ED’s Dear Colleague Letters (DCLs) on IFAP
Listed by DCL category by date
DCL – GEN-14-01: January 31, 2014 – 2014-2015 Federal Pell Grant Payment and Disbursement Schedules
With this letter, ED provides the necessary Payment and Disbursement Schedules for the coming Award Year of 2014-2015. The schedules are provided for varying enrollment statuses (i.e., full-time, three-quarter-time, half-time, and less than half-time). It will be noted that these schedules indicate that the maximum Pell Grant for 2014-2015 is $5,730, which is an $85 increase from 2013-2014. Also, the actual 2014-2015 Award Year minimum award amount for a full-time student is $587. The maximum Pell Grant eligible expected family contribution (EFC) for 2014-2015 is 5157 whereas in the 2013-2014 Award Year it was 5081. Thus, schools may see some additional Pell eligible students in 2014-2015.
DCL – GEN-14-03: February 27, 2014 – Impact of Cohort Default Rates on Institutional Title IV Program Eligibility
In this DCL ED gives a summary of how an institution’s cohort default rate (CDR) is calculated and what regulatory provisions are available to eliminate or lessen the impact of high cohort default rates. While done in a summary format, it is a quite thorough explanation of how the calculations are performed, the consequences of high CDRs, and provisions for challenges, adjustments, and appeals to the CDRs, as well as the sanctions associated with high CDRs. Schools will be well served to become familiar with this information and apply it as appropriate. See also the summary given earlier in this Inside Report for the Electronic Announcement dated February 18, 2014. That EA announced and accompanied the distribution of the three-year draft CDRs.
DCL – GEN-14-04: February 27, 2014 – State Authorization Regulations: Student Complaint Process – Further Guidance and Clarification
ED offers clarification and reminders related to the hot topic of State authorization. Specifically, the Department highlights the two basic requirements for an institution being legally authorized by a State for Title IV purposes. Those two requirements include the State authorizing an institution by name to operate educational programs beyond secondary education in that State; and, the State must have a process applicable to all institutions (except tribal and Federal institutions) to review and appropriately act on complaints concerning the institution, including enforcement of applicable State laws. ED makes a point of emphasizing that these two requirements are separate and distinct. That is, a school may be authorized by the State, but the State may not have a complaint process to use in considering any complaints against the school. Both components of the State authorization must be met for the school to be considered Title IV eligible in that State. In an application to participate in Title IV, or in a recertification of eligibility to participate, the school must be able to identify/describe to ED the complaint process for the State in which it desires eligibility.
DCL – GEN-14-05: March 25, 2014 – IRS Tax Return Transcript Processes for 2014-2015
A thorough explanation of the IRS Tax Return Transcript processes for 2014-2015 is given in this DCL. ED points out the key areas related to requesting a tax return transcript, to include the fact that if a tax return has not been received from, or processed for, the tax filer, the individual’s information will not be accessible for use in an attempt to import data via the IRS Data Retrieval Tool (DRT). ED reminds of the typical timeframes required from submitting a tax return to the time the data will be available for use in the IRS DRT. As with so many things these days, there is now also a new “tool” available for requesting a tax return transcript online. It is the “Get Transcript Online” tool. This tool will allow tax payers to retrieve their tax return transcript immediately online in Portable Document Format (PDF). The tax filer may then forward that document, if so desired, to the financial aid office. Because of the Get Transcript Online tool, IRS will no longer accept requests for transcripts at its Taxpayer Assistance Centers or by phone. However, tax filers may still request a transcript online, submit a paper Form 4506 or 4506-T by mail, or utilize the IRS mobile app, “IRS2GO”, or the IRS automated phone tool at 1-800-908-9946. However, using any of these other methods will require that the transcript be mailed in paper form to the tax filer. (Only in the case of requests made using a paper form can the tax filer identify a third party to receive the transcript.) This DCL also gives very definitive information regarding the steps victims of IRS identity theft may take. For most individuals in such situations, it will require the tax filer to contact IRS’ Identity Protection Specialized Unit (IPSU) for assistance. In most cases the tax filer that has been subject to identity theft will be sent an alternate tax return transcript known as a Transcript DataBase View (TRDBV). A sample of what a TRDBV looks like is included as an attachment with this DCL. Finally, ED addresses the issue of whether a tax filer may have their tax return transcript sent to the school by a third-party that contracts with the IRS. Such third-party entities operate as an Income Verification Express Service (IVES). While schools that accept or utilize assistance from a third-party servicer acting as an IVES, the school may not in any way pass on any charge for such service to the student. Schools are encouraged to read this DCL very carefully.