The New 150% Limit on Subsidized Direct Loans How it Affects Both Your School and Your Students U.S. Department of Education March 27, 2014 NMASFAA Conference Kevin Campbell Training Officer Region VI 214-661-9488 kevin.campbell@ed.gov A copy of this presentation is on www.NMASFAA.org Please complete ED’s survey regarding this presentation: https://s.zoomerang.com/s/KevinCampbell-TX Laws and Regulations 3 Higher Education Act of 1965 has been Amended Resulting from the Moving Ahead for Progress in the 21st Century Act (MAP-21) 150% Direct Subsidized Loan Limit – Interim Final Rule Published May 16, 2013 Comment Period Ended on July 1, 2013 Revised Final Rule published on January 16 Electronic Announcement Posted on January 17 4 MAP-21 • Limits the length of time a student borrower may enjoy the subsidy on a Direct Loan • Intent is to encourage students to progress through their academic programs in a timely manner • Intent is to save money Helpful Definitions and Terms 6 Subsidized Direct Loan • DL that ED pays, or subsidizes, the interest while the borrower is in school at least half time • • Also for certain other statuses Borrower must have need to qualify • COA-EFC=Need • The subsidized interest is a benefit to the borrower and does not get repaid • Unsubsidized DL – ED does not pay the interest • Either paid by borrower while in school or capitalized into the loan itself and is paid by borrower in repayment SULA • Subsidized Usage Limit Applies • Used to describe applicable loans and borrowers Definition of Academic Year • Title IV Academic Year • The AY defined for Title IV purposes • • • AY Used to determine DL annual loan limits • • • Minimum of 900 clock hours AND 26 weeks of instruction Minimum of 24 semester/36 quarter credit hours and 30 weeks of instruction Borrower Based Academic Year (BBAY) Scheduled Academic Year (SAY) SULA usually uses the second definition • One exception First-Time Borrower and Consequences 10 First-Time Borrower Applies only to first-time borrowers as of July 1, 2013: Student who has no outstanding balance on a FFEL or Direct Loan when receiving a Direct Loan on or after July 1, 2013. Example A Student has never borrowed before Student enrolls in August 2013 Student receives a Direct Loan Student is a first-time borrower Example B Student received FFEL and Direct Loans prior to July 1, 2013 11 Student pays off all FFEL and Direct Loans in 2015 Student enrolls in 2017 Student receives a new Direct Loan in 2017 Student is a firsttime borrower Consequence 1: Eligibility Loss Borrower loses eligibility for additional Direct Subsidized Loans when borrower has received Direct Subsidized Loans for 150% of their current academic program Generally measured in time, not dollars. If eligibility is lost, borrower still eligible for Direct Unsubsidized Loans 12 Consequence 2: Interest Subsidy Loss Lost eligibility due to 150% limit Did not complete program Enrolls in program of equal or shorter length Based on enrollment in any program, not borrowing or requesting aid 13 Subsidy loss First Consequence: Loss of Eligibility for Further Subsidized Direct Loans 14 Determining When Eligibility is Lost Let’s examine the formula used for SULA: Maximum Eligibility Period All Subsidized Usage Periods 150% limit is met and further eligibility is lost when Remaining Eligibility Period is zero (or less). 15 Remaining Eligibility Period Maximum Eligibility Period Maximum Eligibility Period All Subsidized Usage Periods 150% limit is met (eligibility is lost) when remaining eligibility period is zero (or less). 16 Remaining Eligibility Period Maximum Eligibility Period • Maximum eligibility period is 150% of the published length of borrower’s current or upcoming academic program • • • • 17 Varies by program Multiply published length of program by 1.5 Measured in academic years or portions ED will calculate using school-reported information Converting Months/Weeks To Years • This is the exception where the definedTitle IV AY is used 18 Subsidized Usage Period Maximum Eligibility Period All Subsidized Usage Periods 150% limit is met (eligibility is lost) when remaining eligibility period is zero (or less). 19 Remaining Eligibility Period Subsidized Usage Period • A Subsidized Usage Period is the period of time for which a borrower receives a Direct Subsidized Loan • Calculated loan-by-loan • Measured in academic years or portions • Rounded, up or down, to nearest tenth of a year* • Includes only periods when Direct Subsidized Loan received • ED will calculate using school-reported information * *changed from IFR 20 Calculating Subsidized Usage Period Loan Period: Period of enrollment for which loan is intended 21 Academic Year: Period used to track annual loan limits (SAY/BBAY) Example 1: Usage-Credit Hour Program is semester-based. Scheduled academic year includes the fall and spring semesters. Student receives one term loan for fall semester only. Begin Date End Date Number of Days Loan Period August 27, 2013 December 21, 2013 117 Academic Year August 27, 2013 May 17, 2014 264 Subsidized Usage Period = 117/264 = .44 Years 22 Rounded to .4 Years Example 2: Usage-Clock Hour Program is 600 clock hours and 20 weeks of instruction. Scheduled academic year is 900 clock hours and 26 weeks of instruction. Student receives a subsidized DL for the program. Begin Date End Date Number of Days Loan Period August 27, 2013 January 13, 2014 140 Academic Year August 27, 2013 February 24, 2014 182 Subsidized Usage Period = 140/182 = .76 Years 23 Rounded to .8 Years Enrollment Status Exception 24 Calculated Full-time = 1.00 subsidized usage period is prorated by enrollment status ¾-time = 0.75 Proration occurs ½-time = 0.50 before rounding Clock hour and Nonterm credit hour students are all Prorate Subsidized Usage considered to be full Period based on enrollment time for this purpose status. Annual Loan Limit Exception Only circumstance where dollars are considered is when a student receives a Direct Subsidized Loan in the amount of the annual loan limit Borrow full annual loan limit Received for less than 1 AY Subsidized Usage Period = 1 Can only occur for standard-term programs or for nonstandard-term programs that are substantially equal and are each at least nine weeks in length 25 Loan Period & Academic Year • Determines the Subsidized Usage Period • Covered in DCL GEN-13-13, applies to all Direct Loans • Loan Period – period of enrollment for which borrower received loan • 26 Must be updated if student’s actual enrollment or eligibility doesn’t match originally reported loan period Loan Period & Academic Year • Academic year – period to which the annual loan limit applies • • 27 For credit-hour programs that use standard terms or non-standard SE9W terms, corresponds to calendar period of terms in SAY or BBAY For clock-hour programs or credit-hour programs that use non-standard NSE9W terms or do not use terms, corresponds to period of time required for borrower to complete a Title IV academic year’s worth of coursework (BBAY3) Updating Loan Periods • Student does not enroll for a payment period covered by the originally reported loan period • Student withdraws from a payment period and all loan funds associated with the payment period are returned (R2T4) • Student cancels all of a disbursement of a loan that is attributable to a payment period 28 Updating Loan Periods - Continued • Student is not otherwise eligible for a loan for a payment period covered by the loan period • The student (in clock-hour programs, non-term programs, and non-standard term NSE9W programs) is not progressing to the next payment period as scheduled *This is a non-exhaustive list 29 Updating Academic Years • If you have terms and use a scheduled academic year (SAY) and • • • • 30 Student is attending a program for which summer is not a “required” term, and Attends summer, and Receives a loan for summer Academic year must be updated to include the summer Updating Academic Years • Student (in clock-hour programs, non-term programs, and non-standard term NSE9W programs) is not progressing to the next payment period as scheduled • Academic year must be updated to reflect the increased time it is taking 31 Concept is based on 1:1 Ratio • • • • • • Loan Period is one academic year AY is one academic year Student receives both disbursements (Fall & Spring) Student has used one year’s eligibility for subsidized DL 1:1 ratio If student only received one disbursement AND it was less than the full years annual loan limit • Student has used ½ of one year’s eligibility for subsidized DL • ½:1 ratio Scope of Guidance • • • • • 33 Applies to all Direct Loans first disbursed on or after July 1, 2013 Applies to all Direct Loan types Applies to all students Applies to all eligible programs and coursework ED will monitor compliance with loan period and academic year date reporting Determining When Limit Is Met Maximum Eligibility Period All Subsidized Usage Periods 150% limit is met and further eligibility is lost when Remaining Eligibility Period is zero (or less). 34 Remaining Eligibility Period Remaining Eligibility Period How much eligibility a borrower has left under the 150% limit. • Accounts for Direct Subsidized Loans received for all enrollment in all programs (except teacher certification programs) • Eligibility for subsidy is lost when remaining eligibility is zero or less • ED will calculate using school-reported information 35 Example 3: Remaining Eligibility Student receives 5 full years of Direct Subsidized Loans while enrolled in a 4-year program. Maximum Eligibility Period 36 All Subsidized Usage Periods Remaining Eligibility Period Maximum Eligibility Period 6 Years All Subsidized Usage Periods 5 Years Remaining Eligibility Period 1 Year Example 4: Remaining Eligibility Student receives 3 years of Direct Subsidized Loans while enrolled in a 2 year program. Student then transfers to a 4 year program. Maximum Eligibility Period All Subsidized Usage Periods Remaining Eligibility Period After year 3 of Upon transfer to 2-year program 4-year program 37 Maximum Eligibility Period 3 Years 6 Years All Subsidized Usage Periods 3 Years 3 Years Remaining Eligibility Period 0 Years 3 Years Example 5: Remaining Eligibility Student receives 1 year of Direct Subsidized Loans while enrolled in a 2-year program. Student transfers to a 1-year clock-hour program. Maximum Eligibility Period All Subsidized Usage Periods Remaining Eligibility Period After year 1 of 2year program Upon transfer to 1year cert. program Maximum Eligibility Period 3 Years 1.5 Years All Subsidized Usage Periods 1 Year 1 Year Remaining Eligibility Period 2 Years 0.5 Years Minimum loan period length in a clock-hour program is lesser of length of program or academic year. School cannot disburse a Direct Subsidized Loan to this student. 38 Second Consequence: Loss of Interest Subsidy on Subsidized Loans Student Already Owns 39 Loss of Interest Subsidy Benefits No Remaining Eligibility Period No Completion Enroll Subsidy loss is effective on the date of the triggering enrollment 40 Subsidy loss Enrollment Types: Subsidy Loss 1 2 3 Student lost eligibility Student lost eligibility Student had remaining eligibility Enrolled at least ½ time in same undergraduate program Enrolled at least ½ time in an undergraduate program of equal or lesser length Student enrolled at least ½ time in shorter undergraduate program where usage ≥ maximum 41 Periods of Interest Subsidy Borrower with interest subsidy: In-school Grace Repay Std. Defer. Forbear. Repay IBR/PAYE* Borrower who lost interest subsidy: In-school Grace Subsidized Period Unsubsidized Period 42 Repay. – Std. Defer. Forbear. Repay – IBR/PAY E Which interest is the borrower’s? Interest accrued before subsidy loss Interest accrued after subsidy loss Subsidy loss is not retroactive to the date of disbursement or from the date of the loss of eligibility. Loss of subsidy is from the date of the enrollment that caused the loss of subsidy 43 Example 6: Subsidy Loss Student received 6 years of Subsidized Loans while enrolled in a 4 year program. Student does not complete and enrolls for a 7th year. No Remaining Eligibility Period 44 No Completion Enrolls Subsidy Loss Maximum Eligibility Period 6 Years All Subsidized Usage Periods 6 Years Remaining Eligibility Period 0 Years Subsidy Loss Yes, enrolled with no remaining eligibility and without completing Example 7: Subsidy Loss Student is enrolled in a 2 year program and received 3 years of Subsidized Loans. Student enrolls for one more semester in the same program, and then transfers to a 4-year program. Before transfer Upon transfer Maximum Eligibility Period 3 Years 6 Years All Subsidized Usage Periods 3 Years 3 Years Remaining Eligibility Period 0 Years 3 Years Subsidy Loss Yes, borrower enrolled after eligibility loss. No, borrower enrolled in a longer program. Student regains eligibility for Subsidized Loans upon transfer. Any new Subsidized Loans will have interest subsidy. Prior Subsidized Loans that lost subsidy do not regain subsidy. • • • 45 Example 8: Subsidy Loss Student received 5 years of Subsidized Loans while enrolled in a 4-year program. Student completes the program and then enrolls in a 2year program End of year 5 Upon transfer Maximum Eligibility Period 6 Years 3 Years All Subsidized Usage Periods 5 Years 5 Years Remaining Eligibility Period 1 Year -2 Years Subsidy Loss No, borrower has remaining eligibility. No, borrower graduated from prior program. 46 Example 9: Subsidy Loss Student received 5 full years of Direct Subsidized Loans while enrolled in a 4-year program. Student does not complete and then enrolls in a 2-year program. No Remaining Eligibility Period No Completion Enrolls Subsidy Loss End of year 5 Upon transfer Maximum Eligibility Period 6 Years 3 Years All Subsidized Usage Periods 5 Years 5 Years Remaining Eligibility Period 1 Year -2 Years Subsidy Loss No, borrower has remaining eligibility. Yes, transfer caused borrower to exceed max. 47 DL – Lost Subsidy • Subsidized DL that has lost subsidy is still considered a subsidized loan • Does not become an unsubsidized loan • Important for calculating aggregate DL limits Special Provisions 49 Preparatory Coursework • Preparatory coursework needed for enrollment in an undergraduate or certificate program • • Up to $2,625 in Subsidized DL for one consecutive 12-month period Preparatory coursework needed for enrollment in a graduate/professional degree or certificate program • Up to $5,500 in Subsidized DL for one consecutive 12-month period 50 Prep Coursework for Undergraduate Program • • Maximum eligibility period for preparatory coursework required for enrollment in undergraduate program • Limited to maximum eligibility period applicable to undergraduate program for which preparatory coursework is required • Enrollment in preparatory coursework does not increase the maximum eligibility period Enrollment in preparatory coursework for entry into an undergraduate program may result in borrower becoming responsible for accruing interest on existing Direct Subsidized Loans 51 Prep Coursework for Graduate/Professional Prog. • Maximum eligibility period for preparatory coursework required for enrollment in graduate/professional program • • Limited to maximum eligibility period for the undergraduate program for which borrower most recently received subsidized loan Borrower with no remaining eligibility period may not receive subsidized loans to complete required coursework • May receive unsubsidized loans 52 Prep Coursework for Graduate/Professional Prog. Enrollment in preparatory coursework needed for entry into graduate/professional program does NOT result in borrower becoming responsible for accruing interest on outstanding subsidized loans 53 Non-Credential Teacher Certification • Student enrolled in teacher certification coursework that does not lead to a credential offered by the school is eligible for Direct Loans Coursework must be required for certification by the state to teach elementary/secondary school • Student may receive up to an annual loan limit of $5,500 in Subsidized DL for teacher certificate coursework • 54 Non-Credential Teacher Certification • • • • Maximum eligibility period limited to 150% of published length of the teacher certification program Only subsidized loans received for teacher certification coursework are in included in the borrower’s subsidized usage period Enrollment in teacher certification coursework counts only against the maximum eligibility period for the borrower’s teacher certification coursework Enrollment in teacher certification coursework does not cause a borrower to become responsible for accruing interest on any subsidized loans 55 Short-Term Programs in 2013-2014 • • • • • 56 First-time borrowers are always eligible to receive their first Subsidized Loan under the 150% limit Most borrowers will not receive a second loan before schools begin using 2014-2015 COD that will track the 150% limit for schools Possible for students in short-term programs to have 150% eligibility limitation School must make own determination – can use ED developed spreadsheet More information in 150% EA #5 Short-Term Programs in 2013-2014 First-time borrowers In shortterm programs Receiving second loan for 2013-2014 School using COD for 20132014 School determines eligibility For this specific purpose only a short-term program one that is shorter than: • 1.5 years • 10 months • 40 weeks 57 Enrollment Status in 2013-2014 • Used to prorate Subsidized Usage Periods • 2014-2015: Schools will report enrollment status to COD, including three-quarter time enrollment • 2013-2014: COD does not have enrollment status and NSLDS does not have three-quarter time enrollment status • • 58 NSLDS reported enrollment status will be used - half-time if reported as “at least half-time but less than full-time” More information in 150% EA #3 Now let’s see, how much is that unsub going to be? Unsubsidized Loan Eligibility 59 Eligibility for Unsubsidized Direct Loans A student cannot receive Direct Unsubsidized Loans for a loan period until the student has received all Subsidized Loan eligibility Is the student able to receive Direct Unsub. Loan? 60 Yes Student may receive Direct Unsub. Loan No Student may NOT receive Direct Unsub. Loan Did student receive all Direct Sub. Loans for which eligible? Example 10: Eligibility for Unsub. Based on COA and EFC, a second-year dependent student is eligible for a Direct Subsidized Loan in the amount of the full annual loan limit of $4,500 Received full subsidized loan amount 61 Scenario 1 Amount Scenario 2 Amount Base amount (sub. loan) $4,500 Base amount (sub. loan) $4,000 Base amount (unsub. loan) N/A Base amount (unsub. loan) $0 Add’l amount (unsub. loan) $2,000 Add’l amount (unsub. loan) $0 Did NOT receive full subsidized loan amount Example 11: Eligibility for Unsub. Based on COA and EFC, a second-year dependent student is eligible for a Direct Subsidized Loan in an amount that is less than the full annual loan limit: $4,000 Scenario 1 Received full subsidized loan amount that he/she was eligible for 62 Amount Scenario 2 Amount Base amount (sub. loan) $4,000 Base amount (sub. loan) $3,800 Base amount (unsub. loan) $500 Base amount (unsub. loan) $0 Add’l amount (unsub. loan) $2,000 Add’l amount (unsub. loan) $0 Did NOT receive full subsidized loan amount that he/she was eligible for School Reporting to ED 63 COD Reporting Requirements Existing • Loan Period Dates • Academic Year Dates New for 2014-2015 • • • • • • • • 64 CIP Credential Level Program Length Length of Title IV Academic Year Flags for Prep Coursework Flag for Teacher Certification Enrollment Status (full, ½, ¾) Payment Period Begin Date Other Changes to COD The borrower is a first-time borrower School submits origination record to COD Subsidized Usage Period > Remaining Eligibility Period COD will reject the loan 65 Other Changes to COD • Each time school submits an origination or disbursement record COD will: • • Calculate Subsidized Usage Periods, including the new loan Inform school of borrower’s Maximum Eligibility, Subsidized Usage, and Remaining Eligibility periods • COD will also inform borrower in disclosure statement • Watch for EA in April describing the COD SULA enhancements 66 NSLDS Reporting Requirements Existing • Enrollment Status – ½ and FT New for 14-15 • • • • • • • 67 CIP Credential Level Program Length Length of Title IV Academic Year Flags for Prep Coursework Flag for Teacher Certification Enrollment Status - FT, ¾, ½ Other Changes to NSLDS • Modify professional access and student view to display 150%-related information • Modify reports available to schools to include 150%-related information • Inform Direct Loan servicers of borrowers enrollment and loss of interest subsidy • Pass information about student’s current Subsidized Usage Period and whether the student has lost interest subsidy to CPS, for inclusion on the SAR/ISIR 68 NSLDS -150% Subsidy Loan Limit The following NSLDS fields will be added to the ISIR: Added Value Subsidized Usage Limit Applies Flag (SULA) Y/N Subsidized Loan Eligibility Used (SLEU) • • • 69 000v000 These fields will be passed from NSLDS to CPS starting with 2014-2015 at the borrower level during pre-screening A SAR Comment 267 will be triggered when SULA Flag is set to Y New NSLDS Post-Screening Reason Code 25 value will be added: Subsidized Usage Applies Flag Status Change ISIR - 150% Subsidy Loan Limit The following NSLDS fields will be added to the ISIR: Added Value Subsidized Usage Limit Applies Flag (SULA) Y/N Subsidized Loan Eligibility Used (SLEU) • • • 70 000v000 These fields will be passed from NSLDS to CPS starting with 2014-2015 at the borrower level during pre-screening A SAR Comment 267 will be triggered when SULA Flag is set to Y New NSLDS Post-Screening Reason Code 25 value will be added: Subsidized Usage Applies Flag Status Change 150% Subsidy Loan Limit 71 • SAR Comment 267 • There is a limit to the total amount of subsidized federal student loans that you may receive. Please visit Studentaid.gov and select Types of Aid/Loans for more information. • Reason Code 25 will be added to the NSLDS Postscreening for a Subsidized Usage Limit Applies Flag status change. 150% Subsidy Loan Limit 72 • SAR Comment 267 • There is a limit to the total amount of subsidized federal student loans that you may receive. Please visit Studentaid.gov and select Types of Aid/Loans for more information. • Reason Code 25 will be added to the NSLDS Postscreening for a Subsidized Usage Limit Applies Flag status change. Loan Counseling 73 Entrance Counseling • Entrance Counseling regulations have been amended to include these new requirements: Possible loss of eligibility for additional Direct Subsidized Loans • How a borrower’s maximum eligibility period, remaining eligibility period, and subsidized usage period are determined • 74 Entrance Counseling • Potential for a borrower becoming responsible for all accruing interest on Direct Subsidized Loans during in-school periods, grace periods, and periods of authorized deferment AND • The impact of borrower responsibility for accruing interest on the borrower’s total debt 75 Exit Counseling • Exit Counseling regulations have been amended to include these new requirements: • • The sum of the borrower’s subsidized usage periods at the time of the exit counseling How to get information from NSLDS on whether he or she has become responsible for accruing interest on any of his or her Direct Subsidized Loans and whether the borrower is eligible to receive additional Direct Subsidized Loans Exit Counseling • • The possible consequences of receiving additional Direct Subsidized Loans for additional undergraduate programs The potential for a borrower becoming responsible for all accruing interest on Direct Subsidized Loans during in-school periods, grace periods, and periods of authorized deferment, even if the borrower does not receive an additional Direct Subsidized Loan Entrance Counseling Resources 78 Let’s Put This In Perspective! 79 Perspective ED will keep track of student eligibility • ED will notify students of eligibility issues • ED will set up a process, in the near future, for dispute resolution • ED will share eligibility data with the CPS so it appears on ISIRs and SARs • Perspective Schools will report the length of program to COD in loan origination record • Schools will ensure that students are counselled with new SULA provisions • Schools will make eligibility determinations for the remainder of 13-14 award year for first-time borrowers who pursue to “short” programs in the award year • Perspective Preparatory Coursework has special provisions • Teacher Certification, that does not lead to an academic credential granted by the school, has special provisions • Perspective Exceeding SULA will not end student’s eligibility for unsubsidized DLs • Annual and aggregate loan limits still apply • Loss of subsidy will usually not be the deciding factor for student in whether to pursue a program or not • Resources IFR Final Regs DCL GEN 13-13 Watch for Electronic Announcement in April describing the new COD releaseFAQs which will allow for SULA reporting. Three Recorded Webinars EAs QUESTIONS? E-mail: 150Percent-Questions@ed.gov Subject: Include organizational affiliation 85 Kevin Campbell Training Officer Region VI 214-661-9488 kevin.campbell@ed.gov Please complete ED’s survey regarding this presentation: https://s.zoomerang.com/s/KevinCampbell-TX