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Ask a Fed:Verification, GE, Pell Recalcs, and More

September 19, 2016

Federal Training Officer David Bartnicki recently provided these updates.bartnicki


ED posted an electronic announcement on July 29, 2016 providing schools with the suggested text for the 2017-18 processing year. The suggested text may be used by schools in developing their verification documentation. Please remember, however, that 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.

In addition, ED published the long awaited GEN-16-14 Dear Colleague Letter that addresses how ED will handle 2015 tax and income information differences between 2016-17 and 2017-18. CPS will identify conflicting information between two years that once resolved would have significant impact on an EFC. If deemed conflicting information by ED, a C-flag will appear with a code of 399 ONLY on the 2017-18 ISIR. If no code 399 appears, the school is not required to resolve income and tax information, but normal conflicting information rules applies for other areas (i.e. citzenship, etc.). When comparing ISIRs, any required adjustments must be corrected and any potential overpayments resolved. Please see GEN-16-14 for more information.

Third-Party Servicers

Many of you have asked questions about what constitutes a third-party servicer for Title IV purposes, and if you have to report certain entities to ED as a third-party servicer. In addition, several businesses have asked me if their services would cause them to be deemed a third-party servicer by ED. I am happy to announce that ED recently provided GEN-16-15 which contains over 20 Q&As addressing common issues related to third-party servicers.

The DCL provides the following information:

  • Key definitions, including a chart with examples of functions and services that are or are not considered to be 3rd party servicing
  • Servicers cannot be located outside the U.S. or owned by non-U.S. citizens/nationals or permanent residents
  • Information on what constitutes working on behalf of an institution
  • Compensation not required to be a 3rd party servicer
  • Written contracts between school and 3rd parties servicers are required
  • Third-party servicer contract requirements and restrictions
  • Notification requirements to ED
  • Data protection requirements (PII)
  • Third-party servicer audit and audit letter requirements and timeframes

For more information, please review GEN-16-15.

Campus Policing

GEN-16-17 provides information and resources to ensure schools are properly policing campuses, adhering to Cleary Act requirements and meeting all Civil Rights obligations. The DCL contains links to the updated Department’s Handbook for Campus Safety and Security Reporting, the President’s Task Force Report, plus several other websites and contact information. We remind schools that the Department’s Campus Security webpage can be found at For more information, please review GEN-16-17.


DON’T FORGET – as mentioned in the July 25, 2016 electronic announcement, the eCampus-Based application for the Fiscal Operations Report for 2015-2016 and Application to Participate for 2017-2018 (FISAP) are now available on the eCampus-Based (eCB) website. The deadline for the electronic submission of the FISAP is 11:59 P.M. (ET) on September 30, 2016.

Any questions should be directed to the Campus-Based Call Center – 877-801-7168.

Gainful Employment

Please remember that all schools with GE programs need to report their 2015-16 program and student GE data by October 1, 2016. To assist with this process, ED posted an electronic announcement on September 13, 2016 – GE electronic announcement #89.

The EA contains information and tips for reporting 2015-16 GE data by October 1, 2016 and correcting previously submitted data. Tips on reporting GE data include:

  • Private loans, tuition/fees, books/supplies/equipment
  • Institutional debt
  • Changing CIP codes
  • Adding new programs

Please note: GE Completers List corrections approved by ED should be corrected by the institution by October 1, 2016. The GE Completer List correction process does NOT update the GE records originally submitted to NSLDS.

In addition, as mentioned in the August 31, 2016 electronic announcement #87, the program tracking functionality in NSLDS has been removed. For this reporting cycle schools should review disbursement records sent to the Common Origination and Disbursement (COD) System, enrollment records sent to NSLDS, and their GE certifications that were submitted to FSA’s School Participation Division to ensure all required GE reporting is done by October 1, 2016.

ITT Students

Lots of schools are calling me asking for information about helping ITT students. We appreciate all of your efforts to assist these students. ED posted an electronic announcement on September 15, 2016 with our most recent guidance, links, websites and contact information surrounding the recent ITT closures.

Pell Recalculations and Modules

Policy recently provided guidance surrounding Pell recalculation policies and modules that I wanted to share.

In general, an institution can only disburse Pell Grant funds for classes that a student has started. The institution may have a policy to recalculate a student’s enrollment status when the number of classes in which a student is enrolled within the term (see 34 CFR 690.80(b)(1)). The policy must be written and needs to be consistent for increases or decreases.

There are two general concepts that apply to recalculation policies and programs offered in modules:

  1. If an institution provides a program offered in modules, the institution can choose to maintain a recalculation policy that applies to coursework within a given module, or it can choose to maintain a recalculation policy that applies regardless of whether the student enrolls during a given module;
  2. If the institution maintains a recalculation policy that is specific to coursework in a module, that recalculation policy is not taken into account unless the student begins attendance in at least one course during the module to which the recalculation policy applies.

Therefore, if an institution maintains a recalculation policy that provides for recalculation dates that are specific to modules within a payment period, the recalculation policy only applies to modules in which a student has begun attendance. However, if an institution’s policy does not specify that a recalculation date is specific to a module, and simply specifies multiple recalculation dates within a payment period, then a student’s Pell Grant enrollment status must be reviewed and adjusted at each recalculation date regardless of whether the student enrolls in coursework during a module.

As always, if any recalculation date does apply, on that date the school must take into account all adjustments to the enrollment status, both increases and decreases, up to that point.

Student Complaints

FSA recently launched a new online feedback system. The new online portal will allow students, parents, borrowers, and others to:

  • Submit complaints and compliments
  • Report allegations of suspicious activity related to their experience with federal student aid programs
  • Receive timely, meaningful resolution to their issues

The feedback system can be found at If any students want to file a complaint with the Department, please direct them to our new online feedback system.

I hope to see many of you on the fall conference and workshop circuit as I travel throughout the southeast.

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