Federal Update
2015 ISFAA Winter Conference
Angela Smith, Training Officer
U.S. Department of Education
2
2015-16 Verification
•
Same verification items and Verification Tracking
Groups to be verified as 2014-15
• Applicant will remain in original 2015–16
Verification Tracking Group for the entire award
year record
3
2015-16 V4/V5 Tracking Results
•
The V4/V5 tracking process in FAA Access that
began in the 2014-15 processing year WILL
CONTINUE for 2015-16.
•
Make sure you’re selecting the proper award year for which
you are providing results
https://faaaccess.ed.gov
4
2015-16 V4/V5 Tracking Results
Whom to report:
Applicant for whom school received an ISIR with a Verification Tracking
Group of V4 or V5 AND for whom school requested verification
documentation
Do NOT include students the school selected for verification of
identity or high school completion status
When to report:
Within 60 days following the institution's first
request to the student to submit the required V4 or V5 identity and high
school completion documentation.
Changes to previously submitted Identity Verification Results must
be updated within 30 days
5
October 17, 2014 Electronic
Announcement
•
Alternative documentation allowed when tax filer
RECENTLY requested but unable to obtain an IRS Tax
Return Transcript using the IRS paper or on-line request
process
•
•
No alternative documents for telephone requests
Exception not permitted for transcripts unable to be obtained simply
because the IRS has not had time to process the data due to a
recent filing
For 2014-2015 award year
6
2014-15 – Transcripts Unavailable
•
In instances where tax filer recently requested a
IRS Tax Return Transcript and was unsuccessful:
•
•
Signed copy of relevant 2013 IRS tax return
AND
Communication from IRS stating request unsuccessful
– Letter from IRS (SIGNED AND DATED BY TAX FILER); or
– Screen shot print (SIGNED AND DATED BY TAX FILER)
•
AND
Completed and signed IRS Form 4506 T-EZ or 4506-T
listing institution as third party
•
7
Send to IRS only if doubt paper tax return accuracy
8
FAFSA Definition of Parent
•
Current definition: biological or adoptive
• New definition will be: biological, adoptive or
person that the state has determined to be the
parent
• Clarifying who is not a parent
•
9
List of people who are not considered a parent unless
they have legally adopted the student will now include
widowed stepparent
Foster Care Screening Question
•
Require all FOTW applicants to tell us if they are
or were in foster care to ensure people entitled to
benefits receive them
• Separate from current dependency question
10
•
New question will be earlier in application process
•
“Yes” answer will result in SAR comment with
hyperlink to information regarding benefits, and
hyperlink will also appear on FOTW confirmation
page
School Listing
•
School selection page
•
•
School selection summary page
•
11
Adding text to tell students that all schools they
select will receive the list of selected schools
Adding text to tell students that for federal
purposes it does not matter in what order
schools are listed but it may be important for
state purposes
Separated – FAFSA Guidance
For FAFSA purposes, a married couple is separated if the
couple is considered legally separated by a state, or if the
couple is legally married but has chosen to live separate
lives, including living in separate households, as though
they were not married. If you and your spouse are
separated but living together, select “I am married /
remarried,” not “I am separated.”
NOTE: When two married persons live as a married
couple but are separated by physical distance (or have
separate households), they are considered married for
FAFSA purposes.
12
IRS DRT – Amended Returns
•
Unusually large number of applicants
report filing an amended return
Rewording question to specifically ask if they
have filed a 1040-X amended return
• Help text will also refer to the 1040-X and make
clear what the 1040-X is
•
13
IRS DRT – Timing Issues
•
Some applicants who are eligible to use
the tool find there is no data to import due
to owing taxes
• New
hyperlink statement: “How you filed your
taxes can affect if tax information is available
to import.”
•
14
Hyperlink will lead to help text that explains
timing for tax information availability
Help Text Changes
•
Clarifying gender question to state we are asking
about gender at birth
•
Adding help text to Citizenship Status question
regarding DACA that explains:
•
•
15
that they should answer that they are neither citizens or
eligible noncitizens
that although they can receive Social Security numbers,
they are not eligible for Title IV
16
Introducing the FSA ID
The FSA ID will modernize access for students, parents and
borrowers to FSA systems
•
FSA is adopting the best practice of using a
username and password instead of personal
information
• The FSA ID
•
•
•
•
•
17
Requires users to enter less information (2 fields
instead of 4)
Provides more secure access to user’s
information
Links to PIN information during registration
Offers self – service capability (name change)
The FSA ID (username and password) will
replace PIN for students, parents and
borrowers accessing FSA systems starting
April 26, 2015
New FSA ID login
Will be
updated
Old PIN login
Introducing the FSA ID
Users still click the Sign in button. This directs them to the FSAID login
page. Once they enter their FSA ID, they are directed back to the
application landing page
Will be
updated
18
Introducing the FSA ID
•
What happens for new user?
•
•
•
What happens if I have a PIN already?
•
•
•
During account creation, the user will be asked for their PIN.
As long as the PIN information matches their other information, the
account will be linked to the FSA ID account
Will the changes affect a user’s ability to access previous
FAFSA submissions?
•
19
Registration requests the same required information as PIN
New users will be directed to the registration page to create an FSA
ID (username and password) similar to today’s PIN creation page
If the user links their PIN, they will have access to previous FAFSA
submissions
Introducing the FSA ID
•
Can users still access FAFSA by providing their Last name, SSN and
DOB?
•
•
•
Will customer support change?
•
•
Customer support will not change. Similar to PIN, all users will be directed
to call the FSAIC helpdesk for login related issues
Will my FSA access to other people’s information require a new
username and password?
•
20
FAFSA functionality will not change except that the FSA ID will replace the
PIN information
Users will not be able to sign or correct their application without their FSA
ID.
This is only for users who are accessing their own information such as
students, parents, borrowers and applicants
FSA ID Communication to Students
•
•
ED to post high-level information about the FSA ID on each impacted
website in mid-April 2015
As of April 26, 2015, users who arrive at impacted websites will be
directed to a link to register for their new FSA ID
•
registration process should take less than seven minutes
•
Later this winter, ED will post a step-by-step guide about registering
for an FSA ID on IFAP for schools to share with students, parents,
and borrowers
•
All information will stress there is nothing a user can or should do
prior to implementation on or after April 26, 2015
21
Defense of Marriage Act
(DOMA)
GEN-13-25
22
Implementation of the Supreme
Court’s DOMA Decision
•
Any legal marriage recognized by a jurisdiction in which it was
celebrated (50 states, D.C., U.S. territory, or foreign country) will be
recognized for Title IV purposes regardless if same or opposite sex
marriage or where couple resides
•
Applies to students and parents of dependent students
•
Applies to student attending institution located in a jurisdiction
that recognizes same-sex marriage and in a jurisdiction that does
not recognize same-sex marriage
•
Applies only to marriages - not domestic partnerships, civil
unions, or similar formal relationships recognized by states
•
Relevant to all FAFSA questions concerning marriage
23
Implementation of the Supreme
Court’s DOMA Decision
•
GEN-14-14
•
•
24
A stepparent, who meets the definition of “parent” in 34
CFR 668.2, and who is of the same sex as the
dependent student’s biological or adoptive parent, may
apply for a Direct PLUS Loan if the stepparent and
parent were legally married
Circumstances where a borrower’s spouse information
is taken into consideration for an income-driven
repayment plan, the term “spouse” includes a same-sex
spouse if the borrower and spouse were legally married
Implementation of the Supreme
Court’s DOMA Decision
•
GEN-14-15
•
•
25
ED discusses section 135 of the HEA which requires a State that
receives assistance under the HEA not to charge a member of the
armed forces (and includes spouse or dependent child) who is on
active duty for more than 30 days and whose domicile or permanent
duty station is in the State more than the in-State tuition rate for
attendance at a public institution of higher education.
A “spouse” to whom a public institution of higher education must
extend in-State tuition benefits includes a spouse in a same-sex
marriage who is legally married to a member of the armed forces
26
Enrollment Reporting Transition
•
All schools must have implemented the new
enrollment reporting processes and file layouts
by October 1, 2014
•
•
New format includes:
•
•
•
27
Schools that report using the new enrollment reporting
file layouts after July 1, 2014 must report program-level
enrollment information retroactive to July 1, 2014
Campus level data
Program level data (can be multiple programs)
Email Address
Enrollment Reporting Frequency
•
ED now requests enrollment information from
schools every 60 days.
• Schools are required to respond to those
requests within 15 days of the date that ED sent
the enrollment reporting roster to the school
Began July 1, 2014
• Schools may choose to receive reports more
frequently
•
28
Upcoming Enhancements
•
Student Contact Information will be mandatory
•
Compliance Measurements/Letters to schools
•
•
•
•
•
29
Focus on roster completion, including program-level
Report all Title IV students attending your school
Escalating notices will be sent for non-compliance
Referral to FSA Program Compliance for action
Updated Enrollment Reporting Guide (Spring
2015)
Gainful Employment
30
Gainful Employment - Regulations
•
Notice of Proposed Rulemaking (NPRM)
•
•
Federal Register - March 25, 2014
OPE Website with discussions and materials associated with GE
negotiated rulemaking:
http://www2.ed.gov/policy/highered/reg/hearulemaking/2012/gainfulemployment.html
•
Final Federal Register - October 31, 2014
•
•
31
Effective date - July 1, 2015
http://ifap.ed.gov/fregisters/attachments/FR103114Final.pdf
Gainful Employment Programs
The HEA provides that to be Title IV eligible an
educational program must be offered by:
•
A public or non-profit
postsecondary
educational institution
and leads to a degree; or
•
Any institution, if the
program prepares
students for “gainful
employment in a
recognized occupation”
32

Generally, all nondegree programs
must lead to gainful
employment

Generally, all
programs at for-profit
institutions must lead
to gainful employment
Which Programs are GE Programs
•
At proprietary institutions, all Title IV eligible
programs are GE Programs except for –
•
•
33
Preparatory coursework necessary for enrollment in an
eligible program
Bachelor’s degree programs in liberal arts offered since
January 2009 that are offered by a proprietary institution
that has been regionally accredited since October 2007
Which Programs are GE Programs
•
At public institutions and not-for-profit institutions,
all Title IV eligible, non-degree programs are GE
Programs except for –
•
•
34
Programs of at least two years in length that are
designed to be fully transferable to a bachelor’s degree
program
Preparatory coursework necessary for enrollment in an
eligible program (loan only)
GE Reporting
•
GE reporting will begin in early 2015
•
Report all Title IV students by July 31, 2015
•
•
•
Report following award years by October after end of the
award year
•
35
Report 2008-09 through 2013-14 award years
Programs with Medical and Dental Residencies report 2007-08
through 2013-14 award years
Report 2014 – 2015 Award Year by October 1, 2015
GE Data to Report
•
•
•
•
•
Institutional Data
Program Data
Student Enrollment Data
Student Financial Data
•
ONLY submit data on students enrolled in a GE program
ONLY submit data on Title IV aid recipients (exclude FWS or FSEOG
only recipients)
ONLY submit data for programs that exist as of 7/1/15
•
Data provided in 2011 will not be available to reuse
•
36
Certifications of Existing Programs
•
December 31, 2015 – Transitional Certifications Due
•
•
Certify that each currently eligible GE Program(s) is:
•
•
•
37
Signed by CEO/President
Approved by accrediting agency and State
Graduates qualify to meet educational prerequisites of the licensing
or certification exam required to work in the state, if any
Certifications renewed when institution recertifies
Program Participation Agreement (PPA)
Gainful Employment – Current
Disclosures
•
•
Court left regulations (34 CFR 668.6(b)) in place that require schools
to disclose certain GE Program data
Schools must use the Department’s GE Disclosure Template to
provide all GE disclosures
•
Schools must update their GE program disclosures with 13-14 information
no later than January 31, 2015
•
•
•
38
GE Electronic Announcement #50 (9/11/14)
Template updates include: improved printing capabilities, updated SOC
codes, optional context boxes, graduate certificate option, school name on
output screen, bulk upload tool used if certain criteria met with different
length programs
Technical questions: (855) 359-3697 or gedt@inovas.net
Disclosure Availability
•
•
Post the Template on your institution’s Web page
Prominently display direct links to the Template on:
•
•
•
Include the Template in all promotional materials about the GE
program
•
•
39
The GE program home page
Other institutional Web pages about the GE program
Promotional materials include invitations, ads, course catalogs, social
media, etc. that mention or otherwise refer to a specific GE program
If not feasible to include the Template, include a live link or URL to it and
clearly explain what is available at that Web page
Disclosures Under New Final Rules
•
Through December 31, 2016, current disclosure requirements
remain in effect
• Occupations; Normal time to complete program; On-time
graduation rate for completers; Tuition & fees, books & supplies,
room & board; Placement rate for completers (as determined by
State or Accreditor methodology); and Median loan debt
•
Institutions must comply with new disclosure requirements (October
31, 2014 Final Rules) beginning January 1, 2017
• conduct consumer testing, hold focus groups and prepare new
disclosure template
40
GE Resources
•
GE Information Page on IFAP
•
•
•
GE presentations at the FSA Training Conference
•
•
•
•
41
Federal Register Notices; DCLs; Electronic Announcements; FAQs;
Webinars; Presentations; Resources
http://www.ifap.ed.gov/GainfulEmploymentInfo/indexV2.html
fsaconferences.ed.gov – sessions #GS1, 30, 58
EA 1/9/14 (GE #51) – Updated NSLDS Gainful Employment
Submittal File Record Layouts
ANN-15-01 - Webinar Recording - Gainful Employment: Reporting
Data to NSLDS
send questions to GE-Questions@ed.gov
Regulatory Activity
42
Institutional Security & Crime
Reporting
•
The “Violence Against Women Act” (VAWA) amended the “Clery Act”
•
•
•
Final Rule published October 20, 2014
Effective July 1, 2015
GEN-14-13 & EA dated 8/1/14
•
•
Statute required institutions to include this new information in annual
security reports beginning with the October 1, 2014 report
Institutions must make a good-faith effort to comply with the statutory
provisions as written
•
should use the statute as the basis for revising or developing policies, procedures,
and programs in advance of the report that must be issued by 10/1/14
• make sure appropriate authorities on campus are aware of these changes
•
Help Desk
•
800-435-5985
• campussafetyhelp@westat.com
43
Direct PLUS Loans
•
Final Rule published 10/23/14
•
•
•
Key elements
•
•
•
•
•
44
Federal Register Notice published 1/14/15
New PLUS loan regulations will be early implemented early as of March 29,
2015
New definitions for “charged off” and “in collection”
Amends what is considered adverse credit history
Requires PLUS loan counseling for approved borrowers with extenuating
circumstances or an endorser
Extends validity of credit check from 90 to 180 days
ED will collect and publish performance of PLUS loans, including default
rate information
“Charged Off” and “In Collection”
•
Charged off – a debt that a creditor has written off as a
loss, but that is still subject to collection action
•
In Collection – a debt that has been placed with a
collection agency by a creditor or that is subject to more
intensive efforts by a creditor to recover amounts owed
from a borrower who has not responded satisfactorily to
the demands routinely made as part of the creditor’s
billing procedures
Adverse Credit History
•
One or more debts with total outstanding balance greater
than $2,085 that are •
•
•
46
90 or more days delinquent as of date of credit report; OR
have been placed in collection or charged off during two years
preceding date of credit report
OR
Subject of default, bankruptcy discharge, foreclosure,
repossession, tax lien, wage garnishment or write-off of a
debt under title IV during the five years preceding date of
credit report
Required PLUS Loan Counseling
•
PLUS loan counseling required for borrowers who have
adverse credit history and successfully:
•
•
•
Counseling will include:
•
•
•
•
•
47
document extenuating circumstances; OR
obtain an endorser (cannot have an adverse credit history)
information on borrowers’ current loan indebtedness
provide estimated loan repayment amounts
describe ways to avoid delinquency and default
provide additional financial aid literacy information
be provided by ED
Voluntary PLUS Loan Counseling
•
•
Enhance consumer information for PLUS applicants
Some items that will be included:
•
•
•
•
•
•
48
Calculator to allow borrowers to estimate future requirement
monthly payment amount under various repayment plans
Tools to assist borrowers in determining how factors such as taking
out additional PLUS loans or deferring repayment affect required
monthly repayment and total amount repaid
Available repayment plans for student/parent PLUS borrowers
Budgeting information for minimum amounts needed
Strategies for avoiding delinquency and default
Available prior to start of the 2015-2016 academic year
Validity of Credit Check
•
Credit check indicating no adverse credit history
will remain valid for 180 days instead of 90 days
• Any action that would normally trigger a credit
check will not do so if prior credit check with no
adverse credit obtained within past 180 days
• Will implement as soon as possible and inform
community of effective date through IFAP
49
Performance of PLUS Loans
•
Will collect and publish (where appropriate)
information about performance of parent
and student PLUS loans, including
default rate information based on credit history
characteristics of PLUS loan applicants and
• individual institutional default rates
•
50
Pay As You Earn Expansion
•
Propose to develop regulations that:
•
•
•
Three Negotiated Rulemaking sessions planned
•
•
•
•
51
Allow more students the opportunity to cap their monthly student
loan payments at 10%
Target new PAYE option to borrowers who would otherwise struggle
to repay their student loans
Session 1: February 24–26, 2015
Session 2: March 31–April 2, 2015
Session 3: April 28–30, 2015
Goal: making repayment option available to borrowers by December
31, 2015
Loan Reaffirmation Agreement
•
Federal Register – Notice: Comment Request; Reaffirmation
Agreement form
•
•
•
52
“This new form will simplify and standardize the reaffirmation process for
the borrower. It will also ensure continued enforceability of the student loan
thereby maintaining fiscal accountability to the federal program and the
taxpayer.”
Comment period open until March 23, 2015
www.regulations.gov Docket ID number ED–2015–ICCD–0007
53
Perkins
•
Barring any Congressional action, the
authority to make new Perkins loans will
end September 30, 2015
• For 2015-16, Perkins loans first disbursed
prior to 10/1/15 will be valid loans and all
subsequent disbursements for those loans
can be made during the award year
54
Ability to Benefit (ATB)
•
The Consolidated and Further Continuing Appropriations
Act, 2015 reinstated the ATB alternatives for Title IV
student eligibility for students enrolled in “career
pathway programs”
•
•
55
Applies to students who are enrolled or who first enroll in an eligible
program of study on or after July 1, 2014
OPE and OGC are currently reviewing the law and will
provide detailed guidance to schools in the near future stay tuned to IFAP!
Unusual Enrollment History (UEH)
•
For the 2015-16 FAFSA processing year, selection of
applicants for UEH Flag has expanded to consider–
•
•
An applicant’s prior receipt of, in addition to a Federal Pell Grant, a
Federal Direct Loan (not including Direct Consolidation Loans or
parent PLUS Loans)
The prior four, instead of three, award years
•
•
For 2015-2016, UEH Flag evaluation includes the 2011-2012, 20122013, 2013-2014, and 2014-2015 award years
A school may institutionally-select a student for UEH (not
selected by ED) if suspect enrollment problems
•
Self-selected students treated as if have UEH 3 flag
DCL coming soon
56
Affordable Health Care and COA
•
If an institution requires health insurance for all or a
category of students attending the institution, it may
include a reasonable amount for health insurance
under “miscellaneous personal expenses” in those
students’ COAs (long standing guidance)
•
The fact that the Affordable Care Act requires
individuals to maintain health insurance does not
bear on this issue because the cost is not specific to
the student’s educational expenses
57
Cohort Default Rates
•
•
CDR sanctions based solely on a school’s 3-year rates
CDR benefits are based on school’s three most recent
fiscal years for which official CDRs are available
•
•
•
Can be made up of 2 or 3 year rates IF both rates exist for a FY
Must pick one rate (either 2 or 3 year rate) to be used for each FY
Currently, the most recent fiscal year CDRs are FY09, FY10 and
FY11 which have official 2 and 3 year rates for each of those FYs
Future FY rates will only have 3 year rates so that by September
2017, the 3 most recent fiscal years will only have 3 year rates
58
Prerequisite Courses
•
If a student is already admitted into a program of study
but needs to take a prerequisite course that is not part of
the program but is necessary in order to take a course in
their current program of study, the prerequisite course in
this scenario is considered “remedial” and falls under all
of our remedial coursework regulations – 34 CFR 668.20
•
•
59
It is counted against the remedial course limits (30 semester or 45
quarter hours) and must be at least qualitatively evaluated within
SAP
If within remedial limits, can be factored into the students enrollment
status and COA
Disability Insurance for Top Athletes
•
Question: If a school pays for total permanent
disability insurance policies for some of their top
student athletes (usually with athletic funds), can
these payments be added to the student’s COA?
• Answer: For packaging purposes, these
payments should be treated as EFA, but may not
be treated as a component of cost of attendance,
even through use of PJ
60
Third Party Servicers
•
GEN-15-01, published January 9, 2015, “Third-Party
Servicer Institutional Requirements and Responsibilities”
•
•
•
•
61
Definition of a Third Party Servicer, 34 C.F.R. §668.2: any
individual or entity that contracts with or performs work on behalf of
an institution to administer, through manual or automated
processing, any aspect of an institution’s responsibilities under the
Title IV, HEA programs.
Institutions must report the names of any/all third party servicers to
ED via the E-app process,
http://www.eligcert.ed.gov/ows-doc/eapp.htm
Must be reported within 10 calendar days of the institution entering
into a contract (or any other written or oral agreement) with the third
party.
Third Party Servicers
•
Check your contracts to ensure that all requirements are included!
•
•
In the contract, the third-party servicer must agree to comply with all
statutory and regulatory provisions applicable to the Title IV functions
provided by the third party
Your third party servicer
•
•
•
may be subject to FERPA requirements
is subject to the same information security requirements established by the
Federal Trade Commission (FTC) for financial institutions as your
institution.
must submit annual compliance audits to ED
Questions?
Contact the Third-Party Servicer Oversight Group
FSAPC3rdpartyserviceroversight@ed.gov
(816) 268-0543
62
Federal Pell Grant Program
Reconciliation
•
•
•
Electronic Announcement posted January 23, 2015
Pell Grant Reconciliation, defined: the process by which a school
reviews and compares Pell Grant data recorded on the Department
of Education’s (the Department’s) systems with the information in the
school’s internal records. This process should be performed on a
regular basis, and is recommended at least monthly.
Final Reconciliation of a Pell Grant Award Year
•
•
63
Data Submission Deadline: September 30, 2015, for the 2014-15 award
year
After this date, COD will not accept upward awards or disbursement
adjustments without prior approval for an extension to the established data
submission deadlines (downward adjustments will continue to be
accepted).
COD Updates – March 2015
•
COD will allow COD Web users to create and submit a Subsidized
Usage inquiry to FSA for Subsidized Usage cases that require FSA
intervention and can’t be resolved by a school
•
•
•
64
Done via new Create Subsidized Usage Inquiry page
COD system will update the number of days a credit check is valid
from 90 days to 180 days
COD will produce a weekly credit status report in COD Web in CSV
format - list of borrowers whose active Original Credit Decision is
'Declined', status of appeals due to extenuating circumstances, PLUS
Counseling and endorsers associated with the credit check/loans
COD Updates – March 2015
•
COD will introduce a Subsidized Usage Calculator on COD Web
•
•
•
65
Users will be able to enter loan data and estimate the students’ subsidized
usage based upon the information entered and the loans existing on the
COD System
Will allow the user to model potential impacts to the student’s subsidized
usage and eligibility
Actions taken via the Subsidized Usage Calculator will NOT result in any
changes to the student’s loans on the COD System
Your Feedback is Requested
Using the link below, please complete an
evaluation of my presentation.
https://s.zoomerang.com/s/AngelaSmith-Reg5
Thank you!
For questions about this presentation,
please feel free to contact me:
Angela Smith, Training Officer
Angela.smith@ed.gov
312-730-1552
Questions? Contact me!
Angela Smith, Training Officer
angela.smith@ed.gov
312-730-1552
67
The HEA turns 50!
Will it get reauthorized
for it’s birthday??
68