Title: Federal Update
1 Federal Update
- GHEAC Annual Conference
- March 4-5, 2003
David Bartnicki 404-562-6290 david.bartnicki_at_ed.g
ov
2Electronic Initiatives
3eZ-Audit
- eZ-Audit will provide schools with a paperless
single point of submission for financial
statements and compliance audits through the web,
as of April 1, 2003. - A designee from your school will simply sign on
to eZ-Audit (www.ezaudit.ed.gov), enter summary
audit and financial data directly from your
report into a web form, attach an electronic
version of the report, and hit the submit button.
- Electronic Announcements 2/5 2/19 (eZ-Audit
User Guide coming soon!) - Questions - 1-877-263-0780 fsaezaudit_at_ed.gov
4Common Origination and Disbursement
- COD replaces the Recipient Financial Management
System (RFMS) and the Direct Loan Origination
System (DLOS) starting in 2002-2003 and will
allow full participants ability to submit
campus-based data EVENTUALLY - ALL SCHOOLS process data via COD in 2002-2003
- All schools must be full participants by
2004-2005 - Pell Rounding
- Effective 12/17/2002 - if a student's Total
Payment Ceiling (Origination Award Amount)
includes pennies, a school can report exact
pennies or round up to the nearest whole dollar
(12/20/02 electronic announcement)
5Common Origination and Disbursement
- COD Website
- cod.ed.gov
- Set up a system administrator
- Send in specific info on school letterhead
- Set up additional users
- View, update, reports, change admin. options
- Electronic Ann. 6/3/02
- Advanced pay schools Pell
- Though you can submit disbursement records up to
30 days prior to disbursement date, COD provides
disbursement data to GAPS no earlier than 7 days
prior to disbursement date (may take a couple of
days to show up in GAPS)
6Common Origination and Disbursement
- 2003-2004 modifications
- EDExpress
- Full Participant in 2003-2004
- Software Modified to support XML Common Record
- Users still need to contact COD customer service
- Pell Grant Changes
- New Pell Verification Status Codes
- S Selected, but Not Verified
- Blank Not Selected
- School/Vendor Testing February/March 2003
- System Start Up April 2003
- Notify COD customer service if you want to be a
full participant for 03/04 by March 1, 2003
(Elec. Ann. 10/29/02)
7Common Origination and Disbursement
- IFAP Website (www.ifap.ed.gov)
- Common Origination and Disbursement page
- Announcements and Frequently Asked Questions
- COD Technical Reference
- Full Participant Implementation Guide
- Phase-In Participant Information
- COD Testing Guide
- COD Customer Service Telephone Numbers
- 1-800-474-7268 for Pell Grant Assistance
- 1-800-848-0978 for Direct Loan Assistance
- Email questions to CODSupport_at_acs-inc.com
8FSA Assessment Modules(Self-Evaluation Tool)
- Tools to prevent and/or identify compliance
issues - Series of questions/comments outlining major
requirements/policies needed to properly
administer the Title IV programs (checklist,
exercises, Q As, description boxes who, what,
when, where, how) - Updated with hyperlinks to Regs and the Student
Financial Aid Handbook - Interactive and noninteractive modules
- All modules have printing options
9Four Categories
- Students
- Student eligibility, Awarding aid, SAP,
Verification - Schools
- Institutional eligibility, Consumer information,
Recertification, Change in ownership, Default
Management - Managing Funds
- Disbursing aid, Reporting/Reconciling, Fiscal
management, R2T4, Perkins due diligence, Perkins
awarding and disbursements, FWS, FSEOG - Campus Needs
- Automation, Administrative capabilities (policy
and procedure manual activity)
10FSA Assessment ModulesEnhancements
- New module formats (easier to use)
- helpful icons, Q As, activities, color codes
- New modules Verification, Default Management,
Perkins awarding and disbursing, FWS, FSEOG - Will soon be an ED supported website
- Helpful hints and trouble shooting tips
- Technical assistance resources
- Effective Practice database
- Management Enhancement Worksheet
- IFAP (ifap.ed.gov tools for schools)
- Schools Portal (fsa4schools.ed.gov resources
and training)
11Quality Analysis (Verification)Tool
- FSA designed the QA Tool to help schools analyze
FAFSA application information reported on the
ISIR. - Users will import ISIR records into the tool and
then use queries and specialized reports to
obtain aid applicant data for illuminating
problematic areas, zeroing in on specific EFC
ranges, data elements, and populations. - School are able to use a series of reports that
indicate how well their verification procedures
are working - Develop verification criteria that fit its
particular population - Learn which application errors occur locally and
educate students and parents about them - Identify and eliminate verification practices
that take time but make little or no difference
in final awards - IFAP (ifap.ed.gov tools for schools)
- Schools Portal (fsa4schools.ed.gov resources
and training)
12New Publications
13Federal Registers
14Loan Issues Program Issues
- NPRM 8/6/02 (Loan Issues)
- NPRM 8/8/02 (Program Issues)
- Final Regs combined both issues
- Effective date 7/1/03 (except GEAR UP
regulations become effective 12/2/03) - ALL provisions can be implemented as of 11/1/02
- Need to use alternative methods to capture
correct data until new forms are developed - Must wait for Perkins MPN to be approved
- Required to take Attendance provision used for
all students who withdraw on/after schools
implementation date - Leave of Absence provision used for all students
that are granted a LOA on or after the schools
implementation date
15Loan Issues - FFEL, DL and Perkins
- Rehabilitation of Defaulted Loans
- Exclude from rehabilitation defaulted Perkins,
FFEL and Direct Loans on which a judgment has
been obtained - Allows for borrower subject to a judgment ability
to regain eligibility at loan holder discretion
(at least 6 consecutive monthly payments) - Clarify voluntary payments
- Promissory Note Retention
- If a promissory note was signed electronically it
must be stored electronically in accordance with
record retention requirements
16Loan Issues - FFEL, DL and Perkins
- Economic Hardship deferments
- Use the borrowers actual monthly payment amount
if the loan is scheduled to be repaid in 10 years
or less or a monthly payment amount on a 10-year
repayment schedule if the borrowers repayment
schedule is longer than 10 years - Initial and Exit Counseling
- School need not provide the counseling, but must
ensure that it is provided - Require only disclosure of average anticipated
repayment amounts (initial and exit) - Provide borrowers with information about
availability of NSLDS (website, 800 number)
17Loan Issues FFEL and DL
- Loan Limits
- A school may not link separate, stand-alone
programs to allow students to be eligible for
higher annual loan limits - A student that has completed the 1st academic
year of a program that is more than one academic
year, but less than two academic years in length,
may receive a prorated loan at the 2nd year level
for the final portion of the program - Unemployment Deferment
- Borrower can provide written certification (can
be electronic) that 6 attempts to secure
employment were made and they have registered
with a local employment agency without providing
detailed information - Consolidation
- If a consolidation loan repaid a PLUS loan
obtained for a student who died, the portion of
the consolidation loan attributable to that PLUS
loan will be discharged. - Discharge of the applicable portion of a joint
consolidation loan if one of the borrowers dies,
becomes totally and permanently disabled or
qualifies for forgiveness under the teacher loan
forgiveness program
18Loan Issues Perkins
- Master Promissory Note
- Provides for use of a Perkins MPN
- Write-Offs
- Allows an institution to write off account
balances of less than 25, and if the borrower
has been billed for at least 2 years, balances of
less than 50 - A borrower whose balance has been written off is
relieved of all repayment obligations - Transfer of Loan Fund
- Eliminate the provision allowing an institution
to transfer its Perkins loan portfolio to another
institution
19Loan Issues Perkins
- Borrower Repayment
- An institution is required to coordinate
borrowers monthly payments with other
institutions only if requested by borrower - This requirement must be explained during the
exit counseling - Copies of Promissory Notes
- Eliminate school requirement to provide borrower
with a copy of the signed promissory note (unless
requested by borrower) - Late Charges
- Schools have the option of assessing late charges
(consistently imposed on borrowers with overdue
payments) - Credit Bureau Reporting
- Institution must report an account as in default
to a national credit bureau when borrower does
not respond satisfactorily to institutions
billing procedures
20Loan Issues Perkins
- Litigation
- Review accounts for litigation once every 2 years
- 500 threshold to determine if required to
litigate - Assignment of Loans
- If a borrower is eligible for a disability
discharge, the school must assign the loan to the
Department - Optional for the Department to require an
institution to reimburse the Perkins fund if an
assigned loan is unenforceable due to an act or
omission by the institution
21Loan Issues FFEL
- Definition of Lender
- Loans held in trust by a trustee lender are not
part of the trustee lenders consumer credit loan
function - Repayment Requirements
- Increases first payment due date for a borrower
that enters initial repayment or reenters
repayment from 45 to 60 days - If a lender receives an updated enrollment status
date that is within the same month and year as
the date previously reported, the lender may use
the previously reported date - A borrower does not have to provide a written
notice to extend a repayment schedule up to the
minimum of 5 years
22Loan Issues FFEL
- Forbearance
- Allows a lender to grant a discretionary
forbearance without a written agreement (must
send the borrower a notice confirming the
agreement within 30 days) - Lender must contact a borrower with a forbearance
once every 6 months (up from 3) and provide
specific data on outstanding debt - Lender can grant a discretionary administrative
forbearance for a borrower impacted by a natural
disaster, or local or national emergency - Sovereign Immunity
- A guaranty agency that is a State agency and does
not assign to other guaranty agencies loans
affected by bankruptcy is not required to file a
proof of claim on loans it holds and may instruct
lenders not to file proof of claims on loans it
guaranteed - Claims Paid on Disability Discharges
- Guaranty agency must pay within 90 days (up from
45)
23Loan Issues Direct Loans
- Cohort Default Rate
- Borrowers included in a proprietary,
non-degree-granting institutions cohort who have
been repaying their loans under the Direct Loan
Programs income-contingent repayment plan for
360 days with scheduled payments less than 15
dollars per month and less than the amount of
interest accruing on the loan, would not be
considered to be in default when calculating the
institutions cohort default rate - Expiration of MPN
- MPNs processed on or after July 1, 2003 would
expire on the earliest of - The date the school or Department receives
borrower written notification that no more loans
can be made under the MPN - One year after the date the borrower signed the
MPN or date Department received MPN if no
disbursements made - 10 years after the date the borrower signed the
MPN or date Department received MPN
24Program Issues
- Branch Campus
- 2-year certification requirement applies to
branch campuses of proprietary institutions of
higher education and postsecondary vocational
institutions (schools can be more than one type) - Change of Ownership
- Definition of family expanded to include
grandchildren, a spouses children and
grandchildren and family members as a result of
marriage - Excluded transactions include transfers of
ownership/control (partnership/corporation/proprie
torship) to family members, OR upon death or
retirement to a person that held an ownership
interest and management role at the school for at
least 2 years (must report change to Department)
25Program Issues
- Definition of Academic Year
- Eliminates the 12-Hour rule for nonstandard and
nonterm credit hour programs - Week of instructional time is the same for all
types of programs (one-day rule) - Payment Periods
- Students required to complete one-half the weeks
in the academic year or program, as well as,
one-half the academic coursework in credit hour
nonterm programs - Students in clock hour or credit hour nonterm
programs that withdraw but return to the same
program at the same school within 180 days of the
original withdrawal, are considered to still be
in the original payment period and eligible for
any aid that had been returned
26Program Issues
- Payment Periods cont.
- Students in clock hour or credit hour nonterm
programs that withdraw but return to the same
program after 180 days, or transfer, within any
time frame, into another program either at the
same school or at another school would start new
payment periods based upon the remainder of the
program that the students have to complete (if
the remainder is one-half of an academic year or
less, the remaining period would constitute one
payment period) - Incentive Payments - 12 safe harbor activities
- 1.) 2 salary adjustments within a 12-month period
to covered school employees (cannot be based
solely on the number of students recruited,
admitted, enrolled, awarded financial aid) - one cost of living increase within a 12-month
period to all full-time employees not considered
an adjustment
27Program Issues
- Incentive Payments (12 safe harbor activities)
cont. - 2.) Payments based upon the enrollment of
students in programs that are NOT Title IV
eligible - 3.) Payments for securing business contracts to
provide education/training to various companies - The company must pay 50 or more of tuition and
fees - Cannot be based on the number of company
employees enrolled or the amount of revenue
generated - Institutional representative cannot have any
contact with the company employees - 4.) Profit-sharing and bonus payments to
substantially all full-time institutional
employees (or within an organizational level) - Similar payments or based upon same salary
percentages
28Program Issues
- Incentive Payments (12 safe harbor activities)
cont. - 5.) Payments based upon students completing a
program, or completing one academic year of
credit (at your institution) for a longer program - 6.) Payments for clerical pre-enrollment
activities - Soliciting students for interviews is considered
recruitment - 7.) Payments to supervisors who do not directly
manage employees that are involved in
recruitment, admissions, enrollment, or financial
aid - 8.) 100 token non-cash gift to alumnus or
students annually - 9.) Profits based upon an employees ownership
interest - 10.) Payments to a service provider for
Internet-based recruitment and admission services
29Program Issues
- Incentive Payments (12 safe harbor activities)
cont. - 11.) Payments to third parties for services other
than recruiting, admissions, enrollment or
financial aid services - 12.) Payments to third parties for recruiting,
admissions, enrollment or financial aid services
as long as compensation is based upon the same
limitations that apply to the institution - Institutions Required to take Attendance
- Institution is considered required to take
attendance if an outside entity specifically
requires attendance taking - If only required to take attendance for a portion
of students, attendance records would only be
required for those students - If required to take attendance for a limited
period of time, attendance records would only be
required for the limited period of time
30Program Issues
- Institutions Required to take Attendance cont.
- If an institution administratively withdraws a
student from all classes, the student officially
withdrew as of the date of the administrative
withdrawal - If through a census on a certain date, all of a
students instructors indicate that the student
is no longer enrolled, the student is considered
to have officially withdrawn as of the census
date - Leaves of Absence (LOA)
- Allows multiple LOAs, as long as the total number
of days for all leaves do not exceed 180 days
within a 12-month period - Requires (via school LOA policy) student to state
leave reason
31Program Issues
- Leaves of Absence (LOA)
- Clarifies that if a student returns from a LOA
and repeats prior coursework - - student cannot incur any additional charges
- Preparatory/repeated coursework not eligible for
Title IV - For R2T4 purposes, still considered to be on a
LOA until the student starts attendance where the
LOA began, except in a clock hour or nonterm
credit hour program, the student need not
complete the exact same coursework he or she
began prior to the leave - Overpayments
- Students not liable for Perkins or Title IV grant
overpayments that are less than 25 - Student is not liable for an overpayment if the
school is liable - Provide students with an opportunity to object to
any overpayment determination
32Program Issues
- Ability to Benefit Tests
- Eliminates the 12 month expiration rule for ATB
tests - School must obtain the results of an approved ATB
test from the test publisher or assessment center
- Late Disbursements
- Increase late disbursements from 90 to 120 days
(applies to post-withdrawal disbursements as
well) - The Department can approve late disbursements
beyond 120 days if the student is not at fault - School must make or offer a post-withdrawal
disbursement - School must make or offer a late disbursement to
a student that completed a payment period or
period of enrollment
33Program Issues
- Late Disbursements cont.
- Eliminates the SAR/ISIR requirement for a late
disbursement of a PLUS loan (student must still
meet all eligibility rules) - Students eligibility for a late Pell Grant
disbursement would be based on the Department
processing a SAR/ISIR with an official EFC while
the student was still eligible (still have to
receive SAR/ISIR before actual disbursement) - Notices and Authorizations
- Eliminates the requirement that an institution
confirm the receipt of a notice sent
electronically (crediting loan funds)
34Program Issues
- Timely Return of Funds
- Must return funds within 30 days after the date
of the institution determined the student
withdrew - Funds are returned when
- deposited in Federal funds account (i.e.
Perkins), - EFT transfer initiated,
- electronic transaction with FFEL lender
initiated, OR - a check is issued (must be endorsed within 45
days) - School can ask the Department to reconsider a
finding of returning funds late due to
exceptional circumstances or auditor/reviewer
error (must show would not have exceeded the 5
threshold had it not been for the exceptional
circumstances or error)
35Program Issues
- Timely Return of Funds cont.
- Letter of Credit (LOC) is due 30 days after the
Department, IG, or guaranty agency issues a
preliminary report with an error of more than 10
(if error rate is 10 or less, LOC would be due
30 days after the final report, if required) - School not required to submit a LOC of less than
5,000 (must have cash reserves of at least
5,000) - Department considers an institution that makes 2
late returns to still be in compliance with the
reserve standard - FWS at For-Profit Schools
- Expand definition of student services to include
job placement, assisting instructors in
curriculum related activities (i.e. teaching
assistant) and security (still require
non-community service jobs to provide student
services that are directly related to the FWS
students training or education)
36Program Issues
- FWS at for-Profit schools cont.
- A service would be considered a student service
if the service provides a benefit either directly
or indirectly to current students - Facility maintenance, cleaning, purchasing, and
public relations jobs are NOT considered student
services - Work in admissions or recruitment still
prohibited - GEAR UP Program
- Eliminate requirement that an institution award
student financial assistance in an established
order for students who are eligible for a GEAR UP
scholarship - A GEAR UP scholarship, along with Title IV aid or
other assistance, may not exceed the students
Cost of Attendance
37Dear Colleague Letters
38- GEN-02-10 (Nov. 02)
- Unless a school is specifically informed
otherwise, all schools participating in the FFEL
or Direct Loan programs that are located in the
United States may allow their student and parent
borrowers to use the multi-year feature of the
MPN. (Foreign schools need to get Dept. approval) - Effective for FFEL loans certified by a school
on or after 3/1/2003 - Effective for 2003-2004 Direct Loans processed
after the 2.0 Release of the Common Origination
and Disbursement System - Institutions, lenders and borrowers are not
required to use the multi-year feature of the MPN
- Will be extended to the use of the Perkins MPN
39- GEN-02-11 (Nov. 02)
- The Department considers that a home-schooled
student is beyond the age of compulsory school
attendance if the State in which the institution
is located does not consider the student truant
once he or she has completed a home-school
program. - Under the student eligibility provisions of
section 484(d)(3) of the HEA, a student who does
not have a high school diploma or GED is eligible
to receive Title IV, HEA program assistance if
the student "completes a secondary school
education in a home school setting that is
treated as a home school or private school under
State law." - An institution may accept a home-schooled
student's self-certification that he or she
completed secondary school in a home school
setting, just as it may accept a high school
graduates self-certification of his or her
receipt of a high school diploma.
40- GEN-03- 02 (Jan. 03)
- (G-03-344
L-03-238) - Federal Family Education Loan (FFEL) Program
loan holders must respond to Consolidation Loan
verification requests within 10 business days. - Loan holders must, within 10 business days
after receiving a request for loan
certification, provide the requesting lender
with the requested certification information or
a reason why it is unable to provide the
information. - 34 CFR 682.209(j) 34 CFR 685.220(f)(1)(i)
41-
-
- GEN-03-03 (Feb. 03)
- (G-03-345
L-03-239) - FFEL PLUS MPN
- Designed for a parent borrower to use as a
multi-year note for one dependent student - When must a new MPN be signed?
- Different lenders (unless result of a merger or
acquisition, or if the earlier loans are sold and
the acquiring lender assumes the right to offer
subsequent loans under the PLUS MPN) - A different parent chooses to borrow a PLUS Loan
for the same dependent student - A separate PLUS MPN must be completed for each
dependent student - At the borrower, school or lenders request
42-
-
- GEN-03-03 Cont.
- Each loan received under a PLUS MPN is a
separate and distinct loan. The terms (i.e.,
interest rates, fees) applicable to each loan are
dependent on the terms in effect at the time each
loan is made. - Before making each PLUS Loan, the parent must
indicate to either the school, the guarantor, or
the lender the PLUS Loan amount that he or she
wants to borrow which can be obtained on - The school certification form
- Separate PLUS loan amount request form
- Parent response section on the institutions
financial aid award letter - Documented telephone or electronic requests
43GEN-03-03 Cont.
- Expiration Conditions
- date the lender receives written notification
from the parent borrower asking that a previously
signed PLUS MPN no longer be used - Twelve months after the date the original PLUS
MPN was signed if no disbursements were ever made
under that MPN - Ten years from the date the parent signed the
PLUS MPN, or the date the lender receives the
PLUS MPN - PLUS Credit Report
- By signing the PLUS MPN, the parent applicant
acknowledges that the lender will review the
parents credit history - If the parent borrower requests additional funds
for an existing loan period (resulting in a loan
amount adjustment, not a new loan), the lender is
not required to obtain a new credit report.
44GEN-03-03 Cont.
- Endorser
- Any loan for which an endorser is required, must
be made under a new PLUS MPN, with a new Endorser
Addendum, because the PLUS MPN becomes a
single-loan promissory note when an endorser is
used - Endorser is liable only for the specific loan or
loans he or she agreed to endorse - PLUS MPN may be used for loan periods beginning
on or after July 1, 2003 - Must be used for all Federal PLUS Loans for loan
periods beginning on or after July 1, 2004, or
for any loan certified on or after July 1, 2004,
regardless of the loan period - MPN and other forms attached to DCL
45 Direct Loan Bulletin-03-07
- Direct Loan PLUS MPN
- Most requirements similar to FFEL PLUS MPN
- Effective with any Direct PLUS Loan made for the
2003-2004 year (ID number includes 04) - If a school is not authorized to use or chooses
not to use the multi-year feature of the Direct
PLUS MPN, it may make multiple Direct PLUS Loans
under a single Direct PLUS MPN within the same
academic year (enrollment period for FFEL) - Must have an active confirmation process for
Direct PLUS Loans made under the multi-year
feature of the Direct PLUS MPN - For operational business rules related to Direct
Loan MPN, please refer to the 2003-2004 COD
Technical Reference Vol. II, Section 1 (Full
Part.) or Vol. IV, Section 1 (Phase-In Part.) - MPN and other forms attached to DLB
46- CB-02-12 (July 02)
- Electronic versions of the Federal Perkins Loan
Program (Perkins eNotes). - Perkins eNotes should be used in conjunction with
the Standards for Electronic Signatures in
Electronic Loan Transactions - Dear Partner
Letter GEN-01-06 - Contains attachments for open-end and closed-end
Notes in PDF and HTML formats - Questions - Neil Sattler at (202) 377-3513
- P-03-1 (Feb. 03)
- 2003-2004 Pell Payment and Disbursement
Schedules - Maximum - 4050 Minimum - 400
- Maximum EFC to receive Pell - 3850
-
47Electronic Announcements
48Electronic Announcements
- Electronic Cohort Default Rate (eCDR)
- Electronic Announcement 2/3/03
- 2001 Draft Cohort Rates available 2/18/03
- Cohort default rate challenge timeframes begin on
the sixth business day after 2/18/03 - eCDR package - a cover letter, a reader-friendly
loan record detail report, and an extract-type
loan record detail report - All domestic schools not already signed up for
eCDR must sign-up at www.sfawebenroll.ed.gov by
June 1, 2003 - Questions - FSA.schools.default.management_at_ed.gov
or via phone at 202-377-4259 - Electronic Announcement 2/24/03
- eCDR Download and File Reviewing Instructions
49Electronic Announcements
- Resources/References
- Electronic Announcement 2/19/03
- a new document called "Sources of Assistance for
Schools" (sfadownload.ed.gov) - phone numbers, e-mail addresses, Web site
addresses, etc. will be updated monthly as needed - Resources for Blind and Visually Impaired
Students - Electronic Announcement 2/6/03
- Aid Audio Guide, Braille publications, screen
readers - Closed School Guide
- Electronic Announcement 1/28/03
- Provides information on how to assist students,
Teach Outs, Transfers, Approving
Locations/Programs, Aid Eligibility - State Authorizing contacts
50"In Case You Didn't Know..."
51HEA Reauthorization
- HEA expires 9/30/03 (automatic 1-year extension)
- House Committee has held some hearings
- Senate Committee may not start working on
reauthorization until 2004 - Department of Education, associations,
organizations, etc. provide proposals, comments,
issues to Congress for consideration - Big issues annual loan limits, origination fees,
consolidation loans and student loan interest
rates - Technical amendments are separate from
reauthorization
52Did You Know?
- GEN-01-13 Military Mobilization and R2T4
- Institutional Charges and Refunds
- We strongly encourage schools to provide a full
refund of required tuition, fees, and other
institutional charges, or to provide a credit for
future charges (still use charges initially
assessed student in R2T4) - If you decide NOT to assess any charges, R2T4
still applies (unless the student never actually
began attendance no-show- GEN-00-24) - Return of Title IV Funds Treatment
- If a Title IV eligible student withdraws because
of being called to active duty, or has been
otherwise impacted by the military mobilization,
the school must perform the Return of Title IV
Funds - If those calculations result in the school being
required to return funds to one or more of the
Title IV programs, it must do so - An institution is not required to collect an
overpayment of grant funds for such a student,
and therefore, is not required to contact the
student, notify NSLDS, or refer the overpayment
to the Department
53Did You Know?
- Sample R2T4 policy summary 02/03, FSA HDBK,
Vol. 2, pages 158-159 - Low income edit (ISIR) removed for 03/04
- Students are NOT automatically selected for
verification based SOLEY on low income - Debit Cards - Schools are prohibited from
charging students a fee for delivering Title IV
FSA funds. If a school delivers FSA funds to
students by crediting funds to a school issued
debit or smart card, the school may not charge
students a fee for making withdrawals of FSA
program funds from that card (02/03 FSA HDBK,
Vol. 2, page 86) - PPA/ECAR schools will now be able to print and
view their Program Participation Agreements and
Eligibility and Certification Approval Reports
online at www.eligcert.ed.gov (EAPP)
54Did You Know?
- Tax preparer signature - you may accept a paper
return on which the tax preparer has stamped,
typed, or printed her name and SSN or EIN (02/03
FSA HDBK, Application/Verification Section, Page
46) - Veteran- Applicants for TIV aid who have been
members of the U.S. Armed Forces and whose
Character of Service is anything but
"dishonorable" meet our definition of an
independent student. Unlike the VA for VA
benefit purposes, there is no minimum amount of
time that the member of the Armed Forces must
have served to meet our definition as an
independent student. However, the distinction
regarding training versus active duty IS made for
members of the Reserve and National Guard.
Members of the Guard or Reserves called into
active duty must serve in other than a training
capacity and have a Character of Service other
than "dishonorable" to meet ED's definition of an
independent student for Federal student aid.
55Did You Know?
- 30 Day Delay - loan proceeds delayed for 30 days
for students that are first-time borrowers (never
borrowed) and first-year (freshman)
undergraduates in a program of study at your
institution (GEN-90-41) - High School Students - A student enrolled in
elementary or secondary school is not eligible
for aid from the FSA programs, even if she is
simultaneously enrolled in an eligible
postsecondary program. A student is considered to
be enrolled in a secondary school if she is
pursuing a high school diploma. A student who has
completed the diploma requirements but has not
yet received a diploma is still considered to be
enrolled in secondary school if she is taking
postsecondary coursework for which the high
school gives credit. - A student still enrolled in high school is not
eligible for TIV aid even if they meet the high
school equivalent requirements (ATB, etc.)
(02/03, FSA HDBK, Vol. 1, page 3)
56Professional Judgment (PJ) (02/03 FSA HDBK,
Application/Verification, page 28, 62)
- Adjusting data elements used to calculate EFC
- Dependency Overrides
- Adjusting Cost of Attendance
- Reasonable decisions on a case-by-case basis
- Adequate Documentation supporting unusual
circumstances - Examples include high medical expenses,
unemployment, high child care costs - Unreasonable judgment includes reducing income
based on vacation expenses or tithing - However, none of the conditions listed below,
singly or in combination, qualify as unusual
circumstances or merit a dependency override - 1) Parents refuse to contribute to the students
education - 2) Parents are unwilling to provide information
on the application or for verification - 3) Parents do not claim the student as a
dependent for income tax purposes - 4) Student demonstrates total self-sufficiency.
57Training
- 2003 Fundamentals of Title IV Administration
- All training held in the RTFs (formerly Precert
Training) - Boston (3/10-14), Seattle (4/28-5/2), Dallas
(5/5-9), Philadelphia (6/9-13), Denver (7/21-25),
San Francisco (8/18-22), Chicago (9/15-19),
Atlanta (9/29-10/3), Kansas City (10/27-31), and
New York City (11/17-21) - EDExpress Training (Pell and Direct Loan)
- Greensboro AT, NC (5/21-22), RTF, Atlanta
(5/28-29), Erwin Tech, Tampa (6/26 Pell only),
RTF Atlanta (7/9-10) - Cash Management Summer/Fall 2003 (August,
Sept., Nov.)
58Training
- FSA Videoconferences
- 10/24/2002 - FSA Application Processing System
(ANN-02-05) - www.edvideo.walcoff.com (also contains archived
videos) - FSA Coach (http//fsacoach.ed.gov)
- 2001-2002 On-line (ANN-02-04) 02/03 soon
- Register (New on-line features ID password)
- www.ed.gov/offices/OSFAP/sfau/index.html
- www.ifap.ed.gov
- Technical 602-282-8450 Register 202-377-3941
- Registration User Guide
59Personnel Changes
- Yolanda Blackman
- New Training Officer in Region IV
- Started January 2003
- 404-562-6291
- yolanda.blackman_at_ed.gov
60 Federal Update
- GHEAC Annual Conference
- March 4-5, 2003
David Bartnicki 404-562-6290 david.bartnicki_at_ed.g
ov