150% SULA

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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
[email protected]
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: [email protected]
Subject: Include organizational affiliation
85
Kevin Campbell
Training Officer
Region VI
214-661-9488
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