Federal Update Ohio PACE Spring Conference April 2014 Agenda - - PDF document

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Federal Update Ohio PACE Spring Conference April 2014 Agenda - - PDF document

For training/discussion purposes only April 2014 Federal Update Ohio PACE Spring Conference April 2014 Agenda Application Processing 2014-15 Gainful Employment Potpourri 2 Application Processing 2014-15 Application Changes and


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SLIDE 1

For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 1

Ohio PACE Spring Conference April 2014

Federal Update

Agenda

  • Application Processing 2014-15
  • Gainful Employment
  • Potpourri

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Application Processing 2014-15 Application Changes and Enhancements

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SLIDE 2

For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 2

FAFSA Completion Initiatives

  • Organizations working with students expressed

interest in working with FSA to further simplify FAFSA completion process

  • Approved partners will offer students the opportunity

to pre-populate data collected by the partner (for example, a VITA site) into FAFSA on the Web (FOTW)

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Issue

  • Student or parent answers “yes” to the asset

threshold question but then reports assets that total less than the Asset Protection Allowance

  • Appears on ISIR as conflicting information requiring

resolution Solution

  • New edit to FAFSA on the Web to prevent this

Preventing Conflicting Asset Information

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Preventing Conflicting Asset Information

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SLIDE 3

For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 3

Issue

  • Income earned from work does not transfer when

students or parents use the IRS Data Retrieval Tool Challenges

  • Income earned from work is not reported separately

when tax filers are married filing jointly, so we don’t know amount applicable to each spouse

  • Schedule K-1 (Form 1065) income must be reported

as part of income earned from work on the FAFSA, but this information is not available for transfer from the IRS

Income Earned from Work

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Income Earned from Work Data Import

  • Solution
  • Marital status other than married and tax return type
  • ther than 1040

− Income earned from work will transfer from IRS

  • If married and/or tax return type is 1040

− Income earned from work will transfer and populate view-only

field “Total Income Earned from Work”

− New worksheet dynamically displays so student/parent can

correct distribute income between spouses and/or add income from Schedule K-1

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Married student filed a 1040

Income Earned from Work Data Import

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SLIDE 4

For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 4

2014-15 FAFSA Parental Information

  • Parental information collection changes
  • See GEN 13-12 April 29, 2013
  • Applies to dependent students when legal parents

live together

− Legal means biological or adoptive − Both parents income and other data must be reported − Regardless of marital status or gender − Higher Education Act Section 475 includes the terms “parent”

and “parents” and not gender-specific terms “mother” and “father”

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Parent 1/Parent 2

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2014-15 FAFSA Parental Information

  • New response of “Unmarried and both parents living

together” will be included as response option for dependent student’s parents

− If option selected, parents will not be presented option of

using IRS Data Retrieval Tool

  • FOTW will have dynamic instructions regarding tax

filing for applicants who select this option

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SLIDE 5

For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 5

Defense of Marriage Act

  • 2014-15 FAFSA

− Applicants and/or parents must respond in accordance with

their legal marital status as of the date of FAFSA completion

  • 2013-14 FAFSA

− New filers must respond in accordance with their legal marital

status as of the date of FAFSA completion

− Earlier filers may change marital status if as of the date the

FAFSA was initially filed they were legally married

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Issue

  • Unable to identify instances where the student or parent

marital status conflicts with the tax filing status

− May result in incorrect income amount reported on FAFSA

Solution

  • Students and parents will begin reporting their tax filing

status on the FAFSA

  • System will compare the tax filing status with the marital

status to determine if potential discrepancies exist

  • Will message accordingly

Tax Filing Status

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Tax Filing Status

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Actual tax filing status will be imported from IRS!

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SLIDE 6

For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 6

Tax Filing Status Discrepancy

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IRS Request Flag 06 – IRS data was transferred from the IRS, but a subsequent change made the student or parent ineligible to use the IRS Data Retrieval Tool

Issue

  • Some students and parents are not provided with the
  • ption to use the IRS DRT, and FAAs don’t know why

− How do you know what documentation to ask for if the

student is selected for verification?

Solution

  • New IRS Display Flags on the ISIR

− Flags will identify the specific reason why a student or parent

was not eligible to use the IRS DRT

IRS Display Flags

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IRS Display Flags - Student

  • Blank = IRS DRT not available
  • A = Dependent student skipped the income and

asset questions – IRS DRT was not displayed

  • B = IRS DRT was displayed to student
  • C = Tax return status not equal to “Already

completed” – IRS DRT was not displayed

  • D = Marital status date greater than or equal to

January 2014 – IRS DRT was not displayed

  • E = First three digits of SSN are 666 – IRS DRT was

not displayed

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For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 7

IRS Display Flags - Student

  • H = Student amended his/her tax return – IRS DRT

was not displayed

  • J = Student filed a Puerto Rican or Foreign tax return

– IRS DRT was not displayed

  • K = Student is married and tax return filing status is

Married Filed Separate Return – IRS DRT was not displayed

  • L = Student is married and tax return filing status is

Head of Household – IRS DRT was not displayed

  • M = Conflict between the student’s marital status and

tax return filing status – IRS DRT was not displayed

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IRS Display Flags - Parent

  • Blank = IRS DRT not available
  • A (if student is dependent) = Dependent student has

special circumstances – IRS DRT was not displayed

  • A (if student is independent) = Independent student

skipped the parent questions – IRS DRT was not displayed

  • B = IRS DRT was displayed to parent
  • C = Tax return status not equal to “Already completed” –

IRS DRT was not displayed

  • D = Marital status date greater than or equal to January

2014 – IRS DRT was not displayed

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IRS Display Flags - Parent

  • E = First three digits of SSN are 666 – IRS DRT was

not displayed

  • F = Non-married parent or both married parents

entered all zeroes in SSN – IRS DRT was not displayed

  • G = Neither married parent entered a valid SSN –

IRS DRT was not displayed

  • H = Parent amended his/her tax return – IRS DRT

was not displayed

  • J = Parent filed a Puerto Rican or Foreign tax return

– IRS DRT was not displayed

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For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 8

IRS Display Flag - Parent

  • K = Parents are married and tax return filing status

is Married Filed Separate Return – IRS DRT was not displayed

  • L = Parents are married and tax return filing status is

Head of Household – IRS DRT was not displayed

  • M = Conflict between the parents’ marital status and

tax return filing status – IRS DRT was not displayed

  • N = Parents’ marital status is “Unmarried and both

parents living together” – IRS DRT was not displayed

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IRS Data Import Scenario

1.

Married parents who filed separately incorrectly answer tax filing status question

2.

Parent cannot authenticate with IRS because tax filing status brought over from FAFSA

3.

Parent changes response to tax filing status question on IRS page and is able to authenticate with IRS

4.

Parent transfers tax data into FAFSA

5.

When data transfers, correct filing status of married filing separately replaces previously reported status

  • f married filing jointly

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IRS Data Import Scenario

5.

When data transfers, correct filing status of married filing separately replaces previously reported status

  • f married filing jointly

6.

Alert displays to tell parents of conflict between marital status and tax filing status

7.

“Transferred from the IRS” labels are removed from all fields that transferred

8.

IRS Request Flag is set to 06 to indicate data was transferred but a subsequent change made parent ineligible to use DRT. IRS Display Flag is set to K

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SLIDE 9

For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 9

Issue

  • Students/Parents return to FOTW to use the IRS

DRT or make other corrections but fail to submit those corrections Solution

  • Modify messaging that displays when a user returns

to FOTW after transferring data from the IRS

  • System will send an e-mail to students with a saved

correction after 7 days of inactivity to encourage them to return to FOTW to submit the corrections

Messaging for Corrections

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Messaging for Corrections

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Postscreening Reason Code 25

  • Two new NSLDS fields in Financial Aid History

section of 2014-15 ISIR

− NSLDS subsidized usage limit applies (SULA) flag − NSLDS subsidized loan eligibility used flag

  • If the SULA flag changes from “Y” to “N” or vice

versa, a system-generated ISIR will be produced with this postscreening reason code

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SLIDE 10

For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 10

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Gainful Employment

Notice of Proposed Rulemaking

  • Notice of Proposed Rulemaking (NPRM) published in

Federal Register on March 25, 2014

− http://www.gpo.gov/fdsys/pkg/FR-2014-03-25/pdf/2014-

06000.pdf

  • Comments are due to the Department no later than

May 27, 2014

  • Proposed regulations establish accountability

framework and transparency framework

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Proposed Metrics

  • Debt-to-earnings (D/E) ratio

− Annual debt-to-earnings rate − Discretionary debt-to-earnings rate − Program could pass, fail, or be in the “zone” − Calculated based on program completers

  • Program cohort default rate (pCDR)

− Calculated like institutional cohort default rate but for the GE

program’s former students

− Program could pass or fail − Calculated based on all students enrolled in the program

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SLIDE 11

For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 11

Proposed Rule

  • A program would lose Title IV eligibility if –

− Fails both debt-to-earnings measures in two out of three

years

− Fails or in the zone for four consecutive years − Fails the program cohort default rate for three consecutive

years

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Proposed Rule

  • Appeals based on alternative earnings

− Earnings data from institutional surveys − Earnings data from state-sponsored data systems

  • Appeals based on mitigating circumstances

− Fewer than 50% of all program completers incurred loan debt

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Proposed Disclosure Requirements

  • Disclose in addition to program information –

− Loan repayment rates − Completion rates − Withdrawal rates − Placement rates − Median loan debt − Percent of students borrowing − Program cohort default rate − Debt-to-earnings rates

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For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 12

Proposed Reporting Requirements

  • Report for six prior award years by July 31 following

final rules effective date

− For example, if effective date is July 1, 2015, report no later

than July 31, 2015 information for award years 2008-2009 through 2013-2014

  • For subsequent award years, report by October 1

following the end of the award year

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Potpourri

Low Cohort Default Rate Exemptions

  • Schools with low cohort default rates are exempt

from the 30-day delay for disbursements to first-time first-year borrowers and from having to make multiple disbursements for single-term loans

  • To be exempt schools must have 3 official cohort

default rates below 15% from the 3 most recently completed fiscal years

  • The rates can be from one calculation (all 2-year

rates) or a combination of 2 and 3 year rates as long as rates are for different fiscal year

− For example – FY 08 2-year; FY 09 3-year; FY 10 2-year

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SLIDE 13

For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 13

Program Integrity Q&A Website

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  • State authorization
  • Repeating coursework
  • Credit hour
  • Ability to benefit
  • Incentive

Compensation

  • Misrepresentation
  • Return to Title IV
  • Satisfactory academic

progress

  • Gainful employment
  • Verification

http://www2.ed.gov/policy/highered/reg/hearulemaking/ 2009/integrity-qa.html

Direct Loan Interest Rates

  • Rates based on the yield of the ten-year T-Note

auctioned at the final auction held prior to June 1, plus add-on

− Rate will update for loans first disbursed on or after July 1,

2014

  • Undergraduate (sub and unsub) - add-on of 2.05%

with cap of 8.25%

  • Graduate Unsubsidized - add-on of 3.60% with cap
  • f 9.5%
  • Parent and Graduate PLUS - add-on of 4.6% with

cap of 10.5%

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Federal Student Aid Application Process

  • FAFSA is the only form a student is required to

complete to be considered for aid from any of the Title IV programs

− The only other information that can be required other than

that to verify application information or to ensure compliance with student eligibility provisions

  • Schools may require additional forms or information

for non-Title IV funding

  • See Electronic Announcement March 18, 2014

− http://www.ifap.ed.gov/eannouncements/031814ApplicationP

rocessforFederalStudentAid.html

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For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 14

Fees, Assessments and Discounts

  • Students may not be charged any fee for completing

the FAFSA or for any other activity or process related to determining student eligibility for Title IV aid

  • Schools must use an amount “required for all

students in the same course of study” to determine the tuition and fees component of the COA

  • Title IV recipients cannot be charged more than

student not receiving aid

− Discounts for students paying early or who pay cash is not

permitted

− See Electronic Announcement March 18, 2014

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FSA PINs and Electronic Signatures

  • Schools or other entities may not ask or allow

students to provide their PIN to any other person or entity including institutional staff

  • Students may not authorize any other person to

apply for a FAFSA PIN on the student’s behalf

  • See Electronic Announcement March 18, 2014

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Importance of Actual Disbursement Date

  • Several terms and conditions of Direct Loans are tied

to actual disbursement date

− Interest begins to accrue on the actual disbursement date

reported by the school

− 120-Day Rule – Borrowers are not responsible for paying any

interest or loan fee if funds are returned to ED within 120 days of actual disbursement date

− Origination fee and interest rate percentages are based on

actual date of first disbursement

− See Electronic Announcement January 29, 2014

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For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 15

COD Credit Check Processing for 2014-15

  • Student identifier information must now be included

in addition to borrower information

− SSN, Date of Birth, First Name and Last Name

  • Will be matched to CPS data across all active award years on file

− If student or borrower information is only available in CPS for

2014-15, COD cannot perform the match until after 2014-15 COD implementation in April 2014

  • If schools cannot delay credit check processing until system

implementation, borrowers can complete the application via StudentLoans.gov

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2012-13 Direct Loan Closeout

  • Schools must closeout the 2012-13 Direct Loan

program year no later than July 31, 2014

− Schools should close out within two months of submitting

final actual disbursements for the program year

  • See Electronic Announcement February 4, 2014

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Paper Checks for Direct Loan Refunds

  • Effective January 1, 2015 COD School Relations

Center will not process paper checks for Direct Loans refunds of cash

− Checks will be returned to sender − See Electronic Announcement February 26, 2014

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For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 16

Online Default Aversion Training

  • Online training on cohort default rate process and

default management now available on FSA’s E- Training website

− http://fsatraining.info − See DCL ANN-14-04 February 24, 2014 − Contains information about draft rates and the challenge

process

− Additional modules will be added in the coming months

  • Adjustments and appeals
  • Default aversion practices

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Impact of Cohort Default Rates

  • See DCL GEN-14-03 February 27, 2014
  • Letter includes summaries of –

− Each cohort default rate challenge − Requests for adjustment − Appeals available

  • Participation Rate Index Challenge and Participation

Rate Index Appeal can provide sanction relief to schools with low percentages of borrowers

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Questions?

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Thank you!

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For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 17

Training Evaluation

To ensure quality training, we ask all participants to complete an online evaluation for each session

  • Go to https://s.zoomerang.com/s/ByronScott

− Evaluation form is specific to Byron Scott

  • Feedback is a tool to help us improve our training and to listen

to our customers

  • Additional concerns about training can be directed to

joann.borel@ed.gov

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Contact Information

If you have follow-up questions about this session, contact me at:

Byron Scott, Training Officer byron.scott@ed.gov 312-730-1534

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