Blog

Since You Asked:  Questions & Answers December 20, 2018 Periodically we are asked questions regarding an interpretation of the laws, regulations, or policies related to the administration of the Title IV Federal Student Aid (FSA) Programs.  In this series we provide questions, and the related answers, generated by our interaction with clients and the U.S. Department of Education (ED).  Contents by Topic Institutional Recertification Emergency Contact Info Valid High School Diploma/Transcript Citizenship and Third-Step Verification Cost of Attendance FAFSA Completion Verification and Deadlines Program Acceleration Satisfactory Academic Progress and Excused Absences Disbursements of Subsequent Loans Record Retention Natural Disasters  

At the stroke of midnight ending December 21, 2018, (i.e., early Saturday morning, December 22, 2018) the U.S. Government entered a partial shutdown due to budget funding not being finalized, and requisite appropriations not being authorized, for all departments and agencies of the government.  The U.S. Department of Education (ED) already received its budget and funding approval back in September 2018, for the full 2018-2019 award year, through September 30, 2019.  Accordingly, it would seem that there should be no impact on institutions and students processing for Federal Student Aid Programs. Yet, there are still some Departments of the U.S. Government that have not received budgets and funding for the current fiscal year.  Those non-funded departments and agencies were required to shut down “non-essential services.”  Thus, this may result in some indirect impact on students’ financial aid applications being fully processed, and on institutions’ ability to process students’ Institutional Student Information Reports (ISIR) generated from students having submitted a Free Application for Federal Student Aid (FAFSA).  So what are some potential implications or effe

Does it seem like ten years is a long time?  That is the period of time over which those working with Federal Student Aid (FSA) have to address the effects of “sequestration.”  For those who have been around a year or more, you will recall that sequestration came about as a result of the Budget Control Act (BCA) of 2011.  The financial aid community was first impacted with the first round of sequestration effective in March of 2013[1].  BCA is commonly called the sequester law.  A portion of the BCA mandates comprehensive cuts in certain programs annually.  The sequestration effects of the BCA are still with us for a few more years, barring any future legislative action to end or reverse the BCA’s impact on the FSA programs. It is important to remember that the BCA impacts various Title IV FSA programs differently.  For example, the Federal Pell Grant program is exempt from sequester.  But, other programs are impacted, specifically the Federal Direct Loan (DL) programs and the Iraq-Afghanistan Service Grants (IASG), as well as the TEACH Grant program.  The DL programs are required to experience an alteration in the applicable l

The U.S. Department of Education (ED) has delayed the implementation of the December 19, 2016, State Authorization section of the Program Integrity and Improvement regulations.  The new effective date for the bulk of the December 2016 State Authorization regulations is July 1, 2020.  A news item, “DeVos Delays State Authorization Rules,” in Inside Higher Ed first reported this delay as official on Monday, July 02, 2018. Although the final regulations were published in December 2016, due to the “Master Calendar” requirements in the law, the effective date of the regulations was set to be July 1, 2018.  This new Final Rule delays the implementation and effective date until July 1, 2020.  The delay is to allow for appropriate time to conduct another round of negotiated rulemaking to address significant concerns propagated by a wide-sector of highe

Recent key announcements from the U.S. Department of Education (ED) have critical information pertinent to your compliant and successful Title IV Federal Student Aid operations. Gainful Employment (GE) Draft Completers List – Institutions must submit any corrections to their GE Draft Completers List by Wednesday, June 13, 2018. Please see our prior Regulatory Bulletin, “Completed or Not?  (The Draft GE Completers List),” which was posted on our Blog page on May 3, 2018 on the FAME Web site.  Also, see ED’s reminder about the due date posted on IFAP.  It appeared in their Electronic Announcement on June 6, 2018.   Department of Homeland Security’s (DHS’) Systematic Alien Verification Entitlement (SAVE) system – The new SAVE system is experiencing issues that prevent schools from verifying students’ immigration status. (The DHS’ new electronic “three-step” process

The economy is one topic that stays relevant and is regularly a subject of news stories.  Closely related is the topic of interest rates.  Without going into a long discourse on economic conditions or policy, suffice it to say that interest rates have a significant impact on the economy.  And, with student loans now reportedly to have grown to be a $1.4 trillion[i] segment of the debt of the population of the United States as of the end of last year, the interest rates applied to student loans is of interest to a large segment of people.   The interest rate for all loans made after July 1, 2013, is set at a fixed rate.  This rate structure was implemented with the Bipartisan Student Loan Certainty Act of 2013, which overh

Financial aid administrators at times may wonder if a student is striving to become a professional student.  But, at other times, the financial aid officer wonders if the student is ever going to complete any educational program!  Interestingly, the U.S. Department of Education (ED) wants to know whether or not they have completed a program, as well—especially a “gainful employment” (GE) program. ED has announced in the Gainful Employment (GE) Electronic Announcement #114 that it has distributed institutions’ Draft Gainful Employment “Completers Lists” to the institutionally designated Student Aid Internet Gateway (SAIG) mailbox for GE message

The U.S. Department of Education (ED) has distributed revised Federal Pell Grant Payment and Disbursement Schedules for the 2018-2019 award year.  The new schedules were released with ED’s Dear Colleague Letter GEN-18-04 (DCL GEN-18-04)[1] on April 10, 2018.  The newly updated schedules were necessitated due to the passage of the Consolidated Appropriations Act of 2018 (Public Law 115-141), which was signed into law on March 23, 2018. Crux of the DCL and New Payment Schedules The new maximum Pell Grant award for 2018-2019 is now $6,095.  The minimum scheduled award for a full year for 2018-2019 will now be $650.  The maximum possible expected family contribution (EFC) that an applicant may have and still receive some amount of Pell Grant for the award year, if otherwise eligible, is 5486.  It is important that institutions ensure that all 2018-2019 Federal Pell Grant awards are made based upon the “revised” schedules included with DCL Gen-18-04.

Dancing the New Three-Step (The Three-Step DHS Verification) Well, let’s face it.  Some are just better than others at doing a two-step on the old dance floor.  What makes the difference?  Perhaps it is due to more training or experience, and for some, perhaps there is just more natural ability.  But, along with, hopefully, some natural ability, it does take some basic understanding of the steps appropriate for the dance. Likewise, in determining certain noncitizens’ eligibility for Federal Student Aid requires knowing and accomplishing the appropriate steps.  Failure to know and appropriately follow those steps could cause the music of the Federal Student Aid dance to stop for some students.

Books, Supplies, and Equipment.  Oh My!  There is a familiar line in the cinema classic, Wizard of Oz, as Dorothy and her unique companions were walking in the dark forest:  “Lions and tigers and bears!  Oh, my!”  No doubt the line in this timeless film could be paraphrased for the world of financial aid:  “Books and supplies, kits and equipment!  Oh, my!”  Yes, in the financial aid realm—especially in the proprietary sector—this topic has, on occasion, perhaps brought apprehension similar to what the traveling trio experienced while traversing down the yellow brick road. It has become clear that not all institutions are charging by the payment period, and thus, accordingly may not charge books, supplies, and kits, as a first payment period charge.  Let us explore concerns related to this refrain about books, supplies, kits, and equipment. Institutional Charges One of the first concepts that requires a clear understanding is the meaning of “institutio

It has been almost 10 years since the signing of the Higher Education Opportunity Act (HEOA) in 2008.  One of the provisions added in that Reauthorization of the Higher Education Act (HEA) of 1965 was the requirement for most institutions to have a Net Price Calculator (NPC) available on the institution’s Web site.  So, it would seem that everyone should know about the NPC requirement and what the law stipulates about it.  But, undoubtedly, there are numerous institutions that are lacking in a thorough understanding of the NPC provisions, or are remiss in fulfilling the mandate of the law.  With the recent release of the 2018 Net Price Calculator template, it is time to take another look at t

“Draft” is an interesting word with many different meanings.  A “draft” is a process used in sports in the United States of America to select players for various teams within a league.  A person can also be “drafted” into politics based upon a large base of public support, as was the case for both major political parties’ candidates in the 1952 presidential election, resulting in the election of President Dwight D. Eisenhower[1].  And, in days gone by, young men were worried about the “draft” resulting in their potential involuntary selection for military service.  But, more generally, we think of a “draft” as being the initial effort at, or version of, a project, report, or writing. With the U.S. Department of Education’s (ED) calculation of cohort default rates, it is no different.  There is an initial “draft” of the rates calculated before the final, official release

October 2017 marked the anniversary of the implementation of what has been called “the early FAFSA,” and the use of prior-prior year (PPY) income when submitting the Free Application for Federal Student Aid (FAFSA).  Two years earlier, on September 14, 2015, President Obama announced major changes in the historic application process for Federal Student Aid.  Those changes included the earlier application processing start-up for subsequent financial aid award years (July 1 through June 30), beginning with the 2017-2018 award year.  This allowed students’ early submission of FAFSAs—for the first time—for the 2017-2018 award year, beginning October 1, 2016.  Likewise, this year students across the country began submitting their FAFSA as of October 1, 2017, for the 2018-2019 award year, even as they are finalizing plans and preparations to attend the postsecondary institution of their choice in the upcoming academic 2018-2019 year. Each year the bulk of those students seeking to enroll in postsecondary education submit the Free Application for Federal Student Aid (FAFSA).  Today, the vast majority of FAFSAs are typically complet

It is time to commence the annual ritual, of recent years, for many postsecondary schools.  That is, it is time for the annual update of institutions’ Gainful Employment (GE) Disclosure Templates, or the GEDT.  The U.S. Department of Education requires all postsecondary institutions that have GE programs to disclose applicable information via the GEDT. The 2018 GE Disclosure Template (GEDT) ED announced the release of the 2018 GEDT on the Information for Financial Aid Professionals (IFAP) Web site via GE Electronic Announcement #110 on Friday, January 19, 2018.  For a number of years, the GEDT had been made available in the

Constellation Software, Inc. Acquires Higher Education Software Provider FAME We are excited to announce a change in the ownership of FAME.  As of November 28, 2017 Constellation Software Inc. (“Constellation”) (TSX:CSU), its wholly-owned division Vela Operating Group (“Vela”) and its subsidiary Aquila Software (“Aquila”) have acquired Financial Aid Management for Education, Inc. (“FAME”).  Constellation, a $2.1 billion company with over 12,000 employees, operates in 80 vertical markets internationally. They currently own software companies that provide K-12 SIS in Australia and England, and have acquired FAME as their entry into the North America educational market. Constellation Software is an international provider of market-leading software and services to a number of industries, both in the public and private sectors. Their mission is to acquire, manage and build market-leading software businesses that develop specialized, mission-critical software solutions to address the specific needs of their particular industries. FAME’s CEO, Bill Little, the entire Executive Team, managers, supervisors and emp

Did you know that a “credit freeze” may delay Federal Direct PLUS Loan approvals?  The U.S. Department of Education’s (ED) Federal Student Aid Office has informed the financial aid community that some applicants for a Federal Direct PLUS Loan may experience a challenge in the process.  Applicants for a Federal Direct PLUS Loan (parent PLUS Loan, or graduate/professional PLUS Loan), or an endorser for a PLUS Loan, that have elected to place a “credit freeze” on their credit profile may not be able to fully complete the process.  ED’s alert to the situation was published on October 13, 2017, in its weekly COD Processing Update.  The full text of the information provided is copied below for your convenience: Credit Check Processing for Borrowers who have requested a “Credit Freeze” (10/13/17) As a result of recent data breach events and heightened security concerns, many consumers are understandably taking steps to protect their personally identifiable information (PII). One of those steps may

At times leaders and managers like to “go with their gut” in making decisions.  This may be adequate in familiar situations and scenarios.  However, once a leader or manager encounters unfamiliar territory, it is helpful to have data upon which to inform his or her decisions as to which next actions to take.  This leads to a need for reliable data.  It has been said that, “leaders themselves need to adopt a more rational, data-driven mindset themselves, instead of relying solely on largely irrational human instincts.”[1] Many may find discomfort with data as a means of making decisions.  But, perhaps there are instances in which most all agree one must use applicable data—that is, when regulatory or legislative language requires knowledge of and action upon such specified data.  One such example is the FY 2014 3-Year official cohort default rate (CDR

Determining when it is “time to say goodbye” to a student is often a situation that may cause angst.  Various ways to maintain the individual as a student are explored.  Yet, that study generates questions as a result of uncertainty in how to proceed. There have been times when an institution has “suspended” a student from his/her enrollment in an academic program.  Such a practice, whether due to academic performance, financial matters, poor attendance, disciplinary measures, or other reason, must be carefully considered.  There are several points related to Title IV Federal Student Aid to ponder when deliberating the possible suspension of a student. Do current regulations allow for the concept of a “suspension?” In ge

Did You Know? The U.S. Department of Education (ED) has updated its guidance related to natural disasters.  In the wake of devastating hurricanes and other disasters that have occurred recently (e.g., wildfires), institutions would be well-advised to become familiar with ED’s latest instructions. This most recent direction is contained in Dear Colleague Letter GEN-17-08, published on August 29, 2017.  The ten-page attachment to the DCL gives specific guidance applicable to individual programs, e.g., Campus-Based Aid programs, Direct Loans, etc., as well as information related to Return of Title IV Funds (R2T4) calculations, enrollment reporting, Federal Pell Grant reporting of disbursements, Fiscal Operations Report and Application to Participate (FISAP) deadline, and much more. The information in GEN-17-08 supersedes and replaces all previous guidance from ED as it relates to natural disasters.  This includes the direction provided in DCL GEN-10-16/FP-10-06 (guidance for helping Title IV participants affected by a major disaster), GEN-04-04 (general guidance for helping Title IV participants a

We, the People… Knowing who we are on Constitution Day, and Every Day. A question came to mind a number of years back.  “Why do I believe what I believe?”  And, perhaps just as importantly, “what do I believe?”  As citizens of the United States of America, we have certain rights that are foundational in our beliefs and way of life, that make us distinct from any other country in the world.  In our unique system of government, our Constitution guides the federal government in matters of interstate commerce, revenue generation for limited purposes (e.g., finance a war effort if necessary), and resolution of disputes between states.  These limited powers of the federal government are fundamental to our

Gainful Employment (GE) programs with their related debt-to-earnings (D/E) rates, disclosures, and alternate earnings appeals have become a frequent topic in the world of Title IV Federal Student Aid.  Last week, the U.S. Department of Education (ED) provided further guidance related to GE alternate earnings appeals deadlines, and associated disclosures. Imperative Dates Clarified In GE Electronic Announcement #108 (GE EA #108), ED provided clarification about, and an update on, the deadlines for institutions that wish to submit an alternate earnings appeal to use institutionally gathered data to substantiate its graduates’ 2014 earnings instead of the 2014 earnings data ED obtained from the Social Security Administration (SSA) for the 2014-2

When Things Stay the Same… The Gainful Employment Reporting Deadline Has Not Changed  This year has been a bit of a roller coaster ride as it relates to postsecondary institutions’ Gainful Employment (GE) programs.  We have noticed more than once this year, that the U.S. Department of Education (ED) has granted slight reprieves for the deadlines to meet some GE requirements.  As those impacted are aware, institutions with any GE program that is in the zone or that is a failing program are allowed by law to submit an alternate earnings appeal if the use of alternate earnings would: improve a zone program to passing, or a failing program to either passing or zone.

Going ‘Round, and ‘Round (or, the Latest Rendition of “Year-Round” Pell) Those who have been around postsecondary education for the last eight years or so, likely recall the quickly implemented “year-round” provision of the Federal Pell Grant (Pell Grant) program in 2009-2010.  That was the “first” edition.  The original “year-round Pell” was created by the Higher Education Opportunity Act (HEOA) of 2008.[1]  It authorized schools to disburse up to two Pell Grants in a single award year to eligible Pell Grant students.  The first edition of year-round Pell provided for implementation beginning in 2009-2010.  Although it was short-lived due to the pr

On Again, Off Again, and On Again?… Gainful Employment Disclosure Requirements In recent weeks and months, many institutions have worked hard to determine the best way to handle new requirements related to Gainful Employment (GE) program disclosures and, what was anticipated to be, warnings to current and prospective students.  Much angst was experienced as institutions explored what the potential ramifications of such disclosures and warnings would be on admissions and current enrollment at institutions.  While all of that effort and thought was not for naught, institutions do have opportunity to take another long breath of fresh air. And, I Start the New Disclosures and Warnings, When? Institutions that have GE programs that did not yield a passing rate for the debt-to-earnings (D/E) rates released by the U.S. Department of Education (ED) back in

On July 5, 2017, the U.S. Department of Education (ED) announced a temporary hold on 2017-2018 FWS and FSEOG drawdowns in G5.  This temporary hold began at 3:00 P.M. (ET) on July 5th due to a recently discovered error in the underlying calculations of tentative and final awards for some schools. As a result, FWS and FSEOG awards will be recalculated for all schools. The hold is expected to last no longer than 7 business days.  In most cases, this recalculation will have little or no impact on final award levels. ED has indicated the average change will be less than $3,500 for FSEOG and less than $2,500 for FWS. Pell Grant and Direct Loan funds are not impacted by this temporary G5 hold. ED will post a subsequent Electronic Announcement to inform schools when recalculated awards are available and G5 drawdown access is restored.

The U.S. Department of Education (ED) has provided updated instruction related to the effects of sequestration that first took place effective March 1, 2013. ED gave this most recent guidance in a June 19, 2017, Electronic Announcement, based on the changes effective October 1, 2017, which is the beginning of the 2018 federal fiscal year (FY 2018). This latest update pertains only to FY 2018. This sequester announcement continues the implementation of the Budget Control Act (BCA) of 2011, also known as the sequester law. The law required across-the-board cuts in certain programs. The sequestration effects of the BCA are applicable for 10 years. Schools are reminded that the Federal Pell Grant program is exempt from sequester. Therefore, the 2017-2018 Pell Grant Payment and Disbursement Schedules continue to be in effect. The changes required by sequestration effective October 1, 2017, are applicable to the Federal Direct Loan fees and the percentage reductions that must be made to awards offered in the Iraq-Afghanistan Service Grant and TEACH Grant Programs where the first disbursement is on or after October 1, 2017.

In Dear Colleague Letter GEN-17-04 dated April 24, 2017, ED announced changes as a result of the suspension of the IRS Data Retrieval Tool.  ED is providing the following immediate flexibilities as options if a school chooses to use them as part of its verification procedures for both the 2016-2017 and 2017-2018 award years. IRS Tax Return Filers – A signed paper copy of the 2015 IRS tax return that was used by the tax filer for submission to the IRS is acceptable documentation to verify ISIR tax return information. Verification of Nonfiling – Documentation obtained from the IRS or other tax authorities are no longer required to verify that the student, the student’s spouse or the student’s parents did not file a 2015 tax return. However, as currently required, they must provide to the school- A signed statement certifying that the individual has not filed and is not required to file a 2015 income tax return. They must list the amounts and sources of any 2015 income earned from work; and A copy of IRS Form W-2, or an equivalent document,

Some things just naturally keep your interest.  One item of which most college students are acutely aware, and which attracts “interest” each year, is the interest rate that will be applicable to loans taken out for the new award year.  Although federal student loans taken out after July 1, 2013, have a fixed interest rate structure, loans borrowed in each award year have a different interest rate than the prior year.  The loans to be borrowed in the award year of July 1, 2017, through June 30, 2018, are no exception.  And, it is of note that interest is rising. As those keen on this topic may recall, a new method of rate determination came about as a result of the Bipartisan Student Loan Certainty Act of 2013, which overhauled the Federal Direct Student Lo

You can use the data from a student’s 2016-2017 ISIR that has an “02” IRS Request Flag code (referred to by some as the “Data Retrieval Tool” code, or DRT code) for verification of the student’s 2017-2018 ISIR data without having to request a tax return transcript. As an example, consider a student for whom you have a 2016-2017 ISIR and the ISIR has the “02” IRS Request Flag code.  The student was not selected for verification in 2016-2017.  The 2017-2018 ISIR was selected for verification, but there was no “02” IRS Request Flag code on the 2017-2018 ISIR, nor was there a SAR Comment Code 399 (which, as you will recall, is assigned when the student or parent reported different 2015 income and tax information on their 2017-2018 FAFSA than what was reported on their 2016-2017 FAFSA[1]).   In this hypothetical student example, the 2015 income on both years’ ISIRs is the same. The U.S. Department of Education’s (ED) guidance in Dear Colleague Letter GEN-16-14 states that, if there is no comment code 399, “the institution is not required to determine if there are any differences in income or

Did You Know? There are specific considerations that must be met in order for a school to be able to include the hours during which a student is at an academically-related professional “show” or “event” in its count of hours “attended” when determining that a student has completed his or her academic program. FAME has been asked on several occasions about including “show” or “event” hours attended as part of completed program hours. FAME sought guidance from the U. S. Department of Education (ED).  ED advised that typically such hours at “shows” or “events” would not be included.   The shows or events actually would have to be a part of their academic program curriculum to be counted.  Further, if they are able to be counted, they would have to be treated like an internship, etc., where supervised instruction is still being provided at an off-site location.  The school’s accrediting agency and its state approving agency would have to approve the program with those specific hours being taught in that manner. If your show or event does not meet the above criteria you may no

Did you know that the IRS Data Retrieval Tool (IRSDRT) at StudentLoans.gov and fafsa.gov has been unavailable for over a week with no relief in sight?  It is anticipated that the online transfer of data from the IRS will be down for several more weeks. The IRS decided to temporarily suspend the Data Retrieval Tool as a precautionary step following concerns that the tool could potentially be misused by identity thieves.  The IRS has an ongoing effort to protect the security of the data.  The IRS and FSA (Federal Student Aid) are jointly investigating the issue and working to further strengthen the security of the information provided by the DRT. Meanwhile, applicants still have the option to complete the FAFSA or IDR (Income Driven Repayment) application using a copy of their 2015 IRS tax return and if selected for verification they can request a Tax Transcript or update the ISIR once the DRT is available. As additional information becomes available FAME will post another notice. ·         2017-03-10 (General) Subject: IRS and Department of Education Statement‎ About the IRS Data Retrieval Tool (DRT)  https://ifap.ed.gov/eannouncements/031017IRSandDeptofE

The U.S. Department of Education (ED) posted late on Monday, March 6, 2017, that it is granting additional time for submission of an Alternate Earnings Appeal to the Gainful Employment (GE) Debt-to-Earnings (D/E) rates that were released by ED on January 9, 2017.[1]  Additionally, ED is extending the deadline by which institutions must comply with the Gainful Employment (GE) disclosure requirements, and the use of the new GE Disclosure Template, that were released in GE Electronic Announcement #103 on January 19, 2017.[2]    The reason stated for the extension of the deadlines was to allow time for ED to further review the GE regulations and their implementation.  The notice was made via one of its routine Electronic Announcements.   The new deadline by which institutions that are going to submit an Alternate Earnings Appeal must do so is July 1, 2017.  Previously, the deadline was March 10, 2017.  (The change in the deadline for submitting an Alternate Earnings Appeal did not also extend the deadline by which institutions had to submit a Notice of Intent to Appeal, which has already passed.  That deadline date for submitting the Notice of Intent to Appeal was January 2

The U.S. Department of Education (ED) distributed the FY 2014 3-Year Draft Cohort Default Rates last Monday, February 27, 2017.  Under regulations published October 28, 2009, a school's Cohort Default Rate (CDR) is calculated as the percentage of borrowers in the cohort who default before the end of the second fiscal year following the fiscal year in which the borrowers entered repayment.  This, in essence, creates the 3-year CDR.[1] The Draft CDRs were distributed to schools’ Student Aid Internet Gateway (SAIG) mailboxes.  The CDRs and accompanying Loan Record Detail Reports may also be downloaded via the National Student Loan Data System (NSLDS) via the NSLDS Professional Access Website. Schools should examine the February 27, 2017, Electronic Announcement to be reminded of the impact that will be incurred if a school’s FY 2014 official 3-year CDR is equal to or greater than 40% when the official CDR is published in September 2017, or if the school’s 3-year CDR has been 30% or greater for three years.

The U.S. Department of Education (ED) has updated its guidance related to acceptable documentation for verification of non-filing tax status. Per ED’s February 23, 2017, Electronic Announcement, there are four types of documents used for verification of tax filing data on the FAFSA: Tax Return Transcript Record of Account Tax Account Transcript Wage and Income Transcript (IRS Form W-2 documentation) The Electronic Announcement gives, except for the routine Tax Return Transcript, more details about the information contained on, and uses of, these less commonly obtained forms of documentation. ED does specify that “IRS documents that clearly indicate that the IRS does not have a tax return record on file for the tax year are acceptable for verification of non-filing.”  This may be wording on the document from the IRS such as, “no record of return on file” or “no transcript on file.”  Naturally, if the document requested from the IRS results in a response that the

Did You Know? Recent explanation of information received from the U.S. Department of Education (ED) may alter your procedures for calculating the date of determination (DOD) in Return of Title IV (R2T4) calculations. For clarification purposes, FAME received guidance from ED that affects schools that are required to take attendance.  The amplification on prior guidance relates to R2T4 and the DOD when a scheduled break is involved in the payment period.  Here are some examples based on ED’s guidance. Scenario 1 – The student’s last day of attendance (LDA) was 12/15/16.  A scheduled break occurred from 12/23/16 until 1/8/17.  Fourteen (14) calendar days[1] started 12/16.  Therefore, the latest date allowed as the DOD occurs 12/29/16, during the break.  The date of 12/29/16 is when the school should start the withdrawal process.  The school would have 45 days (or 30, depending on school policy) from the DOD to return any federal funds, if applicable. The school should reach out to the student prior to the break to see what is going on.  Is he going t

It is important to be familiar with the following verification changes and be reminded of the requirements for subsequent ISIRs and conflicting information.  FAME is enhancing our financial aid software products to assist schools with these requirements and schools will be notified of any changes in product release announcements. Verification Beginning with 2016–2017, a student may move from Verification Tracking Group V1, V4, or V6 to group V5 based on corrections made to their CPS record or on other information available to the U.S. Department of Education.  If verification was already completed for the previous group, the student is only required to verify the V5 information that was not already verified.  If verification was not completed for the previous group, the student only needs to verify the V5 information.  No disbursements of Title IV aid may be made until the V5 verification is satisfactorily completed.  If the applicant does not complete verification, the school is not liable for any Title IV aid it disbursed prior to receiving the group V5 ISIR. The student is liable for the full amount because without verification there is no ev

The U.S. Department of Education (ED) has released the final “Gainful Employment (GE) Debt-to-Earnings Rates for the for the 2015 Debt Measure Year. Per ED’s January 6, 2017 Electronic Announcement, a “GE program passes the D/E rates measure if: its annual earnings rate is less than or equal to 8 percent or its discretionary income rate is less than or equal to 20 percent. A GE program fails the D/E rates measure if: its annual earnings rate is greater than 12 percent, and its discretionary income rate is greater than 30 percent. Also, a discretionary income rate will be considered failing if its denominator is negative or zero, and an annual earnings rate will be considered failing if its denominator is zero. A GE program with D/E rates that are neither passing nor failing is in the zone. If a GE program fails or is in the zone, a tr

Happy New Year!  As if one did not know, it is the start of a new calendar year!  The beginning of a new year has come to be known, for postsecondary education institutions with Gainful Employment (GE) programs, as the time for updating the U.S. Department of Education’s (ED), Gainful Employment Disclosure Template (GEDT).  But, if you are waiting for the new year’s GEDT as the sign of the new year’s start, you may be a little late in realizing the new year has already begun! Delayed Release of GE Disclosure Template Currently, ED anticipates the release of the 2017 GE Disclosure Template in the latter part of January 2017.  The template has typically been made available in the fall of each year so that schools could ensure they had their GE Disclosure Information posted and distributed by January 31 of each year following the most recently completed award year.  This year, 2017, ED does not yet have the GEDT available for schools to use to update their GE Disclosure Information for the award year ending June 30, 2016.  The main reason stated for the delay in availability this year is due to extensive revisions to the GEDT that ar

(Or, Uncertainty in the Face of the Gainful Employment Debt to Earnings Rates) It was a long time coming!  But, the first calculation of the Gainful Employment (GE) draft Debt-to-Earnings (D/E) rates have arrived!  Almost six years to the date after the publication of the original October 29, 2010, Program Integrity Regulations which contained the original version of GE regulations, the U.S. Department of Education (ED) recently released the long-awaited draft GE D/E rates!  Without doubt, many schools opened that message in their Student Aid Internet Gateway (SAIG) mailbox with much trepidation when it arrived!  So that we may assist in alleviating any apprehension, let us review the overall GE D/E rate process, including current options as well as upcoming ones. Draft GE/DE Rates The draft GE D/E rates were calculated by the U.S. Department of Education (ED) after allowing institutions the opportunity to review and submit corrections to the GE Completers List this past summer.  The final submission of the GE Completers List was due July 28, 2016.  This GE Completers List w

(see corrections in red font below) Should Books and Supplies be Included in Tuition and Fees? The Program Integrity Regulations issued on October 30, 2015, contain several new changes, most of which became effective on July 1, 2016.  This Regulatory Bulletin is only going to cover 668.164 which addresses disbursing funds.  Specifically, we will discuss the use of Federal Student Aid funds to pay for books and supplies.  You may click on 34 CFR — Part 668, Subpart K – Cash Management for the actual regulations.   668.164  Disbursing funds.  (m) Provisions for books and supplies. (1) An institution must provide a way for a student who is eligible for title IV, HEA program funds to obtain or purchase, by the seventh day of a payment period, the books and supplies applicable to the payment period if, 10 days before the beginning of the payment period— (i) The institution could disburse the title IV, HEA program

FAME PARTNERS WITH ENROLLMENT RESOURCES TO PROVIDE SEAMLESS STUDENT EXPERIENCE FOR IMMEDIATE RELEASE: October 24th, 2016 Fort Lauderdale, FL – FAME, the largest third-party servicer in the US higher education market, delivering enterprise Student Information Systems (SIS) with integrated Financial Aid Services, has announced a joint agreement with Enrollment Resources, a niche marketing technology company that serves the private postsecondary market. The collaboration will provide FAME’s SIS clients with the ability to implement a mobile-friendly lead generation tool onto their website, and create qualified, exclusive leads. Through FAME’s SIS, administrators have a centralized and automated system that tracks the entire student life-cycle from admissions to student accounts, to financial aid packaging, placement tracking and reporting. With the addition of Enrollment Resources’ industry-leading Virtual Admissions Adviser (VAA), the student life-cycle is moved forward to the point where the students are just thinking about a new career. “Virtual Admissions Adviser provides an amazing opportunity to reach out and create exclusive, qualified leads

The U.S. Department of Education (ED) has released the “GE Debt Measures Backup Data” detail files via the National Student Loan Data System (NSLDS).  The detail files were distributed through institutions’ Student Aid Internet Gateway (SAIG) mailboxes during the evening of October 19, 2016.  The files contain the draft Gainful Employment (GE) Debt-to-Earnings (D/E) rates for each GE program at the school, as well as the data used to calculate the rates. Several Electronic Announcements (EAs) have been distributed by ED recently which institutions should carefully review as they address several key points related to challenging the draft D/E rates, as well as information pertaining to the 45-day deadline for submitting any challenges, in addition to registration information for signing up to attend the two remaining Webinars on how to read your GE D/E rates files, along with a Webinar on how to submit challenges to the GE D/E draft rates. ED also recently released the Gainful Employment SSA Earnings Data Report via the SAIG.  It was designated as a GESSFWOP message class.  See the GE EA #91 (link provided below) fo

With the recent decision of the U.S. Department of Education (ED) to end its recognition of the Accrediting Council for Independent Colleges and Schools (ACICS) as a national entity approved to accredit postsecondary institutions, schools that are accredited by ACICS have to make a decision to wait out an appeal from ACICS or gain another ED-recognized accrediting agency’s approval and submit that change to ED. ACICS has 10 calendar days to inform ED of its intent to appeal and another 20 days to file the appeal. If their appeal is denied by ED, then schools have 18 months to obtain the approval of another primary accrediting agency that is recognized by ED. A few steps will be taken by ED at this time. ED will revise the school’s Program Participation Agreement (PPA) to update its ending date to coincide with the end of the 18 months. ED will place the school on Provisional Certification or update their current Provisional Certification to amend the expiration date to also coincide with the end of the 18 month period. ED could also place additional conditions of the provisional certification such as a limitation on growth, etc. FAME cannot help you make the decision of w

How in the world did we get started?  We know and understand that we fought the Revolutionary War and created this wonderful nation of ours with the Declaration of Independence.  But, how did we know how to proceed from those tumultuous beginnings of war and a brave declaration?  We needed a Constitution. But, how many really know what our Constitution is and says?  How many know what the amendments to the Constitution are?  True, many people talk about “first amendment rights,” or perhaps “second amendment rights.”  But, who knows about the rest of the amendments?  Who even knows how many there are?  How many understand or remember the purpose for our Constitution, as stated in the Preamble to it? Our nation’s Constitution has weathered 227 years, and still remains strong.  As a testament to its enduring effectiveness, although it has had a few amendments (hint:  more than just the first ten,

A requirement of a Title IV eligible institution is to ensure students are provided voter registration information.  It seems that just as our votes are cast for one election, another election cycle is rolling full-steam ahead!  It generates a feeling that it is an ongoing process.  But, in reality, in many cases it is every two to four years between such elections.  The sense of frequency comes from the combination of both state and federal elections.  Depending upon your state, it could be either a state election for governor or state chief executive officer, or a general or special election for federal offices that is on the horizon in any particular year. Of course, this year is a federal election for president, which has generated much commentary on all sides, as depicted in the seemingly unending political advertisements and news commentators’ diatribes and sound bites.   By election

Students are in full swing applying for financial aid as they look toward beginning or resuming their postsecondary education soon. That request for financial assistance in many cases, if not most, includes applying for a Federal Direct Student Loan. These loans, known more commonly as Direct Loans (or DLs), have an interesting rate structure—pun intended. This interest rate structure came about as a result of the Bipartisan Student Loan Certainty Act of 2013 which overhauled the Direct Loan Programs’ prior interest rate configuration. The result of that legislation is that interest rates are now determined based upon the high yield of the last auc

It is that time when millions of students are finalizing plans and preparations to attend the postsecondary institution of their choice during 2016-2017. Each year the majority of those students submit the Free Application for Federal Student Aid (FAFSA).  With more frequency, the FAFSA is typically completed as the FAFSA on the Web (FOTW).  This expedites the opportunity for their FAFSA results to be processed more quickly.  That is, unless they are selected for the process called “verification.” Verification is not anything new.  It is the process of making sure that the applicant for Federal Student Aid “got it right” on their FAFSA, so to speak.  The whole verification concept began with its predecessor back in the 1980s. The, at the time, recently created U.S. Department of Education (ED), promulgated the idea of “validation.”  That validation method had a primary concentration on the accuracy of data in applications for Federal Pell Grants.  But, we must remember that correctness of data has always been a preeminent focus of the Higher Education Act (HEA) related to students’ applications.  Even before validation and verification, the HEA required

The deadline for submitting any necessary corrections to an institution’s Draft Gainful Employment (GE) Completers List is tomorrow, July 28, 2016. By now you should have made any applicable or necessary corrections to the Draft GE Completers List.  Again, the deadline is tomorrow, July 28, 2016.  The U.S. Department of Education (ED) reminded schools of this deadline in the GE Electronic Announcement (EA) #84, dated July 21, 2016. In some cases, documentation may be necessary to substantiate the corrections an institution submits.  Documentation is only submitted when, and if, requested by ED. The information related to how an institution submits supporting documentation for corrections to the GE Draft Completers List is detailed in GE Electronic Announcement #83, dated July 15, 2016. If you receive a request from ED to submit documentation, you will have three (3

Immediate Impact! Almost twenty years ago, a movie that is classified across multiple genres was released:  Deep Impact.  In this disaster drama, people learn of the impending impact of a comet on earth.  Efforts are made to negate the potential for impact from the point of discovery of the comet and its trajectory, until the comet’s projected arrival about a year later.  Suspense mounts, but there is no initial panic, because, although it would cause devastation, there was still time, and there were options to explore.  While it would create a deep impact, it was not immediate.  Thus, there was less alarm to the average person. In our professional world, schools must remain vigilant, as well, to what is barreling through the financial aid skies of legislation, regulation, authorization, and guidance.  One more recent

The Program Integrity Regulations issued on October 30, 2015, contains several new changes, most of which became effective on July 1, 2016.  This Regulatory Bulletin is only going to cover 668.164 which addresses disbursing funds.  Specifically, we will discuss the use of Federal Student Aid funds to pay for books and supplies.  You may click on 34 CFR -- Part 668, Subpart K - Cash Management for the actual regulations.  668.164   Disbursing funds.   

That the Central Processing System (CPS) had a technical issue with the Selective Service System (SSS) Match, which prevented it from providing CPS with the SSS data base match? The Electronic Announcement issued on June 28, 2016, indicated that records processed during the down time would have a blank Selective Service Match value on the SAR and ISIR field # 359. To minimize the impact to applicants and schools, the CPS continued processing application and correction data for active cycles the past week and suspended the SSS matching process. As of July 5, 2016, the technical issue was resolved, and the CPS resumed normal matching routines with the SSS and reprocessed the applications and corrections previously submitted to CPS between June 27 and June 30, 2016, which should have been sent to the SSS during the outage window, and sent system-generated records (commonly called, “pushed” ISIRs).  If a change to the ISIR occurred, it will have a “172” comment code, indicating that the resulting change was due to a report from another agency.  The reprocessed ISIR will display a “50” for the Reprocessing Code (ISIR field #230). The FAA Information page in FAA Ac

Volume 1 includes student eligibility requirements and additional eligibility requirements for specific FSA programs. Volume 2 includes institutional and program eligibility requirements, administrative and audit requirements, updating the E-App, consumer information requirements, record keeping and Program Review information. Make sure you review each volume for any “new” requirements, which are sometimes just a new interpretation by the U.S. Department of Education or changes in procedures. You will want to pay close attention to the sidebars as they contain important information such as regulatory references and links. In Volume 1, there have been changes in areas such as diplomas, immigration documents and Unusual Enrollment History (UEH). Many of the changes mentioned in Volume 2 are found in Chapter 6, Consumer Information. Therefore, it is important to review and update your documentation, policies and/or procedures, as necessary, in order to be compliant with federal requirements.

The 2016-17 Federal Student Aid Handbook, Volume 5, The Return of Title IV Funds, pages 5-84 and 5-85 clarifies the amount of Title IV funds to include in the R2T4 calculation for clock hour and non-term credit hour programs with overlapping loan periods. This latest guidance requires the institution, when the loan period (LP) does not correspond with the payment period as defined in 34 CFR 668.4 and used in the R2T4 calculation, to prorate Title IV funds to determine the amount that should be attributed to the payment period from which the student withdrew. Example #1: The student attended School A and was disbursed a $1,750 subsidized (sub) loan and $3,000 unsubsidized (unsub) loan. The academic year at School A ends on 10/09/15. The student starts School B on 8/24/15 in a 1200 clock-hour program with a 900 hour academic year, and is awarded the remaining $1,750 sub and $3,000 unsub for the 1st short LP of 8/24/15-10/09/15 due to completing the academic year at School A. The 2nd loan is processed for a 900 hour academic year with a LP of 10/10/15 – 3/11/16 for a $1,750 sub loan and a $3,000 unsub loan. Title IV payment period 1 is

One of the Q & A’s is new, DOC 28 Q & A, while others have been revised.  It is important to check the website from time to time to ensure accurate and timely processing of financial aid. Documenting High School Completion Status (DHC) DHC-Q2. Can a student who does not have a high school diploma, or its recognized equivalent, or who has not completed a secondary school education in a homeschool setting, be admitted as a regular student to a postsecondary educational institution? DHC-A2. Yes, only if the student is beyond the age of compulsory school attendance in the State in which the institution is physically located, or is dually or concurrently enrolled in the institution and a secondary school. However the student must have a high school diploma or its recognized equivalent, or have completed a secondary school education in a homeschool setting in order to be eligible to receive Title IV aid. Note one exception: students may qualify for Title IV aid under one of the ATB alternatives, either because the student is “grandfathered,” as described in�

Based on additional recent guidance from the U. S. Department of Education (ED), we would like to share the following information.  This guidance may impact the credits that you submit on your E-APP from the clock to credit conversion that ultimately appear on your ECAR. When a school does a clock-to-credit hour conversion and the financial aid credit hour calculation for an individual course equals a fraction (e.g., 3.25), the school may use the actual fraction to determine the total number of financial aid (FA) credits in the program rather than rounding to the nearest 1 or .5 as some accrediting agencies require.  However, the school may not round up the fraction (example:  3.255 can be 3.255 or 3.25, but not 3.26). This is for the calculation of FA credits only.  Note: The school may not use the FA credits if they are more than the academic credits per individual course or program. Example:  Medical Assistant Program (quarter credits)

The U.S. Department of Education (ED) has announced the official 45-day Review Period for the Draft “GE Completers Lists Correction Period?” The Review Period for reviewing and submitting corrections is established by ED to be from June 14, 2016, through July 28, 2016. The Review Period was announced in ED’s GE Electronic Announcement #81 on June 10, 2016.  Schools should review the information in this Electronic Announcement and submit any necessary corrections to its Draft GE Completers List by July 28, 2016. Additional clarifying information about the Draft GE Completers List was also provided in the May 31, 2016, Gainful Employment Electronic Announcement #78 - Draft GE Completers List Files and the June 8, 2016, GE Electronic Announcement #80.  This information will likely be beneficial for schools to become familiar with, as well, especially the attach

The U.S. Department of Education (ED) will soon be distributing institutions’ Draft “GE Completers Lists” to the institutionally designated Student Aid Internet Gateway (SAIG) mailbox, if an institution had one or more GE Programs with program completers in award years 2010-2011 and 2011-2012. The GE Completers List is used by ED in calculating an institution’s Debt-to-Earnings (D/E) rates using the debt and earnings of students who completed Gainful Employment (GE) programs.  Once ED distributes the Draft “GE Completers’ List,” schools will have 45 days to submit any necessary corrections. ED has strongly encouraged that schools should, no later than May 13, 2016, report to NSLDS any missing GE Program information and make any necessary corrections to information previously reported.  Making any necessary corrections to data now will help to ensure that the Draft “GE Completers Lists” ED sends to the school are accurate and complete.  ED “currently” anticipates creating and releasing the Draft GE Completers Lists to schools by June 1, 2016. Schools that have not yet done so should review the data that ED has post

Attendance Monitoring and Charges for Absences or Being Tardy FAME recently completed its 2016 FAME Annual Financial Aid and Management Conference.  A question arose shortly before the conference for which guidance had been received from the U.S. Department of Education (ED) related to the appropriate response. The Question about Fees or Fines for Absences or Being Tardy A question arose inquiring whether a school could assess fees or fines to a student for being late to class or for being absent from class, and have Title IV funds cover those fines or fees.  In our dialog with the U.S. Department of Education (ED), their initial response was that fees or fines a school assesses a student that are not required of all students in the program, would be considered non-institutional charges, and therefore, not included in a Return to Title IV Funds (R2T4) calculation, similar to library fines or parking fines, etc.  As with library or parking fines, ED indicated that, with the appropriate written student authorization, Title IV funds could be utilized to pay such charges as a fine or fee for being t

Q1:  What is the cost of attendance (COA) for student financial aid purposes? A1:  The COA is an estimate of the expenses a student may be expected to incur in an award year while pursuing their academic program.  It is the underpinning upon which the process of financial aid need determination begins for a student.  The COA includes both the direct and indirect costs of attending school.  The direct costs are those charged directly by the school, such as tuition and fees.  The indirect costs are the other basic necessary expenses a student experiences in order to attend and complete his or her education. Q2:  Why does the COA budget have to include things other than the costs for tuition, fees, books and supplies? A2:  The quick answer is that the components of the COA are dictated in the Higher Education Act (HEA), as amended.  The answer in more practical terms, upon which the HEA dictates are based, is that most students would not be able to attend school if the only aid they received was to cover direct tuition and fee costs.  In many instances a student is not able to work, or not as many hours, while

Prohibited!  That has been the word on the streets about incentive compensation offered by postsecondary educational institutions.  More specifically, the October 29, 2010, Program Integrity Regulations[1] made this prohibition applicable to individuals involved in the recruitment or admission of students, as well as those involved in making decisions about student financial aid.  These regulations related to incentive compensation were generally effective July 1, 2011.  But, was the ban on incentive compensation for recruiters all encompassing?  What is the latest from ED on the matter? The Challenge When the October 29, 2010, regulations were finalized, it was not long before a legal challenge to the incentive compensation section of the rules was presented.

Periodically we are asked questions regarding an interpretation of the laws, regulations, or policies related to the administration of the Title IV Federal Student Aid (FSA) Programs.  In this series we provide questions, and the related answers, generated by our interaction with clients and the U.S. Department of Education (ED).  Q1:  We are a school that teaches in quarters.  The program has three 10-week terms in the program with new students starting each term.  Can we also have a version of the program that has a 5-week term, two 10-week terms, and a 5-week term on every other “start?” A1:  The latest guidance from ED indicates that schools have the ability to create different versions of a program with different calendars (even if both are in the day).  But, the school really needs to treat these programs as two separate programs (e.g., in regard to coding, cohorts, no crossing over between programs, consumer information, and if a student switches programs they must be dropped and re-enrolled, etc.).  Every student within a particular program would follow the same academic calendar; otherwise, you would have one program taught in differ

The Program Integrity Q&A Website has been recently updated in response to questions about acceptable documentation for foreign high school diplomas.  As the New Year begins, we remind you to review your current policies and procedures and make adjustments as needed.  The following are the two questions with answers as posted by the Office of Postsecondary Education in regards to foreign high school diplomas (http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/hsdiploma.html#fhd). Foreign High School Diploma (FHD) FHD-Q1. Is a high school diploma from a foreign country recognized as a valid diploma? FHD-A1. Yes, if the institution determines whether the foreign secondary school credentials are evidence of completing the equivalent of a secondary education in the United States. Institutions that do not have the expertise to make that determination themselves may use a foreign diploma evaluation service. [Guidance issued 1/24/2014] FHD-Q2. What documentation may an institution accept to verify high school completion status for an applicant who indicates that he or

Action: All currently participating schools with GE programs must submit to ED by no later than December 31, 2015, a Transitional Certification of their GE Programs’ accreditation approval and State approval.  See the June 11, 2015 Electronic Announcement for details. Action: All schools must have their GE disclosure information updated utilizing 2014-2015 data by January 31, 2016. Schools must use the updated GE disclosure template (GEDT). This template can be located online at http://ope.ed.gov/GainfulEmployment/. Action: IRS requires that you have all 1098-T generated and postmarked by January 31, 2016. Action: Waiver Request for Underuse of 2016-2017 Funds to ED are due by February 8th, 2016. Action: Collection opens for Winter IPEDS December 9, 2015 and will be closed for Keyholders February 10, 2016 and for Coordinators February 24, 2016. The components included in this submission are: Student Financial Aid; Graduation Rates; 200% Graduation Rates, Admission; and Outcome Measures. The preliminary data will be available Mid-September. Ac

Because the goodwill of those we serve is the foundation of our success, it’s a real pleasure at this holiday time to say thank you, as we wish you a year of happiness and prosperity FAME’s Office will be closed for our Annual Employee Holiday Party at 12:Noon EST on Friday, December 18, 2015 and  will resume normal office hours on Monday, December 21, 2015. FAME will also be closed on December 24th, December 25th and January 1st to celebrate the holidays with our families.

It goes without saying that most institutions of higher education in the United States today rely significantly on the ability of their students to receive funding through the U.S. Department of Education’s (ED) Federal Student Aid programs.  These Federal Student Aid (FSA) programs are authorized through the section of law commonly referred to as Title IV of the Higher Education Act (HEA), as amended.  But, these institutions are not granted, via their students’ eligibility, such resources carte blanche.  As the old saying goes, “He who has the gold makes the rules.”  Not surprisingly, ED requires institutions to exercise care in their fiduciary responsibilities of the more than $128 billion dollars being dispensed to almost 12 million students.

Time stands still for no one!  It seems as though reporting of gainful employment (GE) data to the U.S. Department of Education (ED) was just completed—with hopes that everything was reported accurately.  And, here we are again, talking about GE!  All of that information that you have worked with in the last few months since the first “new” GE reporting in July, now comes into play again.  With that being the case, it is no time to let one’s guard down.  Rather it is time to ensure you have gained the upper hand on the upcoming GE requirements.  There are at least three key items to keep in mind in the coming months regarding GE. GE Transitional Certifications Due By December 31, 2015 This topic has been discussed in various venues since the advent of “GE 2.0.”  But, part of the regulatory requirements pertaining to GE is that schools must ensure they have certified that all of their Title IV-eligible gainful employme

When students are interested in attending school, naturally they look for one that offers academic programs that prepare them for their career ambitions.  But, once they have found one that offers the academic program they are interested in, there is always a question that soon follows.  That question is:  “How much does it cost?”  The answer given in response to that question may, at times, be less than clear.  (Effective as of January 1, 2016, more specificity will be required in data provided by FAME clients.  Continue reading for more details.) Naturally, a student is interested in the direct costs applicable to the educational program; things such as tuition, required fees, typical amounts charged for required textbooks, and so on.  But, the reality is that the various costs a student incurs as they attend school include a broader scope of expenses than just those charged by the institution directly.  In order for a student to at

The U.S. Department of Education (ED) is distributing email notifications to schools that may be non-compliant with GE Reporting.  The letters have indicated severe consequences such as suspending recertification, approval of new programs or additional locations applications, and initiating an administrative action against the institution. Such administrative action may include fines, limitations, suspension or termination of eligibility to participate in the Title IV, HEA programs. Institutions must report student details or the acceptable reason why reporting is not required for every program included on the NSLDS GE Program Tracker List for each award year.  It is important that all students who received Title IV aid for a program have been reported and that the information is complete and accurate.  If an acceptable reason for not reporting student data has been indicated, then you must be able to document why reporting was not required. To confirm if your institution is in compliance, you can review the NSLD

          GAINFUL EMPLOYMENT (GE) EA – Posted September 4, 2015 – (Gainful Employment).  Gainful Employment Electronic Announcement #60 – GE Reporting and Resolving Incorrect Credential Level Data in NSLDS and in COD Schools are alerted to the fact that ED has sent out warning letters to schools that reported at least one loan origination record for 2014-2015 in COD where the record indicated the student was enrolled in a GE program, but the school did not submit GE data to NSLDS by the July 31, 2015, reporting deadline.  This announcement gives schools who received such a warning letter instructions on how to utilize the NSLDS GE Program Tracking List to resolve any errors in the COD System.  (For information on the GE Program Tracking functionality, see also Gainful Employment Electronic Announcement #59, dated August 20, 2015.)  If a school received one of these warning letters about errors, they must not delay in making the

Q1:  If our Program Participation Agreement (PPA) is set to expire, what happens if we have not received our new PPA from ED before the expiration date? A1:  When a school submits a materially complete Recertification application on time, the school’s PPA and Eligibility and Certification Approval Report (ECAR) continues on a month-to-month basis until the review of the new application is completed. Q2:   For a clock-hour GE program, is the school’s satisfactory academic progress (SAP) policy limited to 150% of the minimum number of clock hours required for training in the recognized occupation for which the program prepares the student? A2:  No.  The 150% maximum time frame for SAP purposes is totally different than the requirement that a school’s academic program length not exceed by more than 50% the minimum number of clock hours required for training in the recognized occupation for which the program prepares the student, as established by the State in which the school is located, if the State has established such a requirement, or as established by any Federal agency.  And, to clarify, for a clock-hour program, a SAP maximum time fram

The long and winding road has ended on 9/30/15.  This was the end of a one year extension for the Federal Perkins Loan Program.  According to the latest guidance received from the U. S. Department of Education (ED) (Electronic Announcement dated 10/2/15) Congress did not extend the Federal Perkins Loan Program.  As a result schools can longer originate Perkins loans to new borrowers after 9/30/15.  However, there are some exceptions to the rule as indicated in Dear Colleague Letter GEN-15-03. If a school makes a first disbursement of a Perkins loan for the 2015-2016 award year prior to 10/1/15, the school can make any remaining disbursements for that 2015-2016 loan after 9/30/15. There is also a “grandfathering” provision for 2014-2015 or earlier Perkins loans as long as all of the following conditions are met: One Perkins loan disbursement has to have been made to a student on or before 6/30/15. The student is enrolled at the same institution where the last Perkins loan disbursement was received. The student i

Action:  The new Violence Against Women Act (VAWA) regulations were effective as of July 1, 2015 and are applicable to the Annual Campus Safety and Security Report to be submitted to ED by October 15, 2015. Action:  September 30, 2015, was the last date on which a new borrower could be disbursed a first disbursement of a Federal Perkins Loan.  (Effective September 30, 2015, the Perkins Loan program has expired.)  See Dear Colleague Letter GEN-15-03. Action:  All new Federal Direct Loans first disbursed on or after October 1, 2015, must have the new loan origination fee percentages used when originating the loan.  The new percentage is 1.068 percent for Subsidized and Unsubsidized Direct Loans, and 4.272 percent for PLUS Direct Loans.  (Remember, also, the reduction in the IASG awards by 6.8% for awards first disbursed on or after October 1, 2015, as well as a similar 6.8% reduction for TEACH Grants first disbursed on or after October 1, 2015.) Action:  ED’s annual Federal Student Aid Confere

Our early days as a nation endured a bumpy start.  As the original states were floundering in the New World, the need to live up to the name, “United States of America,” was beginning to become evident.  There was a need for unity.  Each of the states had their own interests they wanted to satisfy, but the confederation of independent states, established as a “league of friendship,”[1] was not organized to fully meet those needs.  The Articles of Confederation, adopted in 1781, lacked in the areas of authority and ability to govern the states in matters of commerce, issues of revenue, and resolution of disputes between states.  Those “simple” matters—interstate commerce, ab

The passage of The Consolidated and Further Continuing Appropriations Act of 2015 (Pub. L. 113-235) reinstituted the opportunity for a student’s Title IV eligibility through ability to benefit (ATB) alternatives.  But, this ATB alternative opportunity is only available if such a student is enrolled in an "eligible career pathway program."  The U.S. Department of Education (ED) has provided some guidance in regard to eligible career pathway programs in Dear Colleague Letter GEN-15-09, but it has been quite limited in scope.  As such, numerous clients have inquired about what they consider to be an eligible career pathway programs (CPP).  We appreciate our clients' interest in the perceived opportunity they anticipate to be available via the CPPs.  Yet, the legislation allowing for CPPs is not as broad as would be hoped.  And, there has been limited and,

FAME is closely monitoring tropical storm Erika. Our corporate offices may be closed Monday/Tuesday. Please check our Client Solution Center for more information.

Sailing on the ocean is a wonderful thing.  There is the vast expanse of the horizon that is in view, and the gentle rocking of the waves that calm the soul.  But, it is a totally different picture when a major weather event comes on scene.  No longer is the view as expansive or the waves as gentle.  Clouds block the horizon and the surface gets rough and unsettling.  That is the way it sometimes happens in financial aid.  Things are going smoothly as you think you have all things appropriately in view.  You have completed the first round of gainful employment (GE) reporting, and you are enjoying the gentle scene until the next round of reporting is due.  Then, all of a sudden, another GE gale arrives and you wonder if you will be sailing on the Sea of Confusion or Consternation instead of the Sea of Clarity and Calm.  Just when you thought you had it all figured out and put to rest for a while…GE comes to the fore once more! The latest GE information presented by the U.S. Department of Education (ED) appeared as Gainful Employment Announcement #58 on

They said it would happen.  And, it is almost here!  The deadline for the first round of Gainful Employment (GE) reporting is July 31, 2015, based upon the requirements of the October 31, 2014, final regulations.  This is a date you do not want to miss! URGENCY and CONSEQUENCES STRESSED FAME staff attended a recent conference at which U.S. Department of Education (ED) staff spoke on the topic of GE reporting.  It was clearly stated that schools must have completed their GE reporting by July 31, 2015.  Failure to do so will have consequences.  Two things will happen if a school misses the July 31, 2015, reporting deadline. ED will send a letter by e-mail to the president of each institution that has GE programs.  The letter will list each of the GE programs for which the institution did not report in a timely manner.  These le

Action:  All results of verification for students selected in Verification Tracking Groups V4 and V5 must be reported within sixty (60) days of when the school requests the information from the student.  For FAME clients the reports will be submitted, however clients must appropriately enter the results of the V4 and V5 verification.  (FAME ESP clients see the August 4, 2014, “What’s New in ESP?” e-mail.  FAME Freedom FinAid clients see the August 14, 2014, “What’s New in Freedom?” e-mail.) Action:  The new Violence Against Women Act (VAWA) regulations are effective as of July 1, 2015. Action:  By July 31, 2015, schools with Gainful Employment (GE) programs must report the applicable data for each of the award years of 2008-2009 through 2013-2014.  (In limited cases, some schools must include data for 2007-2008, as well).  See the Federal Register dated October 31, 2014, for more of the specific details of the applicable regulations and requirements. Action:  The Direct Loan closeout deadline for the 2013-2014 Program Ye

Q1:  A student submitted a 2014-2015 FAFSA and a 2015-2016 FAFSA at the same time and the ISIRs for both came back the same day.  The strange thing is that her 2014-2015 FAFSA came back with no C-Code issues but her 2015-2016 FAFSA has one.  On her 2014-2015 FAFSA the first page says “your citizenship status has been confirmed by DHS and you meet requirements for federal student aid.”  However her 2015-2016 FAFSA says that “USCIS of DHS did not confirm that you are an eligible noncitizen” and she must submit proof to her school.  I understand that this means we need to submit a G-845 with a copy of her Green Card, but my question to you is do we really have to?  Since her 2014-2015 FAFSA says that DHS confirmed her citizenship why would her 2015-2016 FAFSA not say the same, especially because they were submitted and processed at the same time? A1:  The bottom line is that you are correct.  You will need to submit the G-845 for secondary confirmation.  As it currently stands, you are not able to pay based upon the 2014-2015 ISIR because you now have conflicting information since the second ISIR for 2015-2016 did not confirm her eligible status.  There ar

Student loan debt is the hot topic in the news media in recent months.  Most of the articles touching on this subject focus on the amounts students borrow, with an indication that such borrowing is out of control.  Indeed, amounts that students borrow during their academic career are rising1.  Student loan indebtedness is something about which to be cautious (as is any type of debt!).  But, beyond the increase in student loan debt is a perhaps more subtle set of concerns.  These less evident issues relate to the student debt topic from at least two perspectives.  They create the loan counseling conundrums. Conundrum #1 Traditionally, student financial aid professionals have touted caution when providing student loan counseling.  Yet, advice toward caution has often been softened or negated by the offsetting promotions made by either the same financial aid professionals, admissions counselors, or other interested parties.  The counteracting assertions made are that student loan debt is “good debt” because it is obtained with the goal of investing in the student’s future increased earning power.  Thus, students face the first loan counseling con

Those who dance understand that there are a number of specific aspects in being a great dancer.  One is confidence in knowing what steps are appropriate for the music being played.  This characteristic is also important when considering the gainful employment (GE) regulations.  It cannot be considered a truism that those who have responsibility for GE compliance on their campus must be great dancers, or that great dancers would make exceptional employees to work with the GE regulations.  However, the characteristic noted about dancers is also important for those working to comply with the GE regulations. When working with GE, it is important to be confident in the appropriate steps or requirements.  In the GE Dance, the proper steps include both disclosure and reporting requirements as put forth by the US Department of Education (ED).  While the regulations have been out for a while now, and a number of efforts have been made to distinguish the difference between the requirements related to disclosure and those related to reporting, there still seems to be a bit of stumbling in the dance. People remain uncertain of what moves constitute the correct steps.  In choreographi

GAINFUL EMPLOYMENT (GE) DCL – GEN-15-12: June 30, 2015 – Regulatory Requirements Related to Gainful Employment Programs ED has published a synopsis of all of the regulatory requirements that pertain to GE programs.  This DCL summarizes what constitutes a GE program, the disclosure and reporting requirements, the calculation of the D/E ratios and how to challenge draft D/E rates or appeal final D/E rates, as well as the requirement for transitional certification of existing programs by December 31, 2015.  Those who are new to financial aid and the world of GE responsibilities will find this an extensive introductory “summary” of the obligations applicable to the GE regulations.  It can also serve as an excellent executive summary for school leadership (presidents, CEOs, owners, etc.). GENERAL AND VARIED DCL TOPICS DCL – GEN-15-06: April 06, 2015 – Loan Counseling Requirements and Flexibilities ED presents this DCL with a hope that it helps schools remember what their loan counseling responsibilities are, and encourages schools to

            EA – Posted April 20, 2015 – (General).  150% Direct Subsidized Loan Limit:  Electronic Announcement #17 – School Misreporting of Data to COD and NSLDS This EA is an important reminder to schools of the necessity for accuracy in transmitting data to COD and NSLDS.  Of special interest in this discussion is the data related to the academic year length and the program length for the applicable loan.  Specifically, ED details two issues it has observed in data pertaining to acad

        GAINFUL EMPLOYMENT (GE) EA – Posted June 11, 2015 – (Gainful Employment).  Gainful Employment Electronic Announcement #54 – Certification Requirements for Gainful Employment Programs ED reminds schools of two key points related to gainful employment (GE) programs.  First, the point is made that schools are required to ensure that their “Application for Approval to Participate in Federal Student Aid Programs” (E-App) is updated in a timely manner to make certain their Eligibility and Certification Approval Report (ECAR) is current. The other key reminder that ED brings to attention is the fact that schools that offer GE programs must submit a Transitional Certification to ED by no later than December 31, 2015.  The Transitional Certification is the school’s affirmation and assertion that each GE program is included in the institution’s accr

Swimming in murky waters is generally not what one likes to experience.  Much preferred for swimming is the crystal clear water in a newly cleaned pool, a mountain spring-fed lake, or in the waters near a coral reef off a south Pacific island.  Murky waters leave much to the imagination as to what may be just beneath the surface, with none too pleasant outcomes envisioned.  Recent news accounts of several shark attacks in shallow waters near the beaches have accentuated the need to be able to see what is in the water around you.  In similar fashion, murkiness seems to be the environment in which schools find themselves when viewing the latest guidance related to the State authorization regulations. The Murky Waters of State Authorization State authorization has been a requirement for schools to be considered eligible to participate in Title IV Federal Student Aid programs for years.  But, in 2010, in what has come to be called the Program Integrity Regulations of October 29, 20101, the U.S. Department of Education (ED) gave more specificity to what the minimum standards consis

Join our webinar to see how FAME’s predictive analytic tools coupled with your student data can provide the information you need to increase student retention and reduce loan defaults. Learn how Predictive Analytics identifies the key factors that affect students’ performance and completion rates. See how using your historical student data, coupled with the science behind the predictive analytics tools developed by Voyant Analytics and integrated with FAME’s SIS products, can accurately predict 9 out of 10 potential dropouts, saving you hundreds of thousands in lost tuition. Learn about a dynamic program that provides early assessment tools to identify learning characteristics that will assist in ensuring your students meet their academic goals and have a successful outcome, increasing your students’ academic achievements, completion rates and placement rates.  Join us to learn about these

The news reports are out1.   The US Internal Revenue Service (IRS) was hacked!  This is of specific interest to schools participating in the Title IV Federal Student Aid (FSA) programs.  Students and parents who apply for FSA and are selected for “verification” in the application process have potential for being directly impacted due to the hack of the IRS system. The IRS announced2 on Tuesday, May 26, 2015, that its Get Transcript Web site was hacked between February and mid-May of 2015.  It is important to note, however, that the IRS’ main database system was not accessed.  Only the Get Transcript system, which is operated separately from the main IRS computer system, was compromised in this attack.  The hackers were successful in approximately 100,000 of 200,000 attempts at gaining unauthorized access.  The IRS has indicated that it is notifying those tax filers whose information was hacked. The Issue

The response to the one word question in the title of this article resounds with a definite, “Yes!”  That is especially the response for student loan borrowers this coming award year.  The much anticipated announcement of the new interest rates for loans first disbursed on or after July 1, 2015, has been made.  And, the notice is favorable for borrowers who will be obtaining one of the loans available through the Federal Direct Student Loan Programs.  Interest rates have nudged downward! As a reminder, the Bipartisan Student Loan Certainty Act of 2013 overhauled the Direct Loan Programs’ interest rate structure.  The result of that legislation is that interest rates are now determined based upon the high yield of the last auction of the 10-year Treasury notes held prior to June 1 each year.  That yield becomes the “index” in the interest rate formula.  To the index is added a margin, or what is called an “add on”.  The rat

Those in the world of financial aid are always wondering what our friendly Fed had to say.  So, we are going to tell you about what the Fed SAID.  OK.  Yes, the title of this Regulatory Bulletin is a bit of a play on words and acronyms.  But, it is to focus on the importance of what the Feds (i.e., the US Department of Education or, ED) have said is occurring as of May 10, 2015.  That is, the long-time use of the Federal Student Aid PIN is going by the wayside, just like those old car headlight dimmer switches you have seen pictures of on one of those Facebook, “who remembers what this is?” postings.  But, the FSA PIN was a necessity for students applying for Federal Student Aid (FSA)!  What happens to that process now?  As of Sunday, May 10, 2015, all students who wish to use login access for Federal Student Aid Web sites will need to utilize a new Federal Student Aid ID or, as it will be known in shorthand:  FSA ID. The change to

Action: All results of verification for students selected in Verification Tracking Groups V4 and V5 must be reported within sixty (60) days of when the school requests the information from the student. For FAME clients the reports will be submitted, however clients must appropriately enter the results of the V4 and V5 verification. (ESP clients see the August 4, 2014, “What’s New in ESP?” e-mail. Freedom FinAid clients see the August 14, 2014, “What’s New in Freedom?” e-mail.) Action: The deadline date for a waiver of the 2015-2016 Federal Work-Study Community Service requirement is April 27, 2015. The deadline for an electronic submission of a school’s waiver request is 11:59 P.M. (ET) on Monday, April 27, 2015. Action: On May 10, 2015, ED implements the new student/borrower FSA ID login process. Action: The new Violence Against Women Act (VAWA) regulations are effective July 1, 2015. Action: By July 31, 2015, schools with Gainful Employment (GE) programs must report the applicable data for each of the award years of 2008-2009 through 2013-2014. See the Federal Register dated October 31, 2014 Action: The Direct Loan closeout deadline for the 2013-2014

Q1:  We have a cost of attendance (COA) that uses national standards or averages for room and board, personal, and transportation expenses.  But, as of January 2015, for all future starts we would prefer to use the results of a student survey we have conducted.  Can we do that? A1:  There is no prohibition on ED’s part.  A school is able to review and update its Title IV policies and procedures (of which COA is a part) when appropriate.  However, the school must be clear in documenting its policies and procedures in regard to when the change occurred and how it was implemented, etc.  Naturally, the data upon which the new COA figures are based should be maintained as documentation for the COA.  Also, students should be appropriately notified and consumer information updated, etc.   There may be other points to consider regarding such changes in the middle of an award year.  For example, it can create additional challenges for staff to communicate easily and accurately with students when dealing with differing costs during the same award year.  It also has potential to generate more questions from auditors during the annual audit. Q2:  If a studen

DCL – GEN-15-03: January 30, 2015 – Wind-down of the Federal Perkins Loan Program The approaching end of an era is discussed in this DCL.  The Federal Perkins Loan Program, as modified over the years, is the first modern Federal Student Aid program.  Having originally been named the National Defense Student Loan (NDSL) program in the National Defense Education Act of 1958, it began in the era of the space race after the Russian Sputnik was launched in 1957.  It was the first student aid program geared specifically for low income students.  The program was later redesignated as the National Direct Student Loan (NDSL) program as a result of the Higher Education Amendments of 1972.  Subsequently it was again renamed in the 1986 reauthorization of the Higher Education Act in honor of U.S. Representative Carl Perkins (KY) who was an early proponent of the program as well as other student aid programs. Unless Congress intervenes before then, no Perkins Loans may be made to new borrowers after September 30, 2015.  If a loan for the 2015-2016 award year has had a disbursement made prior to September 30, 2015, the school

GENERAL AND VARIED ANNOUNCEMENTS EA – Posted January 12, 2015 – (General).  FSA ID Information – Communicating the Transition to Students ED updates the financial aid community on its major new initiative in the access to student- and borrower-based Websites related to Federal Student Aid (FSA).  As previously announced in an October 1, 2014, Electronic Announcement, this modification will implement user-selected usernames and passwords as a replacement for the current FSA PIN.  The new FSA ID will offer enhanced functionality to allow for a single sign-on process for most of FSA’s systems.  This conversion will eliminate the need for users to enter individual personal identifiers, e.g., Social Security number, date of birth, etc.�

ED has released updates to the Federal Student Aid Handbook this past quarter.  Specifically, ED has released the 2015-2016 Application and Verification Guide and Volume 4 – Processing and Managing FSA Funds of the 2015-2016 Federal Student Aid Handbook.  These updates are available on IFAP.  Schools will do well to review each of the announcements related to these FSA Handbook updates and become familiar with the enhancements provided via these announced changes.

The latest addition to the 2014-2015 Federal Student Aid Handbook was released on February 20, 2015.  This release contains the new Appendix F – Institutional Reporting and Disclosure Requirements for Federal Student Assistance Programs.  The appendix is a fairly comprehensive chart of reporting and disclosure requirements. Schools will find it to be a useful tool to aid them in their efforts to meet the requirements indicated.

PLUS Loans have been in the news in the last few years.  Specifically, the topic of interest has been the impact of an adverse credit history on PLUS Loan applicants.  For nearly twenty years, the PLUS Loan program had no noteworthy issues.  However, in 2011 the U.S. Department of Education (ED) modified the criteria to include unpaid collection accounts and charge-offs in their review of PLUS applicants’ credit history.  This was to be more closely in agreement with then current regulations.  This change was not officially announced before implementation, but rather felt by applicants and schools.  Since that time, after much public opinion was expressed, and some intermediary proactive notifications by ED to applicants who may gain eligibility after a credit history reconsideration, a slow move to change the regulations related to adverse credit meandered through the regulatory process.  The Federal Direct PLUS Loan final regulations were published on October 23, 2014. The final regulations were scheduled to be operational as of July 1, 2015.  But, ED stated in the preamble to the rules that it may implement a

 As spring has just begun, there are a number of upcoming dates to keep in mind.  In this Regulatory Bulletin reminder, we provide a brief list of important events and dates that schools need to have on their calendar.  It is important to plan your schedule of activities accordingly. March 29, 2015 – The new PLUS Loan regulations regarding adverse credit standards go into effect.  These regulations were published in the Federal Register on October 23, 2014 and posted on IFAP.  The published effective date for the regulations was July 1, 2015.  However, in a Federal Register notice on January 14, 2015, ED announced that the regulations would be implemented on March 29, 2015.  An Electronic Announcement was posted on IFAP on January 27, 2015 emphasizing this date change.  Schools must implement the new regulatory standards pertaining to adverse credi

We all likely know people who insist upon being the one who is right.  While such individuals may come across as a bit difficult to interact with, the reality is that we all do want to be right.  And, in our work-a-day world, it is important that we get it right in the critical areas of our profession.  We work in a $150 billion dollar industry as financial aid professionals,1 so there is ample need for not missing the mark in operational accuracy and effectiveness.  In this intermittent series on getting it right, we are highlighting some of the key areas in which it is critical to employ best practices in order to accomplish this goal.  The components covered in this series are:  the right people, the right service, and the right exposure.  In this segment of our series we will highl