Category Archives: Did You Know

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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