ED’s Dear Colleague Letters (DCLs) on IFAP
ED’s Dear Colleague Letters (DCLs) on IFAP – (listed by DCL category by date)
DCL – GEN-14-11: June 30, 2014 – 2015-2016 Award Year: FAFSA® Information to be Verified and Acceptable Documentation
This Dear Colleague Letter (DCL) offers additional information to that provided in the Federal Register on June 25, 2014 regarding 2015-2016 verification requirements and processes, etc. Specifically, the letter highlights the required verification items for 2015-2016 and acceptable documentation for verification purposes. Additionally, the DCL provides clarification and additional guidance on certain verification items and related acceptable documentation. Also of note is that the DCL highlights areas where ED’s guidance has changed or expanded, e.g., dealing with non-tax filers and untaxed income, reporting parental information, guidance on State-approved tests that are considered the equivalent of a high school diploma, changes in the verification tracking groups, etc. The information in this letter is fundamental to schools being able to appropriately comply with the 2015-2016 verification requirements and should be well understood by all involved in the financial aid application and verification processes at their schools.
DCL – GEN-14-14: July 24, 2014 – Additional Guidance on the Supreme Court’s Ruling on the Defense of Marriage Act and Its Implications for the Title IV Student Financial Assistance Programs
ED provides further clarification on the impact of the Windsor case (see the earlier DCL GEN-13-25). This particular letter addresses stepparent eligibility for a Direct PLUS Loan and the consideration of the income of a spouse for “income-driven” repayment plans. The Department clarifies that consistent with the Windsor decision, a stepparent, who meets the definition of “parent” in 34 CFR 668.2, and who is of the same sex as the dependent student’s biological or adoptive parent, may apply for a Direct PLUS Loan if the stepparent and parent were legally married in any domestic or foreign jurisdiction that recognizes the relationship as a valid marriage, regardless of where the couple resides. Likewise, concerning income-driven repayment plans, the term “spouse” includes a same-sex spouse if the borrower and spouse were legally married in any domestic or foreign jurisdiction that recognizes the relationship as a valid marriage, regardless of where the couple resides. This guidance is important in some cases where the spouse’s student loan debt is taken into consideration in determining eligibility for one of the repayment plans and the monthly payment amount, and also in considering the family size for income-driven repayment plan purposes.
DCL – GEN-14-17: August 29, 2014 – NSLDS Program-Level Enrollment Reporting
After discussions with the financial aid community and admissions officers’ and registrars’ associations, ED has developed revised guidance on enrollment status reporting. This change is intended to reduce the complexity of the reporting while remaining in compliance with regulatory and legislative requirements. Specifically, ED gives clarification of “active enrollment status” as that term is used in enrollment reporting. Based upon the new guidance, schools must report a student’s “active enrollment status” (full-time, three-quarter time, half-time, and less than half-time) based on the total number of credit or clock hours in which the student is enrolled at the institution. This is regardless of whether any specific credit applies to the academic program being reported. Naturally, if a student has withdrawn or graduated, the appropriate status would be reported. Schools are encouraged to review the information and examples in this letter in detail for a more complete understanding of this latest guidance.