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Federal Update

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Title: Federal Update


1
Federal Update
  • GHEAC Annual Conference
  • March 4-5, 2003

David Bartnicki 404-562-6290 david.bartnicki_at_ed.g
ov
2
Electronic Initiatives
3
eZ-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

4
Common 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)

5
Common 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)

6
Common 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)

7
Common 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

8
FSA 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

9
Four 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)

10
FSA 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)

11
Quality 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)

12
New Publications
13
Federal Registers
14
Loan 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

15
Loan 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

16
Loan 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)

17
Loan 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

18
Loan 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

19
Loan 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

20
Loan 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

21
Loan 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

22
Loan 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)

23
Loan 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

24
Program 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)

25
Program 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

26
Program 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

27
Program 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

28
Program 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

29
Program 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

30
Program 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

31
Program 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

32
Program 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

33
Program 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)

34
Program 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)

35
Program 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)

36
Program 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

37
Dear 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

43
GEN-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.

44
GEN-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

47
Electronic Announcements
48
Electronic 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

49
Electronic 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..."
51
HEA 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

52
Did 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

53
Did 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)

54
Did 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.

55
Did 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)

56
Professional 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.

57
Training
  • 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.)

58
Training
  • 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

59
Personnel 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
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