It is time to commence the annual ritual, of recent years, for many postsecondary schools. That is, it is time for the annual update of institutions’ Gainful Employment (GE) Disclosure Templates, or the GEDT. The U.S. Department of Education requires all postsecondary institutions that have GE programs to disclose applicable information via the GEDT.
The 2018 GE Disclosure Template (GEDT)
ED announced the release of the 2018 GEDT on the Information for Financial Aid Professionals (IFAP) Web site via GE Electronic Announcement #110 on Friday, January 19, 2018. For a number of years, the GEDT had been made available in the
Constellation Software, Inc. Acquires Higher Education Software Provider FAME
We are excited to announce a change in the ownership of FAME. As of November 28, 2017 Constellation Software Inc. (“Constellation”) (TSX:CSU), its wholly-owned division Vela Operating Group (“Vela”) and its subsidiary Aquila Software (“Aquila”) have acquired Financial Aid Management for Education, Inc. (“FAME”). Constellation, a $2.1 billion company with over 12,000 employees, operates in 80 vertical markets internationally. They currently own software companies that provide K-12 SIS in Australia and England, and have acquired FAME as their entry into the North America educational market.
Constellation Software is an international provider of market-leading software and services to a number of industries, both in the public and private sectors. Their mission is to acquire, manage and build market-leading software businesses that develop specialized, mission-critical software solutions to address the specific needs of their particular industries.
FAME’s CEO, Bill Little, the entire Executive Team, managers, supervisors and emp
Did You Know?
The U.S. Department of Education (ED) has updated its guidance related to natural disasters. In the wake of devastating hurricanes and other disasters that have occurred recently (e.g., wildfires), institutions would be well-advised to become familiar with ED’s latest instructions.
This most recent direction is contained in Dear Colleague Letter GEN-17-08, published on August 29, 2017. The ten-page attachment to the DCL gives specific guidance applicable to individual programs, e.g., Campus-Based Aid programs, Direct Loans, etc., as well as information related to Return of Title IV Funds (R2T4) calculations, enrollment reporting, Federal Pell Grant reporting of disbursements, Fiscal Operations Report and Application to Participate (FISAP) deadline, and much more.
The information in GEN-17-08 supersedes and replaces all previous guidance from ED as it relates to natural disasters. This includes the direction provided in DCL GEN-10-16/FP-10-06 (guidance for helping Title IV participants affected by a major disaster), GEN-04-04 (general guidance for helping Title IV participants a
We, the People…
Knowing who we are on Constitution Day, and Every Day.
A question came to mind a number of years back. “Why do I believe what I believe?” And, perhaps just as importantly, “what do I believe?” As citizens of the United States of America, we have certain rights that are foundational in our beliefs and way of life, that make us distinct from any other country in the world. In our unique system of government, our Constitution guides the federal government in matters of interstate commerce, revenue generation for limited purposes (e.g., finance a war effort if necessary), and resolution of disputes between states. These limited powers of the federal government are fundamental to our
When Things Stay the Same…
The Gainful Employment Reporting Deadline Has Not Changed
This year has been a bit of a roller coaster ride as it relates to postsecondary institutions’ Gainful Employment (GE) programs. We have noticed more than once this year, that the U.S. Department of Education (ED) has granted slight reprieves for the deadlines to meet some GE requirements.
As those impacted are aware, institutions with any GE program that is in the zone or that is a failing program are allowed by law to submit an alternate earnings appeal if the use of alternate earnings would:
improve a zone program to passing, or
a failing program to either passing or zone.
Going ‘Round, and ‘Round
(or, the Latest Rendition of “Year-Round” Pell)
Those who have been around postsecondary education for the last eight years or so, likely recall the quickly implemented “year-round” provision of the Federal Pell Grant (Pell Grant) program in 2009-2010. That was the “first” edition. The original “year-round Pell” was created by the Higher Education Opportunity Act (HEOA) of 2008. It authorized schools to disburse up to two Pell Grants in a single award year to eligible Pell Grant students. The first edition of year-round Pell provided for implementation beginning in 2009-2010. Although it was short-lived due to the pr
Some things just naturally keep your interest. One item of which most college students are acutely aware, and which attracts “interest” each year, is the interest rate that will be applicable to loans taken out for the new award year. Although federal student loans taken out after July 1, 2013, have a fixed interest rate structure, loans borrowed in each award year have a different interest rate than the prior year. The loans to be borrowed in the award year of July 1, 2017, through June 30, 2018, are no exception. And, it is of note that interest is rising.
As those keen on this topic may recall, a new method of rate determination came about as a result of the Bipartisan Student Loan Certainty Act of 2013, which overhauled the Federal Direct Student Lo
It is important to be familiar with the following verification changes and be reminded of the requirements for subsequent ISIRs and conflicting information. FAME is enhancing our financial aid software products to assist schools with these requirements and schools will be notified of any changes in product release announcements.
Beginning with 2016–2017, a student may move from Verification Tracking Group V1, V4, or V6 to group V5 based on corrections made to their CPS record or on other information available to the U.S. Department of Education. If verification was already completed for the previous group, the student is only required to verify the V5 information that was not already verified. If verification was not completed for the previous group, the student only needs to verify the V5 information. No disbursements of Title IV aid may be made until the V5 verification is satisfactorily completed. If the applicant does not complete verification, the school is not liable for any Title IV aid it disbursed prior to receiving the group V5 ISIR. The student is liable for the full amount because without verification there is no ev
The U.S. Department of Education (ED) has released the final “Gainful Employment (GE) Debt-to-Earnings Rates for the for the 2015 Debt Measure Year.
Per ED’s January 6, 2017 Electronic Announcement, a “GE program passes the D/E rates measure if:
its annual earnings rate is less than or equal to 8 percent or
its discretionary income rate is less than or equal to 20 percent.
A GE program fails the D/E rates measure if:
its annual earnings rate is greater than 12 percent, and
its discretionary income rate is greater than 30 percent.
Also, a discretionary income rate will be considered failing if its denominator is negative or zero, and an annual earnings rate will be considered failing if its denominator is zero.
A GE program with D/E rates that are neither passing nor failing is in the zone.
If a GE program fails or is in the zone, a tr
Happy New Year! As if one did not know, it is the start of a new calendar year! The beginning of a new year has come to be known, for postsecondary education institutions with Gainful Employment (GE) programs, as the time for updating the U.S. Department of Education’s (ED), Gainful Employment Disclosure Template (GEDT). But, if you are waiting for the new year’s GEDT as the sign of the new year’s start, you may be a little late in realizing the new year has already begun!
Delayed Release of GE Disclosure Template
Currently, ED anticipates the release of the 2017 GE Disclosure Template in the latter part of January 2017. The template has typically been made available in the fall of each year so that schools could ensure they had their GE Disclosure Information posted and distributed by January 31 of each year following the most recently completed award year. This year, 2017, ED does not yet have the GEDT available for schools to use to update their GE Disclosure Information for the award year ending June 30, 2016. The main reason stated for the delay in availability this year is due to extensive revisions to the GEDT that ar
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tracks the entire student life-cycle from admissions to student accounts, to financial
aid packaging, placement tracking and reporting. With the addition of Enrollment
Resources’ industry-leading Virtual Admissions Adviser (VAA), the student life-cycle
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It is that time when millions of students are finalizing plans and preparations to attend the postsecondary institution of their choice during 2016-2017.
Each year the majority of those students submit the Free Application for Federal Student Aid (FAFSA). With more frequency, the FAFSA is typically completed as the FAFSA on the Web (FOTW). This expedites the opportunity for their FAFSA results to be processed more quickly. That is, unless they are selected for the process called “verification.”
Verification is not anything new. It is the process of making sure that the applicant for Federal Student Aid “got it right” on their FAFSA, so to speak. The whole verification concept began with its predecessor back in the 1980s. The, at the time, recently created U.S. Department of Education (ED), promulgated the idea of “validation.” That validation method had a primary concentration on the accuracy of data in applications for Federal Pell Grants. But, we must remember that correctness of data has always been a preeminent focus of the Higher Education Act (HEA) related to students’ applications. Even before validation and verification, the HEA required
Almost twenty years ago, a movie that is classified across multiple genres was released: Deep Impact. In this disaster drama, people learn of the impending impact of a comet on earth. Efforts are made to negate the potential for impact from the point of discovery of the comet and its trajectory, until the comet’s projected arrival about a year later. Suspense mounts, but there is no initial panic, because, although it would cause devastation, there was still time, and there were options to explore. While it would create a deep impact, it was not immediate. Thus, there was less alarm to the average person.
In our professional world, schools must remain vigilant, as well, to what is barreling through the financial aid skies of legislation, regulation, authorization, and guidance. One more recent
The 2016-17 Federal Student Aid Handbook, Volume 5, The Return of Title IV Funds, pages 5-84 and 5-85 clarifies the amount of Title IV funds to include in the R2T4 calculation for clock hour and non-term credit hour programs with overlapping loan periods. This latest guidance requires the institution, when the loan period (LP) does not correspond with the payment period as defined in 34 CFR 668.4 and used in the R2T4 calculation, to prorate Title IV funds to determine the amount that should be attributed to the payment period from which the student withdrew.
The student attended School A and was disbursed a $1,750 subsidized (sub) loan and $3,000 unsubsidized (unsub) loan. The academic year at School A ends on 10/09/15.
The student starts School B on 8/24/15 in a 1200 clock-hour program with a 900 hour academic year, and is awarded the remaining $1,750 sub and $3,000 unsub for the 1st short LP of 8/24/15-10/09/15 due to completing the academic year at School A.
The 2nd loan is processed for a 900 hour academic year with a LP of 10/10/15 – 3/11/16 for a $1,750 sub loan and a $3,000 unsub loan.
Title IV payment period 1 is
Attendance Monitoring and Charges for Absences or Being Tardy
FAME recently completed its 2016 FAME Annual Financial Aid and Management Conference. A question arose shortly before the conference for which guidance had been received from the U.S. Department of Education (ED) related to the appropriate response.
The Question about Fees or Fines for Absences or Being Tardy
A question arose inquiring whether a school could assess fees or fines to a student for being late to class or for being absent from class, and have Title IV funds cover those fines or fees. In our dialog with the U.S. Department of Education (ED), their initial response was that fees or fines a school assesses a student that are not required of all students in the program, would be considered non-institutional charges, and therefore, not included in a Return to Title IV Funds (R2T4) calculation, similar to library fines or parking fines, etc. As with library or parking fines, ED indicated that, with the appropriate written student authorization, Title IV funds could be utilized to pay such charges as a fine or fee for being t
Q1: What is the cost of attendance (COA) for student financial aid purposes?
A1: The COA is an estimate of the expenses a student may be expected to incur in an award year while pursuing their academic program. It is the underpinning upon which the process of financial aid need determination begins for a student. The COA includes both the direct and indirect costs of attending school. The direct costs are those charged directly by the school, such as tuition and fees. The indirect costs are the other basic necessary expenses a student experiences in order to attend and complete his or her education.
Q2: Why does the COA budget have to include things other than the costs for tuition, fees, books and supplies?
A2: The quick answer is that the components of the COA are dictated in the Higher Education Act (HEA), as amended. The answer in more practical terms, upon which the HEA dictates are based, is that most students would not be able to attend school if the only aid they received was to cover direct tuition and fee costs. In many instances a student is not able to work, or not as many hours, while
Periodically we are asked questions regarding an interpretation of the laws, regulations, or policies related to the administration of the Title IV Federal Student Aid (FSA) Programs. In this series we provide questions, and the related answers, generated by our interaction with clients and the U.S. Department of Education (ED).
Q1: We are a school that teaches in quarters. The program has three 10-week terms in the program with new students starting each term. Can we also have a version of the program that has a 5-week term, two 10-week terms, and a 5-week term on every other “start?”
A1: The latest guidance from ED indicates that schools have the ability to create different versions of a program with different calendars (even if both are in the day). But, the school really needs to treat these programs as two separate programs (e.g., in regard to coding, cohorts, no crossing over between programs, consumer information, and if a student switches programs they must be dropped and re-enrolled, etc.). Every student within a particular program would follow the same academic calendar; otherwise, you would have one program taught in differ
The Program Integrity Q&A Website has been recently updated in response to questions about acceptable documentation for foreign high school diplomas. As the New Year begins, we remind you to review your current policies and procedures and make adjustments as needed. The following are the two questions with answers as posted by the Office of Postsecondary Education in regards to foreign high school diplomas (http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/hsdiploma.html#fhd).
Foreign High School Diploma (FHD)
FHD-Q1. Is a high school diploma from a foreign country recognized as a valid diploma?
FHD-A1. Yes, if the institution determines whether the foreign secondary school credentials are evidence of completing the equivalent of a secondary education in the United States. Institutions that do not have the expertise to make that determination themselves may use a foreign diploma evaluation service. [Guidance issued 1/24/2014]
FHD-Q2. What documentation may an institution accept to verify high school completion status for an applicant who indicates that he or
Action: All currently participating schools with GE programs must submit to ED by no later than December 31, 2015, a Transitional Certification of their GE Programs’ accreditation approval and State approval. See the June 11, 2015 Electronic Announcement for details.
Action: All schools must have their GE disclosure information updated utilizing 2014-2015 data by January 31, 2016. Schools must use the updated GE disclosure template (GEDT). This template can be located online at http://ope.ed.gov/GainfulEmployment/.
Action: IRS requires that you have all 1098-T generated and postmarked by January 31, 2016.
Action: Waiver Request for Underuse of 2016-2017 Funds to ED are due by February 8th, 2016.
Action: Collection opens for Winter IPEDS December 9, 2015 and will be closed for Keyholders February 10, 2016 and for Coordinators February 24, 2016. The components included in this submission are: Student Financial Aid; Graduation Rates; 200% Graduation Rates, Admission; and Outcome Measures. The preliminary data will be available Mid-September.
Because the goodwill of those we serve is the foundation of our success, it’s a real pleasure at this holiday time to say thank you, as we wish you a year of happiness and prosperity
FAME’s Office will be closed for our Annual Employee Holiday Party at 12:Noon EST on Friday, December 18, 2015 and will resume normal office hours on Monday, December 21, 2015.
FAME will also be closed on December 24th, December 25th and January 1st to celebrate the holidays with our families.
It goes without saying that most institutions of higher education in the United States today rely significantly on the ability of their students to receive funding through the U.S. Department of Education’s (ED) Federal Student Aid programs. These Federal Student Aid (FSA) programs are authorized through the section of law commonly referred to as Title IV of the Higher Education Act (HEA), as amended. But, these institutions are not granted, via their students’ eligibility, such resources carte blanche. As the old saying goes, “He who has the gold makes the rules.” Not surprisingly, ED requires institutions to exercise care in their fiduciary responsibilities of the more than $128 billion dollars being dispensed to almost 12 million students.
Time stands still for no one! It seems as though reporting of gainful employment (GE) data to the U.S. Department of Education (ED) was just completed—with hopes that everything was reported accurately. And, here we are again, talking about GE! All of that information that you have worked with in the last few months since the first “new” GE reporting in July, now comes into play again. With that being the case, it is no time to let one’s guard down. Rather it is time to ensure you have gained the upper hand on the upcoming GE requirements. There are at least three key items to keep in mind in the coming months regarding GE.
GE Transitional Certifications Due By December 31, 2015
This topic has been discussed in various venues since the advent of “GE 2.0.” But, part of the regulatory requirements pertaining to GE is that schools must ensure they have certified that all of their Title IV-eligible gainful employme
When students are interested in attending school, naturally they look for one that offers academic programs that prepare them for their career ambitions. But, once they have found one that offers the academic program they are interested in, there is always a question that soon follows. That question is: “How much does it cost?” The answer given in response to that question may, at times, be less than clear. (Effective as of January 1, 2016, more specificity will be required in data provided by FAME clients. Continue reading for more details.)
Naturally, a student is interested in the direct costs applicable to the educational program; things such as tuition, required fees, typical amounts charged for required textbooks, and so on. But, the reality is that the various costs a student incurs as they attend school include a broader scope of expenses than just those charged by the institution directly. In order for a student to at
The U.S. Department of Education (ED) is distributing email notifications to schools that may be non-compliant with GE Reporting. The letters have indicated severe consequences such as suspending recertification, approval of new programs or additional locations applications, and initiating an administrative action against the institution. Such administrative action may include fines, limitations, suspension or termination of eligibility to participate in the Title IV, HEA programs.
Institutions must report student details or the acceptable reason why reporting is not required for every program included on the NSLDS GE Program Tracker List for each award year. It is important that all students who received Title IV aid for a program have been reported and that the information is complete and accurate. If an acceptable reason for not reporting student data has been indicated, then you must be able to document why reporting was not required.
To confirm if your institution is in compliance, you can review the NSLD
GAINFUL EMPLOYMENT (GE)
EA – Posted September 4, 2015 – (Gainful Employment). Gainful Employment Electronic Announcement #60 – GE Reporting and Resolving Incorrect Credential Level Data in NSLDS and in COD
Schools are alerted to the fact that ED has sent out warning letters to schools that reported at least one loan origination record for 2014-2015 in COD where the record indicated the student was enrolled in a GE program, but the school did not submit GE data to NSLDS by the July 31, 2015, reporting deadline. This announcement gives schools who received such a warning letter instructions on how to utilize the NSLDS GE Program Tracking List to resolve any errors in the COD System. (For information on the GE Program Tracking functionality, see also Gainful Employment Electronic Announcement #59, dated August 20, 2015.) If a school received one of these warning letters about errors, they must not delay in making the
The passage of The Consolidated and Further Continuing Appropriations Act of 2015 (Pub. L. 113-235) reinstituted the opportunity for a student’s Title IV eligibility through ability to benefit (ATB) alternatives. But, this ATB alternative opportunity is only available if such a student is enrolled in an "eligible career pathway program." The U.S. Department of Education (ED) has provided some guidance in regard to eligible career pathway programs, but it has been quite limited in scope. As a result, numerous schools have inquired about what they consider to be an eligible career pathway program (CPP). We appreciate our clients' interest in the perceived opportunity they anticipate to be available via the CPPs. Yet, the legislation allowing for CPPs has not developed to be the panacea desired. There has been limited and, apparently, somewhat contradictory information from ED, as we understand it. The result is that a number of concerns have surfaced. As it turns out, venturing into the avenue of CPPs may actually be like a trek down the Yellow Brick Road in search of Oz, fraught with obstacles and peril. Unless and until ED provides more definitive guida
The world has become high tech. It is hard to imagine a world without computers and technology. The “imaginary” world of the1960s television series, Star Trek, utilized technological capabilities that truly seemed to be science fiction. Yet, today many devices employed in the daily activities of the crew of the Enterprise are not seen as futuristic. (Perhaps the “transporter” and “food replicators” would be exceptions!)
Technology advances have indeed increased our capabilities. But, along with these advancements have come prospects for violations of personally identifiable information (PII). Such risks lead to the occasions for identity theft on a personal level. Students understandably ask if their PII is safe. Postsecondary institutions are a source that provides a trove of data for such thievery through the information they collect. An article1 in December 2014 reported there we
The long and winding road has ended on 9/30/15. This was the end of a one year extension for the Federal Perkins Loan Program. According to the latest guidance received from the U. S. Department of Education (ED) (Electronic Announcement dated 10/2/15) Congress did not extend the Federal Perkins Loan Program. As a result schools can longer originate Perkins loans to new borrowers after 9/30/15. However, there are some exceptions to the rule as indicated in Dear Colleague Letter GEN-15-03.
If a school makes a first disbursement of a Perkins loan for the 2015-2016 award year prior to 10/1/15, the school can make any remaining disbursements for that 2015-2016 loan after 9/30/15.
There is also a “grandfathering” provision for 2014-2015 or earlier Perkins loans as long as all of the following conditions are met:
One Perkins loan disbursement has to have been made to a student on or before 6/30/15.
The student is enrolled at the same institution where the last Perkins loan disbursement was received.
The student i
Action: The new Violence Against Women Act (VAWA) regulations were effective as of July 1, 2015 and are applicable to the Annual Campus Safety and Security Report to be submitted to ED by October 15, 2015.
Action: September 30, 2015, was the last date on which a new borrower could be disbursed a first disbursement of a Federal Perkins Loan. (Effective September 30, 2015, the Perkins Loan program has expired.) See Dear Colleague Letter GEN-15-03.
Action: All new Federal Direct Loans first disbursed on or after October 1, 2015, must have the new loan origination fee percentages used when originating the loan. The new percentage is 1.068 percent for Subsidized and Unsubsidized Direct Loans, and 4.272 percent for PLUS Direct Loans. (Remember, also, the reduction in the IASG awards by 6.8% for awards first disbursed on or after October 1, 2015, as well as a similar 6.8% reduction for TEACH Grants first disbursed on or after October 1, 2015.)
Action: ED’s annual Federal Student Aid Confere
Our early days as a nation endured a bumpy start. As the original states were floundering in the New World, the need to live up to the name, “United States of America,” was beginning to become evident. There was a need for unity. Each of the states had their own interests they wanted to satisfy, but the confederation of independent states, established as a “league of friendship,” was not organized to fully meet those needs. The Articles of Confederation, adopted in 1781, lacked in the areas of authority and ability to govern the states in matters of commerce, issues of revenue, and resolution of disputes between states. Those “simple” matters—interstate commerce, ab
The passage of The Consolidated and Further Continuing Appropriations Act of 2015 (Pub. L. 113-235) reinstituted the opportunity for a student’s Title IV eligibility through ability to benefit (ATB) alternatives. But, this ATB alternative opportunity is only available if such a student is enrolled in an "eligible career pathway program." The U.S. Department of Education (ED) has provided some guidance in regard to eligible career pathway programs in Dear Colleague Letter GEN-15-09, but it has been quite limited in scope. As such, numerous clients have inquired about what they consider to be an eligible career pathway programs (CPP). We appreciate our clients' interest in the perceived opportunity they anticipate to be available via the CPPs. Yet, the legislation allowing for CPPs is not as broad as would be hoped. And, there has been limited and,
Sailing on the ocean is a wonderful thing. There is the vast expanse of the horizon that is in view, and the gentle rocking of the waves that calm the soul. But, it is a totally different picture when a major weather event comes on scene. No longer is the view as expansive or the waves as gentle. Clouds block the horizon and the surface gets rough and unsettling. That is the way it sometimes happens in financial aid. Things are going smoothly as you think you have all things appropriately in view. You have completed the first round of gainful employment (GE) reporting, and you are enjoying the gentle scene until the next round of reporting is due. Then, all of a sudden, another GE gale arrives and you wonder if you will be sailing on the Sea of Confusion or Consternation instead of the Sea of Clarity and Calm. Just when you thought you had it all figured out and put to rest for a while…GE comes to the fore once more!
The latest GE information presented by the U.S. Department of Education (ED) appeared as Gainful Employment Announcement #58 on
They said it would happen. And, it is almost here! The deadline for the first round of Gainful Employment (GE) reporting is July 31, 2015, based upon the requirements of the October 31, 2014, final regulations. This is a date you do not want to miss!
URGENCY and CONSEQUENCES STRESSED
FAME staff attended a recent conference at which U.S. Department of Education (ED) staff spoke on the topic of GE reporting. It was clearly stated that schools must have completed their GE reporting by July 31, 2015. Failure to do so will have consequences. Two things will happen if a school misses the July 31, 2015, reporting deadline.
ED will send a letter by e-mail to the president of each institution that has GE programs. The letter will list each of the GE programs for which the institution did not report in a timely manner. These le
Student loan debt is the hot topic in the news media in recent months. Most of the articles touching on this subject focus on the amounts students borrow, with an indication that such borrowing is out of control. Indeed, amounts that students borrow during their academic career are rising1. Student loan indebtedness is something about which to be cautious (as is any type of debt!). But, beyond the increase in student loan debt is a perhaps more subtle set of concerns. These less evident issues relate to the student debt topic from at least two perspectives. They create the loan counseling conundrums.
Traditionally, student financial aid professionals have touted caution when providing student loan counseling. Yet, advice toward caution has often been softened or negated by the offsetting promotions made by either the same financial aid professionals, admissions counselors, or other interested parties. The counteracting assertions made are that student loan debt is “good debt” because it is obtained with the goal of investing in the student’s future increased earning power. Thus, students face the first loan counseling con
Those who dance understand that there are a number of specific aspects in being a great dancer. One is confidence in knowing what steps are appropriate for the music being played. This characteristic is also important when considering the gainful employment (GE) regulations. It cannot be considered a truism that those who have responsibility for GE compliance on their campus must be great dancers, or that great dancers would make exceptional employees to work with the GE regulations. However, the characteristic noted about dancers is also important for those working to comply with the GE regulations.
When working with GE, it is important to be confident in the appropriate steps or requirements. In the GE Dance, the proper steps include both disclosure and reporting requirements as put forth by the US Department of Education (ED). While the regulations have been out for a while now, and a number of efforts have been made to distinguish the difference between the requirements related to disclosure and those related to reporting, there still seems to be a bit of stumbling in the dance. People remain uncertain of what moves constitute the correct steps. In choreographi
Swimming in murky waters is generally not what one likes to experience. Much preferred for swimming is the crystal clear water in a newly cleaned pool, a mountain spring-fed lake, or in the waters near a coral reef off a south Pacific island. Murky waters leave much to the imagination as to what may be just beneath the surface, with none too pleasant outcomes envisioned. Recent news accounts of several shark attacks in shallow waters near the beaches have accentuated the need to be able to see what is in the water around you. In similar fashion, murkiness seems to be the environment in which schools find themselves when viewing the latest guidance related to the State authorization regulations.
The Murky Waters of State Authorization
State authorization has been a requirement for schools to be considered eligible to participate in Title IV Federal Student Aid programs for years. But, in 2010, in what has come to be called the Program Integrity Regulations of October 29, 20101, the U.S. Department of Education (ED) gave more specificity to what the minimum standards consis
Join our webinar to see how FAME’s predictive analytic tools coupled with your student data can provide the information you need to increase student retention and reduce loan defaults. Learn how Predictive Analytics identifies the key factors that affect students’ performance and completion rates. See how using your historical student data, coupled with the science behind the predictive analytics tools developed by Voyant Analytics and integrated with FAME’s SIS products, can accurately predict 9 out of 10 potential dropouts, saving you hundreds of thousands in lost tuition.
Learn about a dynamic program that provides early assessment tools to identify learning characteristics that will assist in ensuring your students meet their academic goals and have a successful outcome, increasing your students’ academic achievements, completion rates and placement rates. Join us to learn about these
The news reports are out1. The US Internal Revenue Service (IRS) was hacked! This is of specific interest to schools participating in the Title IV Federal Student Aid (FSA) programs. Students and parents who apply for FSA and are selected for “verification” in the application process have potential for being directly impacted due to the hack of the IRS system.
The IRS announced2 on Tuesday, May 26, 2015, that its Get Transcript Web site was hacked between February and mid-May of 2015. It is important to note, however, that the IRS’ main database system was not accessed. Only the Get Transcript system, which is operated separately from the main IRS computer system, was compromised in this attack. The hackers were successful in approximately 100,000 of 200,000 attempts at gaining unauthorized access. The IRS has indicated that it is notifying those tax filers whose information was hacked.
The response to the one word question in the title of this article resounds with a definite, “Yes!” That is especially the response for student loan borrowers this coming award year. The much anticipated announcement of the new interest rates for loans first disbursed on or after July 1, 2015, has been made. And, the notice is favorable for borrowers who will be obtaining one of the loans available through the Federal Direct Student Loan Programs. Interest rates have nudged downward!
As a reminder, the Bipartisan Student Loan Certainty Act of 2013 overhauled the Direct Loan Programs’ interest rate structure. The result of that legislation is that interest rates are now determined based upon the high yield of the last auction of the 10-year Treasury notes held prior to June 1 each year. That yield becomes the “index” in the interest rate formula. To the index is added a margin, or what is called an “add on”. The rat
Those in the world of financial aid are always wondering what our friendly Fed had to say. So, we are going to tell you about what the Fed SAID. OK. Yes, the title of this Regulatory Bulletin is a bit of a play on words and acronyms. But, it is to focus on the importance of what the Feds (i.e., the US Department of Education or, ED) have said is occurring as of May 10, 2015. That is, the long-time use of the Federal Student Aid PIN is going by the wayside, just like those old car headlight dimmer switches you have seen pictures of on one of those Facebook, “who remembers what this is?” postings. But, the FSA PIN was a necessity for students applying for Federal Student Aid (FSA)! What happens to that process now? As of Sunday, May 10, 2015, all students who wish to use login access for Federal Student Aid Web sites will need to utilize a new Federal Student Aid ID or, as it will be known in shorthand: FSA ID.
The change to
PLUS Loans have been in the news in the last few years. Specifically, the topic of interest has been the impact of an adverse credit history on PLUS Loan applicants. For nearly twenty years, the PLUS Loan program had no noteworthy issues. However, in 2011 the U.S. Department of Education (ED) modified the criteria to include unpaid collection accounts and charge-offs in their review of PLUS applicants’ credit history. This was to be more closely in agreement with then current regulations. This change was not officially announced before implementation, but rather felt by applicants and schools. Since that time, after much public opinion was expressed, and some intermediary proactive notifications by ED to applicants who may gain eligibility after a credit history reconsideration, a slow move to change the regulations related to adverse credit meandered through the regulatory process. The Federal Direct PLUS Loan final regulations were published on October 23, 2014.
The final regulations were scheduled to be operational as of July 1, 2015. But, ED stated in the preamble to the rules that it may implement a
As spring has just begun, there are a number of upcoming dates to keep in mind. In this Regulatory Bulletin reminder, we provide a brief list of important events and dates that schools need to have on their calendar. It is important to plan your schedule of activities accordingly.
March 29, 2015 – The new PLUS Loan regulations regarding adverse credit standards go into effect. These regulations were published in the Federal Register on October 23, 2014 and posted on IFAP. The published effective date for the regulations was July 1, 2015. However, in a Federal Register notice on January 14, 2015, ED announced that the regulations would be implemented on March 29, 2015. An Electronic Announcement was posted on IFAP on January 27, 2015 emphasizing this date change. Schools must implement the new regulatory standards pertaining to adverse credi
We all likely know people who insist upon being the one who is right. While such individuals may come across as a bit difficult to interact with, the reality is that we all do want to be right. And, in our work-a-day world, it is important that we get it right in the critical areas of our profession. We work in a $150 billion dollar industry as financial aid professionals,1 so there is ample need for not missing the mark in operational accuracy and effectiveness. In this intermittent series on getting it right, we are highlighting some of the key areas in which it is critical to employ best practices in order to accomplish this goal. The components covered in this series are: the right people, the right service, and the right exposure. In this segment of our series we will highl
The statement in the title of this edition of the Regulatory Bulletin is often attributed to the fictional character of Sherlock Holmes of Sir Arthur Conan Doyle’s famous works. However, that exact phrase never appeared in his works. Nevertheless, it has become associated with the character of Sherlock Holmes who was known for his amazing detective skills, enhanced by his deductive reasoning capabilities. With the ongoing popularity of the character of Holmes, as evidenced by a current television program based upon the original works’ premise, there is an apparent interest in the concept of applying detective skills. In the world of financial aid, it is not uncommon that financial aid directors are charged with the responsibility to play detective. Now is one of those times. It is time to pull out the magnifying glass (or other symbolic tools of the trade) and begin investigating the details of your newly released draft Cohort Default Rates (CDR). Yes, close inspection of the underlying data in this most recent draft 3-year CDR—the FY 2012 edition—is critical. The accuracy of data in this draft rate is important to your institution’s continued parti
It does not take much effort to think of several iconic phrases to open this article, borrowing from the entertainment arena. How about, “I’m baaaack!”? Or, maybe, “Second verse, same as the first!”? (Well, pretty much….) Yes, it is back. And, yes, it is pretty much the same as before…in many ways. Perhaps a better reference analogy would have been horror movies as this set of regulations was published on October 31, 2014. But, in case electricity and mail have disappeared from your school in the last few months and years, let us review this new regulatory tome so that you do not miss any of the excitement. Then, you can judge whether the sequel is better than the original.
Gainful Employment Background
The more recent rendition of the gainful employment (GE) moniker surfaced in 2010. As those who have been involved with the financial aid industry since then or before will recall, the topic made the news. New regulations presented a major shift in the accountab
Recently, we began a series on getting it right. We talked about the potential impact on operations and effectiveness when we miss the mark 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
With a title such as is given to this article, one would think that this discussion may contain information on workplace relationships 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
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.
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 school—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
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
For those who subscribe to Maslow’s Hierarchy of Needs, the need for safety and security is foundational, just after the basic physiological 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
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 adds 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
Change 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?
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 changes 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
The 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
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 only 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
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, a 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
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
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 what 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! 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 higher 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
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
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.
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
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
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
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 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
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
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 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
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
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
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, 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.
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
The U.S. Department of Education (ED) has made enhancements to the Free Application for Federal Student Aid (FAFSA) on the Web related to the IRS Data Retrieval Tool (DRT) process. These most recent changes made in September, 2013 include the ability of the IRS DRT to import to the FAFSA the total “Income Earned from Work” for those with marital statuses of single, divorced, separated, or widowed. When the IRS DRT is used and the total “Income Earned from Work” field is updated, it results in the student and/or parent, as applicable, “Income Earned from Work” fields being updated to display dynamic text that indicates the value in that field was transferred from IRS. Additionally, if the student or parent modifies the field values, a message will display to indicate they changed them. Noteworthy is the fact that if the student or parent modifies the data in the “Income Earned from Work” field, it does not change the IRS Request Flag values. That is, a change in the amount of income earned from work does not affect the historic criteria for IRS Request Flags, which is based upon the original or amended adjusted gross income (AGI) or taxes paid figures, not income ear
The Department of Education (ED) has released the latest editions of both, the 2-year Cohort Default Rates (CDR) and the 3-year CDR. As is the case annually when there are both 2- and 3-year rates calculated, the 2-year CDRs were released one week before the 3-year CDRs. The 2-year CDR rates were released on September 16, 2013. The 3-year CDR rates were released on September 23, 2013.
Since the CDR rates are crucial to a school’s continued participation in Title IV Federal Student Aid programs, it is vitally important that each institution review its CDR packages that ED distributed, and specifically the data used to calculate the rates to ensure it is accurate. These CDR notification packages were distributed via the Student Aid Internet Gateway (SAIG). The information was sent to the SAIG mailbox for the destination point that the school had designated for that purpose. The information was sent only to those schools enrolled in the Electronic Cohort Default Rate (eCDR) process. Therefore, if a school has not signed up for the eCDR process, the information was not distributed to the school. If an institution did not sign up for eCDR, it is incumbent upon the school to acces
Important U.S. Department of Education (ED) deadline dates are approaching that may need your action. With the soon arriving end of the Federal fiscal year, a number of dates of which schools need to be aware are critical and require schools to take the necessary action applicable to their operations. Some of these dates are applicable to closing out the 2012-2013 award year, while others will impact 2014-2015 funding. Significant deadlines are highlighted in the following information.
September 21, 2013 – This is the deadline by which corrections to a SAR or ISIR must be submitted for the 2012-2013 award year. This date will likely affect few students and schools currently, but may impact some.
September 28, 2013 – This is the deadline by which all applicable valid 2012-2013 SARs or ISIRs must be received by the institution. Notwithstanding, the valid SAR/ISIR must have been submitted not later than the student’s last date of attendance in the award year (unless the student meets the conditions for a late disbursement).
September 28, 2013 – All verification documents for the
Did You Know? ED is sending out more money. That is, the Department of Education is sending out additional disbursements of Pell Grant Administrative Cost Allowances (ACA).
ED began sending subsequent disbursements of the ACA for the 2011-12 and 2012-2013 award years on August 26, 2013. These disbursements are the third and final ACA disbursement for 2011-2012 and the second ACA disbursement for the 2012-2013 award year. The amount of the total ACA disbursements for an award year is based upon the number of unduplicated Federal Pell Grant recipients an institution paid during the applicable award year. The amount authorized by Federal regulation for the Federal Pell Grant ACA is $5.00 per unduplicated Pell Grant recipient in an award year. Thus, an institution may determine how much total ACA it should receive in an award year by multiplying the total number of Pell Grant recipients by $5.00. The amount of $5 per Pell Grant recipient that is paid to the school is to be used to offset the costs of administering the Title IV programs. Specifically, the costs that may be offset are those associated with administering the Federal Pell
All schools participating in the Federal Pell Grant (Pell Grant) and Federal Direct Loan (DL) programs are required to submit disbursement and payment adjustments to the Common Origination and Disbursement (COD) system within 15 calendar days of such transactions taking place. Prior to April 1, 2013, schools had 30 days within which to report disbursements or adjustments to previously made disbursements. However, effective for all disbursements and payment adjustment transactions on or after April 1, 2013 schools must submit such transaction records within 15 calendar days of the transaction taking place. These changes in the time frames for reporting the disbursement transactions are critical to help avoid potential institutional and student liabilities for overpayments due to such factors as exceeding Pell Grant Lifetime Eligibility Used (LEU) limits or impacting students’ eligibility for Subsidized DLs due to the 150% of program length limit. ED has requested that schools not wait until the end of the 15 day period but rather report the transaction records to COD as quickly as possible. ED has also indicated that failure to report required changes within the appropriate timefr
ED began a process of notifying certain PLUS Loan applicants of their opportunity to be reconsidered for a loan. Those being notified were previously denied a PLUS Loan based upon their credit check that showed an adverse credit history, but are individuals whom ED believes will likely be approved if they request reconsideration of their original credit check. The first notification of such PLUS Loan applicants began on April 21, 2013. The individuals being informed of this opportunity are being notified by e-mail, unless ED does not have a valid e-mail address for them. In such cases, the individual is sent a letter by traditional mail. Applicants that are notified are instructed to contact ED’s Student Loan Support Center at 1-800-557-7394 for more information. If the applicant requests reconsideration in a timely manner, it may alleviate the need for an additional credit check. It is important that the PLUS Loan applicant is the one to contact the Student Loan Support Center and not the school or the student on behalf of the parent applicant. While ED does not guarantee that those who are reconsidered for the P
September 17th of each year is designated as Constitution Day.As required by the Consolidated Appropriations Act, 2005 (Pub. L. 108–447, signed into law on December 8, 2004), schools that receive Federal funding in a Federal fiscal year (e.g., Title IV Federal Student Aid) are required to “hold an educational program on the United States Constitution on September 17 of such year for the students served by the educational institution.’’ The regulation pertaining to this requirement is in the Federal Register dated May 24, 2005.
While the U.S. Department of Education (ED) does not stipulate what the requirements of such a program on Constitution Day should include, it does offer some resources in the Federal Register. Some of these may include such sources as the Library of Congress’ American Memory Web page, as well as the National Arch
Extended foster care payments are generally not reported on the Free Application for Federal Student Aid (FAFSA). Likewise, the payments are not included as Estimated Financial Assistance (EFA).
Extended foster care payments are payments made directly to students who have not yet reached the age of 21. This extension of foster care payments beyond the traditional foster care payments made to foster parents, group homes, etc. while a child is below the age of 18 was enacted into law in 2008 with the Fostering Connections to Success and Increasing Adoptions Act of 2008 (Public Law 11—351). This law amended Title IV – E of the Social Security Act. The law change allows individuals receiving the benefit of foster care to continue receiving such benefit beyond age 18 up to the age of 21. However, the individual does have to meet certain criteria such as being either enrolled in high school, postsecondary education or vocational school, a job training program, or working at least 80 hours per month. Each State may have additional criteria applicable to this provision.
The distinguishing factor of whether the extended foster care payments are included on the FAFSA or not is whet
As reported in this week's FAME Inside Report, and prior August 1 FAME "Did You Know?," Congress had finally reached agreement on the student loan interest rate debate. Congress passed the Senate-amended version of the House Bill, HR 1911, on July 31 which creates a new interest rate structure that lowers all 2013-2014 undergraduate Direct Loans to 3.86%. All that remained was for President Obama to sign the bill.
Friday, August 9, 2013, the president signed the Senate-amended HR1911 (now known as the Bipartisan Student Loan Certainty Act) into law. The new student loan interest rate structure discussed previously in the FAME Inside Report and "Did You Know?" is now in effect. (No
This news flash is making the headlines across the country. After months of political back and forth, both houses of Congress have come to a resolution on the student loan interest rate debate. Late yesterday the House passed the Senate-amended version of House Bill, HR 1911. It now awaits the president's signature, which is anticipated to happen without delay. The new interest rate structure will be applied retroactively to all Federal Direct Loans with a first disbursement on or after July 1, 2013.
The current version of the bill awaiting signature of the president puts the interest rate structure to be set using the following formulas:
Undergraduate Stafford loans (subsidized and unsubsidized): 10-year Treasury Note plus 2.05 percent, capped at 8.25 percent.
Graduate Stafford loans: 10-year Treasury Note plus 3.6 percent, capped at 9.5 percent
PLUS loans (graduate and parent): 10-year Treasury Note plus 4.6 percent, capped at 10.5 percent.
There have been recent additions to two separate ED publications. The first is a new volume, “The Direct Loan Program”, being added to the Blue Book. This release is volume 8 of the newly updated Blue Book (2013 edition). As noted in FAME’s April 2013 Inside Report, the 2013 volumes released this year provide the first updates to the Blue Book since 2005. Although typically the Blue Book is geared to those individuals responsible for managing, accounting for, and reporting on the use of Title IV funds at an institution (e.g. fiscal office personnel), this volume will be of interest to anyone wanting to have a more comprehensive knowledge of the Direct Loan (DL) program. This volume covers the whole gamut of the DL program, from loan limits, the Master Promissory Note, and required counseling, to disbursements and reconciliation. It gives ample opportunity in the material covered to either learn of the DL program initially, or to receive a refresher on items that a particular staff member may not work with on a daily basis, but would like to know more about.
The Website has Q&As applicable to each of the 10 major components of the Program Integrity regulations. The Q&A Website is available at http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/integrity-qa.html. The Q&As are a helpful tool to use to stay abreast of ED’s latest guidance related to the various topics of the Program Integrity regulations.
One of the most recent updates to the Website is in the section related to verification. The Q&As are divided into various topics. So that each subject’s Q&As are easily referenced, they have topic designators that lead the Q&A number. For example, “Introductory Verification Questions” have the Q&A numbers preceded with “IVR”; “Verification Items” have the Q&A numbers p
We are delighted to announce after more than a year Sabbatical, Sally Samuels has returned once again to FAME as Director of Compliance.
Sally will dedicate her time to ensuring that FAME’s practices maintain compliance with Federal regulations as well as doing what she loves best speaking at venues throughout the country as one of the country’s leading authorities on Federal financial aid administration.
Sally brings her humor and real life experiences to her audience making complex topics easy to understand and apply.
Look for upcoming posts here on the FAME blog and in our newsletters announcing future speaking engagements with Sally.
This rate is the same rate as is applicable to the Direct Unsubsidized Loans. This increase was long-anticipated as it is the way that the law was originally written that authorized this change. The current interest rate structure that resulted in the temporary 3.4% rate was authorized on September 27, 2007 as part of the College Cost Reduction and Access Act (CCRAA). Before this law was enacted, all Direct Loans—Subsidized and Unsubsidized—were at the 6.8% interest rate. The CCRAA allowed for the gradual, but temporary, decrease in the Subsidized Direct Loan interest rate over the succeeding years until it eventually reached the 3.4% rate that was applicable in the 2011-2012 award year. As of July 1, 2012, the interest rate on the Subsidized Direct Loans was to return to the prior rate of 6.8% as written in the CCRAA back in 2007. Congress, of course, delayed that increase a year ago to extend the 3.4% interest rate applicable to Subsidized Direct Loans until June 30, 2013. This resulted in the automatic increase back to the former 6.8% rate on July 1, 2013 as there was no change to what the law required.
The question has been raised as to whether there will yet be any chan
Schools that participate in the Title IV financial aid programs are required 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.
Schools in all states required t
The 150% limit on Direct Subsidized Loans is in effect now, as of July 1, 2013. All first-time borrowers on or after July1, 2013 are subject to the new provisions. The requirements associated with this new provision also stipulate additional requirements of schools, including enhanced entrance counseling. See below for more of the details.
The U.S. Department of Education (ED) states that, generally, a first-time borrower is one that did not have an outstanding balance of principal or interest on a Direct Loan (or on an older FFEL Program Loan) as of July 1, 2013. The provision, which is authorized by the Moving Ahead for Progress in the 21st Century Act (MAP-21), was enacted almost a year ago on July 6, 2012. The law states that a first-time borrower’s eligibility for a Direct Subsidized Loan may not exceed 150% of the length of the borrower’s educational program. The borrower’s educational program is defined as the eligible program that the student is enrolled in, and for which he or she is applying for a Direct Subsidized Loan. In addition, MAP-21 will, in certain circumstances, result i
ED has released another volume of the 2013-2014 Federal Student Aid Handbook. This release is “Volume 5 – Withdrawals and the Return of Title IV Funds”. The annual volume is a useful resource for guidance with the myriad questions that arise from student withdrawals and leaves of absence (LOAs), etc. For example, this year’s edition includes text that addresses what a school must do if a student remains only enrolled in non-Title IV eligible courses. Also, guidance is provided that a student’s SAR/ISIR with a comment code that needs resolution at the time of withdrawal must be resolved before including any funds in “Aid that Could Have Been Disbursed” in R2T4 calculations.
If you have any questions regarding this information, please contact your Customer Service Representatives via support.fameinc.com.
As part of our ongoing efforts to develop and deliver new initiatives which aim to provide you with the very best support possible, we have added a new position to our support model, the Account Executive.
We’re happy to announce that Leslie Valdes has been appointed to the first of these new positions, the Account Executive. In her new role, Mrs. Valdes will function as a dedicated resource for customers using our eSolutions Financial Aid Software as a Service or Advantage/Hosted Student Information Systems from implementation to ongoing support.
Mrs. Valdes brings over ten years of experience in higher education, which includes comprehensive knowledge of financial aid and expertise in FAME’s solutions. Mrs. Valdes also has extensive experience working with Student Information Systems and school operations.
The Office of Management and Budget (OMB) has approved a new Private Education Loan Applicant Self-Certification form (Self-Certification form). This newly approved form does not contain any substantive changes from the prior Self-Certification form that had an expiration date of February 28, 2013. The new Self-Certification form is available for use immediately and may be accessed from the Dear Colleague Letter (DCL) GEN-13-15 where it was provided as an attachment to the DCL. The older, expired form has still been accepted thus far even though the expiration date had passed. ED states that it may continue to be distributed by schools through June 30, 2013, and may be accepted through July 31, 2013. After these dates, all schools that distribute the Self-Certification form must use the newly released version that became available on June 12, 2013. The new form has an expiration date of May 31, 2016.
The Self-Certification form has been a requirement for schools since February 14, 2010. It is applicable to situations when a student chooses to apply for a non-Federal private education loan. The law requi
ED has provided yet a third update on guidance related to the effects of sequestration that took place effective March 1, 2013. In the announcement that ED made on Friday, May 31, 2013, schools are informed that the most recent estimates by the Office of Management and Budget (OMB) shows that the effect of sequestration will result in a less than previously announced reduction in the award amounts for TEACH Grants.
In the last sequestration announcement on April 26, 2013, ED stated that the TEACH Grant amounts would have to be reduced by 7.1% for any TEACH Grant first disbursed after March 1, 2013. This required reduction amount has now been lowered yet again to 6.0% for any TEACH Grants first disbursed after March 1, 2013. Although this may create some revisions to awards that schools have already made, it is important that schools ensure that students receive all the award amounts for which they are entitled.
Also, it is important to note that there were no further reductions in the previously announced sequestration effect on the Iraq-Afghanistan Service Grant (IASG) awards. The sequestration reduction amount required for any IASG awards disbursed after March 1, 2
Effective June 9, 2013, the Student Aid Internet Gateway (SAIG) will only retain files for 90 days. This is a reduction from the 180 days that has heretofore been the data retention period. The data retention period is how long ED retains files in the system that are transmitted via the SAIG. Schools should ensure that all files that are stored in archive or that have not yet been pulled in from their SAIG mailboxes are retrieved and appropriately handled prior to June 9, 2013. Any files in SAIG that are older than 90 days as of June 9, 2013 will no longer be able to be retrieved or accessed in SAIG.
If you have any questions regarding this information, please contact your Customer Service Representatives via support.fameinc.com.
The Department of Education (ED) has made changes in the information related to loan counseling. Schools should be aware that StudentLoans.gov now contains additional information for required loan counseling that was not previously on this site. As of March 24, 2013 StudentLoans.gov now contains enhanced Entrance Counseling, Financial Awareness Counseling, and Exit Counseling modules. It is important to note that Exit Counseling is no longer available through the NSLDS Student Access Web site. All Exit Counseling that is performed through ED's resources must now be done through StudentLoans.gov. This will necessitate schools that use ED's Direct Loan Exit Counseling to update their consumer information regarding Exit Counseling (e.g., where you tell students to go to complete the counseling in your catalogs, brochures, and on your Web site, etc.). Schools are encouraged to review and be cognizant of all of the enhancements and the list of "clarifications" (questions and answers) that ED has provided related to the enriched StudentLoans.gov in the
With Ed focusing on reducing loan debt and default aversion, Detecting Potential Default Scenarios is one session that you don’t want to miss!
Join speaker Sally Samuels of FAME on Wednesday, June 5th 2:00pm-2:50pm, as she provides you with tools and resources to ensure compliance. This interactive session will focus on Recognizing potential defaulters, Common characteristics of defaulters, Why do they default ?, and Steps you can take to identify and lessen potential default.
Sally Samuels is one of the country’s leading authorities on Federal financial aid administration with more than 30 years of “in the trenches” experience, and currently serves on the FAME Advisory Board. As a respected Industry leader, she is frequently called upon to speak at schools, accrediting, regional and state conferences as well as to act as a school liaison during program reviews and state compliance audits.Having processed, reviewed an
ED has released Volume 4 of the 2013-2014 FSA Handbook, “Processing Aid and Managing FSA Funds”. Some of the new items contained in this year’s edition of Volume 4 are:
A reminder that schools may not use Title IV funds to pay “overtime charges” for a student who fails to complete his or her academic program within the normal time frame;
An additional reminder that although schools do not have to return Direct Loan proceeds if a student who received a Direct Loan disbursement begins attendance for the loan period, but does so on a less than half-time basis, the school must not make any subsequent disbursements of the loan, unless the student resumes enrollment on at least a half-time basis;
A whole new chapter on “Reconciliation” in this year’s edition (which also happens to be included in the recently released new Blue Book).
Subsequent to the release of Volume 4, two additional volumes have also been made ava