1. 2015 ISFAA Winter Conference
Federal Update
2015 ISFAA Winter Conference
Angela Smith, Training Officer U.S. Department of Education

2. Verification

3. Verification
Same verification items and Verification Tracking Groups to be verified as
Applicant will remain in original 2015–16 Verification Tracking Group for the entire award year record

4. 2015-16 V4/V5 Tracking Results https://faaaccess.ed.gov
The V4/V5 tracking process in FAA Access that began in the processing year WILL CONTINUE for
Make sure you’re selecting the proper award year for which you are providing results

5. Within 60 days following the institution's first
V4/V5 Tracking Results
Whom to report:
Applicant for whom school received an ISIR with a Verification Tracking Group of V4 or V5 AND for whom school requested verification documentation
Do NOT include students the school selected for verification of identity or high school completion status
When to report:
Within 60 days following the institution's first
request to the student to submit the required V4 or V5 identity and high school completion documentation.
Changes to previously submitted Identity Verification Results must be updated within 30 days

6. October 17, 2014 Electronic Announcement
Alternative documentation allowed when tax filer RECENTLY requested but unable to obtain an IRS Tax Return Transcript using the IRS paper or on-line request process
No alternative documents for telephone requests
Exception not permitted for transcripts unable to be obtained simply because the IRS has not had time to process the data due to a recent filing
For award year

7. 2014-15 – Transcripts Unavailable
In instances where tax filer recently requested a IRS Tax Return Transcript and was unsuccessful:
Signed copy of relevant 2013 IRS tax return
AND
Communication from IRS stating request unsuccessful
Letter from IRS (SIGNED AND DATED BY TAX FILER); or
Screen shot print (SIGNED AND DATED BY TAX FILER)
Completed and signed IRS Form 4506 T-EZ or 4506-T listing institution as third party
Send to IRS only if doubt paper tax return accuracy

8.
FAFSA
Processing

9. FAFSA Definition of Parent
Current definition: biological or adoptive
New definition will be: biological, adoptive or person that the state has determined to be the parent
Clarifying who is not a parent
List of people who are not considered a parent unless they have legally adopted the student will now include widowed stepparent

10. Foster Care Screening Question
Require all FOTW applicants to tell us if they are or were in foster care to ensure people entitled to benefits receive them
Separate from current dependency question
New question will be earlier in application process
“Yes” answer will result in SAR comment with hyperlink to information regarding benefits, and hyperlink will also appear on FOTW confirmation page

11. School Listing School selection page School selection summary page
Adding text to tell students that all schools they select will receive the list of selected schools
School selection summary page
Adding text to tell students that for federal purposes it does not matter in what order schools are listed but it may be important for state purposes

12. Separated – FAFSA Guidance
For FAFSA purposes, a married couple is separated if the couple is considered legally separated by a state, or if the couple is legally married but has chosen to live separate lives, including living in separate households, as though they were not married. If you and your spouse are separated but living together, select “I am married / remarried,” not “I am separated.” NOTE: When two married persons live as a married couple but are separated by physical distance (or have separate households), they are considered married for FAFSA purposes.

13. IRS DRT – Amended Returns
Unusually large number of applicants report filing an amended return
Rewording question to specifically ask if they have filed a 1040-X amended return
Help text will also refer to the 1040-X and make clear what the 1040-X is

14. IRS DRT – Timing Issues
Some applicants who are eligible to use the tool find there is no data to import due to owing taxes
New hyperlink statement: “How you filed your taxes can affect if tax information is available to import.”
Hyperlink will lead to help text that explains timing for tax information availability

15. Help Text Changes
Clarifying gender question to state we are asking about gender at birth
Adding help text to Citizenship Status question regarding DACA that explains:
that they should answer that they are neither citizens or eligible noncitizens
that although they can receive Social Security numbers, they are not eligible for Title IV

16. The FSA PIN Replacement Person Authentication
FSA ID:
The FSA PIN Replacement
Person Authentication
Service (PAS)

17. Introducing the FSA ID
The FSA ID will modernize access for students, parents and borrowers to FSA systems
FSA is adopting the best practice of using a username and password instead of personal information
The FSA ID
Requires users to enter less information (2 fields instead of 4)
Provides more secure access to user’s information
Links to PIN information during registration
Offers self – service capability (name change)
The FSA ID (username and password) will replace PIN for students, parents and borrowers accessing FSA systems starting April 26, 2015
New FSA ID login
Will be updated
Old PIN login

18. Introducing the FSA ID
Users still click the Sign in button. This directs them to the FSAID login page. Once they enter their FSA ID, they are directed back to the application landing page
Will be updated

19. Introducing the FSA ID What happens for new user?
Registration requests the same required information as PIN
New users will be directed to the registration page to create an FSA ID (username and password) similar to today’s PIN creation page
What happens if I have a PIN already?
During account creation, the user will be asked for their PIN.
As long as the PIN information matches their other information, the account will be linked to the FSA ID account
Will the changes affect a user’s ability to access previous FAFSA submissions?
If the user links their PIN, they will have access to previous FAFSA submissions

20. Introducing the FSA ID
Can users still access FAFSA by providing their Last name, SSN and DOB?
FAFSA functionality will not change except that the FSA ID will replace the PIN information
Users will not be able to sign or correct their application without their FSA ID.
Will customer support change?
Customer support will not change. Similar to PIN, all users will be directed to call the FSAIC helpdesk for login related issues
Will my FSA access to other people’s information require a new username and password?
This is only for users who are accessing their own information such as students, parents, borrowers and applicants

21. FSA ID Communication to Students
ED to post high-level information about the FSA ID on each impacted website in mid-April 2015
As of April 26, 2015, users who arrive at impacted websites will be directed to a link to register for their new FSA ID
registration process should take less than seven minutes
Later this winter, ED will post a step-by-step guide about registering for an FSA ID on IFAP for schools to share with students, parents, and borrowers
All information will stress there is nothing a user can or should do prior to implementation on or after April 26, 2015

22. Defense of Marriage Act (DOMA)
GEN-13-25

23. Implementation of the Supreme Court’s DOMA Decision
Any legal marriage recognized by a jurisdiction in which it was celebrated (50 states, D.C., U.S. territory, or foreign country) will be recognized for Title IV purposes regardless if same or opposite sex marriage or where couple resides
Applies to students and parents of dependent students
Applies to student attending institution located in a jurisdiction that recognizes same-sex marriage and in a jurisdiction that does not recognize same-sex marriage
Applies only to marriages - not domestic partnerships, civil unions, or similar formal relationships recognized by states
Relevant to all FAFSA questions concerning marriage

24. Implementation of the Supreme Court’s DOMA Decision
GEN-14-14
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
Circumstances where a borrower’s spouse information is taken into consideration for an income-driven repayment plan, the term “spouse” includes a same-sex spouse if the borrower and spouse were legally married

25. Implementation of the Supreme Court’s DOMA Decision
GEN-14-15
ED discusses section 135 of the HEA which requires a State that receives assistance under the HEA not to charge a member of the armed forces (and includes spouse or dependent child) who is on active duty for more than 30 days and whose domicile or permanent duty station is in the State more than the in-State tuition rate for attendance at a public institution of higher education.
A “spouse” to whom a public institution of higher education must extend in-State tuition benefits includes a spouse in a same-sex marriage who is legally married to a member of the armed forces

26. NSLDS
Enrollment Reporting

27. Enrollment Reporting Transition
All schools must have implemented the new enrollment reporting processes and file layouts by October 1, 2014
Schools that report using the new enrollment reporting file layouts after July 1, 2014 must report program-level enrollment information retroactive to July 1, 2014
New format includes:
Campus level data
Program level data (can be multiple programs)
Address

28. Enrollment Reporting Frequency
ED now requests enrollment information from schools every 60 days.
Schools are required to respond to those requests within 15 days of the date that ED sent the enrollment reporting roster to the school
Began July 1, 2014
Schools may choose to receive reports more frequently

29. Upcoming Enhancements
Student Contact Information will be mandatory
Compliance Measurements/Letters to schools
Focus on roster completion, including program-level
Report all Title IV students attending your school
Escalating notices will be sent for non-compliance
Referral to FSA Program Compliance for action
Updated Enrollment Reporting Guide (Spring 2015) 29

30. Gainful Employment

31. Gainful Employment - Regulations
Notice of Proposed Rulemaking (NPRM)
Federal Register - March 25, 2014
OPE Website with discussions and materials associated with GE negotiated rulemaking:
Final Federal Register - October 31, 2014
Effective date - July 1, 2015

32. Gainful Employment Programs
The HEA provides that to be Title IV eligible an educational program must be offered by:
A public or non-profit postsecondary educational institution and leads to a degree; or
Any institution, if the program prepares students for “gainful employment in a recognized occupation”
Generally, all non-degree programs must lead to gainful employment
Generally, all programs at for-profit institutions must lead to gainful employment

33. Which Programs are GE Programs
At proprietary institutions, all Title IV eligible programs are GE Programs except for –
Preparatory coursework necessary for enrollment in an eligible program
Bachelor’s degree programs in liberal arts offered since January 2009 that are offered by a proprietary institution that has been regionally accredited since October 2007

34. Which Programs are GE Programs
At public institutions and not-for-profit institutions, all Title IV eligible, non-degree programs are GE Programs except for –
Programs of at least two years in length that are designed to be fully transferable to a bachelor’s degree program
Preparatory coursework necessary for enrollment in an eligible program (loan only)

35. GE Reporting GE reporting will begin in early 2015
Report all Title IV students by July 31, 2015
Report through award years
Programs with Medical and Dental Residencies report through award years
Report following award years by October after end of the award year
Report 2014 – 2015 Award Year by October 1, 2015

36. GE Data to Report Institutional Data Program Data
Student Enrollment Data
Student Financial Data
ONLY submit data on students enrolled in a GE program
ONLY submit data on Title IV aid recipients (exclude FWS or FSEOG only recipients)
ONLY submit data for programs that exist as of 7/1/15
Data provided in 2011 will not be available to reuse

37. Certifications of Existing Programs
December 31, 2015 – Transitional Certifications Due
Signed by CEO/President
Certify that each currently eligible GE Program(s) is:
Approved by accrediting agency and State
Graduates qualify to meet educational prerequisites of the licensing or certification exam required to work in the state, if any
Certifications renewed when institution recertifies Program Participation Agreement (PPA)

38. Gainful Employment – Current Disclosures
Court left regulations (34 CFR 668.6(b)) in place that require schools to disclose certain GE Program data
Schools must use the Department’s GE Disclosure Template to provide all GE disclosures
Schools must update their GE program disclosures with information no later than January 31, 2015
GE Electronic Announcement #50 (9/11/14)
Template updates include: improved printing capabilities, updated SOC codes, optional context boxes, graduate certificate option, school name on output screen, bulk upload tool used if certain criteria met with different length programs
Technical questions: (855) or

39. Disclosure Availability
Post the Template on your institution’s Web page
Prominently display direct links to the Template on:
The GE program home page
Other institutional Web pages about the GE program
Include the Template in all promotional materials about the GE program
Promotional materials include invitations, ads, course catalogs, social media, etc. that mention or otherwise refer to a specific GE program
If not feasible to include the Template, include a live link or URL to it and clearly explain what is available at that Web page

40. Disclosures Under New Final Rules
Through December 31, 2016, current disclosure requirements remain in effect
Occupations; Normal time to complete program; On-time graduation rate for completers; Tuition & fees, books & supplies, room & board; Placement rate for completers (as determined by State or Accreditor methodology); and Median loan debt
Institutions must comply with new disclosure requirements (October 31, 2014 Final Rules) beginning January 1, 2017
conduct consumer testing, hold focus groups and prepare new disclosure template

41. GE Resources GE Information Page on IFAP
Federal Register Notices; DCLs; Electronic Announcements; FAQs; Webinars; Presentations; Resources
GE presentations at the FSA Training Conference
fsaconferences.ed.gov – sessions #GS1, 30, 58
EA 1/9/14 (GE #51) – Updated NSLDS Gainful Employment Submittal File Record Layouts
ANN Webinar Recording - Gainful Employment: Reporting Data to NSLDS
send questions to

42. Regulatory Activity

43. Institutional Security & Crime Reporting
The “Violence Against Women Act” (VAWA) amended the “Clery Act”
Final Rule published October 20, 2014
Effective July 1, 2015
GEN & EA dated 8/1/14
Statute required institutions to include this new information in annual security reports beginning with the October 1, 2014 report
Institutions must make a good-faith effort to comply with the statutory provisions as written
should use the statute as the basis for revising or developing policies, procedures, and programs in advance of the report that must be issued by 10/1/14
make sure appropriate authorities on campus are aware of these changes
Help Desk

44. Direct PLUS Loans Final Rule published 10/23/14 Key elements
Federal Register Notice published 1/14/15
New PLUS loan regulations will be early implemented early as of March 29, 2015
Key elements
New definitions for “charged off” and “in collection”
Amends what is considered adverse credit history
Requires PLUS loan counseling for approved borrowers with extenuating circumstances or an endorser
Extends validity of credit check from 90 to 180 days
ED will collect and publish performance of PLUS loans, including default rate information

45. “Charged Off” and “In Collection”
Charged off – a debt that a creditor has written off as a loss, but that is still subject to collection action
In Collection – a debt that has been placed with a collection agency by a creditor or that is subject to more intensive efforts by a creditor to recover amounts owed from a borrower who has not responded satisfactorily to the demands routinely made as part of the creditor’s billing procedures

46. Adverse Credit History
One or more debts with total outstanding balance greater than $2,085 that are -
90 or more days delinquent as of date of credit report; OR
have been placed in collection or charged off during two years preceding date of credit report OR
Subject of default, bankruptcy discharge, foreclosure, repossession, tax lien, wage garnishment or write-off of a debt under title IV during the five years preceding date of credit report

47. Required PLUS Loan Counseling
PLUS loan counseling required for borrowers who have adverse credit history and successfully:
document extenuating circumstances; OR
obtain an endorser (cannot have an adverse credit history)
Counseling will include:
information on borrowers’ current loan indebtedness
provide estimated loan repayment amounts
describe ways to avoid delinquency and default
provide additional financial aid literacy information
be provided by ED

48. Voluntary PLUS Loan Counseling
Enhance consumer information for PLUS applicants
Some items that will be included:
Calculator to allow borrowers to estimate future requirement monthly payment amount under various repayment plans
Tools to assist borrowers in determining how factors such as taking out additional PLUS loans or deferring repayment affect required monthly repayment and total amount repaid
Available repayment plans for student/parent PLUS borrowers
Budgeting information for minimum amounts needed
Strategies for avoiding delinquency and default
Available prior to start of the academic year

49. Validity of Credit Check
Credit check indicating no adverse credit history will remain valid for 180 days instead of 90 days
Any action that would normally trigger a credit check will not do so if prior credit check with no adverse credit obtained within past 180 days
Will implement as soon as possible and inform community of effective date through IFAP

50. Performance of PLUS Loans
Will collect and publish (where appropriate) information about performance of parent and student PLUS loans, including
default rate information based on credit history characteristics of PLUS loan applicants and
individual institutional default rates

51. Pay As You Earn Expansion
Propose to develop regulations that:
Allow more students the opportunity to cap their monthly student loan payments at 10%
Target new PAYE option to borrowers who would otherwise struggle to repay their student loans
Three Negotiated Rulemaking sessions planned
Session 1: February 24–26, 2015
Session 2: March 31–April 2, 2015
Session 3: April 28–30, 2015
Goal: making repayment option available to borrowers by December 31, 2015 51

52. Loan Reaffirmation Agreement
Federal Register – Notice: Comment Request; Reaffirmation Agreement form
“This new form will simplify and standardize the reaffirmation process for the borrower. It will also ensure continued enforceability of the student loan thereby maintaining fiscal accountability to the federal program and the taxpayer.”
Comment period open until March 23, 2015
Docket ID number ED–2015–ICCD–0007

53. Policy Potpourri…

54. Perkins
Barring any Congressional action, the authority to make new Perkins loans will end September 30, 2015
For , Perkins loans first disbursed prior to 10/1/15 will be valid loans and all subsequent disbursements for those loans can be made during the award year

55. Ability to Benefit (ATB)
The Consolidated and Further Continuing Appropriations Act, 2015 reinstated the ATB alternatives for Title IV student eligibility for students enrolled in “career pathway programs”
Applies to students who are enrolled or who first enroll in an eligible program of study on or after July 1, 2014
OPE and OGC are currently reviewing the law and will provide detailed guidance to schools in the near future - stay tuned to IFAP!

56. Unusual Enrollment History (UEH)
For the FAFSA processing year, selection of applicants for UEH Flag has expanded to consider–
An applicant’s prior receipt of, in addition to a Federal Pell Grant, a Federal Direct Loan (not including Direct Consolidation Loans or parent PLUS Loans) 
The prior four, instead of three, award years  
For , UEH Flag evaluation includes the , , , and award years
A school may institutionally-select a student for UEH (not selected by ED) if suspect enrollment problems
Self-selected students treated as if have UEH 3 flag
DCL coming soon

57. Affordable Health Care and COA
If an institution requires health insurance for all or a category of students attending the institution, it may include a reasonable amount for health insurance under “miscellaneous personal expenses” in those students’ COAs (long standing guidance)
The fact that the Affordable Care Act requires individuals to maintain health insurance does not bear on this issue because the cost is not specific to the student’s educational expenses

58. Cohort Default Rates
CDR sanctions based solely on a school’s 3-year rates
CDR benefits are based on school’s three most recent fiscal years for which official CDRs are available
Can be made up of 2 or 3 year rates IF both rates exist for a FY
Must pick one rate (either 2 or 3 year rate) to be used for each FY
Currently, the most recent fiscal year CDRs are FY09, FY10 and FY11 which have official 2 and 3 year rates for each of those FYs
Future FY rates will only have 3 year rates so that by September 2017, the 3 most recent fiscal years will only have 3 year rates

59. Prerequisite Courses
If a student is already admitted into a program of study but needs to take a prerequisite course that is not part of the program but is necessary in order to take a course in their current program of study, the prerequisite course in this scenario is considered “remedial” and falls under all of our remedial coursework regulations – 34 CFR
It is counted against the remedial course limits (30 semester or 45 quarter hours) and must be at least qualitatively evaluated within SAP
If within remedial limits, can be factored into the students enrollment status and COA

60. Disability Insurance for Top Athletes
Question: If a school pays for total permanent disability insurance policies for some of their top student athletes (usually with athletic funds), can these payments be added to the student’s COA?
Answer: For packaging purposes, these payments should be treated as EFA, but may not be treated as a component of cost of attendance, even through use of PJ

61. Third Party Servicers
GEN-15-01, published January 9, 2015, “Third-Party Servicer Institutional Requirements and Responsibilities”
Definition of a Third Party Servicer, 34 C.F.R. §668.2: any individual or entity that contracts with or performs work on behalf of an institution to administer, through manual or automated processing, any aspect of an institution’s responsibilities under the Title IV, HEA programs.
Institutions must report the names of any/all third party servicers to ED via the E-app process,
Must be reported within 10 calendar days of the institution entering into a contract (or any other written or oral agreement) with the third party.

62. Third Party Servicers
Check your contracts to ensure that all requirements are included!
In the contract, the third-party servicer must agree to comply with all statutory and regulatory provisions applicable to the Title IV functions provided by the third party
Your third party servicer
may be subject to FERPA requirements
is subject to the same information security requirements established by the Federal Trade Commission (FTC) for financial institutions as your institution.
must submit annual compliance audits to ED
Questions?
Contact the Third-Party Servicer Oversight Group
(816)

63. Federal Pell Grant Program Reconciliation
Electronic Announcement posted January 23, 2015
Pell Grant Reconciliation, defined: the process by which a school reviews and compares Pell Grant data recorded on the Department of Education’s (the Department’s) systems with the information in the school’s internal records. This process should be performed on a regular basis, and is recommended at least monthly.
Final Reconciliation of a Pell Grant Award Year
Data Submission Deadline: September 30, 2015, for the award year
After this date, COD will not accept upward awards or disbursement adjustments without prior approval for an extension to the established data submission deadlines (downward adjustments will continue to be accepted).

64. COD Updates – March 2015
COD will allow COD Web users to create and submit a Subsidized Usage inquiry to FSA for Subsidized Usage cases that require FSA intervention and can’t be resolved by a school
Done via new Create Subsidized Usage Inquiry page
COD system will update the number of days a credit check is valid from 90 days to 180 days
COD will produce a weekly credit status report in COD Web in CSV format - list of borrowers whose active Original Credit Decision is 'Declined', status of appeals due to extenuating circumstances, PLUS Counseling and endorsers associated with the credit check/loans

65. COD Updates – March 2015
COD will introduce a Subsidized Usage Calculator on COD Web
Users will be able to enter loan data and estimate the students’ subsidized usage based upon the information entered and the loans existing on the COD System
Will allow the user to model potential impacts to the student’s subsidized usage and eligibility
Actions taken via the Subsidized Usage Calculator will NOT result in any changes to the student’s loans on the COD System

66. Your Feedback is Requested
Using the link below, please complete an evaluation of my presentation.
Thank you!
For questions about this presentation,
please feel free to contact me:
Angela Smith, Training Officer

67. Angela Smith, Training Officer angela.smith@ed.gov 312-730-1552
Questions? Contact me!
Angela Smith, Training Officer

68. Will it get reauthorized for it’s birthday??
The HEA turns 50!
Will it get reauthorized for it’s birthday??