eligible to apply for and/or as a current grantee of a Title III or Title V grant program automatically receive the waiver of the non-federal share requirement for the Campus-Based Programs for the 2016-2017 Award Year.

A notice has been published in the Federal Register dated November 19, 2015 ( announcing the details of the new automated Title III and Title V determination process.

Institutions that are not coded on the OPE/IS Eligibility Matrix as being designated as an eligible Title III and Title V institution may have the option to submit to OPE/IS a waiver requesting reconsideration of Title III or Title V eligibility. The deadline to submit such a waiver is January 4, 2016.

Historically Black Colleges and Universities (HBCUs) or Tribally Controlled Colleges and Universities (TCCUs) automatically qualify for the waiver of the Campus-Based non-federal share requirement. These waivers are granted indefinitely unless Federal Student Aid’s Grants and Campus-Based Programs division receives information from OPE/IS that the institution has lost its HBCU or TCCU status.

Please note: To qualify for a Title III or Title V waiver of the non-federal share requirement an institution (one having a unique six-digit OPEID with a two-digit extension of “00”) must submit its own annual Fiscal Operations Report and Application to Participate (FISAP). Its FISAP cannot be submitted as part of an affiliated institution’s FISAP.

For more information and contact information please see the November 23, 2015 Electronic Announcement and the November 19, 2015 Federal Register.


In light of some of the changes occurring within the Perkins programs schools are asking many questions around a student’s eligibility, especially as they relate to the new grandfather clauses. Please note that policy recently posted new and updated Q&A’s to the Perkins Q&A website on IFAP .

Some key new Q&A’s include:

AWD-Q10: For a borrower who does not meet the grandfathering provisions and who has remaining Perkins Loan eligibility for the 2015-2016 award year, is the institution permitted to change the 2015-2016 Perkins Loan’s end date to include another term or to increase the loan amount?

AWD-A10: Yes. An institution is permitted to change the end date of a Perkins Loan to include additional payment periods within the 2015-2016 award year or to increase the amount of the Perkins Loan that was originally awarded for the 2015-2016 award year for a borrower, provided that there was at least one disbursement of the 2015-2016 loan prior to October 1, 2015. [November 23, 2015]

AWD-Q11: An institution originally made a disbursement of a Perkins Loan for the 2015-2016 award year to a student who is not a grandfathered student, but later cancelled that disbursement because a subsequent ISIR requiring review was received (verification, unusual enrollment history, etc.). May the institution re-issue the Perkins Loan disbursement it had originally disbursed before October 1, 2015?

AWD-A11: Yes, if the institution’s documentation clearly shows a disbursement of the Perkins Loan was made prior to October 1, 2015, the institution may re-issue the first disbursement with a date after October 1, 2015 providing that the review of the subsequent ISIR record results in the student remaining eligible for the disbursement. Of course, a grandfathered student would always be eligible to receive any re-issued disbursements. [November 23, 2015]

AWD-Q12: If a grandfathered student who is enrolled in one program of study (e.g., Business Administration) received a Perkins Loan for the 2014-2015 award year, would the student be eligible to receive a Perkins Loan for the 2016-2017 award year if the student changes their program of study (e.g., Biology) in the fall of 2015?

AWD-A12: No. The student is not eligible to receive a Perkins Loan for the 2016-2017 award year because the student is not enrolled in the same academic program, Business Administration, that they were enrolled in when the last Perkins Loan disbursement was made by the institution prior to July 1, 2015. [November 23, 2015]

For a listing of all Q&A’s please see the Perkins Q&A website on IFAP (upper right-hand side)-

Also, please do not forget to return the Federal share of your school’s Excess Liquid Capital (ELC) by December 31, 2015. The Department attached a worksheet to calculate both the federal share and institutional share of the ELC to the GEN-15-19 Dear Colleague Letter. Please remember that any institutional share of the ELC  must be removed from the fund and returned to the institution (not placed back in the Perkins fund). For more information please see GEN-15-19 –

Transfer Students and Abbreviated Loan Periods (nonterm and clock hour programs)

For those schools with nonterm credit and clock hour programs that have to deal with abbreviated loan periods when working with transfer students, I just wanted to share some clarifications I recently received with policy.

Please note that an abbreviated loan period is not considered a regular payment period for Title IV purposes under 34 CFR 668.4, and as such, would not be used as a payment period when performing an R2T4 calculation. So when a student withdraws during an abbreviated loan period, the payment period to use within the R2T4 calculation is the regular Title IV payment periods initially established for the program to award other Title IV aid, such as Pell Grants.

In addition, if a student transfers into School B, normally School B can provide the student the difference between the loan amounts received at School A and the annual loan limit at School B’s grade level for the abbreviated loan period. However, there is an exception to this approach.   If the program at School B is less than an academic year (AY) in length, or is a remaining portion of a program that is less than an AY in length, the total loan amount the student may receive for the program at School B, for the abbreviated loan period and any subsequent loan period combined, may not exceed the statutory prorated annual loan limit for the program or remaining portion of a program.

Saying Goodbye

For those that may not know I wanted to let you know that a good friend and colleague of ours recently retired from FSA. Dan Klock recently retired after working many, many years with PLI and Jeff Baker. Many of you know Dan as the R2T4 guru or the ATB expert. Dan will be sorely missed but we wish him all the best as he retires to North Carolina to be with his wife Ginger (former FSA, as well).

I hope everyone has a safe and happy holiday season free from regulations and Title IV policies. There will be time enough to discuss those issues in the New Year!

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