donna bellflower and franka dennis | dec. 2014 u.s. department of education 2014 fsa training...
TRANSCRIPT
Donna Bellflower and Franka Dennis | Dec. 2014
U.S. Department of Education
2014 FSA Training Conference for Financial Aid Professionals
Understanding and Managing the CDR Challenge and Appeal Process
Session 25
Presentation Purpose Presentation Purpose
The purposes of this presentation are to: The purposes of this presentation are to:
•Review Cohort Default purpose, sanctions and Review Cohort Default purpose, sanctions and benefitsbenefits•Clarify how understanding the loan record Clarify how understanding the loan record report aids with the management of filing report aids with the management of filing adjustments, challenges and/or appealsadjustments, challenges and/or appeals•Explain how special circumstance effect cohort Explain how special circumstance effect cohort ratesrates•Discuss when, why and how to submit requests Discuss when, why and how to submit requests for adjustments, challenges and/or appealsfor adjustments, challenges and/or appeals
2
What is a 3-Year Cohort Default Rate?What is a 3-Year Cohort Default Rate?
For schools having 30 or more borrowers entering For schools having 30 or more borrowers entering repayment in a fiscal year, the school’s cohort default rate repayment in a fiscal year, the school’s cohort default rate is the percentage of a school’s borrowers who enter is the percentage of a school’s borrowers who enter repayment on certain Federal Family Education Loans repayment on certain Federal Family Education Loans (FFELs) and/or William D. Ford Federal Direct Loans (DL) (FFELs) and/or William D. Ford Federal Direct Loans (DL) during that fiscal year and default (or meet the other during that fiscal year and default (or meet the other specified condition) within the cohort default period. specified condition) within the cohort default period.
For schools with 29 or fewer borrowers entering repayment For schools with 29 or fewer borrowers entering repayment during a fiscal year, the cohort default rate is an “average during a fiscal year, the cohort default rate is an “average rate” based on borrowers entering repayment over a three-rate” based on borrowers entering repayment over a three-year period. year period.
3
3-Year Cohort Default Rate3-Year Cohort Default Rate SANCTIONSSANCTIONS
4
SchoolSchool SanctionsSanctions
A school‘s three most recent official A school‘s three most recent official cohort default rates are cohort default rates are 30.030.0 percent or percent or greater for the three year calculation.greater for the three year calculation.
Except in the event of a successful Except in the event of a successful adjustment or appeal, a school will adjustment or appeal, a school will lose lose Direct Loan Direct Loan and and Federal Pell Federal Pell Grant Grant program eligibility for the program eligibility for the remainder of the fiscal year in which remainder of the fiscal year in which the school is notified of its sanction the school is notified of its sanction and for the following two fiscal years.and for the following two fiscal years.
A school‘s current official cohort A school‘s current official cohort default rate is greater than default rate is greater than 40.040.0 percent, for the three year CDR percent, for the three year CDR calculation.calculation.
Except in the event of a successful Except in the event of a successful adjustment or appeal, a school will adjustment or appeal, a school will lose lose Direct Loan Direct Loan program eligibility program eligibility for the remainder of the fiscal year in for the remainder of the fiscal year in which the school is notified of its which the school is notified of its sanction and for the following two sanction and for the following two fiscal years.fiscal years.
3-Year Cohort Default Rate 3-Year Cohort Default Rate BENEFITSBENEFITSEffective with the Release of the FY 2011 3-year Cohort Default RatesEffective with the Release of the FY 2011 3-year Cohort Default Rates
5
Eligible SchoolEligible School BenefitsBenefits
A school whose most recent official cohort A school whose most recent official cohort default rate is less than default rate is less than 5.05.0 percent and is an percent and is an eligible home institution that is originating eligible home institution that is originating loans to cover the cost of attendance in a study loans to cover the cost of attendance in a study abroad program.abroad program.
-May disburse loan proceeds in a single -May disburse loan proceeds in a single installment to a student studying abroad installment to a student studying abroad regardless of the length of the student’s loan regardless of the length of the student’s loan period.period.
-May choose not to delay the disbursement -May choose not to delay the disbursement of the first installment of loan proceeds for of the first installment of loan proceeds for first-year, first-time borrowers studying first-year, first-time borrowers studying abroad.abroad.
A school with a cohort default rate of less than A school with a cohort default rate of less than 15.015.0 percent for each of the three most recent percent for each of the three most recent fiscal years for which data are available, fiscal years for which data are available, including eligible home institutions and foreign including eligible home institutions and foreign institutions.institutions.
-May disburse, in a single installment, loans -May disburse, in a single installment, loans that are made for one semester, one that are made for one semester, one trimester, one quarter, or a four-month trimester, one quarter, or a four-month period. period.
-May choose not to delay the first -May choose not to delay the first disbursement of a loan for 30 days for first-disbursement of a loan for 30 days for first-time, first-year undergraduate borrowers.time, first-year undergraduate borrowers.
The Loan Record Detail Report The Loan Record Detail Report (LRDR)(LRDR)
The first step to CDR The first step to CDR management of Challenges, management of Challenges, Adjustments and Appeals Adjustments and Appeals
6
Reading the LRDRReading the LRDR
7
TITLE SECTION (Top of each page of LRDR)
School Name and Address
Cohort Fiscal Year
Specifies whether the LRDR is a draft or official cohort draft rate and indicates whether it was generated for a school or data manager.
Organization ID – the school’s Office of Postsecondary Education Identification (OPEID) number.
Date cohort default rate was calculated – note that all dates on the LRDR are listed in MM/DD/CCYY format. MM=month DD=day
U.S. DEPARTMENT OF EDUCATION NATIONAL STUDENT LOAN DATA SYSTEM (NSLDS)
RATE CALCULATION DATE: XX/XX/XX PAGE NO: 1
COHORT YEAR XXX OFFICIAL LOAN RECORD DETAIL REPORT (SCHOOL)
Attention: Name: Address: City: Country:
Alexander Peachum Graphic Tech 9765 Arts Lane Coral City United States
Organization ID Number: 999999
State: Iowa Postal Code: 12345 Program Type: FFEL Years: 1
Program Type – FFEL, Direct, or Dual
Number of cohort fiscal years included in the cohort default rate calculation – always “1” for a draft LRDR. If the school qualifies for use of the average rate calculation, data from three cohort fiscal years will be used, and a “3” will be shown on the official LRDR.
TIP: Follow these steps to print your LRDR report in a more easily read format after the file is returned through the SAIG and saved to a PC:
6. Change the margins to:
1. 2. 3. 4. 5.
Open Microsoft Word and then open your file. Click Edit, then Select All in the Menu bar. Click Format, then Font in the Menu bar. In the Font dialog box, change the font size to 8 and the style to Courier New. Then click Ok. Click File, then Page Setup. Select the Margins tab.
Top = 1" Bottom = 1" Left = 0.7" Right = 0.7" Gutter = 0"
7.
8.
Click the Paper Size tab. Select the Landscape radio button. Click Ok.
Body Section- Line 1 BorrowerBody Section- Line 1 Borrower
Attenti
0001-01-0001 CHARM JIM K 06/30/1977 00XXXXXX 09/01/1999 05/30/2000
SSN
1
First/M.I. Last Name Begin Date Original School D.O.B End Date
Academic Level
rincipal Balance) rincipal Balance) Usage 1 Codes only) & B Usage 1 Codes)
(Negative Amortization Only)
ort Generation Date: XX/XX/05 rect Numerator/Denominator,
U.S. DEPARTMENT BODY SECTION – LINE 1 BORROWER OF EDUCATION NATIONAL STUDENT LOAN DATA SYSTEM (NSLDS)
OPEID of the school that certified/originated the loan
RATE CALCULATION DATE: PAGE NO:
Borrower’s Social Security Number
Last Name
Name:
COHORT YEAR XXX OFFICIAL LOAN RECORD DETAIL REPORT (SCHOOL) First Name/ Date of
on: Middle Initial Birth
Address: City: Country:
Alexander Peachum Graphic Tech 9765 Arts Lane Coral City United States
State: Iowa Postal Code:
XX/XX/XX 1
Borrower’s
Organization ID Number: 999999 Academic Level
When Loan Was Beginning & Ending [Class] Obtained Dates for Loan Period (see code list)
12345 Program Type: FFEL Years: 1
----------------------------------------- STUDENT ----------------------------------- -------- CLASS -----------
----------- ----------------------------------- ------------- ---------- Guarantor/
-------- ---------- ----------- 0 - LENDER/SVCR/HOLDER - -- Loan - Claim Rsn/
Originating Current Type Stat Code ----------- --------- ---- ---- ----------
DEFAULT/ NegAm Date
-----------
Guaranty Enrollment Stat/ Usage Repay Date Amount ---------- ------
Servicer ---------
Loan/Date Code Date ---------- ----------------
1 -----
2
8888888888 9999999999 SF RP 00/00/0000 10/31/2002 $ 2,625 667 09/02/1999 W 12/31/2001 D FD 0001-01-0001 CHARM JIM K 06/30/1977 00XXXXXX 09/01/2000 04/30/2001 3
8888888888 9999999999 SU RP 00/00/0000 10/31/2002 $ 5,500 667 08/21/2000 W 12/31/2001 E E 0002-01-0001 XU DENZEL A 10/01/1973 00XXXXXX 01/12/2000 05/12/2000 2
0101 0101 D1 DU IX 12/17/2003 11/02/2002 $ 3,500 0101 02/14/2000 W 05/10/2002 B DB 0003-00-0001 Jackson MARK R 10/29/1983 00XXXXXX 08/22/2002 05/09/2003 1
0101 0101 D1 DA 00/00/0000 06/14/2003 $ 2,625 0101 11/04/2002 W 12/13/2002 D DD
FFEL DIRECT DUAL ------------- ------------- -------------
TOTAL DOLLARS IN DEFAULT : 1,071,266 7,875 0 (Based on Outstanding P TOTAL DOLLARS IN REPAYMENT : 6,950,053 44,625 0 (Based on Outstanding P TOTAL INSURANCE CLAIM PAYMENTS: 0 ************* = Not Available -Actual Numerator Count : 134 Report Count : 134(B Actual Denominator Count: 842 Actual Default Rate: 15.9 Report Count : 842(D INDIVIDUAL PROGRAM TALLY: FFEL: 134/842 DIRECT: 3/20 Appealed Rate flag: N (D=Direct, I=Indirect, N=No Appeal, U=Unknown) IC: 0
0 End of Loan Record Detail Report Rep -Default Rate Usage 1: D=Denominator, B=Numerator/Denominator, N=Not Used, E=Eligible but not counted Default Rate Usage 2: FD=FFEL Denominator, FB=FFEL Numerator/Denominator, DD=Direct Denominator, DB=Di
IC=ICR (Negative Amortization Only), N = Not Used, E = Eligible but not counted
Information Protected By the Privacy Act of 1974 As Amended
Academic Level Codes
1 Freshman/First Year
2 Sophomore/Second year
3 Junior/Third Year
4 Senior/Fourth Year
5 Fifth Year/Other
A First Year Graduate/Professional
B Second Year Graduate/Professional
C Third Year Graduate/Professional
D Beyond Third Year Graduate/Professional
G Graduate/Professional
N Not Available
8
Body Section- Line 2 Loan InformationBody Section- Line 2 Loan Information
COHO tention: Alexande me: Graphic
765 Arts Lane oral City nited States
-------- STUDENT ---
At
City: Count
-----------------
Usage 1 2
8888888888 9999999999
------------- - ULT : 1,071,266 YMENT : 6,950,053 PAYMENTS: 0 vailable
: 134 unt: 842 Actual De LLY: FFEL: 134/842 (D=Direct, I=Indirect, N=No
End of Loan Rec ault Rate Usage 1: D=Denominator, B=Numerator/Denomi ault Rate Usage 2: FD=FFEL Denominator, FB=FFEL Nume
IC=ICR (Negative Amortization Onl
Information Protec
Rate: 15.9 Repo IRECT: 3/20 al, U=Unknown) rd Detail Report ator, N=Not Used, E ator/Denominator, D ), N = Not Used, E
ed By the Privacy A
--------- 0 (Based 0 (Based
=Direct Denominator, DB=Direc Eligible but not counted
of 1974 As Amended
utstanding Principal utstanding Principal
134(B Usage 1 842(D & B Usa
0 (Negat
00/00/0000 10/31/2002 $ 2,625 09/02/1999 W 12/31/2001 667 RP SF FD D
LATION DATE: XX/XX/XX PAGE NO: 1
umber: 999999
ears: 1
Balance) Balance)
Codes only) 1 Codes)
ve Amortization Only) ration Date: XX/XX/05 erator/Denominator,
Enrollment Stat/ Code Date
Guarantor/ Servicer
Guaranty Loan/Dat
Claim Rsn/ Code
DEFAULT/ NegAm Date
-- Loan - Type Stat
- LENDER/SVCR/HOLDER Originating Current Repay Date Amount
Lender/Servicer/ Holder – that provided loan to the borrower
Loan Type – FFEL or Direct Loan (see code list)
U.S. DEPARTMENT OF EDUCATION RATE CALCU NATIONAL STUDENT LOAN DATA SYSTEM (NSLDS)
RT YEAR XXX OFFICIAL LOAN RECORD DETAIL REPORT (SCHOOL)
r Peachum Organization ID N
Usage Usage 1 – identifies how the borrower is used in the school’s cohort default rate calculation.
Na Tech Usage 2 – identifies how the Address: 9 Loan Status borrower is counted in each
C State: Iowa individual loan program
---------
Loan Holder – at time CDR was calculated
ry: U
-------
at time CDR was calculated (see code list)
Postal Code: 12345 Program Type: FFEL Y
-------------------------------- Original -------- CLASS ----------- Academic SSN Last Name First/M.I. D.O.B School Begin Date End Date Level ----------- ----------------------------------- ------------- ---------- -------- ---------- -----------
0 - e
----------- --------- ---- ---- ---------- ----------- ---------- ------ --------- ---------- ---------------- ----- 0001-01-0001 CHARM JIM K 06/30/1977 00XXXXXX 09/01/1999 05/30/2000 1
0001-01-0001 CHARM JIM K 06/30/1977 00XXXXXX 09/01/2000 04/30/2001 3 8888888888 9999999999 SU RP 00/00/0000 10/31/2002 $ 5,500 667 08/21/2000 W 12/31/2001 E E
0002-01-0001 XU DENZEL A 10/01/1973 00XXXXXX 01/12/2000 05/12/2000 2 0101 0101 D1 DU IX 12/17/2003 11/02/2002 $ 3,500 0101 02/14/2000 W 05/10/2002 B DB
0003-00-0001 Jackson MARK R 10/29/1983 00XXXXXX 08/22/2002 05/09/2003 1 0101 0101 D1 DA 00/00/0000 06/14/2003 $ 2,625 0101 11/04/2002 W 12/13/2002 D DD
FFEL DIRECT DUAL
TOTAL DOLLARS IN DEFA TOTAL DOLLARS IN REPA TOTAL INSURANCE CLAIM ************* = Not A
-Actual Numerator Count
Claim Reason Code – identifies why a claim was paid on a FFEL or if a Direct Loan or FFEL purchased by the Department is considered in
------------ ---- 7,875 44,625
Amount – the original principal amount of the loan.
Report Count :
on O on O
Guaranty Loan/Date – date that the guaranty agency insured a FFEL or the first date of disburse-
Enrollment Status Code— borrower’s enrollment status at time the rate was calculated.
Enrollment Status Date —
Actual Denominator Co INDIVIDUAL PROGRAM TA
default because the borrower has defaulted or met the other
fault D
Repay Date – date the borrower
rt Count : ment for a Direct Loan.
ge Last date the borrower’s enrollment status changed. If
Appealed Rate flag: N Appe 0 Default/Neg Am Date o
entered into repayment on the
IC: i Report Gene
no date is available, the data manager may use 01/01/1900.
-Def The date a guaranty agency paid a default claim to a lender n
loan. This date =Eligible but not counted (Note that the enrollment Def (claim paid date) on a FFEL or the day a Direct Loan or FFEL r
purchased by the Department is considered in default either y
because the borrower has defaulted (default date) or met the other specified condition. This date determines if the loan is included in the numerator of the cohort default rate
t
calculation.
determines if the borrowerloan is included in the denominator of the cohort default rate calculation
D Guarantor/Servicer = The data manager responsible
for the loan. See data manager addresses at:
ct Ifap.ed.gov/DefaultManagement
t Num status code and date ; may reflect subsequent enrollment at a different school; rather than borrower’s enrollment at the school listed on the LRDR.)
These fields are the ones most often cited in challenges and adjustments.
9
SUMMARY – bottom of last page of LRDRSUMMARY – bottom of last page of LRDR
10
FFEL DIRECT DUAL
------------- ------------- ------------- TOTAL DOLLARS IN DEFAULT : 1,071,266 7,875 0 (Based on Outstanding Principal Balance) TOTAL DOLLARS IN REPAYMENT : 6,950,053 44,625 0 (Based on Outstanding Principal Balance) TOTAL INSURANCE CLAIM PAYMENTS: 0 ************* = Not Available -Actual Numerator Count : 134 Report Count : 129(B Usage 1 Codes only) Actual Denominator Count: 842 Actual Default Rate: 15.9 Report Count : 837(D & B Usage 1 Codes) INDIVIDUAL PROGRAM TALLY: FFEL: 134/842 DIRECT: 3/20 Appealed Rate flag: N (D=Direct, I=Indirect, N=No Appeal, U=Unknown) IC: 0 (Negative Amortization Only)
0 End of Loan Record Detail Report Report Generation Date: XX/XX/05 -Default Rate Usage 1: D=Denominator, B=Numerator/Denominator, N=Not Used, E=Eligible but not counted Default Rate Usage 2: FD=FFEL Denominator, FB=FFEL Numerator/Denominator, DD=Direct Denominator, DB=Direct Numerator/Denominator,
IC=ICR (Negative Amortization Only), N = Not Used, E = Eligible but not counted
Information Protected By the Privacy Act of 1974 As Amended
Total Dollars in Default – total outstanding principal balance (including any interest that has accrued on the loan since it went into default) for the defaulted loans that are included in the CDR calculation.
Total Dollars in Repayment – total dollar volume for loans that have entered repayment during the
Actual Numerator Count – total number of unduplicated borrowers included in the numerator of the CDR calculation.
Actual Denominator Count – Is the total number of unduplicated borrowers included in the denominator of the CDR calculation.
Actual Default Rate – based on one cohort fiscal year of data, which is, in most cases the school’s cohort default rate. However, if a school has 29 or fewer borrowers entering repayment in the CDR calculation or if the school has a combined, substituted, or merged cohort default rate, the actual default rate will not reflect the school’s cohort default rate.
Report Count/ Numerator –unduplicated borrowers listed on the LRDR with a “B” in the Usage 1 field.
Report Count/Denominator – unduplicated borrowers listed on the LRDR with a “D” or “B” in the Usage 1 field.
NOTE: the Report Count may differ from the Actual Count if rate has changed due to adjustment/appeal. The Actual Count will reflect adjustment/ appeal changes.
cohort fiscal year in question.
Total Insurance Claim Payments – actual amount of guaranty agency claims paid to lenders on FFELs.
Because the Total Dollars in Default includes interest, this figure will not match the Total Insurance Claim Payments, which does not include interest.
Individual Program Tally – the number of borrowers identified with each loan program and the number of those borrowers who have defaulted or met the other specified condition. These fields are purely informational and do not reflect the school’s cohort default rate.
Appealed Rate Flag – (D) Direct = School’s cohort default rate altered due to the school’s adjustment/appeal (I) Indirect = School’s cohort default rate altered due to an adjustment/appeal filed by a different school in a combination/substitution/merger (N) No Appeal = School’s cohort default default rate not altered by an adjustment/appeal (U) Unknown = Adjustment/appeal status unknown for a cohort default rate prior to FY 1993.
Income Contingent – this field is no longer used.
Interpreting the LRDR CodesInterpreting the LRDR Codes
Usage 1 Codes D Denominator only
B Both Numerator and Denominator
N Not Used
E Eligible, but not counted
Enrollment Status Codes
A Approved leave of absence
D Deceased
F Full-time
G Graduated
H Half-time or more, but less than full-time
L Less than half-time
N Not available
W Withdrawn
X Never attended
Z No record found
Loan Type Codes
CL FFEL Consolidated Loan
D1 Direct Subsidized Loan
D2 Direct Unsubsidized Loan
D4 Direct PLUS Loan
D5 Direct Unsubsidized Consolidation Loan
D6 Direct Subsidized Consolidation Loan
D7 Direct PLUS Consolidation Loan
PL FFEL PLUS Loan
RF FFEL Refinanced Loan
SF FFEL Subsidized Stafford Loan
SL FFEL Supplemental Loans for Students Loan
SU FFEL Unsubsidized Stafford Loan
Usage 2 Codes
Code Program
FD FFEL Denominator
FB FFEL Numerator and Denominator
DD Direct Loan Denominator
DB Direct Loan Numerator and Denominator
N FFEL/Direct Loan
Not included in the cohort default rate calculation
E FFEL/Direct Loan
Eligible, but not counted or used in the cohort default rate calculation
Claim Reason Codes BC FFEL Bankruptcy, Chapter 13
BO FFEL Bankruptcy, Other
CS FFEL Closed School
DE FFEL Death
DF FFEL Default
DI FFEL Disability
EX FFEL Exempt
FC FFEL False Certification
IX Direct Loan, Defaulted Loan
11
Special CircumstancesSpecial Circumstances
How do special circumstances effect the How do special circumstances effect the cohort default rate?cohort default rate?
Special circumstances only effect the cohort Special circumstances only effect the cohort default rate calculation if the school timely default rate calculation if the school timely submits documentation of the special submits documentation of the special circumstance to the data manager.circumstance to the data manager.
12
Special CircumstancesSpecial Circumstances
13
Special Circumstances cont’dSpecial Circumstances cont’d
14
Special Circumstances cont’dSpecial Circumstances cont’d
15
Special Circumstances cont’dSpecial Circumstances cont’d
16
Special Circumstances cont’dSpecial Circumstances cont’d
17
Special Circumstances cont’dSpecial Circumstances cont’d
18
Challenges, Adjustments, and Appeals
19
When and Why SubmitWhen and Why Submit• After reviewing your CDR for either the Draft or Official After reviewing your CDR for either the Draft or Official
period, you have the option to submit a request for an period, you have the option to submit a request for an adjustment, challenge, or appeal. Most of these requests adjustment, challenge, or appeal. Most of these requests are submitted through the eCDR Appeal systemare submitted through the eCDR Appeal system
• Why submit? If a school’s CDR contains incorrect data Why submit? If a school’s CDR contains incorrect data causing the rates to be inaccurate, or if there are causing the rates to be inaccurate, or if there are exceptional mitigating circumstances that would remove the exceptional mitigating circumstances that would remove the school from being subjected to sanctions, an adjustment, school from being subjected to sanctions, an adjustment, challenge, or appeal should be filedchallenge, or appeal should be filed
• A review of the LRDR is required for most submissionsA review of the LRDR is required for most submissions
20
Incorrect Data Challenges (IDC) Incorrect Data Challenges (IDC) IDC: IDC: A school has “DATA” to show that borrowers on the LRDR are A school has “DATA” to show that borrowers on the LRDR are incorrectly reported. incorrectly reported. See chapter 4.1 of the CDR guideSee chapter 4.1 of the CDR guide
When should a school file an IDC? When should a school file an IDC? During the Draft PeriodDuring the Draft Period
Why File? Why File? The correction of incorrect data will impact the official rate. The correction of incorrect data will impact the official rate. Possible incorrect data may be:Possible incorrect data may be:•Borrower did not enter repayment during cohort yearBorrower did not enter repayment during cohort year•Borrower did not default for CDR purposes during the monitoring period Borrower did not default for CDR purposes during the monitoring period •Other borrowers entered repayment during cohort periodOther borrowers entered repayment during cohort period
How to File? How to File? Use the LRDR codes to determine how borrowers are Use the LRDR codes to determine how borrowers are counted for the cohort year. Submit the IDC if the data you have reported counted for the cohort year. Submit the IDC if the data you have reported to NSLDS contradicts the information on the LRDR. Ensure that you have to NSLDS contradicts the information on the LRDR. Ensure that you have the borrower’s SSN, name, basis of alleged error and copies of relevant the borrower’s SSN, name, basis of alleged error and copies of relevant supporting documentationsupporting documentation
21
Participation Rate Index Challenges/Appeals (PRI)Participation Rate Index Challenges/Appeals (PRI)
PRIPRI: : Alleges that a school should not be subject to loss of eligibility or Alleges that a school should not be subject to loss of eligibility or potential placement on provisional certification based solely on its CDR potential placement on provisional certification based solely on its CDR because the school has a PRI that meets a specific criteria. because the school has a PRI that meets a specific criteria. See chapters See chapters 4.2 and 4.8 of the CDR guide4.2 and 4.8 of the CDR guide
When should a school file a PRI? When should a school file a PRI? During Draft and/or Official PeriodsDuring Draft and/or Official Periods
Why File? Why File? The draft CDR suggests that the school will be subject to The draft CDR suggests that the school will be subject to loss of eligibility or potential provisional certification after the release of the loss of eligibility or potential provisional certification after the release of the official CDR.official CDR.
The official CDR release confirms that the school is subject to sanction or The official CDR release confirms that the school is subject to sanction or provisional certification provisional certification
How to File? How to File? Using paper submission, a school must send its PRI Using paper submission, a school must send its PRI challenge to the Department within 45 calendar days for the draft process, challenge to the Department within 45 calendar days for the draft process, or 30 calendar days for the PRI appeal for the official processor 30 calendar days for the PRI appeal for the official process
22
Uncorrected Data Adjustments (UDA)Uncorrected Data Adjustments (UDA)
UDAUDA: : Reflects changes that were correctly agreed to by a data Reflects changes that were correctly agreed to by a data manager (DM), as a result of an IDC submitted after the release of the manager (DM), as a result of an IDC submitted after the release of the draft CDR, but not reflected in the official release. draft CDR, but not reflected in the official release. See chapter 4.3 of See chapter 4.3 of the CDR guidethe CDR guide
When should a school file a UDA? When should a school file a UDA? During the Official PeriodDuring the Official Period
Why File? Why File? The school’s LRDR report indicates that one or more The school’s LRDR report indicates that one or more borrower’s agreed upon changes from the IDC are not reflected in the borrower’s agreed upon changes from the IDC are not reflected in the official CDR. An adjustment may possibly decrease the current CDRofficial CDR. An adjustment may possibly decrease the current CDR
How to File? How to File? This adjustment is filed through the eCDR Appeals This adjustment is filed through the eCDR Appeals system. The system will compare the LRDR for the draft and official system. The system will compare the LRDR for the draft and official rates and determine if agreed upon changes were maderates and determine if agreed upon changes were made
23
New Data Adjustment (NDA) New Data Adjustment (NDA)
NDA: NDA: A new data adjustment allows a school to challenge the accuracy A new data adjustment allows a school to challenge the accuracy of “new data” included in the school’s most recent official cohort default of “new data” included in the school’s most recent official cohort default rate. rate. See chapter 4.4 of the CDR guideSee chapter 4.4 of the CDR guide
When should a school file an NDA? When should a school file an NDA? During the Official PeriodDuring the Official Period
Why File? Why File? A school’s review of the LRDR for the draft and official rates A school’s review of the LRDR for the draft and official rates show data newly included, excluded, or otherwise changed during the show data newly included, excluded, or otherwise changed during the period between the calculation of the draft and official CDR. If errors are period between the calculation of the draft and official CDR. If errors are confirmed by the DM, a school’s rate will be adjustedconfirmed by the DM, a school’s rate will be adjusted
How to File? How to File? This adjustment is available via eCDR Appeals only for This adjustment is available via eCDR Appeals only for most recent cohort of borrowers, used to calculate most recent official most recent cohort of borrowers, used to calculate most recent official rate rate
24
Erroneous Data Appeals (ER)Erroneous Data Appeals (ER)
ER: ER: Alleges that a school’s LRDR for the official rate includes disputed Alleges that a school’s LRDR for the official rate includes disputed data from the IDC, or incorrect new data. Because of the new and/or data from the IDC, or incorrect new data. Because of the new and/or disputed data, a school’s official CDR is inaccurate. disputed data, a school’s official CDR is inaccurate. See chapter 4.5 of the See chapter 4.5 of the CDR guideCDR guide
When should a school file an ER? When should a school file an ER? During the Official PeriodDuring the Official Period
Why File? Why File? A school’s official CDR includes new and/or disputed data, is A school’s official CDR includes new and/or disputed data, is subject to sanctions or provisional certification based solely on the official subject to sanctions or provisional certification based solely on the official CDR, the successful ER either by itself or in combination with a UDA or CDR, the successful ER either by itself or in combination with a UDA or LSA will result in a recalculated CDR below the sanction thresholdLSA will result in a recalculated CDR below the sanction threshold
How to File? How to File? This adjustment is filed by paper submission. A school This adjustment is filed by paper submission. A school begins the process by sending its ER to the DM responsible for the loan begins the process by sending its ER to the DM responsible for the loan within 15 calendar days of the timeframe begin datewithin 15 calendar days of the timeframe begin date
25
Loan Servicing Appeals (LSA)Loan Servicing Appeals (LSA)
LSA: LSA: Alleges a school’s official cohort default rate includes defaulted Alleges a school’s official cohort default rate includes defaulted Federal Family Education Loans (FFELs) or William D. Ford Federal Direct Federal Family Education Loans (FFELs) or William D. Ford Federal Direct Loans (DL) that are considered improperly serviced for CDR purposes. Loans (DL) that are considered improperly serviced for CDR purposes. See See chapter 4.6 of the CDR guidechapter 4.6 of the CDR guide
When should a school file an IDC? When should a school file an IDC? During the Official PeriodDuring the Official Period
Why File? Why File? A school believes that the CDR calculation includes one or A school believes that the CDR calculation includes one or more defaulted FFEL or DL improperly serviced for CDR purposes. more defaulted FFEL or DL improperly serviced for CDR purposes.
How to File? How to File? A school begins the process by sending its request for A school begins the process by sending its request for loan servicing records to the relevant DM(s) responsible for a loan within loan servicing records to the relevant DM(s) responsible for a loan within 15 calendar days of the timeframe begin date via the eCDR Appeals 15 calendar days of the timeframe begin date via the eCDR Appeals System.System.
26
When is a defaultedWhen is a defaulted FFELFFEL considered improperly serviced for cohort default rate purposes?considered improperly serviced for cohort default rate purposes?
A defaulted FFEL is considered improperly serviced for cohort default rate purposes if one A defaulted FFEL is considered improperly serviced for cohort default rate purposes if one or more of the following occur:or more of the following occur:
The borrower never made a loan payment, and the school can document that the lender was required but failed The borrower never made a loan payment, and the school can document that the lender was required but failed to send at least one letter (other than the final demand letter) urging the borrower to make payments on the to send at least one letter (other than the final demand letter) urging the borrower to make payments on the loan.loan.
The borrower never made a loan payment, and the school can document that the lender was required but failed The borrower never made a loan payment, and the school can document that the lender was required but failed to attempt at least one telephone call to the borrower.to attempt at least one telephone call to the borrower.
The borrower never made a loan payment, and the school can document that the lender was required but failed The borrower never made a loan payment, and the school can document that the lender was required but failed to submit a request for pre-claims assistance or default aversion assistance to the guaranty agency.to submit a request for pre-claims assistance or default aversion assistance to the guaranty agency.
The borrower never made a loan payment, and the school can document that the lender was required but failed The borrower never made a loan payment, and the school can document that the lender was required but failed to send a final demand letter to the borrower.to send a final demand letter to the borrower.
The borrower never made a loan payment, and the school can document that the lender was required but failed The borrower never made a loan payment, and the school can document that the lender was required but failed to submit a certification (or other documentation) to the guaranty agency to demonstrate that the lender to submit a certification (or other documentation) to the guaranty agency to demonstrate that the lender performed skip tracing.performed skip tracing.
27
When is a defaulted When is a defaulted Direct Loan or FFEL PUT to the Department Direct Loan or FFEL PUT to the Department considered improperly considered improperly serviced for cohort default rate purposes?serviced for cohort default rate purposes?
A defaulted Direct Loan is considered improperly serviced for cohort default rate purposes A defaulted Direct Loan is considered improperly serviced for cohort default rate purposes if one or more of the following occur:if one or more of the following occur:
The borrower never made a loan payment, and the school can document that the Federal Servicer was required The borrower never made a loan payment, and the school can document that the Federal Servicer was required but failed to send at least one letter (other than the final demand letter) urging the borrower to make payments but failed to send at least one letter (other than the final demand letter) urging the borrower to make payments on the loan.on the loan.
The borrower never made a loan payment, and the school can document that the Federal Servicer was required The borrower never made a loan payment, and the school can document that the Federal Servicer was required but failed to attempt at least one telephone call to the borrower.but failed to attempt at least one telephone call to the borrower.
The borrower never made a loan payment, and the school can document that the Federal Servicer was required The borrower never made a loan payment, and the school can document that the Federal Servicer was required but failed to send a final demand letter to the borrower.but failed to send a final demand letter to the borrower.
The borrower never made a loan payment, and the school can document that the Federal Servicer was required The borrower never made a loan payment, and the school can document that the Federal Servicer was required but failed to document that skip tracing was performed if the Federal Servicer determined it did not have the but failed to document that skip tracing was performed if the Federal Servicer determined it did not have the borrower’s current address.borrower’s current address.
28
Economically Disadvantaged Appeals (EDA) Economically Disadvantaged Appeals (EDA) EDA: EDA: Alleges that a school should not be subject to loss of eligibility (or Alleges that a school should not be subject to loss of eligibility (or potential placement on provisional certification if based on two successive potential placement on provisional certification if based on two successive three‐year rates of 30.0% or more), because it has a high number of low‐three‐year rates of 30.0% or more), because it has a high number of low‐income students and meets the placement or completion thresholds. income students and meets the placement or completion thresholds. See See chapter 4.7 of the CDR guidechapter 4.7 of the CDR guide
When should a school file an EDA? When should a school file an EDA? During the Official PeriodDuring the Official Period
Why File? Why File? If an EDA is successful, it exempts the school from loss of If an EDA is successful, it exempts the school from loss of eligibility or placement on provisional certification until the next official cohort eligibility or placement on provisional certification until the next official cohort default rates are released. default rates are released.
How to File? How to File? Within 30 calendar days, an eligible school may submit a Within 30 calendar days, an eligible school may submit a paper copy of an EDA along with the management’s written assertion to the paper copy of an EDA along with the management’s written assertion to the Department. Within 60 calendar days, the school must submit an Department. Within 60 calendar days, the school must submit an independent auditor’s opinion to the Department.independent auditor’s opinion to the Department.
29
Other Cohort Default Rate AppealsOther Cohort Default Rate Appeals
Average Rate AppealsAverage Rate Appeals
•A school whose 3 most recent CDRs are at or above 30% is not subject to A school whose 3 most recent CDRs are at or above 30% is not subject to sanction if at least 2 of the 3 CDRs were calculated as average rates and sanction if at least 2 of the 3 CDRs were calculated as average rates and would have been less than 30% if calculated using only data for those would have been less than 30% if calculated using only data for those cohort fiscal years alone, or, if most recent CDR is above 40% and was cohort fiscal years alone, or, if most recent CDR is above 40% and was calculated as an average rate, the school is not subject to sanction. calculated as an average rate, the school is not subject to sanction. See See chapter 4.9 of the CDR guidechapter 4.9 of the CDR guide
•Before notice of official rate Department will make an initial determination Before notice of official rate Department will make an initial determination that school may qualify for an average rate appeal that school may qualify for an average rate appeal
•If school qualifies they will receive notice of that determination at the same If school qualifies they will receive notice of that determination at the same time they receive notice of official ratetime they receive notice of official rate
30
Other Cohort Default Rate AppealsOther Cohort Default Rate Appeals
Thirty-or-Fewer Borrower AppealsThirty-or-Fewer Borrower Appeals
•If combined total of all three years of borrowers entering repayment is less If combined total of all three years of borrowers entering repayment is less than 30, there will be no loss of eligibility. than 30, there will be no loss of eligibility. See chapter 4.10 of the CDR See chapter 4.10 of the CDR guideguide
•Before notice of official rate Department will make an initial determination Before notice of official rate Department will make an initial determination that school may qualify for a thirty-or-fewer borrower appeal that school may qualify for a thirty-or-fewer borrower appeal
•If school qualifies they will receive notice of that determination at the same If school qualifies they will receive notice of that determination at the same time they receive notice of official ratetime they receive notice of official rate
31
Appeals, Adjustment and Challenge Quick Reference
32
Draft/ OfficialDraft/ Official Type of ActionType of Action PurposePurpose
DraftDraft IDCIDC Correct data before the official cohort default rates Correct data before the official cohort default rates are released.are released.
DraftDraftPRI PRI
(Challenge)(Challenge)
Demonstrate a low borrower participation rate to Demonstrate a low borrower participation rate to avoid an anticipated sanction with the official avoid an anticipated sanction with the official cohort default rate.cohort default rate.
OfficialOfficial UDAUDAContest a data error that was agreed upon in the Contest a data error that was agreed upon in the draft process but is still reflected in the official draft process but is still reflected in the official cohort default rate data.cohort default rate data.
OfficialOfficial NDANDA
For a school that is not subject to sanction, contest For a school that is not subject to sanction, contest official cohort default rate data that was not official cohort default rate data that was not included in draft cohort default rate data or that is included in draft cohort default rate data or that is different from the draft cohort default rate data.different from the draft cohort default rate data.
Appeals, Adjustment and Challenge Quick Reference
33
Draft/ Draft/ OfficialOfficial Type of ActionType of Action PurposePurpose
OfficialOfficial ERER
For a school that is subject to sanction, For a school that is subject to sanction, contest official cohort default rate data that contest official cohort default rate data that was not included in the draft cohort default was not included in the draft cohort default rate data (new data) and/or contest the rate data (new data) and/or contest the (DM) decision (disputed data).(DM) decision (disputed data).
OfficialOfficial LSALSA Contest servicing of the borrower’s loan Contest servicing of the borrower’s loan account.account.
OfficialOfficial EDAEDADemonstrate a high number of low-income Demonstrate a high number of low-income students and high placement or completion students and high placement or completion rates.rates.
Appeals, Adjustment and Challenge Quick Reference
34
Draft/ OfficialDraft/ Official Type of ActionType of Action PurposePurpose
OfficialOfficial PRI (Appeal)PRI (Appeal) Demonstrate a low borrower participation Demonstrate a low borrower participation rate.rate.
OfficialOfficial Average Rates Average Rates AppealAppeal Demonstrate a low number of borrowers.Demonstrate a low number of borrowers.
OfficialOfficial Thirty-or-Fewer Thirty-or-Fewer Borrowers AppealBorrowers Appeal Demonstrate a low number of borrowers.Demonstrate a low number of borrowers.
Additional ResourcesAdditional ResourcesChapter 2.1 of the Cohort Default Rate Guide Chapter 2.1 of the Cohort Default Rate Guide •Contains tables listing these and other special circumstances and Contains tables listing these and other special circumstances and how they affect the cohort default rate, beginning on page 2.1-10.how they affect the cohort default rate, beginning on page 2.1-10.
Chapter 3.1 of the Cohort Default Rate Guide Chapter 3.1 of the Cohort Default Rate Guide •Contains helpful information regarding how a school should Contains helpful information regarding how a school should prepare for the draft and official cohort default rate release, how a prepare for the draft and official cohort default rate release, how a school can determine if they should submit a cohort default rate school can determine if they should submit a cohort default rate challenge/adjustment/appeal, and types of supporting challenge/adjustment/appeal, and types of supporting documentation.documentation.
Chapter 4 of the Cohort Default Rate Guide Chapter 4 of the Cohort Default Rate Guide •Contains information on each type of Contains information on each type of challenge/adjustment/appeal.challenge/adjustment/appeal.
35
Submitting Appeals/Adjustments•Use eCDR Appeals at ecdrappeals.ed.gov) to submit IDC, UDA, LSA, and NDA•At this time, all other CDR appeals will continue to be submitted via hard copy
36
Operations
Perform
ance
Divisio
n
202-377-4259
Phone: 202-377-4259
E-mail: [email protected]
Website: ifap.ed.gov/DefaultManagement/DefaultManagement.html
E-Appeals: https://ecdrappeals.ed.gov/ecdra/index.html
Contact Information
37
QUESTIONS?
38