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Federal Update

Federal Update. Tri-State Spring Training April 3 , 2014. Greg Martin U.S. Department of Education. DEFAULT RATES. Transition Period. National Student Loan Default Rates. 2011 2013. 3-yr Cohort Default Rate.

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Federal Update

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  1. Federal Update Tri-StateSpring Training April 3, 2014 Greg Martin U.S. Department of Education

  2. DEFAULT RATES

  3. Transition Period

  4. National Student Loan Default Rates 2011 2013 3-yr Cohort Default Rate FY 2011 3-year draft cohort default rates planned to be released 2/18/14 The FY 2010 Official 3-Year national rate is 14.7% Which represents an increase of 9.7% from the FY 2009 Official rates of 13.4%

  5. Default Sanctions* (3-year rates) • Default Prevention Plans • 1st year CDR is equal to or greater than 30%: • Establish a default prevention task force; and • Develop and submit a default prevention plan to ED • 2 consecutive CDRs equal to or greater than 30%: • Revise and submit default prevention plan • ED may require specific adjustments/actions • 3 consecutive CDRs equal to or greater than 30%: • Lose Direct Loan AND Pell Grant eligibility • FY2011 or later CDR above 40% lose DL eligibility *ability to appeal/challenge rates

  6. GEN-14-03 • Provides a summary of: • Cohort Default Rate calculations • Consequences of high default rates • NOTE: An institution’s decision to stop participating in the Direct Loan Program does NOT eliminate the possibility that it will lose eligibility to participate in the Pell Grant Program. CDRs, and possible consequences, continue until no more of the institution’s former students enter repayment on their DL or FFEL loans taken for attendance at the institution • CDR challenges, adjustments and appeals • Detailed discussion and chart on participation rate index challenges and appeals

  7. INTEREST RATES:Bipartisan Student Loan Certainty Act of 2013(EA – August 9, 2013)

  8. Interest Rates • The Administration worked with Congress to reach agreement on a plan to reverse the interest rate increase • New rate structure applies to all loans first disbursed after June 30, 2013 • Annual fixed rates based on 10 Year T-Bill plus add-on • Applies to loans first disbursed between July 1 and June 30 • Rate applies for the life of the loan 8

  9. Interest Rates • Undergraduate Students - Sub and Unsub • 3.86% (last year’s Sub - 3.4% and Unsub - 6.8%) • Add-on of 2.05% with cap of 8.25% • Graduate students – Unsubsidized Loans only • 5.41% (last year’s Grad Unsub - 6.8%) • Add-on of 3.60% with cap of 9.5% • PLUS Loans (parent and grad/professional) • 6.41% (last year’s - 7.9%) • Add-on of 4.6% with cap of 10.5% 9

  10. Sequestration (GEN-13-22; GEN-13-27)

  11. Sequestration • TEACH Grant awards reduced by 6.0 percent for FY 2013 and 7.2 percent0.89 percent for FY 2014 • Iraq-Afghanistan Service Grant awards reduced by 10.0 percent for FY 2013 and 7.2 percent for FY 2014 • New reductions for either grant is for 13/14 grants where the first disbursement is made between October 1, 2013 and September 30, 2014

  12. Sequestration • Direct Subsidized and Direct Unsubsidized loan fees increased from – • 1.0 percent to 1.051 percent for loans first disbursed on or after July 1, 2013 and before December 1, 2013, and to – • 1.072 percent for loans first disbursed on or after December 1, 2013 and before October 1, 2014

  13. Sequestration • Direct PLUS loan fees (parent and grad) increased from – • 4.0 percent to 4.204 percent for loans first disbursed on or after July 1, 2013 and before December 1, 2013, and to – • 4.288 for loans first disbursed on or after December 1, 2013 and before October 1, 2014

  14. 150% Direct Subsidized Loan Limit

  15. Subsidized Loan Limit • Statute: On July 6, 2012, the Moving Ahead for Progress in the 21st Century Act (MAP-21) was enacted(P.L. 112-141) • Regulations: • Interim Final Regulations published on May 16, 2013 • Revised Final Regulations published on January 17, 2014

  16. Subsidized Loan Limit • Limit on how many years a “first-time borrower” may receive subsidized loans • Applies to first-time borrowers on or after July 1, 2013. A first-time borrower is one who - • Has no balance on any FFEL or Direct Loan on July 1, 2013, or • Has no balance on any FFEL or Direct Loan when receiving first Direct Loan (any type) on or after July 1, 2013

  17. Subsidized Loan Limit • Condition - Student has received Direct Subsidized loans for a period of time that is equal to 150% of the published length of the student’s current academic program • Result - Student may not receive additional subsidized loans for enrollment in that program or in any program of equal or lesser length

  18. Subsidized Loan Limit • Students maximum time to receive subsidized loans is established based on the length of the program the student is enrolled in • Remaining subsidized eligibility is calculated by subtracting from maximum eligibility for the program, the time the student has already received subsidized loans for enrollment in any program

  19. Subsidized Loan Limit • Astudent who loses eligibility for additional subsidized loans may lose interest subsidy on previously received subsidized loans, if - • Student did not complete program, and • Continues in same program or, • Enrolls in another undergraduate program of the same or shorter length • Effective on the date of the student’s continued or new enrollment

  20. GEN-13-13 (AY and Loan Periods) • Schools must report and update corrections to the Direct Loan academic year and loan period dates in COD for loans first disbursed on or after 7/1/13 • Summer term treated as header/trailer in a scheduled academic year must not be included in the academic year dates unless the student will actually be receiving a Direct Loan for the summer • Loan period and/or academic year dates may need to be adjusted based on actual student enrollment • Provides 13 examples in standard term and nonterm program situations

  21. Special Considerations • Preparatory Coursework • Non-credential Teacher Certification Programs • Part-time enrollment • Half-time (sub usage period multiplied by .5) • Three-quarter-time (sub usage period multiplied by .75) • Borrowing a full annual subsidized loan amount for a period shorter than a full academic year equals one full year of subsidized usage • Borrower responsibility of interest accrual impacted by completing or not completing program in timely manner

  22. ED Responsibilities • ED Responsibilities (NSLDS/COD/CPS) • Calculating a 1st-time borrower’s maximum eligibility period; • Calculating a 1st-time borrower’s subsidized usage periods; • Determining if 1st-time borrower has eligibility & how much; • Determining if a 1st-time borrower loses interest subsidy

  23. School Responsibilities • Must ensure that first-time borrowers begin receiving counseling on the 150 percent limit on July 1, 2013 - May use counseling documents attached to 5/16/12 EA - As of 6/28/13, ED entrance counseling on StudentLoans.gov will be updated with new information • Correctly report DL Academic Years and Loan Period dates in COD per GEN-13-13 • In 14/15 DL processing year begin providing new program and student data in COD and NSLDS (CIP codes, program length, enrollment status, credential level, preparatory coursework or non-credential teacher certificate)

  24. COD Updates • Subsidized Usage Limit Applies (SULA) field in COD • Identifies a first-time borrower • Located on the COD View Person Information page • Populated with date first actual disbursement of a DL award for first-time borrower is accepted by COD • New COD Warning edit (Edit 200) • Web-only report automatically posted weekly to school’s COD Reporting Newsbox in (.csv) file format • Report will list all borrowers subject to the 150% limit • Electronic Announcement - June 20, 2013

  25. Subsidized Usage Period – 2013-2014 • Electronic Announcement - 8/30/13 • Alternative method for COD to obtain enrollment statuses for loans made for the 2013-2014 year • NSLDS does not currently have a three-quarter time enrollment status (will add a 3/4 status in future) • All Subsidized Usage Periods for 13/14 Direct Subsidized Loans with an enrollment status of H in NSLDS for any portion of a loan period will be prorated on the basis of “half-time” enrollment even if the borrower is or was actually enrolled on a 3/4-time basis • COD calculation of Sub Usage starts March 2014

  26. Teacher Certification in 2013-2014 • Loans received only count against the Maximum Eligibility Period for Teacher Certification Programs • School must provide ad-hoc reporting to COD Feb. 2014 • Loans subject to reporting and that are/were first disbursed prior to 3/15/14, schools must submit a Teacher Certification Program Ad-Hoc Reporting File prior to April 5, 2014 • Loans subject to reporting and that are first disbursed on/after 3/15/14, schools must submit a Teacher Certification Program Ad-Hoc Reporting File within 15 days of making the first disbursement of the loan • Teacher Certification Program Ad-Hoc Reporting File layout in 2014-2015 COD Technical Reference (Vol. II, Section 1, p.181) • More information - 150% EA #4 and #10

  27. Limited School Calc. - EA 11/12/13; 3/10/14 • For 13/14 limited number of instances where school will need to calculate Remaining Eligibility Periods prior to originating a Direct Subsidized Loan (13/14 COD not able to calculate) • Performed by schools only in the following circumstances: • Borrower is a first-time borrower on or after July 1, 2013 • Borrower received DL Sub (at any school) first disbursed on or after 7/1/13 • School is considering student for another DL Sub for the borrower’s enrollment in a program with a published length that is: • For programs measured in years, less than 1.5 years; • For programs measured in months, less than 10 months; or • For programs measured in weeks, less than 40 weeks. • School plans on originating the new DL Sub using the 13/14 COD System • Optional Excel worksheet provided (updated 3/10/14 EA) • Not required if originating in the 14/15 COD System release

  28. Revised Final Rule • Usage Period Calculations • Rounded to nearest 10.0 percent and not to the lowest 25.0 percent • Both exceptions will now apply to borrowers who are enrolled part-time and receive the annual loan limit for a period of enrollment less than an academic year – • First the annual loan limit exception will be applied and then the part-time exception will be applied

  29. Revised Final Rule • Maximum Eligibility Period (MEP) Calculations • Two-year bachelor’s degree completion program considered to be 4 years long (MEP = 6 years) • Requires an associate degree or 2 years of postsecondary coursework for admission • Special admission associate degree programs considered to be four years long (MEP = 6 years) • Program requires an associate degree or at least two years of coursework for admission • Selective admissions • Coursework necessary for licensure

  30. 150% DL Sub Limit Resources • 150% Direct Subsidized Loan Limitation Website • IFAP.ed.gov (right-hand side) • http://ifap.ed.gov/150PercentDirectSubsidizedLoanLimitInfo/index.html • Contains: • Federal Registers • DCLs and EAs • Q & As (over 50 questions) • Training materials • Additional resources and references

  31. Verification2014-2015

  32. Verification Tracking Groups Summary Kept V1, V3, V4 and V5 Eliminated Group V2 – SNAP SNAP still an item under V1, V4, V5 and V6 Added Group V6 – Household Resources Income appears not sufficient to support family size 2014-15 Verification

  33. All items indicated-Tax Filer (V1); or All items indicated-Non-Tax Filer (V1); AND Other untaxed income from 2014-2015 FAFSA: Payments to tax-deferred pension and savings Child support received Housing, food and other living allowances paid to members of the military, clergy and others Veterans noneducation benefits Other untaxed income Money received or paid on the applicant’s behalf V6 – Household Resources

  34. If school determines amounts provided do not appear to provide sufficient support for family members reported, the applicant (and parent/spouse) must: Provide additional signed statement listing other resources used to support family (may include items not required to be reported on FAFSA or other verification forms) Explain how financially supported during 2013 calendar year V6 – Household Resources Other Untaxed Income Documentation: 1. Signed statement listing – - Sources and amounts of income for tax year 2013 2. Copy of IRS W2s for sources of employment income received for tax year 2013where applicable

  35. Identity Theft – 2014-2015 • Beginning with the 2013 tax year, a tax filer who is not able to request an IRS Tax Return Transcript because of identity theft, will be able to call a special IRS toll-free number (1-800-908-4490) • Upon verification of identity, the tax filer can request the IRS provide a paper copy of an alternative document unique to identity theft issues (Tax Return Data Base View - TRDBV) • The TRDBV is an official transcript that can be submitted to the school to meet verification requirements DCL – GEN-14-05

  36. Transcript Requests – 2014-2015 • Online IRS Transcript requests • Beginning with tax year 2013, once an online transcript request is validated, the IRS will return in real-time, a transcript in portable document format (pdf) through the new “Get Transcript Online” tool • Tax filer can print/save/forward pdf transcript as needed • Other Transcript Requests • Tax filers can submit requests via - IRS2GO mobile app, online “Get Transcript by Mail”, automated phone tool (1-800-908-9946), or paper Form 4506 or 4506-T • These request methods will result in a paper transcript DCL – GEN-14-05

  37. V4/V5 Tracking Results – 2014-2015 Issue: Provide an efficient method for FAAs to report the verification results for records selected with the V4 and V5 Verification Tracking Groups Solution: FAA Access will be updated to add Identity Verification Results functionality to allow FAAs to enter results individually or by file upload starting January 1, 2014 Electronic Announcement November 13, 2013 https://faaaccess.ed.gov

  38. V4/V5 Tracking Results – 2014-2015 • Whom to report: student 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: on a regular basis with all reporting for 2014-2015 submitted within a short time after the end of the 2014-2015 award year • Future Federal Register Notice will provide specific deadlines to submit all documentation for 14/15

  39. References & Resources Federal Register Notice - June 13, 2013 DCL GEN-13-16 - June 13, 2013 DCL GEN-14-05 – March 25, 2014 14/15 FSA HDBK, AVG Section, Chapter 4 EA dated 11/8/13 – suggested text EA dated 11/13/13 – FAA Access tracking V4 & V5 Program Integrity Q & A Website (verification topic) http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/integrity-qa.html 2014-15 Verification

  40. Defense of Marriage Act (DOMA)

  41. Implementation of the Supreme Court’s Defense of Marriage Act Decision • In June the Supreme Court struck down section 3 of the Defense of Marriage Act (DOMA) that provided that for purposes of federal programs, a marriage can only be between one man and one woman • See Dear Colleague Letter GEN-13-25 published on December 13, 2013

  42. Implementation of the Supreme Court’s Defense of Marriage Act 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

  43. Implementation of the Supreme Court’s Defense of Marriage Act Decision • 2014-2015 FAFSA – • All responses must be consistent with legal marital status • 2013-2014 FAFSA – • New filers - All responses must be consistent with legal marital status • Earlier filers – If legally married when FAFSA was initially filed may change marital status as a correction and school must approve request • If married after FAFSA processed, school’s updating martial status policy applies

  44. FAFSAs & ISIRs

  45. 2013-2014 FOTW • September 2013 Enhancement (6/25/13 EA) • Income Earned from Work field will now be automatically updated with the IRS value for: • students who use the IRS DRT and indicate a marital status of Single, Separated, or Divorced or Widowed, • parents of dependent applicants who indicate a marital status of Single, Divorced or Separated, or Widowed • If marital status is Married/Remarried, Income Earned from Work is displayed in view-only and the total amount must be input for each spouse • Changing this field will not change IRS Request Flag

  46. 13/14 and 14/15 ISIRs Update NSLDS Fraud Loan Flag Issue: NSLDS receives records from the Office of Inspector General (OIG) that indicate someone has been convicted of fraudulently obtaining Federal Loans and is no longer eligible for aid Solution: Beginning January 1, 2014: • Records will receive Reject Reason 24 and SAR Comment 272 • Effective for 2013-14 and 2014-15

  47. 2014-2015 FAFSA (GEN-13-12) • New parental data collection: • Dependent students will be required to include FAFSA income and other information from the dependent student’s legal parents, regardless of the parents’ marital status or gender,if those parents live together • Legal parent means biological or adoptive • New marital status response for dependent student’s parents - “Unmarried and both parents living together” • If divorced parents (biological or adoptive) of a dependent student still live together, they complete the FAFSA as "unmarried and living together" with information from both

  48. 2014-2015 FAFSA Tax Filing Status Issue We are unable to identify instances where the student or parent marital status conflicts with the tax filing status, resulting in the possibility that either too much income or not enough income is being reported on the FAFSA. Solution Students and parents will begin reporting their tax filing status on the FAFSA. The system will compare the tax filing status with the marital status to determine where potential discrepancies exist, and message accordingly.

  49. 2014-2015 ISIR 150% Subsidized Loan Limit The following NSLDS fields will be added to the ISIR: • These fields will be passed from NSLDS to CPS starting with 2014-2015 at the borrower level during pre-screening • A SAR Comment 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

  50. Gainful Employment

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