Federal Update PASFAA East/West April 16 and 18, 2013 2012-13 Deadlines Federal Register Notice, 2/28/13 • • • 2 ISIR with official EFC calculated by CPS no later than student’s end date or 9/28/13 • Process date of ISIR is school’s receipt date Corrections to 12/13 ISIRs, paper or electronic, no later than 9/21/13 Pell and Iraq-Afghanistan Service Grant disbursement records to COD no later than 9/30/13 Change to COD Disbursement Reporting Applies to 2012-13 and 2013-14 • Actual disbursements and adjustments to disbursements made on/after 4/01/13 must be submitted to COD no later than 15 calendar days after date of disbursement • Applies to Pell Grant, Iraq-Afghanistan Service Grant, TEACH Grant and Direct Loan An institution's failure to submit disbursement records within the required timeframe may result in the Secretary rejecting all or part of the reported disbursement. In addition, such failure may result in an audit or program review finding. 3 Sequestration Federal Pell Grant Program No impact to either 2012-2013 or 2013-2014 FWS and FSEOG Programs No impact on 2012-2013 allocations 2013-2014 allocations will be reduced Reflected in final allocations 5.52% decrease in 2013-2014 available funds in both FWS and FSEOG 4 Sequestration TEACH Grant and Iraq-Afghanistan Service Grant • Reductions apply only when the first disbursement of the award is made after 3/01/13 TEACH Grant awards must be reduced by 12.6 percent from the award amount the recipient would otherwise have been entitled Iraq-Afghanistan Service Grant awards must be reduced by 37.8 percent from the award amount the recipient would otherwise have been entitled 5 Sequestration Direct Loans Increased Loan fees effective for loans first disbursed on/after July 1, 2013 • Direct Subsidized and Direct Unsubsidized loan fees are increased from 1.0 percent to 1.051 percent • Example -- fee on a $5,500 loan will increase by $2.80 from $55.00 to $57.80 • Direct PLUS loan fees (parent and graduate PLUS) are increased from 4.0 percent to 4.204 percent • Example -- fee on a $10,000 PLUS loan will increase by $20.40 from $400.00 to $420.40 6 New Loan Fees • • • • • 7 New fees effective based upon date of first disbursement, not period of enrollment or award year dollars Schools must revise any loans first disbursed before July 1, 2013 that were processed with new fees • Make appropriate adjustments to students accounts Schools must cancel any loans already submitted to COD with first disbursements on/after July 1, 2013 COD will accept loans with higher fees beginning June 28,2013 No impact on loans with second/subsequent disbursements after July 1, 2013 Sequestration Direct Loan • Systems (ED and school)will need modification • FSA will include implementation time for those modifications before the new fee structure will be required • Institutions will not be liable for the difference between the 1 percent and 4 percent fees and the revised fee amounts • If needed, ED will work with the students and borrowers 8 2013-2014 Pell Grant Payment Schedules DCL GEN-13-06 • Maximum Scheduled Award is $5,645 Maximum Eligible EFC is 5081 Minimum Scheduled Award (formula) is $565 Minimum Scheduled Award (schedules) is $582 No LEU Minimum CPS Reprocessing began on 3/19/13 • • • • • 9 2013-14 Funding Pell and TEACH Grant are “records first” • COD must have accepted disbursement record before G5 will allow drawdown of funds • Schools may report up to 7 calendar days in advance of actual disbursement date • Direct Loan • School with history of “early” disbursements will receive initial Direct Loan current funding level in G5 on/about 3/25/13 • All other schools will have current funding level in June 2013 • Update to current funding level in November 2013 • 10 Pell Grant Lifetime Limits Consolidated Appropriations Act, 2012 • Limits duration of individual student’s Pell Grant eligibility to 12 semesters or equivalent • ED defines as 600% of Pell Scheduled Award • Includes BEOG disbursements back to 1973-74 • Effective for ALL students effective with 2012-13 Law prohibits funding a student in excess of 600% 11 NSLDS/COD & Pell LEU NSLDS is being updated with COD Pell LEU data daily • Warning Icons • Lifetime Limit Flag • Post-screening reason codes BUT COD IS THE SYSTEM OF RECORD FOR PELL LEU DATA!!!! 12 Pell LEU within NSLDS Warning Icons New for 2013-14 • NSLDS is sending the Pell LEU% to CPS for inclusion on the ISIR • NSLDS Professional Access website to display Pell Grant Warning Icons – “Close to Pell Grant LEU Limit” and “Meets or Exceeds Pell Grant LEU Limit” 13 NSLDS Pell Lifetime Limit Flag New for 2013-14 NSLDS will provide reason codes to reflect the new Pell LEU limits in pre and post screening • Only students who are Pell Grant eligible will be considered for post-screening with the following reason codes: Code Warning Threshold E Meets or Exceeds Pell Grant LEU Limit Greater than or equal to 600.000% C Close to Pell Grant LEU Limit Between 500.001% and 599.999% H High Percentage Warning Between 400.000% and 500.000%* N No Problem Less than or equal to 399.999% *previously between 450.000% and 500.000% 13 NSLDS Post-screening Reason Code For Pell LEU, system generated ISIR in message class IGSG13OP • 20 – Pell eligible and met or exceeded limit • 21 – No longer meeting or exceeding limit • 22 – Pell eligible and close to limit • 23 – No longer close to limit 14 16 COD Edits • • HARD REJECT in COD beginning in summer 2013 • Will prevent Pell disbursements to students with LEU greater than 600% • Will apply to 2012-13 and forward Modified COD warning edits • 177 – Pell LEU equal/greater than 450% but equal/less than 600% • 178 – Pell LEU exceeds 600% 17 Pell Grant LEU Report • 2013-14 LEU report to be delivered via SAIG – Message class is PGLEYYOP (YY is award year) – File name example PGLE14OP for 13/14 • 18 2012-13 LEU report posted to School NewsBox on COD site through 10/05/13 Cohort Default Rates FY 2011 2-year draft rates send 3/18/13 via SAIG Challenge period began 3/26/13 FY 2010 3-year draft rates sent 3/25/13 via SAIG Challenge period began 4/02/13 Challenges must be submitted within 45 days, via eCDR Appeals application, Incorrect data Participation rate index FY 2010 official 3-year rate (to be published 09/13) equal/greater 30% requires Default Prevention Task Force and plan 19 Cohort Default Rates • • • 20 For purposes of 30 day delay and single disbursement of one-term only loans, you can use a mix of 2 year and 3 year rates to get three years below 15% FY 2011 2-year rate will be last 2-year rate calculated As of 2014, we will have three 3-year rates calculated Grace Period Interest Subsidy Consolidated Appropriations Act, 2012 • Temporarily eliminates interest subsidy on Direct Subsidized Loans during 6 month grace period • Effective for new Subsidized Loans first disbursed on/after July 1, 2012 and before July 1, 2014 • COD will monitor for compliance • Will only impact students whom you report as out of school or less than half-time 21 Resolving Inadvertent Overborrowing Inadvertent student borrowing in excess of annual or aggregate loan limits ISIR reflects flags and comment codes • Student regains eligibility by Repaying excess amount in full Making satisfactory payment arrangements • Involves reaffirmation DCL GEN-13-02 21 Direct Loan & Student Attendance Student must begin attendance to be Direct Loan • eligible Failure to begin attendance in any class School must return any DL funds applied to student account Immediately notify loan servicer of non-attendance • Failure to begin attendance on a less than half-time basis No return of funds required by school or student No subsequent disbursements until student resumes at least half-time status DCL GEN-13-02 23 StudentLoans.gov For 2013-14 All FSA loan counseling tools together on this site • Entrance Counseling Subsidized, Unsubsidized, and Graduate/Professional PLUS • Exit Counseling NSLDS will continue to provide detailed exit counseling reports • Financial Awareness Counseling • New Repayment Estimator on “My Preferences” screen 24 StudentLoans.gov for 2013-2014 New features for signed-in students • New landing page with guidance to help the student select the right type of counseling • Select schools to notify from a list of associated schools • Add new schools to notify • Select preferred repayment plan in Exit Counseling • Send notifications of previously completed counseling sessions Entrance Counseling Financial Awareness Counseling 25 Counseling Reports • • 26 Posted to your School NewsBox on COD site New counseling type indicators “S” for Subsidized & Unsubsidized Entrance Counseling “P: for Subsidized, Unsubsidized, and PLUS Entrance Counseling “L” for Financial Awareness Counseling “X” for Exit Counseling StudentLoans.gov for 2013-2014 27 StudentLoans.gov for 2013-2014 28 Subsidized Loan Limitation Public Law 112-141 • Sets new time limits on Direct Subsidized Loan eligibility • Applies to “new borrowers” on/after 7/01/13 • “New borrower” is a borrower with no balance on FFEL or Direct Loan on 7/01/13 • Subsidized loan eligibility ends when student has received subsidized loans for 150% of the published length of educational program • Under certain conditions, borrower who loses eligiblity for additional subsidized loans may lose interest subsidy on subsidized loans received from 7/01/13 29 Subsidized Loan Limitation Transfers Student’s maximum time to receive subsidized loans is established based on the length of the student’s program Remaining subsidized eligibility is calculated by subtracting from maximum eligibility the time the student has already received subsidized loans 30 Subsidized Loan Limitation Example • Student receives three years of subsidized loans while enrolled in a two year AA program • Student transfers to four year program BA program • Total eligibility for four year program is 6 years • Student has three years of remaining subsidized eligibility in the four year program 31 Subsidized Loan Limitation Example • Student receives three years of subsidized loans while enrolled in a four year BA program • Student transfers to a two year AA program • Total eligibility for a two year AA program is three years • Student has no remaining subsidized eligibility for the two year AA program 32 Subsidized Loan Limitation Examples Program Length 4-Year Bachelor’s Degree 2-Year Associates Degree 1-Year Certificate Program 10 Week Certificate Program 33 Limitation on Subsidized Loan Eligibility 6 Years of subsidized loan eligibility 3 Years of subsidized loan eligibility 1 ½ Years of subsidized loan eligibility 15 Weeks of subsidized loan eligibility Ability To Benefit (ATB) Consolidated Appropriations Act, 2012 • Eliminated Title IV aid eligibility for students without a high school diploma or equivalent (34 CFR 600.2) • Effective for 2012-13 award year DCL GEN-12-01 and GEN-12-09 Exception explained in DCL • Students who were enrolled in a Title IV eligible program anytime prior to July 1, 2012, as ATB student, may continue to qualify under one of the ATB alternatives Approved ATB test Completion of six credit or 225 clock hours 34 COD & Ability To Benefit Ability To Benefit Code Tag is required field on COD records for 2013-14 and forward • Valid values are 01 – Testing Completed 02 – College Credit 04 – Home Schooled 06 – High School Diploma 07 – GED DO NOT SUBMIT VALUES OF 03 and 05 35 2013-14 CPS/FAFSA Changes • Income Threshold for Automatic Zero EFC increased from $23,000 to $24,000 • The PIN signature option will display more prominently – “Sign Electronically With My PIN” will be the default signature option for most applicants – Students/parents can choose another option for signing, and when selected, the system will display options to use PIN, print a signature page, or submit without signatures, along with definitions for each 36 Enhanced IRS DRT Questions • The format of the IRS Data Retrieval Tool filtering question will be enhanced • Question labels will be improved for clarity 37 IRS Tidbits • 2013-14 Tax Return Transcript Matrix published IFAP E.A. 3/15/13 • IRS Form 8863 – Education Credit Issue IFAP E.A. 3/18/13 38 Unusual Enrollment Patterns NOT VERIFICATION – Separate Process • Students identified based on history of receipt of Pell Grant • New ‘C’ Code added to ISIR • New Unusual Enrollment History Flag (UEH FLAG) added to ISIR • Flag value will determine needed action • Resolution guidance provided in DCL GEN-13-09 39 2013-2014 Unusual Enrollment History Flag NSLDS will add edits to identify records with unusual enrollment histories and set a new NSLDS Unusual Enrollment History Flag • Pre-Screening - Unusual Enrollment History Flag: Five flag values (N, Blank and 1- 3) 40 2013-2014 Unusual Enrollment History Flag • Values for the NSLDS Unusual Enrollment History Flag are described in the following table NSLDS Unusual Enrollment History Flag SAR C Flag? SAR Comment 1 For Federal Student Aid Use Only No N/A 2 Unusual Enrollment History 2 (Possible enrollment pattern problem, school may need to resolve) Yes 359 3 Unusual Enrollment History 3 (Questionable enrollment pattern, school must resolve) Yes 360 N Enrollment pattern not unusual (No school action required) No N/A Record not sent for match No N/A Blank 41 Description 2013-2014 Unusual Enrollment History ISIR/SAR Comment Codes • ISIR/SAR comments and the “C” Flag will be generated for flags 2 and 3 Comment No. 359 SAR Comment Your school may request additional information to determine your eligibility for federal student aid. Note: This comment will generate a SAR C flag as already documented. 360 Based upon data provided by the National Student Loan Data System (NSLDS), your school will request additional information to determine your eligibility for federal student aid and before disbursement of funds can be made.” Note: This comment will generate a SAR C flag as already documented. 42 School Action to include Action depends on whether the school is a new school for the applicant for 2013-2014. If not a new school, school not required to take any action but may look into the applicant’s enrollment history. If new school for applicant, school must take certain actions that will be developed by FSA and OPE policy. School must take certain enhanced actions that will be developed by FSA and OPE policy. 2013-14 Unusual Enrollment History Post-Screening Reason Code • CPS will system-generate a new transaction with Reason Code 24 for records that have a change in the NSLDS Unusual Enrollment History Flag value after the initial pre-screening • The new transaction will include the new value for the NSLDS Unusual Enrollment History Flag and a SAR Comment or C Flag as appropriate 51 Unusual Enrollment Patterns Resolving Unusual Enrollment History Flags • An institution must take the following steps to resolve an ISIR reported UEH Flag UEH Flag value is ‘2’: The institution must review the student’s records to determine if, during the three award year review period the student received a Pell Grant at the institution that is performing the review If yes, no additional action is required If no, the institution must follow the guidance that is provided for a UEH Flag of ‘3’ 44 Unusual Enrollment Patterns Resolving Unusual Enrollment History Flags • An institution must take the following steps to resolve an ISIR reported UEH Flag UEH Flag value is ‘3’: The institution must review the student’s records to determine if academic credit was earned at each of the institutions during the award(s) when the student received Pell Grant funds for enrollment at that institution. Academic credit is considered to have been earned if the academic records show that the student completed any credit hours or clock hours during the award year. 45 Resolving Unusual Enrollment History Flags Academic Credit Earned If academic credit was earned at each of the previously attended institutions during the relevant award years, no further action required 46 Resolving Unusual Enrollment History Flags Academic Credit Not Earned If academic credit was not earned at a previously attended institution and, if applicable, at the institution performing the review, obtain documentation from the student explaining why the student failed to earn academic credit. Determine whether the documentation supports (1) the reasons given by the student for the student’s failure to earn academic credit; and (2) that the student did not enroll only to receive credit balance funds. 47 Unusual Enrollment Patterns Approval of Continued Eligibility • If FAA approves student’s continued eligibility, the FAA may choose to – Require student to establish an academic plan Counsel student about the Pell Grant duration of eligibility provisions [Lifetime Eligibility Used (LEU)] and upcoming time limitations on the receipt of subsidized loans Denial of Continued Eligibility • If FAA denies student’s continued eligibility, the student must be provided with – An opportunity to question and appeal the decision and Information as to subsequently regain eligibility 48 NSLDS Enrollment Reporting • New record layouts must be used effective 3/31/13 • NSLDS no longer accepting SSCR for Windows software data • Removed from FSA Download site 4/01/13 • Students being added• Pell Grant only recipients beginning with 12/13 • Perkins Loan recipients at any school if you report them as in-school or in-school deferment • Reporting required only once for student who has Pell and loans or Perkins and other aid DCL GEN-12-06 49 NSLDS Enrollment Reporting New Data To Be Reported • Credential level code (GE) required when reporting Graduated – “G” • Student address • Term dates (optional) of most recent enrollment 50 NSLDS Enrollment Reporting Remember to: • Report on all students on roster. Recertify each time even if status didn’t change • Report graduation status when student completes academic program Example- Student graduates from Program A and begins Program B • If new program begins after graduation include two transactions for student on same roster • If new program begins before graduation, submit roster with graduation first. Once processed, submit new enrollment. 51 NSLDS Enrollment Reporting Remember To: • Add transfer-in students to your roster • Report anticipated graduation date for all students on roster who are enrolled • Update status on students previously reported as less than half-time 52 NSLDS - What Else Is New? • • Students may report • Own transfer and that will be added to current school’s enrollment roster • Current home address Schools may manage multiple campuses with enrollment reporting • Identify campus with six-digit OPEID • Receive either individual eight-digit OPEID rosters or combined roster 53 Experimental Sites 2013-14 New deadline is 4/30/13 for application to participate for 2013-14 award year DCL GEN-13-03 and GEN-13-08 Experiment 1 – Federal Pell Grant Program – Eligibility of students with bachelor's degrees who enroll in vocational or career programs • Experiment 2 – Federal Pell Grant Program – Eligibility of students who enroll in certain short-term training programs • Experiment 3 – Direct Loan Program – Single disbursement of a one-term loan for study abroad students 54 Experimental Sites 2013-14 Experiment 4 – Direct Loan Program – Early disbursement for study abroad students and for students enrolled in foreign institutions • Experiment 5 – Direct Loan Program – Unequal disbursements • Experiment 6 – Direct Loan Program – Limiting unsubsidized loan amounts • Experiment 7 – Direct Loan Program – PLUS Loans for parents of students with intellectual disabilities • Experiment 8 – Student Eligibility – Eligibility of students with intellectual disabilities who are also enrolled in high school • 55 FWS Community Service Waiver • Deadline for waiver request is 4/19/13, via FISAP site • School may request waiver of 7% community service requirement and/or Reading tutor/family literacy requirement • Must demonstrate that causes hardship for STUDENTS • Penalty for failing to meet community service requirements Liability in amount of difference between what should have spent and what actually spent on community service and Possible limitation, suspension, termination 56 Financial Aid Shopping Sheet • • • Developed in cooperation with Consumer Financial Protection Bureau Notify FSA of intent to use at ShoppingSheet@ed.gov Resources IFAP E.A. September 28, 2012 DCL GEN-12-17, 08/12 DCL GEN-12-12, 07/12 DCL GEN-12-10, 07/12 57 Financial Aid Shopping Sheet • If school signed Principles of Excellence, E.O. 13607, with Defense/VA – • Shopping Sheet must be provided to prospective undergrad and graduate students who are eligible for Federal military and veterans educational benefits if those students have applied for Title IV aid using the FAFSA • • Prospective means prior to enrollment Other schools may opt to use Shopping Sheet • Expected that is provided to all undergraduate and graduate students who apply for Title IV aid using the FAFSA 58 Financial Aid Shopping Sheet Cost of Attendance Elements Grants and Scholarships Net price After Grants Work Options Institutional Metrics Graduation rate under “Student Right-to-Know” 59 Student Specific Information Most recent cohort default rate Median debt for completers Loan Options Other Options Including Family Contribution Loan repayment information Contact information 59 College Scorecard College Scorecard An online tool that will make it easier for students and families to compare colleges by comparing information such as: net price; graduation rates; default rates; student loan debt; and earnings potential 60 Regulatory Activity • • • 61 Loan II Neg/Reg package −Stand alone Direct Loan regulations −Elimination of unnecessary FFEL regulations −Reasonable and affordable payments for defaulted loan rehabilitation 150% Direct Loan Subsidized Limitation Fraud Prevention −New Neg/Reg process spring 2013 Program Integrity Regulations Q&A Web Site http://www2.ed.gov/policy/highered/reg/hearule making/2009/integrity-qa.html Includes• State authorization • Repeating coursework • Credit hour definition • Ability-to-benefit • Incentive compensation • Misrepresentation • R2T4 • Satisfactory academic progress • Gainful employment 62 Items To Note On IFAP • Perkins Loan default rates for 2011-12 4/12/13 IFAP Electronic Announcement • New NSLDS Message Class Sent Via SAIG 4/12/13 IFAP Electronic Announcement • Updates to FOTW as of 4/21/13 4/11/13 IFAP Electronic Announcement • Availability of EDExpress version 2.0 for 13/14 4/10/13 IFAP Electronic Announcement • 2012-13 Verification Status Code “W” 4/22/13 will reduce disbursement 4/09/13 IFAP Electronic Announcement 63 QUESTIONS? Gregory Martin Training Officer U.S. Department of Education 215-656-6452 Gregory.martin@ed.gov 64