Category Archives: Uncategorized

Regulatory Bulletin — DHS 3-Step Electronic Verification of Eligibility – May 1, 2018

April 12, 2018
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Dancing the New Three-Step (The Three-Step DHS Verification) Well, let’s face it.  Some are just better than others at doing a two-step on the old dance floor.  What makes the difference?  Perhaps it is due to more training or experience, and for some, perhaps there is just more natural ability.  But, along with, hopefully, some natural ability, it does take some basic understanding of the steps appropriate for the dance. Likewise, in determining certain noncitizens’ eligibility for Federal Student Aid requires knowing and accomplishing the appropriate steps.  Failure to know and appropriately follow those steps could cause the music of the Federal Student Aid dance to stop for some students.

DYK – FY2014 DRAFT CDRs Released

March 6, 2017
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The U.S. Department of Education (ED) distributed the FY 2014 3-Year Draft Cohort Default Rates last Monday, February 27, 2017.  Under regulations published October 28, 2009, a school's Cohort Default Rate (CDR) is calculated as the percentage of borrowers in the cohort who default before the end of the second fiscal year following the fiscal year in which the borrowers entered repayment.  This, in essence, creates the 3-year CDR.[1] The Draft CDRs were distributed to schools’ Student Aid Internet Gateway (SAIG) mailboxes.  The CDRs and accompanying Loan Record Detail Reports may also be downloaded via the National Student Loan Data System (NSLDS) via the NSLDS Professional Access Website. Schools should examine the February 27, 2017, Electronic Announcement to be reminded of the impact that will be incurred if a school’s FY 2014 official 3-year CDR is equal to or greater than 40% when the official CDR is published in September 2017, or if the school’s 3-year CDR has been 30% or greater for three years.

Partners with Enrollment Resources Announcement

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

Clock to Credit Hour Conversion Important Information

June 20, 2016
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Based on additional recent guidance from the U. S. Department of Education (ED), we would like to share the following information.  This guidance may impact the credits that you submit on your E-APP from the clock to credit conversion that ultimately appear on your ECAR. When a school does a clock-to-credit hour conversion and the financial aid credit hour calculation for an individual course equals a fraction (e.g., 3.25), the school may use the actual fraction to determine the total number of financial aid (FA) credits in the program rather than rounding to the nearest 1 or .5 as some accrediting agencies require.  However, the school may not round up the fraction (example:  3.255 can be 3.255 or 3.25, but not 3.26). This is for the calculation of FA credits only.  Note: The school may not use the FA credits if they are more than the academic credits per individual course or program. Example:  Medical Assistant Program (quarter credits)

The Last Round of Sparring on Incentive Compensation

February 15, 2016
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Prohibited!  That has been the word on the streets about incentive compensation offered by postsecondary educational institutions.  More specifically, the October 29, 2010, Program Integrity Regulations[1] made this prohibition applicable to individuals involved in the recruitment or admission of students, as well as those involved in making decisions about student financial aid.  These regulations related to incentive compensation were generally effective July 1, 2011.  But, was the ban on incentive compensation for recruiters all encompassing?  What is the latest from ED on the matter? The Challenge When the October 29, 2010, regulations were finalized, it was not long before a legal challenge to the incentive compensation section of the rules was presented.

Since You Asked: Questions & Answers

October 9, 2015
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Q1:  If our Program Participation Agreement (PPA) is set to expire, what happens if we have not received our new PPA from ED before the expiration date? A1:  When a school submits a materially complete Recertification application on time, the school’s PPA and Eligibility and Certification Approval Report (ECAR) continues on a month-to-month basis until the review of the new application is completed. Q2:   For a clock-hour GE program, is the school’s satisfactory academic progress (SAP) policy limited to 150% of the minimum number of clock hours required for training in the recognized occupation for which the program prepares the student? A2:  No.  The 150% maximum time frame for SAP purposes is totally different than the requirement that a school’s academic program length not exceed by more than 50% the minimum number of clock hours required for training in the recognized occupation for which the program prepares the student, as established by the State in which the school is located, if the State has established such a requirement, or as established by any Federal agency.  And, to clarify, for a clock-hour program, a SAP maximum time fram

REMINDERS

July 17, 2015
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Action:  All results of verification for students selected in Verification Tracking Groups V4 and V5 must be reported within sixty (60) days of when the school requests the information from the student.  For FAME clients the reports will be submitted, however clients must appropriately enter the results of the V4 and V5 verification.  (FAME ESP clients see the August 4, 2014, “What’s New in ESP?” e-mail.  FAME Freedom FinAid clients see the August 14, 2014, “What’s New in Freedom?” e-mail.) Action:  The new Violence Against Women Act (VAWA) regulations are effective as of July 1, 2015. Action:  By July 31, 2015, schools with Gainful Employment (GE) programs must report the applicable data for each of the award years of 2008-2009 through 2013-2014.  (In limited cases, some schools must include data for 2007-2008, as well).  See the Federal Register dated October 31, 2014, for more of the specific details of the applicable regulations and requirements. Action:  The Direct Loan closeout deadline for the 2013-2014 Program Ye

Since You Asked: Questions & Answers

July 17, 2015
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Q1:  A student submitted a 2014-2015 FAFSA and a 2015-2016 FAFSA at the same time and the ISIRs for both came back the same day.  The strange thing is that her 2014-2015 FAFSA came back with no C-Code issues but her 2015-2016 FAFSA has one.  On her 2014-2015 FAFSA the first page says “your citizenship status has been confirmed by DHS and you meet requirements for federal student aid.”  However her 2015-2016 FAFSA says that “USCIS of DHS did not confirm that you are an eligible noncitizen” and she must submit proof to her school.  I understand that this means we need to submit a G-845 with a copy of her Green Card, but my question to you is do we really have to?  Since her 2014-2015 FAFSA says that DHS confirmed her citizenship why would her 2015-2016 FAFSA not say the same, especially because they were submitted and processed at the same time? A1:  The bottom line is that you are correct.  You will need to submit the G-845 for secondary confirmation.  As it currently stands, you are not able to pay based upon the 2014-2015 ISIR because you now have conflicting information since the second ISIR for 2015-2016 did not confirm her eligible status.  There ar

Important Reminders for Q2_2015:

April 24, 2015
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Action: All results of verification for students selected in Verification Tracking Groups V4 and V5 must be reported within sixty (60) days of when the school requests the information from the student. For FAME clients the reports will be submitted, however clients must appropriately enter the results of the V4 and V5 verification. (ESP clients see the August 4, 2014, “What’s New in ESP?” e-mail. Freedom FinAid clients see the August 14, 2014, “What’s New in Freedom?” e-mail.) Action: The deadline date for a waiver of the 2015-2016 Federal Work-Study Community Service requirement is April 27, 2015. The deadline for an electronic submission of a school’s waiver request is 11:59 P.M. (ET) on Monday, April 27, 2015. Action: On May 10, 2015, ED implements the new student/borrower FSA ID login process. Action: The new Violence Against Women Act (VAWA) regulations are effective July 1, 2015. Action: By July 31, 2015, schools with Gainful Employment (GE) programs must report the applicable data for each of the award years of 2008-2009 through 2013-2014. See the Federal Register dated October 31, 2014 Action: The Direct Loan closeout deadline for the 2013-2014

Since You Asked: Questions & Answers

April 24, 2015
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Q1:  We have a cost of attendance (COA) that uses national standards or averages for room and board, personal, and transportation expenses.  But, as of January 2015, for all future starts we would prefer to use the results of a student survey we have conducted.  Can we do that? A1:  There is no prohibition on ED’s part.  A school is able to review and update its Title IV policies and procedures (of which COA is a part) when appropriate.  However, the school must be clear in documenting its policies and procedures in regard to when the change occurred and how it was implemented, etc.  Naturally, the data upon which the new COA figures are based should be maintained as documentation for the COA.  Also, students should be appropriately notified and consumer information updated, etc.   There may be other points to consider regarding such changes in the middle of an award year.  For example, it can create additional challenges for staff to communicate easily and accurately with students when dealing with differing costs during the same award year.  It also has potential to generate more questions from auditors during the annual audit. Q2:  If a studen

ED’s 2015-2016 Federal Student Aid Handbook

April 24, 2015
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ED has released updates to the Federal Student Aid Handbook this past quarter.  Specifically, ED has released the 2015-2016 Application and Verification Guide and Volume 4 – Processing and Managing FSA Funds of the 2015-2016 Federal Student Aid Handbook.  These updates are available on IFAP.  Schools will do well to review each of the announcements related to these FSA Handbook updates and become familiar with the enhancements provided via these announced changes.

ED’s 2014-2015 Federal Student Aid Handbook

April 24, 2015
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handbookThe latest addition to the 2014-2015 Federal Student Aid Handbook was released on February 20, 2015.  This release contains the new Appendix F – Institutional Reporting and Disclosure Requirements for Federal Student Assistance Programs.  The appendix is a fairly comprehensive chart of reporting and disclosure requirements. Schools will find it to be a useful tool to aid them in their efforts to meet the requirements indicated.

ED’s Dear Colleague Letters (DCLs) on IFAP

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

ED’s 2014-2015 Federal Student Aid Handbook

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

ED’s Electronic Announcements (EAs) on IFAP

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

Important Reminders for Q1_2015

January 29, 2015
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Action:  All results of verification for students selected in Verification Tracking Groups V4 and V5 must be reported within sixty (60) days of when the school requests the information from the student.  For FAME clients the reports will be submitted, however clients must appropriately enter the results of the V4 and V5 verification.  (ESP clients see the August 4, 2014, “What’s New in ESP?”.  Freedom FinAid clients see the August 14, 2014, “What’s New in Freedom?”) Action:  All schools must have their GE disclosure information updated utilizing 2013-2014 data by January 31, 2015.  Schools must use the updated GE Disclosure Template (GEDT) referenced in the GE Electronic Announcement # 50 that was released on IFAP on September 11, 2014. Action:  As of February 1, 2015, ED will no longer accept enrollment reporting files in file layout formats that are older than those posted to the Information for Financial Aid Professionals (IFAP) Web site on February 27, 2014 (“the new formats”). An enrollment

Since You Asked: Questions & Answers

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

Since You Asked: Questions & Answers

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

Important Reminders for Q4_2014

October 28, 2014
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REMINDERS: Action:  As a result of the Subsidized Direct Loan 150% limit, schools are required to start reporting to NSLDS students’ enrollment information at the program level.  Schools were able to begin using ED’s new file layouts no sooner than April 14, 2014.  All schools must begin using the new file layouts no later than October 1, 2014. Action:  As of October 1, 2014, schools must have updated their Enrollment Reporting Profile Page in NSLDS to indicate when they will be reporting NSLDS Enrollment Reporting data by the student’s academic “program”.  This is primarily as a result of the Subsidized Direct Loan 150% limit.  The date you select may not be later than October 1, 2014.  (NOTE:  FAME makes this update for its clients for whom it does Enrollment Reporting.) Action:  All results of verification for students selected in Verification Tracking Groups V4 and V5 must be reported within sixty (60) days of when the school requests the information from the student.  F

EDs Federal Registers (FR) on IFAP

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

Dramatically Improve your Default Prevention Process

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

Important Reminders for Q3_2014

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

Since You Asked: Questions & Answers

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

Federal Registers on IFAP

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

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

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

Since You Asked: Questions & Answers

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

Important Reminders in Quarter 2-2014

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

FAME will keep you cooking with compliance at AACS Spring!

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

Important Reminders in Quarter 1 2014

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

Since You Asked: Questions & Answers

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

Important Reminders in Quarter 4

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

Since You Asked: Questions & Answers

October 14, 2013
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FAME Frequently Asked Questions & Answers  Below you will find the frequently asked questions and answers featured in the Q4 2013 edition of FAME’s Inside Report.   Q1:  The 2013-2014 Federal Student Aid Handbook states (page 3-26) that "Schools with cohort default rates of less than 15 percent for each of the three most recent fiscal years for which data are available..." are eligible for the exceptions to some requirements.  It does not specify whether that is using the 3-year cohort default rate (CDR) or 2-year CDR, or a combination of both.  Which rate should be used? A1:  The regulations state in 34 CFR 685.301(b)(6)(i)(A)(2)(ii) that in years when the school has a 2-year and 3-year CDR calculated where the rate is 15% or lower in each of three years, the institution is eligible for the benefits applicable to low-default rate schools.   The appropriate rate to use is for the 3 most recently completed CDR calculati

Important Reminders in Q3

August 8, 2013
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REMINDERS: Action:  Beginning July 1, 2013, the sequestration induced Direct Loan fee increases become effective.  The increases are applicable to loans with a first disbursement on or after July 1, 2013.  The fees are increased from 1.0% to 1.051% for Direct Loans and from 4.0% to 4.204% for PLUS Loans. Action:  Implementation of the 150% of academic program limit for receipt of subsidized Direct Loans for new borrowers starting on or after July 1, 2013.  Schools must implement a method of monitoring and addressing students who exceed the 150% limit. Action:  Federal Direct Subsidized Loans disbursed on June 30, 2013 or before have an interest rate of 3.4%.  Federal Direct Subsidized Loans disbursed on or after July 1, 2013 have an interest rate of 6.8% (unless Congress passes a law that is signed by the President to change the law that is currently in effect that caused this increase).  NOTE:  There has been interest expressed by members of Congress to make

Since You Asked: Questions & Answers

August 6, 2013
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FAME Frequently Asked Questions & Answers (FAME Inside Report_ Quarter 3_ 2013) Below you will find the frequently asked questions and answers featured in the Q3 2013 edition of FAME's Inside Report.  
Q1:  Which parent’s income can be reported on the FAFSA in a situation where the student’s mother and father are divorced?  The father refuses to provide his income even though the student lives with father and the father supports him.  The mother does not live with them nor does she provide support to the student. A1:  The student must use the custodial parent which is defined as the parent that the student lived with the longest over the last 12 months.  If the student lived equally with each parent, he or she would then list the parent who provided the most financial support.  In the case presented, that would be the father.  The mother’s information would not be included.  Refer to page AVG-29 of the 2013-2014 Application and Verification Guide.   Q2:  If an ISIR is not selected for verificati

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

April 30, 2013
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PROCESSING FOR 2013-2014 EA – Posted January 25, 2013 – (Campus-Based).  Tentative 2013-2014 Funding Levels for the Campus-Based Programs ED announced that the tentative funding levels for Campus-Based programs for the upcoming award year were available as of February 1, 2013.  It is helpful for schools to review the attachment to the announcement that gives an explanation of the calculation of each tentative funding level contained in the worksheet for each program.  Important to note is that the tentative funding levels are based upon the 2012-2013 award year appropriations until the outcome of the appropriations for 2013-2014 is known.  Institutions were notified by e-mail to the school’s Financial Aid Administrator when the tentative funding levels and worksheets were available on the eCB Web site. EA – Posted February 1, 2013 – (Application Processing).  2013-2014 Federal School Code List of Participating Schools (February 2013) The 2013-2014 Federal School Code List of Participating Schools is provided for schools to be able to review

ED’s Federal Student Aid Handbook: 2013-2014 Edition

April 30, 2013
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2013-2014 EDITION EA – Posted January 31, 2013 – (General). 2013-2014 Federal Student Aid Handbook, Application and Verification Guide With this announcement, ED has posted the first portion of the 2013-2014 Federal Student Aid Handbook. This Application and Verification Guide (AVG) section is the key document that assists financial aid administrators begin their processing for the upcoming award year. It is critical that all FAAs are familiar with the content of this new AVG. Some of the notable changes in the AVG for 2013-2014 are the elimination of the homebuyer tax credit information as that credit is no longer available to taxpayers; guidance that Social Security disability benefits are not to be counted as untaxed income which is in accord with how other disability benefits are treated; and, an update to the chart that indicates signature requirements for when a student or parent must document tax-related information on the FAFSA. Additionally, this AVG provides a thorough discussion of the new verification tracking groups and includes a description of acceptable documentation of high school completion status and the identity/statem

Gainful Employment: Weighed in the Balance

April 26, 2013
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Gainful employment. This has developed into one of the most debated topics in modern Title IV regulatory history.  Ever since before their publication in the Federal Register, the October 29, 2010 Final Rules (also known as the Program Integrity Regulations), have been a hot topic.  The 10/29/2010 regulations, along with the June 13, 2011 Final Rule on the Gainful Employment – Debt Measures, have provided plenty of fodder for ongoing dialog and debate in the higher education industry. Legal Proceedings But, of course, the dialog and debate did not just remain in the realm of the higher education industry.  It has wound its course into the legal system as well.  After an early suit in July 2011 filed by the Association of Private Sector Colleges and Universities (APSCU) not long after the last of the GE regulations were published, the results of the suit have been decisions from the Courts and appeals by the U.S. Department of Education (ED).  Last June the U.S. District Court for the District of Columbia reached a decision regarding APSCU's challenge to the Department of Education's GE regulations wherein the Court vacated (made legally null and void)

IT Tips – BYOD (Bring Your Own Device)

November 27, 2012
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Wi-Fi Signal logo BYOB is a good way to have a party. But BYOD is no party if it’s not set up well. What is BYOD? It stands for Bring Your Own Device. It’s the current trend in many work environments where people are bringing their smart phones, iPads, Kindles, iPods, and other personal electronic devices to work. If a company has no policy or does not prevent it through technical means, people can connect their devices to their PCs or to the company’s internal WiFi network. This is a major information security risk because it can allow confidential data to be copied to a device, and enables hackers to connect to the company’s internal network via a device’s wireless interfaces.Instead of forbidding those devices, here at FAME we have decided to take the issue head-on and set up a safe way to give those devices Internet access without endangering our internal network. We have set up a WiFi network in our office that connects di