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ED’s Dear Colleague Letters (DCLs) on IFAP

January 29, 2015
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DCL – GEN-14-22: December 18, 2014 – Apprenticeships and the Federal Student Aid Programs This Dear Colleague Letter (DCL) highlights schools’ ability to use FSA programs to support apprenticeship programs as part of the Administration’s efforts to double the number of apprentices in the United States in the next five years.  The letter provides guidance to those schools who may offer educational programs with an apprenticeship component.   In order for a student who is in an apprenticeship program to be able to receive FSA funds, the apprenticeship component has to be part of an otherwise Title IV-eligible program.  The program must lead to a degree, diploma, certificate, or other recognized credential that the institution awards.  The program must also meet all other requirements related to program length, both in regard to weeks of instructional time, as well as the number of credit or clock hours.  Any school that may offer an apprenticeship program or have a program that includes an apprenticeship component should review this DCL in detail. DCL – GEN-14-23: December

ED’s 2014-2015 Federal Student Aid Handbook

January 29, 2015
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handbookThis past quarter ED released new appendices to the Federal Student Aid Handbook for the first time.  While individual volumes within the FSA Handbook have had appendices, (e.g., Volume 3 and its appendices related to the various Pell Grant formulae), this is the first time there has been an appendix to the entire Handbook.  And, since they implemented this addition, they went at it with a full swing and provided a total of 5 appendices to the FSA Handbook.  Some of the appendices were previously included as part of The Blue Book, or certain sections of the FSA Handbook.  They include such items as a glossary, and a list of common acronyms applicable to financial aid, resources and contacts for technical assistance, steps a school should take in circumstances of a student’s death, and finally, the table of contents to the Higher Education Act which may be helpful in researching specific

ED’s Electronic Announcements (EAs) on IFAP

January 29, 2015
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PROCESSING FOR 2015-2016 EA – Posted October 7, 2014 – (Application Processing).  2015-2016 ISIR Guide The 2015-2016 ISIR Guide was released with this announcement, which is an earlier release than has been historically the case.  The Guide is an extremely useful tool for financial aid administrators.  It provides all the details needed to interpret data contained on the ISIR, to include student FAFSA application data, results of the National Student Loan Data System (NSLDS) data matches, reject codes and reasons, etc.  Any questions one may have about the ISIR will likely be answered in the ISIR Guide. EA – Posted October 28, 2014 – (Application Processing).  2015-2016 SAR Comment Codes and Text Guide The 2015-2016 SAR Comment Codes and Text Guide is another beneficial tool that schools may use in conjunction with the ISIR Guide described earlier.  The Guide includes a description of changes to the SAR comments for 2015-2016 and gives the complete text for all 201

Important Reminders for Q1_2015

January 29, 2015
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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?”.  Freedom FinAid clients see the August 14, 2014, “What’s New in Freedom?”) Action:  All schools must have their GE disclosure information updated utilizing 2013-2014 data by January 31, 2015.  Schools must use the updated GE Disclosure Template (GEDT) referenced in the GE Electronic Announcement # 50 that was released on IFAP on September 11, 2014. Action:  As of February 1, 2015, ED will no longer accept enrollment reporting files in file layout formats that are older than those posted to the Information for Financial Aid Professionals (IFAP) Web site on February 27, 2014 (“the new formats”). An enrollment

Since You Asked: Questions & Answers

January 29, 2015
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Q1:  If we have a student who had a G-845 received in the 2013-2014 award year and their citizenship paperwork does not expire until 2015, and we received a 2014-2015 ISIR with a C code, can we use the previously completed G-845 to confirm eligibility for the 2014-2015 award year? Or, must we complete a new G-845 for each award year? A1:  If you have confirmed the student’s eligible noncitizen status in a previous award year, and you have no conflicting information or reason to doubt the student’s claim of having an eligible noncitizen status, you are not required to perform secondary confirmation in the subsequent award year if the documents used for that prior year’s secondary confirmation have not expired. Q2:  Is there anything that would prohibit a clock hour for-profit school from having a “summer break”? A2:  There is not a Title IV regulatory prohibition to having summer breaks for any school type.  The important thing is that the school follows its approved academic year definition.  Having a summer break may provide a student retention challenge in programs that are typically offe

Getting it Right – The Right People

November 17, 2014
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Recently, we began a series on getting it right.  We talked about the potential impact on operations and effectiveness when we miss the 11-17-2014 3-11-24 PMmark in our work environment.   In the $150 billion dollar world of financial aid administration1, the effect of not getting it right may cripple an institution.  There are at least three components in getting it right:  the right people, the right service, and the right exposure.  The concept of getting it right is often referred to as employing best practices.  In this segment of our series we will highlight getting it right in regard to the people in the organization. Schools that participate in the Title IV Federal Student Aid programs are aware of the regulatory requirement in

Since You Asked: Questions & Answers

October 28, 2014
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Since You Asked: FAME Frequently Asked Questions & Answers Q1:  For a clock hour program that has a 900 clock hour academic year definition which equals 1 year for Subsidized Loan Eligibility Used (SLEU) purposes, if you have a student attending 30 hours per week and a student attending 20 hours per week, should you report them both as attending fulltime for the enrollment status? The reason for the question is because if you report the 20 hours per week student as halftime, won't that calculate to be 0.5 year for the SLEU?  For both of these students, the loan period and the academic year will be reported as the start date to when they will complete 900 hours and both should calculate to be 1 year for SLEU. A1:  For the purposes of prorating subsidized usage periods under the 150% Subsidized Loan limit, ED will not acknowledge enrollment in a clock-hour program that is less than full time. Therefore, for students in such programs, schools must always report a full-time enrollment status to COD.  ED has also provided guidance that if a school has a program where student

Important Reminders for Q4_2014

October 28, 2014
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REMINDERS: Action:  As a result of the Subsidized Direct Loan 150% limit, schools are required to start reporting to NSLDS students’ enrollment information at the program level.  Schools were able to begin using ED’s new file layouts no sooner than April 14, 2014.  All schools must begin using the new file layouts no later than October 1, 2014. Action:  As of October 1, 2014, schools must have updated their Enrollment Reporting Profile Page in NSLDS to indicate when they will be reporting NSLDS Enrollment Reporting data by the student’s academic “program”.  This is primarily as a result of the Subsidized Direct Loan 150% limit.  The date you select may not be later than October 1, 2014.  (NOTE:  FAME makes this update for its clients for whom it does Enrollment Reporting.) 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.  F

EDs Federal Registers (FR) on IFAP

October 28, 2014
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Federal Registers FR – Posted July 11, 2014 – Notice:  2014-2015 Federal Student Aid Deadline Dates This posting notifies the financial aid community of the deadline dates for reports and records related to FAFSA processing and FSA program administration.  It is important for schools to become cognizant of these deadlines and plan their operations throughout the year accordingly.  The PDF version of the Notice contains tables that highlight the various deadlines for specific points of interest.  Good practice would suggest either printing the tables out for reference throughout the year and/or transferring the dates into the institution’s own calendar system for planning and tracking purposes.  The Federal Register is available in PDF format at Federal Register, Volume 79, No. 133, Friday, July 11, 2014, and page 40084.                     THE INFORMATION PROVIDED TO

ED’s Dear Colleague Letters (DCLs) on IFAP

October 28, 2014
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ED's Dear Colleague Letters (DCLs) on IFAP - (listed by DCL category by date) DCL – GEN-14-11: June 30, 2014 – 2015-2016 Award Year:  FAFSA® Information to be Verified and Acceptable Documentation This Dear Colleague Letter (DCL) offers additional information to that provided in the Federal Register on June 25, 2014 regarding 2015-2016 verification requirements and processes, etc.  Specifically, the letter highlights the required verification items for 2015-2016 and acceptable documentation for verification purposes.  Additionally, the DCL provides clarification and additional guidance on certain verification items and related acceptable documentation.  Also of note is that the DCL highlights areas where ED’s guidance has changed or expanded, e.g., dealing with non-tax filers and untaxed income, reporting parental information, guidance on State-approved tests that are considered the equivalent of a high school diploma, changes in the verification tracking groups,

ED’s Electronic Announcements: GENERAL AND VARIED ANNOUNCEMENTS

October 28, 2014
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ED's Electronic Announcements (EAs) on IFAP_Q4-2014 EA – Posted August 4, 2014 – (Direct Loans).  Revised Master Promissory Notes for Direct Subsidized Loans, Direct UnsubsidizedNEW MPN Loans, and Direct PLUS Loans (Paper Versions) The release of newly revised Master Promissory Notes (MPN) is announced in this EA.  As is obvious, these dlMPNs are for those schools and/or borrowers who wish to utilize a paper MPN versus the electronic options.  The new paper MPNs have an expiration date of February 29, 2016.  Between now and December 31, 2014, borrowers may use either the new MPN

ED’s Electronic Announcements: GAINFUL EMPLOYMENT

October 28, 2014
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ED's Electronic Announcements (EAs) on IFAP_Q4-2014 EA – Posted September 11, 2014 – (Gainful Employment).  Gainful Employment Electronic Announcement #50 – Release of the Updated Disclosure Template for Gainful Employment (GE) Programs The financial aid community is made aware of the updated GE Disclosure Template (GEDT) with the release of this EA.  Per regulation, the GEDT is specified as the tool schools are to use for disclosing the required items of information.  Schools are required to use it as their means of providing the public the necessary information mandated by regulation.  All schools must have their GE disclosure information updated utilizing 2013-2014 data by January 31, 2015.  Schools are encouraged to review this announcement with great care.  For a more detailed discussion and additional background information about the GEDT, please refer to FAME’s Regulatory Bulletin dated January 7, 2014.  

ED’s Electronic Announcements: DEFAULT RATES

October 28, 2014
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ED's Electronic Announcements (EAs) on IFAP _Q4-2014 DEFAULT RATE INFORMATION EA – September 22, 2014 – (Loans).  FY 2011 3-Year Official Cohort Default Rates Distributed September 22, 2014 Schools are informed of the release of the FY 2011 3-Year official cohort default rate (CDR) notification packages.  Schools had to deadliinehave been enrolled in eCDR in order to receive the notification packages.  If a school was not enrolled in eCDR at the time of distribution of the notification packages, the school will need to access the data via the NSLDS Professional Access Web site.  The deadline for appealing any information in this CDR package began September 30, 2014.  Depending upon the specific item being appea

ED’s 2014-2015 Federal Student Aid Handbook

October 28, 2014
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ED's 2014-2015 Federal Student Aid Handbook Over this past quarter ED has released numerous updates to the Federal Student Aid Handbook (FSA Handbook).  In fact, all of the remaining volumes of the 2014-2015 FSA Handbook not previously released prior to June 30, 2014, have now been published.  Specifically, the volumes distributed this past quarter to complete the 2014-2015 edition (shown with the date of the volume’s release) are: Volume 2 - School Eligibility and Operations – August 18, 2014 Volume 3 - Calculating Awards & Packaging – July 11, 2014 Volume 4 - Processing Aid and Managing Federal Student Aid Funds – July 3, 2014 Volume 5 - Withdrawals and the Return of Title IV Funds – July 9, 2014 Volume 6 - The

Keeping it Professional

October 28, 2014
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With a title such as is given to this article, one would think that this discussion may contain information on workplace relationshipsmad or performance.  However, there is another appropriate area for discussion in regard to the admonition to keep it professional.  In the world of Federal Student Aid, that area for exploration is the matter of professional judgment. Professional judgment is an interesting topic.  A number of schools hardly ever use this provision in the law, while some may seem to be quite zealous in the application of this component of the financial aid administrator’s tool kit.  Yet others, though they may utilize the option for professional judgment with some frequency, they do so with trepidation as they are uncomfortable with the opportunities and requirements of taking such action. In light of these differing approaches to the use of professional judgment in financial aid, we will review this topic in more depth.  While t

Is Your Data Safe in The Cloud?

October 13, 2014
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It seems like every week we hear about another security breach at a major company: Apple, Target, Home Depot, TJ Maxx, etc. With more and more of our personal data being stored in cloud databases, how vulnerable is our personal information? And how worried should we be about our students’ information in our Student Information System and Financial Aid systems? The short answer is, it depends on your cloud provider. When set up properly, cloud systems can be more secure than your PC at work or at home. Let’s look at how these big breaches have occurred. Naughty pics of celebrities were taken on their iPhones and uploaded to Apple’s iCloud. Apple’s database didn’t have a weakness; the celebrities’ passwords did. They were too easy to guess, and they were the same as on other applications that may have had weaker security. So use strong passwords with at least 8 characters, with a combination of upper case and lower case letters, numbers, and special characters. Don’t use the same password for everything. Yes, it’s hard to remember a lot of different passwords. The solution is to have a password manager application which stores your passwords to different websites.

Getting it Right

September 23, 2014
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We humans have a common trait among us.  We do not like to be wrong, or even to be perceived as being wrong.  Students in schoolstudent—whether in elementary school or at postsecondary levels—frequently do not want to answer questions in class due to a fear of answering incorrectly, not getting it right, and being perceived as the class dunce.  Likewise, in our professions we also have that fear of not “getting it right,” not knowing the right information, or making mistakes.  So, in wisdom we seek guidance on how we should do things.  In fact, a term has been developed over the years that indicate a professional’s desire to know the answer on pertinent topics and to ensure that he or she is performing at expected standards.  The descriptor that has developed is “best practices.”  In the realm of financial aid we also hear of best practices.  The National Association of Student Financial Aid Administrators (NASFAA) at one time conducted an

A Strong Constitution

September 5, 2014
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It slips the memory at the moment as to where and when, but as a child growing up this writer heard that terminology used to describe an individual.   As the adults were talking they said, “He is a boy of strong constitution.”  The word was new in my vocabulary, or at least as used in that context.  But, the meaning was immediately understood.  They were referring to the individual’s health, stamina, and demeanor.  But, more importantly, their words spoke of his character.  By use of that phrase they were actually speaking to the very make-up or nature of the individual, his overall being, and what made him who he was.  Some things the boy could change, such as his attire, his favorite flavor of ice cream, or perhaps his hobbies.  But, who he was—his inmost character—no, that would not change.  He had a recognizably strong constitution. Our nation, the United States of America, has a strong Constitution.  The Constitution has weathered 227 years, but remains strong.  It

Safe and Secure

August 28, 2014
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For those who subscribe to Maslow’s Hierarchy of Needs, the need for safety and security is foundational, just after the basic Maslows Hierarchy of Needsphysiological needs of air, water, food, shelter, etc.  As humans, with or without Maslow’s chart, it is a given that we place a strong emphasis on safety and security.  This is evidenced in our society partly by the laws we enact.  Even the higher education community has legislation for which it is responsible that is related to individuals’ safety and security needs.  Those in the postsecondary education arena know well what that means, especially at this season of the year.  It is once again time for the 2014 edition of the annual Campus Safety and Security Survey, which the U.S. Department of Education (ED) so graciously provides.  But, before we delve into the requirements and time frame for completing the survey, let us explore some concepts and terminolo

CHANGE: Trying to “Find My Place in this World….”

August 25, 2014
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  The fact that change occurs has been our topic for the past three weeks.  Change happens and it presents in many areas that have practical implications.  Thus far, we have discussed the reality that change may bring positive results.  Other changes on campuses for which we have addressed points for consideration include changes in key personnel and changes in ownership or control of an institution.  In this edition of the Regulatory Bulletin we consider another change which we observe a greater preponderance of today than in the past.  That situation is when a school either changes locations or addsearth a new location.  It is almost like multi-Grammy Award winner Michael W. Smith singing that he is trying to “find my place in this world”; or perhaps a similar sentiment expressed by more recent Grammy winner, Taylor Swift, as she sang she was

Dramatically Improve your Default Prevention Process

August 20, 2014
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  FAME Invites you to take part in a complimentary webinar! Learn How to Dramatically Improve the Default Prevention Process at Your Institution On Friday, August 29th 2 pm EST, we will be hosting a webinar conducted by Stephen Epstein, creator of the DollarCamp Default Prevention System.   Why you should attend this Webinar: See why current enrollment interviews and exit counseling are ineffective and don't work Learn how to overcome the main obstacle of getting students to repay their loans Discuss the THREE main barriers to students' understanding of their loans and how to overcome them Learn about innovative solutions that will reduce default rates and boost enrollment (which begin to work as soon as you implement them!)  

CHANGE: “Who is in Control?”

August 15, 2014
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Change can create a loss of control.  But, conversely, change brings new control.  Otherwise, change would result only in chaos.  Our shutterstock_158056886discussion last week included important considerations when there was a change in personnel in a key role at a school, i.e., the director of financial aid.  This week’s focus is on another frequent occurrence of change in some segments of higher education.  That situation is when there is a change of control of an institution.  Some involved in such a change may, depending upon their era growing up, believe they are like Frank Sinatra and want to “have it my way.”  Or, for those in more recent years, they may see such change as expressed by Janet Jackson when she sang, “I wanna be the one in control.”  Yes, changes in institutional control or ownership may have some of that thought process behind the reasons for the change, but we will leave that f

CHANGE: “You’re Gonna Change, or….”

August 6, 2014
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shutterstock_127148477Change does happen.  We talked last week about what some of the impacts of change may be, along with how to see change as an opportunity.  This week we continue with the same topic, but look specifically at one of the common changes that occur in the financial aid world.  Hank Williams sang, “You’re gonna change, or I’m gonna leave.”  That may be what a financial aid director is saying to his boss!  Or, it may be that the boss slightly modified the song to sing to the financial aid director, “you’re gonna change, and you’re gonna leave!”  Either way, whether the financial aid director makes an abrupt decision to change jobs, or the boss helps her make the decision, it is not an infrequent occurrence to see a change in who fills the role of financial aid director.  What is the impact when there is a switch in the person in this role?

CHANGE: Practical Implications

July 28, 2014
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We hear much about “change” from such great authors as Spencer Johnson in Who Moved My Cheese? and Stephen Covey in 7 Habits of Highly Effective People, among many others.  As we know, change is a constant factor in financial aid—from ongoing shutterstock_158056886changes in legislation, regulation, and policy changes on a federal or state level, to changes in key staffing roles and perhaps, even institutional direction.  In such conditions, how does one maintain and even enhance excellence in the financial aid environment?  Let us consider the topic of “change” and some common changes in the financial aid arena in a short series.  This week we will address general concepts of change and implications of such.  In the following weeks, we will look more specifically at some of the familiar changes that schools encounter that impact financial aid.  Specifically, we will address consideration

Thousands of New ISIRs Are on the Way!

July 21, 2014
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fed student aidThe U.S, Department of Education announced on July 18, 2014 that close to 200,000 Institutional Student Information Records (ISIRs) will be reprocessed the evening of Monday, July 21, 2014. The cause for the reprocessing is due to the fact that at least that many applicants for Federal Student Aid (FSA) incorrectly entered data on their Free Application for Federal Student Aid (FAFSA) when completing the FAFSA-on-the-Web. The errors have the potential to significantly impact those students’ eligibility for aid such as the Federal Pell Grant, as well as other types of FSA programs such as Federal Direct Subsidized Student Loans (Direct Loans) and Federal Supplemental Educational Opportunity Grants (FSEOG), etc. The ISIR Issue The issue arises from applicants that incorrectly entered income earned from work and adjusted gross income (AGI) figures with a decimal point. The instructions for completing those f

Campus-Based Title IV Funding and the FISAP Process

July 15, 2014
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The world of financial aid stays interesting…all year round!  Just as you are working on awards for 2014-2015 for students about to start this new award year, you have to switch gears in your thinking—in two directions.  It is now time to start thinking ahead to 2015-2016 if your institution is interested in participating in any of the Campus-Based programs of the Title IV Federal Student Aid Programs.  That is, if you desire your institution’s participation in any one or more of the Federal Supplemental Educational Opportunity Grant (FSEOG), Federal Work-Study (FWS), or Federal Perkins Loan (Perkins) programs in the 2015-2016 award year, it is time to begin preparation for, and completion of, the Fiscal Operations Report for 2013-2014 and Application to Participate for 2015-2016 (FISAP). [Note:  Based upon current funding authorization by Congress, no new Perkins Loan program participants will be authorized in 2015-2016 since no new Federal Capital Contribution (FCC) will be allocated in the Perkins Loan program.  Schools with current Perkins Loan funds may continue to request Levels of Expenditure for 2015-2016.]  As the name of the FISAP indicates, it is also time t

Help your admissions team be their best

July 14, 2014
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Attracting students to your school is harder and more expensive than ever. In fact, it requires 50% more marketing budget to get the same number of enrollments that you had in 2008, according to recent research by Velocify, evaluating cost-per enrollment at publicly-traded proprietary schools. If your school competes for students, it is more important than ever to get every bit of value out of your marketing dollars by ensuring your admissions team is optimizing all new student inquiries. To make sure your admissions team is operating at their very best, here are three of the most important habits of successful enrollment counselors: 1. They follow up The first habit is to simply follow up. Make sure you are following up with every inquiry. While this may seem basic, a staggering 66% of prospective students reported they have experienced a “no response” from a school they had expressed interest in, according to a recent study jointly conducted with

State Authorization…Once More

July 13, 2014
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The time for the State authorization regulation enforcement is upon us.  Oh, but wait.  “JK!”  (That is “Just kidding!” in social media lingo.)  But, it phoneseems like we have heard “State authorization” before.  Actually, we have heard it before.  More than once!   Maybe it is time for the enforcement?  What is the scoop on State authorization? Regulatory Deadline Extensions The enforcement of the regulation in 34 CFR 600.9 and the explanatory dialog in the preamble to these October 29, 2010, Program Integrity regulations were to be effective July 1, 2011.  However, a stay of enforcement on this requirement was allowed until July 1, 2013, for those schools in States* that could not implement the changes in the regulations by July 1, 2011.  Subsequently, an additional extension was granted to allow for delayed enforcement of the regulation until July 1, 2014.  This was due to several States notifying the U.S. Department of

Important Reminders for Q3_2014

July 13, 2014
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REMINDERS: Action:  As of July 1, 2014, schools should update their Enrollment Reporting Profile Page in NSLDS to indicate when they wish to begin reporting NSLDS Enrollment Reporting data by the student’s academic “program”.  The date you select may not be later than October 1, 2014.  (NOTE:  FAME will make this update for its clients for whom it does Enrollment Reporting.) Action:  Beginning July 1, 2014, ED will request enrollment information from schools at least once every 60 days.  Schools are required to respond to those enrollment requests within 15 days of the date the electronic enrollment reporting roster is sent to the school.  See the NSLDS Newsletter #46 for June 2014, posted on IFAP on June 30, 2014 for more details. Action:  On July 15, 2014 (and repeated on July 16, 2014) at 1:30 p.m. (ET), ED will be conducting the 150% Direct Subsidized Loan Limit Webinar #4.  The topic is “General Overview of Program-Level Enrollment Reporting.”  See the June 27, 2014 Electronic A

Priming the Pump: A Primer on the Reauthorization of the Higher Education Act

July 13, 2014
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In times gone by, it was not uncommon for families in the United States to have their own well as a source of water.  Attached to the well was a pump.  PUMPThe iconic hand pump was a necessary component to having the water drawn up out of the well to the surface, whether the pump was located outside the house or one that was installed inside the house, most likely by the kitchen sink.  A key point for success in drawing the water from the well was to ensure the pump was primed.  In this article we want to prime your pump, so to speak, to give you an understanding of what reauthorization of the Higher Education Act is all about, and to hopefully open up the free flow of thoughts on the topic that you may share with your colleagues and Congressional representatives in both houses of Congress. The Higher Education Act (HEA) Through the Years Most individuals involved in some aspect of higher education have at least heard of the term, Higher E

Since You Asked: Questions & Answers

July 13, 2014
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FAME Frequently Asked Questions & Answers _Q3 2014 Q1:  In DCL, GEN-14-07, we noticed the requirement to respond to Enrollment Reports has been reduced from 30 days to 15 days.  I would just like to confirm that this is correct and also ask if the 10-day requirement to respond to error files has changed. A1:  The requirement to respond to rosters has changed from 30 days to 15 days.  The 10-day window to respond to error files has not changed, and is still 10 days. Q2:  When a 2014-2015 Subsidized Loan origination is submitted to COD, will the loan reject if the new calculated percentage results in exceeding the 150% limit?  For example, a student has 25% remaining eligibility and a new loan being originated calculates to be 30% of the published program.  Will the loan get accepted or rejected at the time of origination? A2:  We can’t speak to the hypothetical you posed, because the remaining eligibility, maximum eligibility period, and subsidized usage periods are all in units of years, not percentages.  That being said, if a

Federal Registers on IFAP

July 13, 2014
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FR – Posted June 20, 2014 – Proposed Rule:  Violence Against Women Act This posting alerts the financial aid community of the Notice of Proposed Rulemaking (NPRM) that ED has published related to the recent changes in the Violence Against Women Reauthorization Act of 2013 (VAWA).  The intent of these proposed regulations are to update, clarify, and improve the current regulations.  These proposed new regulations carry potential for significant impact on institutions, including potential for increased costs related to training requirements, reporting, etc.  Some of the points related to changes in the law, which are now reflected in this new NPRM, were highlighted in our March 11, 2014 FAME Regulatory Bulletin, along with implementations tips.  (That edition of the Regulatory Bulletin is available at https://www.fameinc.com/blog/violence-women-reauthorization-act-2013-new-version-specifications.)  Schools are encouraged to review, analyze and provide their comments on this new NPRM to ED within the req

ED’s Dear Colleague Letters (DCLs) on IFAP

July 13, 2014
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(listed by DCL category by date) DCL – GEN-14-06: April 11, 2014 – Recognized Equivalent of a High School Diploma With this letter, ED provides important information about changes in what is considered a recognized equivalent of a high school diploma.  Effective January 1, 2014, a number of States have either replaced the General Educational Development Certificate (GED) with a different State-authorized examination, or they now offer a choice of several different State-authorized examinations.  Two such tests that may be acceptable in some States are the High School Equivalency Test (HiSET) and the Test Assessing Secondary Completion (TASC).  A State may have established yet a different official State-authorized examination for determining equivalency of a high school diploma than any of the ones specified here.  Schools that have questions about what is acceptable in a particular State should contact that State’s education authority.  Contact information for such State education authorities may be found at

ED’s Electronic Announcements (EAs) on IFAP: GENERAL AND VARIED ANNOUNCEMENTS

July 13, 2014
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EA – Posted May 6, 2014 – (Application Processing).  Launch of Student Aid History on StudentAid.gov The enhancement and expansion of the StudentAid.gov Web site is announced in the EA.  ED explains that the site will now allow for students to studentsaccess their federal student aid history directly in that one location.  The site will allow a student or other borrower to view all of their federal loan and grant information from the one site now, including information about loan defaults and grant overpayments.  Individuals accessing the site may do so via tablets and smartphones in addition to a typical personal computer or laptop, etc.  ED provided sample screenshots with the announcement so that aid administrators will have an understanding of what students will see on the site.  Note that the NSLDS Student Access Web site is still available to

ED’s Electronic Announcements (EAs) on IFAP: GAINFUL EMPLOYMENT (GE)

July 13, 2014
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EA – Posted May 1, 2014 – (Gainful Employment).  Gainful Employment Electronic Announcement #49 – Updated Gainful Employment Information Page ED provides an update on the status of the Gainful Employment (GE) Information page accessible via IFAP.  The page, originally implemented in 2011, has been updated to be renamed the “Gainful Employment Information Page 2014”.  With this renaming of the page, older GE information that is no longer valid or applicable has been removed from the newly renamed page.  ED’s stated goal is to ensure schools have easy access to the most current GE information related to regulatory requirements and ED’s plans.  Schools may still access the older GE information by selecting the “Resources” option on the page and then selecting “Archived Gainful Employment Information Page” option.  The public is reminded that ED is in the process of regulating all aspects of the GE provisions.  The March 25, 2014 Notice of Proposed Rulemaking (NPRM) comment period ended the on May 27, 2014.  The community at large awaits the final regulations resulting from the NPRM and the comments ED re

ED’s Electronic Announcements (EAs) on IFAP: PROCESSING FOR 2014-2015

July 13, 2014
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EA – Posted April 17, 2014 – (General).  2014-2015 FAFSA Verification-IRS Tax Return Transcript Matrix With this announcement ED provides a matrix for use in verifying IRS income and tax information when an IRS Tax Return Transcript has been submitted by a student or parent.  ED specifies how the items on the IRS Tax Return Transcript relate to the items on the FAFSA and ISIR.  This is important due to the fact that the tax return transcript does not have line or item numbers and uses wording that may be different than what is used on the FAFSA and ISIR for some items.  Also, there are some items on the transcript that may have more than one value reported.  When only one value is reported for an item, that is the value that must be used for verification purposes.  However, when an item has more than one value reported on the transcript, the one that must be used for verification purposes is the one that says “Per Computer”.  This is true even if it is a value different than what the tax filer reported when submitting their tax return.  Financial Aid Administr

Dropouts: The Cost is High

July 11, 2014
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Whatever the reason a student chooses to walk away from an education – the statistics are clear: too many are dropping out. For educators, there’s nothing more discouraging than witnessing the lost potential of students who will never gain the knowledge, skills and confidence that come with earning a degree or lay the crucial foundation that prepares them for personal and professional success. The economic impact on the student – and on the college, university or vocational school – is great as well. Students who fail to finish a degree suffer from lower future incomes (up to half a million dollars) and are more likely to default on loans. High dropout rates not only erode the reputations of educational institutions and cause undue hardship on instructors, but directly lead to lower revenues and may jeopardize government-backed loans. Early Warning Systems (EWS) Work Using predictive analytics and automated data processing (or “machine learning”), Voyant can mine the vast amounts of data collected by FAME to uncover patterns of historical behavior. For example, do first-time post-secondary goers over the age of 20 drop out more often than ot

In Case You Missed It….Important Loan Details

July 11, 2014
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Subsidy on Federal Direct Subsidized Loans in Grace Period Returns and Updated Addendum to Entrance Counseling Guide for Direct Loan Borrowers   Where does time go?  It seems like only yesterday we were talking about the nation’s Federal Fiscal Year 2012 (FY 2012) budget.  But, it was December 23, 2011, that President Obama signed into law the Consolidated Appropriations Act, 2012 (Public Law 112-74).  That legislation had significant impact on the Title IV Federal Student Aid Programs.  Most of the changes made by that law have become routine in our understanding and day-to-day operations.  However, there was one provision in the law that had a specific limitation to it.  That limited provision was regarding interest subsidy on Federal Direct Subsidized Loans during a borrower’s grace period. Grace Period Interest Subsidy Resumes In the Consolidated Appropriations Act, 2012, the law directed that interest subsidy on Subsidized Direct Loans during the borrower’s grace period would

Working with Code: CIP Codes

June 30, 2014
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There is a bit of mystery in the concept of codes.  Codes are thought of, many times, as a way to talk or communicate in a unique way such that postalonly the informed can understand.  And, the code may be used to disguise secret or classified information.  But, codes may also be seen as a way that would seem to simplify a larger concept.  A case in point:  Zip codes are used by the U.S. Postal Service to represent a geographic location that otherwise would have to be spelled out in great length.  For example, Kleinfeltersville, Pennsylvania—which is one of the longest non-hyphenated single word city names in the United States—would be quite the chore to write regularly in the postal distribution process.  So, the use of its assigned Zip code of “17039” works quite handily in the Postal Service’s processing of mail addressed to folks there.  Likewise, in our field of postsecondary education, we like to expedite things by the use of codes and acr

The Pounding of the Gavel and the Stroke of a Pen: The Effects of Legislative and Regulatory Changes on NSLDS Enrollment Reporting

June 18, 2014
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It is the iconic symbol of an official meeting’s action.  When the gavel comes down, it is done.  In the case of a proposed law in the United States, aLAW legislative bill’s passage is affirmed by the gavel’s strike.  The bill then awaits the stroke of a pen, the historic presidential pen.  Likewise, the regulatory process implements changes.  These changes are also brought to life by the stroke of a pen, the Secretary’s pen.  For our purposes, it is the signature of the Secretary of the U.S. Department of Education (ED) that brings life to much discussed language as prescriptive rules. The recent legislative and regulatory changes of interest today are those related to NSLDS Enrollment Reporting.  Formerly, the information now included in NSLDS Enrollment Reporting was called the Student Status Confirmation Report (SSCR).  That prior nomenclature had been around for decades.  But, with the shift of enrollment reporting to being accomp

FAME Partners with KLASS App to Launch the FAME Student Mobility App

June 13, 2014
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Fort Lauderdale, FL – June 13, 2014 – FAME, one of the largest third party servicers in the higher education market, delivering enterprise Student Information Systems (SIS) with integrated Financial Aid Services, has announced a joint agreement with KLASS App, a unique student interface via a custom mobile application. The collaboration will provide FAME’s SIS clients with the ability to engage instantly with students and prospects from one central application.  Students will be able to communicate directly with the school via a school branded App on their smart phone or tablet. 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. The integrated FAME Mobility App will improve student engagement in all aspects of Admissions, Financial Aid, Education, and Student Services, Career Services by providing direct contact to students through a mobile App working in tandem with an administrative portal. FAME’s Student Mobility App will improve the school’s key performance indicators by providi

Voter Registration Counts

June 11, 2014
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It seems that it is almost an annual occurrence.  It is either a state or federal election that is on the horizon.  And, with an election in view come the seemingly unending political advertisements.   Most would probably agree that by election time, one has seen and heard more than enough of whatVOTE seems to have become endless diatribes rather than civil and intelligent discourse on issues.  But, regardless, such an event highlights the privilege and responsibility of citizens to exercise their vote.  In preparation for doing so, naturally, eligible citizens should ensure they are not only cognizant of the issues and candidates on the ballot, but also are appropriately registered to vote. Responsibility for Schools Interestingly, postsecondary schools that participate in the Title IV Federal Student Aid programs are required to make a good faith effort to distribute vo

Just Charge It: Considerations When Charging by the Program

June 4, 2014
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  Just charge it!  That sounds like a theme from a credit card commercial.  But, the reality is that for a good number of schools that is what they do.  They charge it to the students—their program costs that is.  It is not uncommon for schools in the technical and career training sectors of highercredit card education to charge students the full program costs up front as they begin the program.  Said differently, the charges assessed at enrollment are for the entire length of the program.  This has several implications when doing so.  Naturally, it gives a boost to the school’s accounts receivables.  And, depending upon the school’s institutional refund policy, it could have some advantages in funds being able to be retained if a student does withdraw.  It also may make it simpler to determine the appropriate “program” costs when completing the Net Price Calcu

FAME’s Response: Program Integrity: Gainful Employment; Proposed Rule (dated March 25, 2014)

June 2, 2014
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May 27, 2014   Ms. Ashley HigginsU.S. Department of Education1990 K Street, NWRoom 8037Washington, DC20006-8502  DOCKET ID:  ED-2014-OPE-0039 34 CFR Parts 600 and 668 Program Integrity:  Gainful Employment; Proposed Rule (dated March 25, 2014)   Dear Ms. Higgins: On behalf of FAME, and the hundreds of institutions we serve, and the thousands of students they serve, we submit the following items for the Department of Education’s consideration in regard to the above identified Notice of Proposed Rules (NPRM) published in the Federal Register on March 25, 2014. FAME is dedicated to meeting the diverse needs of postsecondary educational institutions. From its inception in September of 1978, FAME has provided service excellence to institutions participating in federal financial aid programs and for those seeking quality, affordable Student Information Systems.  FAME has a long history in providing comprehensive, high quality, cost effective Student Information Systems and efficient, accurate fin

New Student Loan Interest Rates Make for Interesting Times

May 29, 2014
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    This time of year is always interesting!  (Yes, that is a bit of a play on words.)  In the world of financial aid, this time of year is when schools and Interest Ratesstudents anxiously await the announcement of what the new interest rates will be on Federal Direct Student Loans.  As you may recall, last year the Bipartisan Student Loan Certainty Act of 2013 was signed into law.  The focus of this legislation was to overhaul the Federal Direct Student Loan Programs’ interest rate structure.  With this new law, interest rates are determined based upon the high yield of the last auction of the 10-year Treasury notes held prior to June 1 each year, plus a margin, or what is called an “add on”.  The change in the law set the rates for the Subsidized and Unsubsidized Direct Loans to undergraduate students at equal rates.  Also, the law established the interest for Direct Unsubsidized Loans for graduate/pro

Look for FAME at the APSCU Annual Convention & Expo!

May 20, 2014
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The Association of Private Sector Colleges and Universities (APSCU) Annual Convention & Exposition is the premier event for private sector higher education and FAME's Sales Team will be making their way around the convention!
Make sure you catch up with Julia Brown-VP, Sales & Market Development, Rick Rosado-Sales Manager, Bob Pike- Executive Sales Representative, and Bruce Capps- Executive Sales Representative.

FAME is heading to Region V

May 7, 2014
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Regions PCCS (Private Career Colleges and Schools) Financial Aid conferences are held throughout the year in different regions of the United States. The PCCS goal is to provide a common ground to meet and exchange ideas in Education, Business and Compliance issues. FAME will be at the Region V conference which includes institutions from Illinois, Wisconsin, Minnesota, Michigan, Ohio and Indiana. This year's conference, “Partnership in Growth” will be held on May 19th & May 20th at the Indian Lakes Resort in Chicago. Make sure to visit with Julia Brown, FAME's VP of Sales & Market Development, in the exhibit hall at the event!  Also, don't miss out on some great sessions presented by FAME's very own, Director of Compliance, Sally Samuels. She will focus on keeping you in compliance with sessions like: On the Lookout for Identify Theft & Fraud, How Innocent Mistakes Can Lead to Disastrous Results, and  What happens to the Data & Gainful Employment Disclosures.     Come see us in person! Click here

Identity Verification Results: A Journalistic View of Verification Tracking Groups V4 and V5

May 5, 2014
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  Students of journalism become very familiar with the “who what, when, where, why, and how” questions of fact gathering.  These five questions BUILDINGare sometimes called the “Five Ws and one H”, or more simply, the “Five Ws”.  These basic investigative questions are utilized to get to the crux of a matter being considered.  The origin of such method for inquiry dates back to the ancient Greeks (e.g., Hermagoras and Cicero), although it was revitalized in more recent times by Rudyard Kipling in his writings, and specifically in “The Elephant’s Child”.  So, what does this have to do with financial aid? Financial aid can, in many situations, be viewed as a prime opportunity for utilizing the Five Ws.  One specific case in point is the recent guidance offered by the U.S. Depart

Since You Asked: Questions & Answers

April 24, 2014
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FAME Frequently Asked Questions & Answers _Q2 2014   Q1:  If a school has a policy that requires a student to buy the first textbook on their own, can the school charge a student a 20% surcharge if the student does not buy the first book on their own?  That is, the school wants to bill a surcharge if it has to purchase the book for the student and then charge the student’s account ledger and use Title IV Federal Student Aid to pay for it (if the student receives Title IV assistance). A1:  No.  That would unfairly be charging an extra fee essentially for Title IV recipients.  Under the Program Participation Agreement regulations in 34 CFR 668.14, a school may not charge additional fees to a student to get Title IV aid or because they are getting aid.  In addition, for Federal Pell Grant recipients for whom ten days before the beginning of the payment period the school could have disbursed FSA funds to the student and for whom disbursement of those funds would have created an FSA credit balance, the school must provide the books or a way to o

When Hell Does not Freeze Over

April 24, 2014
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News reports this past fall highlighted two situations of institutions that had been recipients of a Federal Program Review of their Title IV Federal Student Aid (FSA) programs.  The schools had been cited by the U.S. Department of Education (ED) for going further than ED believed to be warranted and acceptable in exercising discretion in the use of professional judgment when considering students’ applications for FSA funding.  Compliance FeatureYes, this can many times be an area of exploration by ED program reviewers when visiting schools.   But, the interesting point in these two cases is that ED conducted the on-site program reviews at these institutions in the 1990s.  (Did someone ask the question of when ED will complete the determination on their own more recent program review?)  Late last year ED contacted the two institutions with a request for payment of funds as a result of the program review in the ‘90s. 

A Careful Look at Time

April 24, 2014
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Tick tock. A careful eye is kept upon the clock.  Many managers are—without desire, yet by circumstance required—on the lookout for those certain clocksemployees who like to keep an eye upon the clock; those always ready to bound for the door as soon as the clock’s hands get in right alignment.  But, of course, in the world of financial aid, there is another key aspect of clock watching that is critical to a successfully run financial aid operation. That comes in the sphere of clock-to-credit hour conversions.  This concept has been around for years, being one of several other pivotal aspects of the now famous October 29, 2010 Program Integrity regulations.  But, it has gained a new place of prominence as if the very idea of clock-to-credit hour conversions was to be on display like the legendary Big Ben.  While it is true that the majority of such schools affected by this are in the private, proprietary sector

ED’s Dear Colleague Letters (DCLs) on IFAP

April 24, 2014
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Listed by DCL category by date     DCL – GEN-14-01: January 31, 2014 – 2014-2015 Federal Pell Grant Payment and Disbursement Schedules With this letter, ED provides the necessary Payment and Disbursement Schedules for the coming Award Year of 2014-2015.  The schedules are provided for varying enrollment statuses (i.e., full-time, three-quarter-time, half-time, and less than half-time). It will be noted that these schedules indicate that the maximum Pell Grant for 2014-2015 is $5,730, which is an $85 increase from 2013-2014.  Also, the actual 2014-2015 Award Year minimum award amount for a full-time student is $587.  The maximum Pell Grant eligible expected family contribution (EFC) for 2014-2015 is 5157 whereas in the 2013-2014 Award Year it was 5081.  Thus, schools may see some additional Pell eligible students in 2014-2015. DCL – GEN-14-03: February 27, 2014 – Impact of Cohort Default Rates on Institutional Title IV Program Eligibility In this DCL ED gives a summary of how an institution’s cohort default rate (CDR) is calculated and what regu

ED’s Electronic Announcements (EAs) on IFAP: 150% DIRECT SUBSIDIZED LOAN LIMIT

April 24, 2014
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EA – Posted January 17, 2014 – (General).  150% Direct Subsidized Loan Limit:  Electronic Announcement #8 – Final Regulations Published This announcement alerts the financial aid community of the publication of the final regulations related to the 150% Direct Subsidized Loan Limit.  These final regulations published on January 17, 2014 replace the interim final regulations provided last May 16, 2013.  A number of important changes were made in these final regulations of which schools should be cognizant.  First, in the prior interim regulations a Direct Subsidized Loan borrower's calculated Subsidized Usage Period (SUP) was required to be rounded down to the nearest quarter of a year in all situations.  However, under these new final regulations a SUP will be rounded up or down, as appropriate, to the nearest tenth of a year. The second area in which changes were made in these final regulations pertained to the annual loan limit exception and the part-time enrollment status exception for determining the SUPs.  Under the interim regulations, if a student was considered to have met the exception based upon having bor

ED’s Electronic Announcements (EAs) on IFAP: GAINFUL EMPLOYMENT

April 24, 2014
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EA – Posted March 25, 2014 – (Gainful Employment).  Gainful Employment Electronic Announcement #48 – Notice of Proposed Rulemaking on DeadlineGainful Employment ED announces the publication of the Notice of Proposed Rulemaking (NPRM) on gainful employment in the Federal Register.  This is the official copy for review and response versus the advance copy submitted on March 14, 2014 in GE Announcement #47.  The public has until May 27, 2014 to provide comments for consideration before the NPRM is finalized.  It is important that schools read and respond to this notice if there are concerns with the proposals.  A school may submit its response via the regulations.gov Web site per the instructions in the NPRM.   Click here for access to ED's Elect

ED’s Electronic Announcements (EAs) on IFAP: PROCESSING FOR 2014-2015

April 24, 2014
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EA – Posted January 16, 2014 – (Campus-Based).  Deadline Date Notice for 2014-2015 Campus-Based Programs ED notifies the financial aid community of the applicable deadline dates that occur during the 2014-2015 award year that relate to the Federal SEOG, Federal Work-Study, and Federal Perkins Loan programs (more commonly referred to as the Campus-Based aid programs).  It is important to note that the deadlines are applicable to more than one award year.  That is, although the deadline may occur in the 2014-2015 award year, the deadline may actually be applicable to a prior or future award year.  For example, the 2013-2014 Fiscal Operations Report and the 2015-2016 Application to Participate (together called the FISAP) have a deadline of October 1, 2014.  This particular Electronic Announcement actually refers the reader to the January 15, 2014 Federal Register where ED published the official notice of the deadlines.  That Federal Register contains a useful chart for being able to see at a quick glance all applicable deadline dates for the Campus-Based programs during the 2014-2015 award year.  The

Important Reminders in Quarter 2-2014

April 24, 2014
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REMINDERS: Action:  The deadline date for a waiver of the Federal Work-Student Community Service requirement is April 25, 2014.  The deadline for an electronic submission of a school's waiver request is 11:59 P.M. (ET) on Friday, April 25, 2014. Action:  Institutions must submit any comments on the Gainful Employment (GE) Notice of Proposed Rulemaking (NPRM) by May 27, 2014 for official consideration in the final regulations that will be published on GE. Action:  The Direct Loan closeout deadline for the 2012-2013 Program Year is Thursday, July 31, 2014. Action:  As a result of the Subsidized Direct Loan 150% limit, schools are required to start reporting to NSLDS students’ enrollment information at the program level.  Schools may begin using ED’s new file layouts no sooner than April 14, 2014.  All schools must begin using the new file layouts no later than October 1, 2014. Action:  The deadline for submitting the 2013-2014 Fiscal Operations Report and the 2

ED’s Electronic Announcements (EAs) on IFAP: GENERAL AND VARIED ANNOUNCEMENTS

April 23, 2014
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EA – Posted February 18, 2014 – (Loans).  FY 2011 3-Year Draft Cohort Default Rates Distributed February 18, 2014 The FY 2011 3-Year Draft Cohort Default Rates were distributed on February 18, 2014.  Under regulations published October 28, 2009, beginning with the FY 2009 cohort year, 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.  ED no longer calculates a 2-year CDR.  Beginning with 2014, only 3-year rates are published since three 3-year rates have now been calculated (FY 2009 published in 2012, FY 2010 published in 2013, and FY 2011 published in 2014). Schools should review this Electronic Announcement to be reminded of the impact that will be incurred if a school’s FY 2011 official 3-year CDR is equal to or greater than 40% when the official CDR is published in September 2014, or if the school’s 3-year CDR has been 30% or greater for three years. The time period for challenging a school's FY 2011 3

FAME will keep you cooking with compliance at AACS Spring!

April 2, 2014
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    The American Association of Cosmetology Schools will be hosting its upcoming AACS Spring Operations Conference,Create a Recipe for the Future, at the Wild Horse Pass in Phoenix, AZ. See what FAME is cooking up at AACS Spring Conference! Visit with Julia Brown, VP of Sales and Market Development and Bob Pike, Executive Sales Representative at booth #106. Also, join Sally Samuels, Directory of Compliance, in the Financial Aid Lounge and in her advanced financial aid session to keep you cooking with compliance! May 4th 10:45 am – 11:45 am-Financial Aid Lounge Talk with Sally Samuels, FAME Is your head spinning from all that you have learned so far this weekend? Did you think of some new questions you didn’t get the chance to ask in a session? Visit the Financial Aid Lounge for the opportunity to ask those questions of our experts as well as talk with your peers about best practices in a casual setting. May 5th 10:45am-11:45am-GE: A Proactive Approach | Old Recipes, New Variations Sometimes a very sm

Violence Against Women Reauthorization Act of 2013: The New Version Specifications

March 11, 2014
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In modern technology parlance, the Violence Against Women Reauthorization Act (VAWA) of 2013 (Pub. Law 113-4) would be called VAWA.2013.  This edition of VAWA is the fourth “version” of the law which was originally signed into existence on September 13, 1994.  Subsequent reauthorizations occurred on October 28, 2000 and January 5, 2006.  This latest version, VAWA.2013, was signed into law on March 7, 2013. The New Version Specifications Yes, one year ago, VAWA was reauthorized.  The newest version of this important legislation brought with it various new reporting requirements for postsecondary institutions that participate in the Title IV Federal Student Aid programs.  These new requirements were accomplished by VAWA’s amending the Clery Act portion of the Higher Education Act (HEA) of 1965, as amended. Data Components The specifics of the law that affect reporting requirements include stipulations that institutions compile statistics for certain crimes that are reported to campus security authorities or local police agencies.  The newly added crimes for which institutions must now gather dat

Dancing Through the Draft Default Rates

February 20, 2014
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Rhythm, a sequence in time repeated, featured ... It is that time of year again!  It is time to brush off those dancing shoes and refresh your steps so you do not miss a beat as you waltz through the draft Cohort Default Rates (CDR) review.  Yes, the dance is recommended to be more of a waltz than a salsa as the review of the draft CDR is important to your institution’s continued participation in Title IV Federal Student Aid programs.  Thus, it is necessary to take it steady and slow as you move through the annual review. New FY 2011 Draft 3-Year CDR The U. S. Department of Education (ED) announced the release of the new FY 2011 3-year draft CDR in an Electronic Announcement on February 18, 2014.  This is the first year in which there is only a 3-year draft CDR bein

When is a Disbursement a Disbursement?

February 11, 2014
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It is a routine question asked of students:  “When will my loans be disbursed?”  Likewise, the Business Office regularly inquires of the Financial Aid Office:  “When do we expect Ima Student’s loans to be disbursed?”  Well, that is a good question!  One response heard across the country is the old standby, “It depends….”  That response can be apropos at times, for example when the Financial Aid Office is waiting on a student to turn forms in to complete his or her file.  But, more specifically, there is a definite point in time when the students’ loans are disbursed.  This precise definition of “disbursement date” at times may be misunderstood.  To clarify the explicit meaning of the term, the U.S. Department of Education (ED) recently disseminated an Electronic Announcement to schools to remind everyone what “disbursement date” truly means, especially as it applies to Federal Direct Loans. The fact that ED distributed this reminder would indicate that they note schools are having issues in utilizing the correct disbursement date, especially for Direct Loans.  What is the “disbursement date”?  The disbursement for Direct Loans occu

Time to Update Your School’s Net Price Calculator

January 30, 2014
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Each year schools are required by law to update the information used in their Net Price Calculator (NPC). The U.S. Department of Education (ED) provides an updated template annually.  ED’s plan is that it will usually be available in January each year for the most recently completed award year.  As an example, this year ED has released the updated template on January 27, 2014 for updating a school’s NPC utilizing data from the 2012-2013 award year.  (The 2012-2013 award year is the most recently completed award year prior to the release of the updated template).  This year’s updated template was released in the January 27, 2014 Electronic Announcement. The purpose of the NPC is to assist interested parties such as prospective students and their parents in understanding the estimated “net price” of attendance at the school before they actually enroll.  It also serves as a tool in comparing the net price of any number of schools before finally deciding which school they desire to attend.  Any school that enrolls full-time undergraduate students in a degree or certificat

Deadline to Apply for Waiver of Penalty for Underuse of Campus-Based Allocations

January 23, 2014
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If a school did not use all of its 2012-2013 Title IV Campus-Based programs' federal allocations, and that amount not used exceeds 10% of its federal allocation, a school has until February 7, 2014 to submit a request for a waiver of the penalty for not using all of the allocation. If an acceptable request for waiver of the penalty is not submitted by that date, the institution’s Campus-Based federal allocations for 2014-2015 will be reduced by the amount not utilized in 2012-2013. A waiver may be granted only if the school is able to explain that the underuse was due to circumstances beyond its control and why those circumstances are not expected to recur. A school can tell if they may be subject to the underuse penalty by reviewing its most recent Fiscal Operations Report for 2012-2013 and the Application to Participate for 2014-2015 (FISAP). A school may also tell if they are potentially subject to the penalty by reviewing their Campus-Based Tentative Funding Worksheet for 2014-2015. [The Campus-Based Tentative Funding Worksheets for 2014-2015 are scheduled to be posted to the eCampus-Based (eCB) Web site not later than Ja

Important Reminders in Quarter 1 2014

January 23, 2014
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Reminders: Action:  Institutions must have their Gainful Employment (GE) disclosure information utilizing 2012-2013 data updated by January 31, 2014. Action:  As a result of the Subsidized Direct Loan 150% limit, schools are required to start reporting to NSLDS students’ enrollment information at the program level.  Schools may begin using ED’s new file layouts no sooner than April 14, 2014.  All schools must begin using the new file layouts no later than July 1, 2014. Action:  Make sure FAME has your current contact information so that you are receiving items like FAME's Regulatory Bulletin.  If you are a client and do not receive FAME's various informational, regulatory, and technical communiqués, please make sure to let us know by filling out the form at https://www.fameinc.com/contact/ and indicating that you would like to be added to our mailing list. Action:  FAME’s Annual Conference at Pier 66 in Ft. Lauderdale, FL, March 25-26, 2014.

Since You Asked: Questions & Answers

January 23, 2014
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FAME Frequently Asked Questions & Answers  Below you will find the frequently asked questions and answers featured in the Q1 2014 edition of FAME’s Inside Report.   Q1:  If our State requires 85% attendance but we have a 10% excused absence policy for disbursing aid and we make everyone comply with 90% attendance for graduation, does this mean that we have to change our satisfactory academic progress (SAP) policy which says students need to complete 66.67% of the hours to be able to complete within 150% of the maximum time frame? A1:  No, a school can have a separate attendance policy that is different from their SAP policy.  It is important to remember that pace of progression is about successful completion of hours and not just seat time (although they can be similar at times).  Successfully passing courses with the appropriate grades in a timely manner (SAP) is separate and distinct from how many hours a student may sit in class (attendance).   Q2:  We are a school that has a master’s program.  We charge by the credit hour.  If we do a s

The Supreme Court on the Defense of Marriage Act and Title IV Aid

January 23, 2014
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The United States Supreme Court. In June of 2013, the Supreme Court of the United States (SCOTUS) ruled on the Defense of Marriage Act (DOMA) in the case of United States v. Windsor commonly referred to as the Windsor case.  Specifically, the Court’s decision invalidated Section 3 of the DOMA.  That section of the DOMA prohibited federal agencies from recognizing same-sex marriages for purposes of federal programs, including the Title IV Federal Student Aid (FSA) programs.  Since that section of the law was rendered invalid, there have been significant implications regarding the application for FSA programs, as well as related processing effects. The U.S. Department of Education (ED) recently released its official guidance on the impact of the SCOTUS decision in the

ED’s Dear Colleague Letters (DCLs) on IFAP

January 23, 2014
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ED's Dear Colleague Letters (DCLs) on IFAP - (listed by DCL category by date) DCL – GEN-13-22: October 17, 2013 – FY 2014 Sequestration Changes to the Title IV Student Aid Programs (Updated October 25, 2013)Reminder Of interest to the financial aid community is this fourth update on the across the board budget cuts to the Federal Student Aid programs.  This round of adjustments, known as sequestration, further impact a number of the Title IV programs, specifically the Iraq-Afghanistan Service Grants, the TEACH Grants, and the origination fees on the Direct Loan programs.  For a detailed review of this round of sequestration effects, as well as a chart outlining the required changes resulting from sequestration, please see

ED’s Electronic Announcements (EAs) on IFAP: GENERAL AND VARIED ANNOUNCEMENTS

January 23, 2014
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EA – Posted October 23, 2013 – (COD System).  COD Computer-Based Training – 2013 Updates Group 3 ED announces the availability of the updated Common Origination and Disbursement (COD) Computer-Based Training (CBT) and provides a link to the CBT components in this EA.  These CBT components cover a multitude of simulations related to the various functions and activities schools utilize in working with the COD system.  This is the last update of the year for the CBT.  This particular release includes updates to COD System simulations on the topics of “Locating Grant Information”, “Working with Batches”, and “Requesting Data”, while the CBT modules updated include “Direct Loan Reports” and “Pell Grant Reports”. EA – Posted October 28, 2013 – (Loans).  Loan Servicing Information – Repayment Plan Preference Information Shared with Loan Servicers Beginning January 2014 In this announcement the financial aid community is reminded that effective January 1, 2014 ED began to share borrowers’ elected repayment plan preference with loan servicers.  T

ED’s Electronic Announcements (EAs) on IFAP: 150% DIRECT SUBSIDIZED LOAN LIMIT

January 23, 2014
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EA – Posted October 25, 2013 – (Loans).  150% Direct Subsidized Loan Limit:  Electronic Announcement #4 – Tracking Teacher Certification Programs for the 2013-2014 Direct Loan Processing Year The information shared in this announcement provides the details necessary for schools to understand how the 150% Direct Subsidized Loan limit is to be handled for tracking the loan eligibility used for teacher certification programs vs. other undergraduate programs.  ED clarifies the process that will be necessary to track and report students’ usage of Direct Subsidized Loans in a teacher certification program in 2013-2014 until ED implements enhancements in the 2014-2015 COD System for tracking such distinction of loan usage by type of program.  Schools are informed of the type of data elements that they will have to report on loans processed for borrowers in teacher certification programs.  It is important that schools with teacher certification programs analyze this EA for the steps necessary for accurate reporting of their students’ Subsidized DL usage. EA – Posted November 12

ED’s Electronic Announcements (EAs) on IFAP: GAINFUL EMPLOYMENT

January 23, 2014
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EA – Posted November 13, 2013 – (Gainful Employment).  Gainful Employment Electronic Announcement #45 – Posting of Session Two materials related to Negotiated Rulemaking Committee. In this posting ED’s Office of Postsecondary Education (OPE) announced the availability of the draft regulatory language that will be used as the basis for the next meeting of the Negotiated Rulemaking (Neg Reg) Committee. The Committee’s next meeting held after this announcement was November 18-20, 2013.  This draft information may be found via the OPE’s Higher Education Negotiated Rulemaking 2013-2014 – Gainful Employment Web page.  Along with the draft regulatory language, ED also provided a brief PowerPoint overview of the content of that draft language to be discussed in the second meeting.  The overview gives a quick visual representation of the basics of the draft language. EA – Posted November 22, 2013 – (Gainful Employment).  Gainful Employment Electronic Announcement #46 – R

ED’s Electronic Announcements (EAs) on IFAP: FSA CONFERENCE

January 23, 2014
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EA – Posted November 19, 2013 – (General).  2013 Federal Student Aid Training Conference Presentations Posted and Registration Closing In preparation for the 2013 FSA Conference ED announced the posting of the PowerPoint presentations on its FSA Conferences Web site.  Those who did not attend the conference may find some benefit from a review of these handouts as well.  They are accessible at 2013 FSA Conference Web site.  The conference was held December 3-6, 2013 at the Mandalay Bay Hotel in Las Vegas, NV.                 The information provided to you is FAME’s opinion based upon our interpretation of the issues and details provided, and our interpretation of the Title IV regulations, legislation, and U.S. Department of Education guidance, as applicable. FAME shall not be liable for any error contained herein or for any damages whatsoever arising out of or related to the use of this information.

ED’s Electronic Announcements (EAs) on IFAP: VERIFICATION FOR 2014-2015

January 23, 2014
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EA – Posted November 8, 2013 – (Verification).  2014-2015 Verification – Suggested Text In this announcement ED provides the financial aid community sample text to use for 2014-2015 when communicating with applicants regarding specific requirements for verification of data unique to individual students.  Schools are reminded that the change to “suggested text” rather than ED-developed verification worksheets is in concert with the Department’s move to a more customized and individualized verification process of student application data.  ED emphasizes that one of the goals of customized verification is to remove unnecessary burden in the application process.  In keeping with that goal, ED stresses that items that are not necessary to the verification process should not be an automatic requirement of all students.  That is, an institution should not develop one all-encompassing verification form that includes all possible items of verification since this may imply to applicants that they need to answer or provide all such information or data that is referenced.  Additionally, obtaining more data elements th

ED’s Electronic Announcements (EAs) on IFAP: VERIFICATION FOR 2013-2014

January 23, 2014
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EA – Posted October 23, 2013 – (Verification).  Acceptable Documentation Update for 2013-2014 Award Year Verification ED clarifies what is considered acceptable documentation for the remainder of the 2013-2014 processing cycle.  Specifically, the announcement states what is considered acceptable alternative documentation when the tax filer has attempted to request an IRS Tax Return Transcript via the IRS online or paper request process, but was unsuccessful in obtaining the tax transcript.  It is important to note that the tax filer must have used either the IRS online request or the paper request in order to be able to document the unsuccessful attempt to obtain the IRS Tax Return Transcript.  This eliminates the telephone request option as a choice since the IRS has no documentation alternative for that method of request.  Additionally, tax filers that submit a copy of the documentation of their unsuccessful attempt to get the tax transcript must also provide a copy of the IRS Form 4506T-EZ or IRS Form 4506-T with the school listed on line 5 as the third party to whom the IRS will mail the 2012 IRS Tax

ED’s Electronic Announcements (EAs) on IFAP: PROCESSING FOR 2013-2014

January 23, 2014
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EA – Posted October 18, 2013 – (COD System).  Additional COD System Implementation for 2013-2014 Award Year In this announcement ED provides information on the enhancements made to the COD System capabilities effective October 27, 2013.  The areas affected by these changes in the COD System impact Direct Loan processing.  Specifically, an expansion of all of the counseling modules at StudentLoans.gov now provides for the availability of the modules in Spanish.  Additionally, now all of the counseling modules on StudentLoans.gov include the required information about the 150% limit on Subsidized Direct Loans.  Finally, the enhancements in this update modified the required data elements and implements a new CPS data-matching for COD Web Quick Credit Checks. As a result of these developments, all authorized users conducting a PLUS credit check via the COD Web site must include student identifier information as well as borrower identifier information and school information to be able to match CPS data across all active CPS award years on file.           THE INFORMATION PROVIDED TO

ED’s Electronic Announcements (EAs) on IFAP: PROCESSING FOR 2014-2015

January 23, 2014
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EA – Posted October 23, 2013 – (Application Processing).  2014-2015 ISIR Guide The 2014-2015 ISIR Guide was released with this announcement.  The Guide is an extremely useful tool for financial aid administrators.  It provides all the details needed to interpret data contained on the ISIR, to include student application data, results of the NSLDS data matches, reject codes and reasons, etc.  If you have a question about the ISIR, you will get the answer in the ISIR Guide. EA – Posted October 30, 2013 – (Application Processing).  Reminder:  Submit 2013-2014 SAR and ISIR Corrections by January 13, 2014 in Preparation for 2014-2015 Renewal Reminder Distribution ED reminds schools that students' SARs/ISIRs must be updated with correct e-mail addresses by January 13, 2014 in order to be sent the Renewal FAFSA reminder for the coming school year.  Students who meet the 2014-2015 FAFSA renewal eligibility requirements will be sent a reminder by e-mail between January 16, 2014 and January 22, 2014.  Schools sho

ED’s Electronic Announcements (EAs) on IFAP: PROCESSING FOR 2013-2014

January 23, 2014
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EA – Posted October 18, 2013 – (COD System).  Additional COD System Implementation for 2013-2014 Award Year In this announcement ED provides information on the enhancements made to the COD System capabilities effective October 27, 2013.  The areas affected by these changes in the COD System impact Direct Loan processing.  Specifically, an expansion of all of the counseling modules at StudentLoans.gov now provides for the availability of the modules in Spanish.  Additionally, now all of the counseling modules on StudentLoans.gov include the required information about the 150% limit on Subsidized Direct Loans.  Finally, the enhancements in this update modified the required data elements and implements a new CPS data-matching for COD Web Quick Credit Checks. As a result of these developments, all authorized users conducting a PLUS credit check via the COD Web site must include student identifier information as well as borrower identifier information and school information to be able to match CPS data across all active CPS award years on file.     THE INFORMATION PRO

ED’s Federal Student Aid Handbook 2013-2014 EDITION

January 23, 2014
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EA – Posted October 23, 2013 – 2013-2014 Federal Student Aid Handbook with Index Linked to Entries ED has posted a complete version of the 2013-2014 FSA Handbook with live links.  This is the fourth year that this feature has been available for the Handbook.  Once more this year ED has superseded its prior publication records in that this edition is yet again the earliest that an index with live links has been provided for a processing year.  The link capability allows you to look up a topic in the index and click on the page number to be taken directly to the subject of interest.  It can be used to expedite your search in the Handbook.  The link to this edition is accessible from IFAP’s iLibrary page for the Federal Student Aid Handbook, or directly at 2013-2014 Federal Student Aid Handbook with Active Index Linked to Entries EA – Posted October 24, 2013 – Errata and Updates – Volume 1 – Student Eligibility and

The Gainful Employment (GE) “Disclosures” requirement is not the same as the GE “Reporting” requirement

January 16, 2014
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Now that the U.S. Department of Education (ED) has come out with its Gainful Employment Disclosure Template (GEDT) in the November 22, 2013 GE Electronic Announcement #46, many have experienced confusion as to what is required. First, and foremost, it is important to understand the difference between GE disclosure requirements and GE reporting requirements.  As schools will recall, there was much legal battling that occurred over the October 29, 2010 Gainful Employment regulations and related guidance.  The 2012 Court decisions “vacated”, or invalidated, the section of the regulations that required schools to “report” GE data.  Specifically, schools do not have to report the information that was previously required the one time back in November 2011 (which included the reporting of several prior years’ data all at once).  As stated in the GE Electronic Announcement #39 on July 6, 2012, “…the Court’s decision vacated the gainful employment reporting requirements in 34 CFR 668.6(a). Therefore, institutions are not required to submit gainf

January 31, 2014 is the deadline for disclosing 2012-2013 award year information via the Gainful Employment Disclosure Template

January 7, 2014
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The long-anticipated Gainful Employment (GE) disclosures template has finally been released by the U.S. Department of Education (ED). This template was a requirement of the historic Program Integrity regulations of October 29, 2010. As schools are aware, there was much legal battle over the concept of the GE regulations. However, the Court’s decision resulted in the GE disclosures requirement being upheld. Therefore, schools have been responsible for providing the stipulated disclosures related to GE programs at their institution. Heretofore, in the absence of the ED-developed template, schools were obligated to determine the best means of collecting and, within certain parameters, disseminating the disclosure information. With the release of ED’s template for GE disclosures on November 22, 2013, schools are now mandated to utilize this tool. The deadline for disclosing information for the 2012-2013 award year is January 31, 2014. The template was made public in the Gainful Employment Electronic Announcement #46. As instructed in the announcement, schools may access the template at the URL given for the 2009-2010 Negotiated Rulemaking Web page. (The URL for direct access

The guidance related to acceptable documentation for verification purposes has been updated

December 19, 2013
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The United States Department of Education (ED) provided clarification on October 23, 2013 as to what constitutes acceptable documentation regarding IRS Tax Return Transcript requirements for the remainder of 2013-2014.  In the announcement, ED specifies further situations when a paper Federal tax return may be accepted for verification purposes.  Previously, financial aid administrators were informed that there were limited circumstances in which a signed copy of a paper tax return may be accepted.  The most common of those restricted scenarios included cases where a tax filer had experienced identity theft, filed an amended tax return, or filed a foreign tax return.  ED now expands the situations in which a signed copy of a paper tax return may be accepted to include situations in which a tax filer requested an IRS Tax Return Transcript using the IRS paper or online methods for requesting the tax transcript but was unsuccessful in obtaining it.  However, the signed copy of the paper tax return alone is not sufficient. First, to be considered acceptable alternative documentation for verification purposes, the signed paper cop

Schools which participate in the William D. Ford Direct Loan Program are required to have a quality assurance process in place

November 26, 2013
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The U.S. Department of Education (ED) has re-emphasized the requirement that schools which participate in the William D. Ford Direct Loan Program are required to have a quality assurance process in place.  While this is a regulatory requirement specified in 34 CFR 685.300(b)(9), a school would be hard-pressed to find any information about it elsewhere on the “Information for Financial Aid Professionals” (IFAP) Web page at www.ifap.ed.gov.  Thus, it is quite understandable that questions may have been raised when ED produced the November 13, 2013 Electronic Announcement with the reminder of the requirement. [And, to clarify, the requirement to have a DL quality assurance program and processes is separate and distinct from the option to participate in a Quality Assurance Program related to verification described in 34 CFR 668.53(a)(1)-(4); 668.54(a)(1),(2), and (4); 668.56; 668.57; and, 668.60(a).] The Direct Loan (DL) quality assurance requirement stipulates that schools must implement a quality assurance (QA) process that ensures they are complying with the DL program requirements and meeting the DL program objectives.  Schools must also be able to document

An e-mail campaign to prior student loan borrowers is being conducted

November 19, 2013
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The U.S. Department of Education (ED) has initiated this e-mail contact to emphasize the availability of the “income-driven” repayment plan options.  The intent is to ensure that all borrowers have the appropriate information to select the repayment plan that is appropriate for their individual circumstances “so that student loan debt does not stand in the way of life’s opportunities.” The focus of this undertaking includes several categories of borrowers.  The first priority is those borrowers whose grace period will end soon.  Additionally, borrowers who have become delinquent in payments, along with those borrowers in deferment or forbearance due to financial hardship or unemployment are included in the aim of this thrust.  And, finally, the last group encompassed in this particular drive is those who have higher-than-average student loan debts. Borrowers are urged to access and review various resources pertinent to gaining an understanding of the diverse repayment plan options.  They are also informed that their loan servicer will be contacting them soon, if they have not already, regarding the various repayment options.  ED suggests the loan servicer as a

The Department of Education has modified its stance when working with overlapping academic years

November 13, 2013
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The U.S. Department of Education (ED) has modified its stance related to steps used when working with overlapping academic years in scenarios where students change schools.  The updated guidance clarifies the authorized method for schools to use in determining the beginning date of the academic year at a student’s prior school in situations where there is a potential overlap of the academic year at the prior school and the student’s current school.  Previously, and as remains an option, schools always had the choice to contact the prior school to obtain documentation of that school’s academic year begin and end dates in potential overlapping year cases.  But, schools could also choose to assume the dates of the academic year at the prior school when the information was not available.  Using this alternative assumption method, the new school could consider—in most cases—that the prior academic year began with the starting date of the student’s most recent loan period (as shown in NSLDS) and to have ended 30 calendar weeks later.  ED no longer authorizes this alternative assumption method as an acceptable way for determining the dates of the prior academic year.  Th

There are several things to keep in mind as you begin to look to the start of the 2014-2015 award processing year

November 6, 2013
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Yes, it seems that 2013-2014 has just begun, but it is already time to be planning for 2014-2015.  ED has provided several items that schools should be aware of in anticipation of the start of 2014-2015 processing in January. First, schools will want to review the initial 2014-2015 Federal School Code (FSC) List of Participating Schools.  This list contains the codes that students use to select your institution to receive the results of their Free Application for Federal Student Aid (FAFSA).  The FSC list must be kept current and correct with up-to-date school addresses and six-digit OPE codes to ensure you receive your students’ FAFSA results.  Schools may access the list to review it at Initial 2014-2015 Federal School Code (FSC) List of Participating Schools.  (Alternatively, you may find it on IFAP under “ILibrary” in the “Publications by Document Type”.)  Any corrections that may be needed must be made on the E-App Web site utilizing the “Update your Federal School Code Addresses which are used by the FAFSA”, located on the left side of the page under

The steps for validating or deleting SAIG accounts are as follows:

November 1, 2013
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To perform the account validation process, each organization’s Primary DPA must follow the steps outlined below for both the organization's SAIG mailboxes (Destination Points/TG numbers) and Electronic Services accounts. Failure to complete this process by December 13, 2013will result in loss of access to Federal Student Aid data systems, including services such as Institutional Student Information Record (ISIR) deliveries, ISIR requests, Free Application for Federal Student Aid (FAFSA) corrections, and NSLDS enrollment reporting and updates. Note:  The Primary DPA must have an FSA User ID to complete the process described below. To obtain an FSA User ID, go tohttps://fsawebenroll.ed.gov/PMEnroll/PMAccountServlet.jrun, provide identifying information, and follow the remaining registration steps. Once the registration process is complete, including establishing a password, the FSA User ID will be e-mailed to the Primary DPA. The Primary DPA of the primary TG number (Destination Point/mailbox) must perform the following steps to provide a

Organizations enrolled for a SAIG account must review and validate their assigned TG numbers by December 13th

October 30, 2013
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Every organization enrolled for a Student Aid Internet Gateway (SAIG) account is required to review and validate its assigned TG numbers by December 13, 2013. Failure to complete this process by December 13, 2103 will result in the loss of the user’s access to Federal Student Aid data systems, including access to such items as Institutional Student Information Records (ISIRs), duplicate ISIR requests, Free Application for Federal Student Aid (FAFSA) corrections via FAA Access to CPS Online, and NSLDS enrollment reporting and updates. Accounts that must be validated include TG numbers (SAIG mailboxes) with access to the NSLDS Professional Access Web site, the eCampus-Based (eCB) Web site, and all FAA Access to CPS Online user accounts. It also includes TG numbers enrolled for SAIG batch services for the National Student Loan Data System (NSLDS), the Central Processing System (CPS), the Common Origination and Disbursement system (COD), and the Financial Management System (FMS). We remind you to please only validate services that are listed under your school’s TG number. Please do not update any services that are listed under agreement with FAME’s TG number that is associa

Bill Little will resume the role as FAME’s CEO & President

October 25, 2013
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Bill Little, a FAME co-founder, has assumed the role he previously held for over 20 years as FAME’s lead visionary, CEO & President.  Bill’s vision for FAME is to continually improve the products and services that it provides to the Higher Education market, while continuing to maintain its leadership position in the industry.  He is passionate about propelling FAME to even greater levels of success by providing Higher Education with affordable, world class Student Information Systems and quality Financial Aid Services focused on compliance.  Bill, and Laura Little, FAME’s Co-Owner, and the Executive Management Team are focused on meeting the needs of FAME’s clients by providing a superior customer experience utilizing advanced technology.

Several post-“government re-opening” items have been announced of which schools should be aware

October 23, 2013
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These include changes in COD that impact the COD Web Quick Credit Checks for PLUS Loans, enhancements to loan counseling modules, a new deadline of October 24, 2013 for submitting Annual Campus Safety and Security reports this year, and finally, a re-scheduling of the second round of meetings for the Gainful Employment Negotiated Rulemaking (Neg Reg) committee. ED has announced that effective next week the online credit check process for PLUS Loans in COD is being enhanced.  As of October 27, 2013, when a credit check is requested, there will now be the requirement to include both the borrower’s and the student’s identifier information, as well as the school information related to the loan request.  Previously, the student’s information was not a requirement if the credit check was for a parent PLUS Loan.  The form on the Web is being modified to include the selection of whether the credit check is for a parent PLUS Loan borrower or a graduate student PLUS Loan borrower.  The student identifier information in both cases, whether for the parent PLUS borrower or the graduate PLUS borrower, will be compared against CPS data (ISIR) to verify a student match exists.  If th

The United States government is back in business!

October 17, 2013
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Last night Congress passed a bill to allow the government to re-open as early as today, October 17, 2013.  President Obama signed the measure into law early this morning.  The bill offers only a short-term stopgap response to the issues that led to the shutdown we just experienced.  That is, the bill extends funding for the federal government through January 15, 2014, and raises the federal debt ceiling through February 7, 2014.  As such, although the government is back in business, there is much work to be done between now and January. The direct impact as it relates to student financial aid, of course, is that federal employees will be returning to work.  This will prevent any further backlogs or delays in the Federal Student Aid system and processes.  Fortunately, the government shutdown, although naturally affecting some situations, was comparatively low in overall disruption of day to day processing. Of immediate importance are two points.  First, the influences of sequestration are still in effect.  The bill passed last night did not eliminate sequestration.  Therefore, the prior guidance the U.S. Department of Education (ED) disseminated in various information

Updated ED Corrections 10/17/13: The U.S. Department of Education (ED) has provided yet another—the fourth in all—update on guidance related to the effects of sequestration that first took place effective March 1, 2013

October 14, 2013
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In the direction that ED gave on Friday, October 11, 2013, schools are informed that this most recent sequester guidance is based on the changes effective October 1, 2013, which was the beginning of the 2014 Federal fiscal year (FY 2014).  The information in this latest update from ED pertains only to FY 2014.  It does not replace or supersede the information provided in the three previous communications from ED related to the impact of the sequester on Federal Student Aid programs for FY 2013, which ended September 30, 2013.  It is also important to realize that this sequester impact announcement is not related to the Federal government shut-down currently in place.  Rather, this sequester announcement is the continuing implementation of the effects of the Budget Control Act (BCA) of 2011 (effective August 2, 2011) that required the across-the-board cuts in programs unless Congress had enacted legislation to reduce the Federal deficit by March 1, 2013. Schools are reminded that the Federal Pell Grant program is exempt from sequester.  Therefore, the 2013-2014 Pell Grant Payment and Disbursement Schedules continue to be in effect.  Also, the 2013-2014 Campus-Based aid prog

Important Reminders in Quarter 4

October 14, 2013
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REMINDERS: Action:  Appeals of information applicable to an institution’s Cohort Default Rates (CDR) are due within 15-30 days from the date of the CDR appeal begin date, depending upon the item being appealed.  The 2-year CDRs were released on September 16, 2013 with an appeal begin date of September 24, 2013.  The 3-year CDRs were released on September 23, 203 with an appeal begin date of October 1, 2013. Action:  The deadline for submission of nominations is October 21, 2013 for the Negotiated Rulemaking (Neg Reg) committee that will propose recommended regulations to address the changes to the campus safety and security reporting requirements made by the Violence Against Women Reauthorization Act of 2013 (VAWA). Action:  Corrections to the Fiscal Operations Report for 2013-2014 and Application to Participate for 2015-2016 (FISAP) due to the edit process and Federal Perkins Loan Cash on Hand updates are due by December 13, 2013. Action:  The 2014 FAME Annual Conference will be held at Pier 66 in Ft. Lauderdale, FL, March 25-26, 2014. Registration and more details w

Seeing Red

October 14, 2013
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Have you been seeing anything “red” lately? One piece of regulation that affects many schools that may often time be overlooked is a little thing called the “Red Flags Rule”.  This piece of regulation is applicable to all schools that participate in the Federal Perkins Loan program, and may apply to many institutions that offer an extension of credit to their students, e.g., granting institutional loans or allowing students to make installment payments. The definition that most likely is applicable to educational institutions that makes the “Red Flag Rules” pertinent is the part that refers to “any other account that the financial institution or creditor offers or maintains for which there is a reasonably foreseeable risk to customers or to the safety and soundness of the financial institution or creditor from identity theft, including financial, operational, compliance, reputation, or litigation risks.”  If an account is subject to a reasonably foreseeable risk to consumers (students) or to the institution from identity theft, it may be considered a “covered account” to which the “Red Flag Rules” apply.  Thus, it is possible that an educational instit

ED’s Dear Colleague Letters (DCLs) on IFAP

October 14, 2013
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ED's Dear Colleague Letters (DCLs) on IFAP - (listed by DCL category by date) DCL – GEN-13-17: July 1, 2013 – Requirement for distribution of voter registration forms Schools are reminded of the requirement to make a good faith effort to distribute voter registration forms to their students.  This requirement is applicable to schools in most states and the District of Columbia which are covered under the National Voter Registration Act (NVRA) of 1993.  That is, schools in states that require voter registration prior to Election Day or that do not allow for voter registration at the time of voting must comply with this requirement that is delineated in your Title IV Program Participation Agreement.  Currently, the only states exempt from this requirement are Idaho, Minnesota, New Hampshire, North Dakota, Wisconsin, and Wyoming.  Likewise, Puerto Rico, Guam, the Virgin Islands, and American Samoa are not covered by the NVRA and thus are not required to distribute the voter registration forms.  

ED’s Electronic Announcements (EAs) on IFAP: DEFAULT RATE INFORMATION

October 14, 2013
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DEFAULT RATE INFORMATION EA – August 20, 2013 – (Loans).  Default Rates for Cohort Years 2006-2010 The release of the four types of student loan default rates for the 2006-2010 five-year period is disclosed with this EA.  This information is useful for aid administrators to be aware of and more fully appreciate the impact of student loan defaults over time.  In addition to the familiar 2-year and 3-year cohort default rates (CDR), the budget lifetime default rate (BLDR) and the cumulative lifetime default rate (CLDR) are also described.  The BLDR is the projected percentage of loans (FFEL and DL Stafford Loans) originated in a given federal fiscal year that will default during a projected 20-year life of the loan cohort.  This percentage is what is used when the president makes annual federal budget projections.  The CLDR is the percentage of all FFEL/DL loan types (i.e., Stafford, PLUS, Grad PLUS, and consolidation loans) that enter repayment in a given federal fiscal year and that now have defaulted as of the end of the most recent fiscal year for which data is available.  This rate provides a performance tool to analyze the risk of defaults over

ED’s Electronic Announcements (EAs) on IFAP: GENERAL AND VARIED ANNOUNCEMENTS

October 14, 2013
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GENERAL AND VARIED ANNOUNCEMENTS EA – Posted July 9, 2013 – (General).  Volume 8 – The Direct Loan Program [2013 Blue Book] In this announcement ED has released the last portion of the 2013 Blue Book.  This volume consists of a thorough overview of the Direct Loan program.  It comprises much of the same information as is in the Federal Student Aid Handbook, but it also includes more comprehensive information that was previously contained in the former publication, The Direct Loan School Guide.  As such, it includes chapters on such operational aspects of awards and loan periods, and the Master Promissory Note (MPN), but also there are chapters on reconciliation and borrower care.  The Blue Book is somewhat to the Fiscal Office/Bursar’s Office what the Federal Student Aid Handbook is to Financial Aid Administrators.  However, because this Volume 8 of the Blue Book is a comprehensive resource on Direct Loans, financial aid administrators will likely find this to be a very useful resource for information related to Direct Loans.  Schools will do well

ED’s Electronic Announcements (EAs) on IFAP: GAINFUL EMPLOYMENT (GE)

October 14, 2013
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GAINFUL EMPLOYMENT (GE) EA – August 30, 2013 – (OPE Announcements).  Gainful Employment Electronic Announcement #44 – Posting of Session One materials related to Negotiated Rulemaking Committee In this announcement ED’s Office of Postsecondary Education (OPE) highlights the information provided to the Negotiated Rulemaking (Neg Reg) Committee in preparation for the meeting held September 9-11, 2013.  This information may be found via the OPE’s Higher Education Negotiated Rulemaking 2013-2014 – Gainful Employment Web page.  It includes the link to draft regulations on the topic of Gainful Employment (GE).  With the information is provided a comparison of the prior GE regulations and the proposed regulations and a high-level analysis of GE data.  The Neg Reg Committee is scheduled to meet again October 21-23, 2013.  

ED’s Electronic Announcements (EAs) on IFAP: FSA CONFERENCE

October 14, 2013
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FSA CONFERENCE EA – Posted July 9, 2013 – (General).  2013 FSA Training Conference for Financial Aid Professionals [Note:  Subsequent Updates to the 2013 FSA Training Conference were provided in EAs posted August 1, 2013 and September 30, 2013.] The dates and location of the 2013 FSA Conference are given with the statement that this event provides premiere financial aid training for the financial aid community.  The conference is December 3-6, 2013 at the Mandalay Bay Hotel in Las Vegas, NV.  A draft agenda and session descriptions are available on the 2013 FSA Conference Web site.  

ED’s Electronic Announcements (EAs) on IFAP: PROCESSING FOR 2014-2015

October 14, 2013
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EA – Posted September 19, 2013 – (Application Processing).  2014-2015 Expected Family Contribution (EFC) Formula Guide The annual update to the EFC Formula Guide is provided in this announcement.  The EFC Formula Guide gives all of the details of how a student’s EFC is calculated, including the charts that detail the allowances and taxation rates used in the formula.  It also contains worksheets so that schools may calculate an estimated EFC.  This EFC Formula Guide with its included worksheets can be used as an excellent training tool to help staff become aware of what goes in to the calculation of an EFC and what items may affect the its calculation.  

ED’s Electronic Announcements (EAs) on IFAP: PROCESSING FOR 2013-2014

October 14, 2013
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EA – Posted July 22, 2013 – (Application Processing).  2013-2014 ISIR Guide (July 2013 Update) An update to the 2013-2014 ISIR Guide was released with this announcement.  This particular update provides minor revisions to information in Appendices C and D.  The Guide is an extremely useful tool for financial aid administrators.  It provides all the details needed to interpret data contained on the ISIR, to include student application data, results of the NSLDS data match, reject codes and reasons, etc.  If you have a question about the ISIR, you will get the answer in the ISIR Guide. EA – Posted July 22, 2013 – (Application Processing).  2013-2014 SAR Comment Codes and Text Guide (July 2013 Update) In this update to the 2013-2014 SAR Comment Codes and Text Guide a correction to a deadline date was provided, and the addition of two new comment codes with defaulted loan contact information were provided.  This Guide is another extremely useful tool of which schools should be cognizant.   It includes a descr

ED’s Electronic Announcements (EAs) on IFAP: VERIFICATION FOR 2013-2014

October 14, 2013
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EA – Posted July 16, 2013 – (Verification).  Program Integrity Questions and Answers (Q&A) Website Update The Financial Aid community is alerted to the most recent update to the Program Integrity Q&As Web site.  This resource covers all of the main topics of the Program Integrity regulations published on October 29, 2010.  This particular update provides answers related to verification and clarifies some of the requirements related to verification Tracking Group V.  Schools are encouraged to review this Web site regularly for updated Q&As. EA – Posted July 16, 2013 – (Verification).  Spanish Statement of Educational Purpose for 2013-2014 In the announcement, ED provides the Statement of Educational Purpose in Spanish.  This version of the required text for the Statement was developed to address the concerns of schools that serve Spanish-speaking students.  Schools that choose to provide a Spanish version of the Statement of Educational Purpose mu