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2015 ISFAA Winter Conference
Angela Smith, Training Officer
U.S. Department of Education
Federal Update
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Verification
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
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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
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
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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
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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• Send to IRS only if doubt paper tax return accuracy
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2015-2016FAFSA
Processing
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• List of people who are not considered a parent unless
they have legally adopted the student will now include widowed stepparent
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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• 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
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School Listing
• School selection page• Adding text to tell students that all schools they select will receive the list of selected schools
• School selection summary page• 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
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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.
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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
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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.”
• Hyperlink will lead to help text that explains timing for tax information availability
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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:• 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
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FSA ID: The FSA PIN
ReplacementPerson Authentication
Service (PAS)
Introducing the FSA ID
• FSA is adopting the best practice of using a username and password instead of personal information
• The FSA ID • 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
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New FSA ID login
Old PIN login
The FSA ID will modernize access for students, parents and borrowers to FSA systems
Will be updated
Introducing the FSA ID
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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
Introducing the FSA ID
• What happens for new user?• 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
• 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?• If the user links their PIN, they will have access to previous FAFSA
submissions
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Introducing the FSA ID
• Can users still access FAFSA by providing their Last name, SSN and DOB?• 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. • 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?• This is only for users who are accessing their own information such as
students, parents, borrowers and applicants
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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
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Defense of Marriage Act (DOMA)
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GEN-13-25
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
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Implementation of the Supreme Court’s DOMA Decision• GEN-14-14
• 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
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Implementation of the Supreme Court’s DOMA Decision• GEN-14-15
• 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
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NSLDSEnrollment Reporting
Enrollment Reporting Transition
• All schools must have implemented the new enrollment reporting processes and file layouts by October 1, 2014 • 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
• New format includes: • Campus level data• Program level data (can be multiple programs)• Email Address
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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
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Upcoming Enhancements
• Student Contact Information will be mandatory
• Compliance Measurements/Letters to schools• 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)
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Gainful Employment
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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• Effective date - July 1, 2015• http://ifap.ed.gov/fregisters/attachments/FR103114Final.pdf
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Gainful Employment Programs
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Generally, all non-degree programs must lead to gainful employment
Generally, all programs at for-profit institutions must lead to gainful employment
• 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”
The HEA provides that to be Title IV eligible an educational program must be offered by:
Which Programs are GE Programs
• At proprietary institutions, all Title IV eligible programs are GE Programs except for –• 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
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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 –• 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)
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GE Reporting
• GE reporting will begin in early 2015
• Report all Title IV students by July 31, 2015• Report 2008-09 through 2013-14 award years• Programs with Medical and Dental Residencies report 2007-08
through 2013-14 award years
• Report following award years by October after end of the award year• Report 2014 – 2015 Award Year by October 1, 2015
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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
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Certifications of Existing Programs
• December 31, 2015 – Transitional Certifications Due • Signed by CEO/President
• Certify that each currently eligible GE Program(s) is:• 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)
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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• 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 [email protected]
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Disclosure Availability
• Post the Template on your institution’s Web page• Prominently display direct links to the Template on:
• The GE program home page• Other institutional Web pages about the GE program
• Include the Template in all promotional materials 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
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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
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GE Resources
• GE Information Page on IFAP • Federal Register Notices; DCLs; Electronic Announcements; FAQs;
Webinars; Presentations; Resources• http://www.ifap.ed.gov/GainfulEmploymentInfo/indexV2.html
• GE presentations at the FSA Training Conference• 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 [email protected]
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Regulatory Activity
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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 • [email protected]
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Direct PLUS Loans
• Final Rule published 10/23/14• Federal Register Notice published 1/14/15• New PLUS loan regulations will be early implemented early as of March 29,
2015• Key elements
• 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
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“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 - • 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
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Required PLUS Loan Counseling
• PLUS loan counseling required for borrowers who have adverse credit history and successfully:• document extenuating circumstances; OR• obtain an endorser (cannot have an adverse credit history)
• Counseling will include:• 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
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Voluntary PLUS Loan Counseling
• Enhance consumer information for PLUS applicants• Some items that will be included:
• 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
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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
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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
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Pay As You Earn Expansion
• Propose to develop regulations that:• 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
• Three Negotiated Rulemaking sessions planned • 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
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Loan Reaffirmation Agreement
• Federal Register – Notice: Comment Request; Reaffirmation Agreement form• “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
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Policy Potpourri…
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
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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”• 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!
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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, 2012-2013,
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
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DCL coming soon
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
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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
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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• 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
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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
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Third Party Servicers
• GEN-15-01, published January 9, 2015, “Third-Party Servicer Institutional Requirements and Responsibilities”• 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.
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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
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Questions? Contact the Third-Party Servicer Oversight Group
[email protected] (816) 268-0543
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• 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).
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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• 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
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COD Updates – March 2015
• COD will introduce a Subsidized Usage Calculator on COD Web• 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
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Your Feedback is Requested
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Using the link below, please complete an evaluation of my presentation.
Thank you!
For questions about this presentation, please feel free to contact me:Angela Smith, Training [email protected]
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Questions? Contact me!
Angela Smith, Training Officer
312-730-1552
The HEA turns 50!
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Will it get reauthorized for it’s birthday??
