For training/discussion purposes only April 2014 150% Direct - - PDF document

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For training/discussion purposes only April 2014 150% Direct - - PDF document

For training/discussion purposes only April 2014 150% Direct Subsidized Loan Limit - How it Affects Your School and Your Students Ohio PACE Spring Conference April 2014 Agenda Regulations, definitions and calculations School


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

Ohio PACE Spring Conference April 2014

150% Direct Subsidized Loan Limit - How it Affects Your School and Your Students

Agenda

  • Regulations, definitions and calculations
  • School reporting requirements
  • Departmental responsibilities

2

Regulations Definitions and Calculations

3

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

Subsidized Loan Limitation

  • Public Law 112-141 established a limit of how

many years a student may receive subsidized loans

  • Applies to “first-time” borrowers on or after July 1,

2013

  • First-time borrower is one who –

− Has no balance on any FFEL or Direct Loan on July 1,

2013

− Receives first Direct Loan (any type) on or after July 1,

2013

4

Subsidized Loan Limitation

  • When student has received subsidized loans for

150% of the published time of the academic program –

− The student may not receive any additional subsidized

loans for that program or any program of equal or lesser length

− Borrower still eligible for unsubsidized loans

  • Generally measured in time, not dollars
  • Special calculation for transfer students and less-

than-full-time students

5

Subsidized Loan Limitation

  • Law waived requirement for negotiated rulemaking

and publication of regulations in accordance with master calendar

  • Interim Final Rule published May 16, 2013

− Effective upon publication − Revised 34 CFR 685.200, 685.202 and 685.304

  • Final regulations published January 17, 2014

− Final regulations effective March 18, 2014

  • http://www.ifap.ed.gov/fregisters/attachments/FR011714.pdf

6

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

Components

  • Maximum Eligibility Period - 150% of the published

length of the educational program in which borrower is currently enrolled

  • Subsidized Usage Period – Period of time for which

a borrower received a Direct Subsidized Loan

  • Remaining Eligibility Period – Difference between

the Maximum Eligibility Period and the total of all Subsidized Usage Periods

7

Maximum Eligibility Period

less Total of Subsidized Usage Periods equals Remaining Eligibility Period

*150% Limit Met when Remaining Eligibility Period equals zero (or less than zero)

8

Determining When 150% Limit Is Met Maximum Eligibility Period

9

  • Maximum eligibility period is 150% of the

published length of the borrower’s current or upcoming educational program

− Varies by program − Multiply published length of program by 1.5 − Measured in academic years or portions − ED will calculate using school-reported information

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

Two Exceptions

  • Bachelor’s degree-completion programs have MEP
  • f 6 years

− Only admit students who have completed associate degree

  • r 2 years of prior coursework
  • Special admission associate degree programs

have MEP of 6 years

− Only admit students who have completed associate degree

  • r 2 years of prior coursework
  • Admits student on a competitive basis (no open enrollment)
  • Prepares students for occupation requiring licensure from state

(for example, Nursing)

10

Subsidized Usage Period

  • Subsidized Usage Period – The period of time for

which a borrower receives a Direct Subsidized Loan

− Calculated on loan-by-loan basis − With one exception, not related to amount of loan − Measured in academic years and rounded up or down to the

nearest tenth of a year

− Includes only periods when Direct Subsidized Loan was

received

− COD will calculate based on school-provided information

11

Calculating Subsidized Usage Period

  • Number of days in the loan period divided by number
  • f days in the loan’s academic year

− Loan period – Beginning and ending dates of period covered

by loan

− Academic year – Beginning and ending dates of the academic

year used for annual loan limit progression

  • Either a Scheduled Academic Year (SAY) or a Borrower Based

Academic Year (BBAY)

  • Likely not the same as the Title IV academic year because of

breaks and summers

12

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

Calculating Subsidized Usage Period

𝑇𝑣𝑐𝑡𝑗𝑒𝑗𝑨𝑓𝑒 𝑉𝑡𝑏𝑕𝑓 𝑄𝑓𝑠𝑗𝑝𝑒 = 𝐸𝑏𝑧𝑡 𝑗𝑜 𝑀𝑝𝑏𝑜 𝑄𝑓𝑠𝑗𝑝𝑒 𝐸𝑏𝑧𝑡 𝑗𝑜 𝐵𝑑𝑏𝑒𝑓𝑛𝑗𝑑 𝑍𝑓𝑏𝑠

Loan Period: Period

  • f enrollment for

which loan is intended Academic Year: Period used to track annual loan limits (SAY/BBAY)

13

Subsidized Usage Period Academic Year

1.

Title IV academic year must be defined

a.

Minimum of 900 clock hours and 26 weeks of instruction 2.

Academic year used to determine Direct Loan annual loan limits

a.

Use BBAY period, which includes all calendar weeks

  • Subsidized usage period usually based on second

definition

14

Converting Months or Weeks to Years

15

If the published length of the program is measured in months or weeks, ED will convert the school reported months or weeks to years (or portions of years) –

Days in Academic Program Days in Title IV Academic Year = Program Length

Month = 30 days Week = 7 days

  • This is the exception where the Title IV defined academic

year is used

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

Converting Months or Weeks To Years

  • Weeks Example –

−Clock hour school defines its Title IV academic year as

26 weeks: 182 days

−Program A’s published length is 18 weeks: 126 days

  • 126 days divided by 182 days = 0.69 years, round to 0.70

−Program B’s published length is 35 weeks: 245 days

  • 245 days divided by 182 days = 1.35 years, round to 1.40

−Program C’s published length is 48 weeks: 336 days

  • 336 days divided by 182 days = 1.85 years, round to 1.90

16

Converting Weeks or Months to Years

  • Program is 600 clock hours and 20 weeks of instruction

Scheduled academic year is 900 clock hours and 26 weeks

  • f instruction
  • Student receives a subsidized DL for the program

Begin Date End Date Number of Days Loan Period August 27, 2013 January 13, 2014 140 Academic Year August 27, 2013 February 24, 2014 182

Subsidized Usage Period = 140/182 = .76 Years Rounded to .8 Years

17

Determining When Eligibility is Lost

18

Maximum Eligibility Period All Subsidized Usage Periods Remaining Eligibility Period

150% limit is met and further eligibility is lost when Remaining Eligibility Period is zero (or less)

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

Subsidized Loan Limitation - Transfers

  • Students’ maximum time to receive subsidized

loans is established based on the length of the program in which the student is enrolled

  • Remaining subsidized eligibility is calculated by

subtracting from maximum eligibility the time the student has already received subsidized loans

19

Remaining Eligibility Period Calculation

Examples

  • Student receives 3 years of subsidized loans while

enrolled in a 2-year program

− Student transfers to a 4-year BA program

  • Student has 3 years of remaining subsidized loan eligibility
  • Student receives 3 years of subsidized loans while

enrolled in a 4-year BA program

− Student enrolls in a 2-year AA program

  • Student has no remaining subsidized loan eligibility

20

Remaining Eligibility Period Calculation

  • Borrower enrolls in a 2-year program with maximum

eligibility period of 3 years

− Receives 2.5 years of subsidized loans − Has 0.5 years remaining eligibility in that program

  • Borrower enrolls in a 1-year clock hour program

− Minimum permissible loan period is program length of one year − Student cannot borrow because remaining eligibility period is

less than minimum permissible loan period

− No loss of subsidy because borrower has remaining eligibility –

does not matter that loan can’t be made

21

Minimum loan period length in a clock-hour program is lesser of length of program or academic year. School cannot disburse a Direct Subsidized Loan to this student.

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

Loss of Interest Subsidy Benefits

Lost eligibility due to 150% limit Did not complete program Enrolls in program of equal or shorter length Subsidy loss Based on enrollment, not borrowing or requesting aid!!

22

Loss of Interest Subsidy Benefits

  • A student who loses eligibility for additional

subsidized loans loses interest subsidy on previously received subsidized loans if –

− Student did not complete program

  • AND continues on at least a half-time basis in same program
  • OR enrolls in another undergraduate program of the same or

shorter length

  • Effective on the date of the student’s continued or

new enrollment

23

Interest Subsidy Loss

  • Loss of subsidy begins the date of the enrollment

that causes the loss of subsidy

− Not retroactive to date of disbursement, or date of loss of

eligibility for additional subsidized borrowing

  • Department is responsible for interest accrued

before subsidy loss

  • Borrower is responsible for interest accrued after

subsidy loss

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

  • Responsibility for interest based on continued

enrollment, not borrowing or Title IV receipt

  • Loan remains a Direct Subsidized Loan

− Without interest benefits

  • Unpaid accrued interest is capitalized in same

manner as for Direct Unsubsidized Loans

  • If interest benefits are lost, they are permanently

lost

Loss of Interest Subsidy Benefits

25

Loss of Interest Subsidy Example

26

  • Borrower enrolls in 4-year program – maximum

eligibility period is 6 years

− Receives 4 years of Direct Subsidized Loans − Has 2 years of remaining eligibility in this program − Borrower does not complete program

  • Borrower enrolls in a 1-year program – maximum

eligibility period is 1.5 years

− Borrower has no remaining eligibility − Borrower loses interest subsidy because of enrollment in

shorter program, even with no additional loans.

Impact of Graduation

27

Remaining Eligibility Period < 0 Graduation Triggering Enrollment No sub eligibility No subsidy loss

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

No Remaining Eligibility

  • Borrower enrolls in 4-year program – maximum

eligibility period is 6 years

− Receives 4 years of Direct Subsidized Loans and

completes the program

− Has 2 years of remaining eligibility in this program

  • Borrower enrolls in 1-year program – maximum

eligibility period is 1.5 years

− Borrower has no remaining subsidized eligibility − Borrower does not lose interest subsidy because she/he

completed the earlier program

28

Direct Unsubsidized Loan Eligibility

  • Students can only receive an unsubsidized loan

(base or additional) for a loan period if the student has been awarded the full amount of her/his eligibility for a subsidized loan

  • Student not awarded full subsidized loan eligibility

may not receive any unsubsidized loan for the same loan period

29

Loan Counseling

  • Entrance and exit counseling regulations updated

to include requirements related to 150% Direct Subsidized Loan limit

  • All counseling on StudentLoans.gov has been

updated to include required information

  • Schools must ensure that all Direct Loan

counseling materials contain required information

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

31

School Reporting Requirements

Loan Period and Academic Year Reporting

  • For all loans, schools must –

− Correctly report to COD the academic year and loan period

dates

− Update dates as necessary − Applies to all borrowers with loans with first disbursement

dates on or after July 1, 2013

  • Guidance and examples

− DCL GEN-13-13 posted May 10, 2013 − 150% Loan Limit Webinar #1 recording posted to IFAP

under DCL ANN-13-08

  • http://www.ifap.ed.gov/dpcletters/ANN1308.html

32

Loan Period and Academic Year

  • Academic year is the period to which the annual

loan limit applies

  • For clock-hour programs this corresponds to the

period of time required for borrowers to complete the coursework in a Title IV academic year

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

Academic Year Calculation

  • For programs that are less than an academic year in

length schools must determine how long it would take a student to complete an academic year

− Example – program is 700 clock hours offered over 32 weeks

  • f instructional time and students attend 22 clock hours per

week

  • Academic year is 26 weeks and 900 hours
  • Loan period is beginning and end of 32-week program
  • Academic year is from the start of the program though the later of

completion of 26 weeks of instruction or 900 clock hours

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900 clock hours in AY 22 hours per week = 41 weeks to complete academic year

Updating Loan Period

  • Student does not enroll for a payment period covered

by the originally reported loan period

  • Student withdraws from a payment period and all loan

funds associated with the payment period are returned (R2T4)

  • Student cancels all of a disbursement of a loan that is

attributable to a payment period

  • Student is not otherwise eligible for a loan for a

payment period covered by the loan period

  • Student in a clock-hour programs is not progressing to

the next payment period as scheduled

35

Updating Academic Year

  • Student in a clock-hour program is not progressing

to the next payment period as scheduled

  • If updating loan period or academic year is required

as a result of an R2T4 calculation, update COD within 15 days of date of R2T4 calculation

  • If updating due to slow progression, update at end
  • f loan period or withdrawal date

36

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

Example 9: Borrower Enrolled in Clock-Hour Program That is One Academic Year in Length

37

Student’s Enrollment Pattern Anticipated Actual Length of Program Length of Program School’s Reporting to COD Initial Updated Begin Date End Date Begin Date End Date Loan Period July 29, 2013 January 31, 2014 No Update No Update Academic Year July 29, 2013 January 31, 2014 No Update No Update

Example 10: Borrower Enrolled in Clock-Hour Program That is One Academic Year in Length, Withdraws Between Payment Periods

38

Student’s Enrollment Pattern Anticipated Actual Length of Program Withdrew After First Payment Period School’s Reporting to COD Initial Updated Begin Date End Date Begin Date End Date Loan Period July 29, 2013 January 31, 2014 July 29, 2013 October 25, 2013 Academic Year July 29, 2013 January 31, 2014 No Update No Update Example 11: Borrower Enrolled in Clock-Hour Program That is One Academic Year in Length, Withdraws During Payment Period and All Funds Returned for Payment Period

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Student’s Enrollment Pattern Anticipated Actual Length of Program Withdrew From Second Payment Period School’s Reporting to COD Initial Updated Begin Date End Date Begin Date End Date Loan Period July 29, 2013 January 31, 2014 July 29, 2013 October 25, 2013 Academic Year July 29, 2013 January 31, 2014 No Update No Update

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

Example 12: Borrower Enrolled in Clock-Hour Program That is Less Than One Academic Year in Length

40

Student’s Enrollment Pattern Anticipated Actual Length of Program Length of Program School’s Reporting to COD Initial Updated Begin Date End Date Begin Date End Date Loan Period July 1, 2013 September 20, 2013 No Update No Update Academic Year July 1, 2013 December 27, 2013 No Update No Update

Example 13: Borrower Enrolled in Clock-Hour Program, Fails to Progress As Scheduled

41

Student’s Enrollment Pattern Anticipated Actual Length of Program, Timely Progression Length of Program, Untimely Progression School’s Reporting to COD Initial Updated Begin Date End Date Begin Date End Date Loan Period July 1, 2013 September 20, 2013 July 1, 2013 October 4, 2013 Academic Year July 1, 2013 December 27, 2013 July 1, 2013 January 10, 2014

Short-Term Programs in 2013-2014

  • First-time borrowers are always eligible to receive their

first Subsidized Loan under the 150% limit

  • Most borrowers will not receive a second loan before

schools begin using 2014-2015 COD that will track the 150% limit for schools

  • Possible for students in short-term programs to have

150% eligibility limitation

  • School must make own determination – can use ED

developed spreadsheet

  • See 150% Electronic Announcement #5 for more

information, posted November 12, 2013

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

Short-Term Programs in 2013-2014

For this specific purpose only a short-term program

  • ne that is shorter than:
  • 1.5 years
  • 10 months
  • 40 weeks

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School determines eligibility School using COD for 2013- 2014 Receiving second loan for 2013-2014 In short- term programs First-time borrowers

School Calculation of Remaining Eligibility

  • Schools must determine a borrower’s remaining

eligibility period only if –

− Borrower is a new borrower on or after July 1, 2013 − Borrower previously received a Direct Subsidized Loan first

disbursed on or after July 1, 2013

− Borrower is enrolled a program shorter than 1.5 years, 10

months, or 40 weeks

− The new loan will be originated using 2013-14 COD system

  • Updated worksheet posted in 150% Electronic

Announcement #11 March 10, 2014 and must be used beginning March 18, 2014

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COD Reporting Requirements

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  • Loan Period Dates
  • Academic Year Dates

Existing

  • CIP
  • Credential Level
  • Program Length
  • Length of Title IV Academic Year
  • Flags for Prep Coursework
  • Flag for Teacher Certification
  • Enrollment Status (full, ½, ¾)
  • Payment Period Begin Date

New for 2014-2015

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

COD Reporting for 2014-15

  • Beginning with 2014-2015, schools will report to COD

additional student and program information –

− Student’s Enrollment Level (FT, TQT, HT) − Classification of Instructional Program Code (CIP) − Credential Level (Certificate, Diploma, Degree) − Length of Program – years, months, weeks − Special Program Flag – Teacher Certification or Preparatory

Coursework

− Payment Period Begin Dates – prorate subsidized usage when

payment period enrollment is less than full time

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New Reporting Requirements

  • Schools will be required to report enrollment to

NSLDS at a minimum of every 60 days

  • Reporting of new enrollment data will begin July 1,

2014

− Retroactive reporting of all programs prior to July 1, 2014

is not required

− Programs in which a borrower is enrolled on July 1, 2014

may have a Program Start Date and Enrollment Status Effective Date prior to July 1, 2014

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NSLDS Reporting Requirements

48

  • Enrollment Status – ½ and FT

Existing

  • CIP
  • Credential Level
  • Program Length
  • Length of Title IV Academic Year
  • Flags for Prep Coursework
  • Flag for Teacher Certification
  • Enrollment Status - FT, ¾, ½

New

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

NSLDS Record Type Reporting

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Campus-Level

Certifying 8-digit OPEID “Move To” 8-digit OPEID Student Name, SSN, and DOB Student Physical Address Student Phone Number Certification Date Enrollment Status Enrollment Status Effective Date Anticipated Completion Date Term Begin and End Dates

Program-Level (new)

Classification of Instructional Program (CIP) Code Program Credential Level Published Program Length Publish Program Length Measurement (Years, Months, Weeks) Weeks Title IV Academic Year Special Program Indicator Program Enrollment Status Program Enrollment Status Effective Date Student’s Program Begin Date

E-mail (new)

Student E-mail Address

49 50

Department of Education Responsibilities

Department Responsibilities

  • ED/FSA will calculate and inform students and

institutions

− CPS – Codes and comments on SARs and ISIRs − NSLDS – New borrower − NSLDS – Subsidized Usage Period − NSLDS – Loss of subsidy indicator − COD – Reports to schools − COD – Editing and enforcement − Direct Loan Servicers – Loss of subsidy benefits

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For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 18

COD Processing

52

The borrower is a first-time borrower School submits origination record to COD Subsidized Usage Period > Remaining Eligibility Period COD will reject the loan

COD Role

  • Each time school submits an origination or

disbursement record COD will:

− Calculate Subsidized Usage Periods, including the new

loan

− Inform school of borrower’s Maximum Eligibility,

Subsidized Usage, and Remaining Eligibility periods

  • COD will also inform borrower in disclosure

statement

53

NSLDS Changes

  • New Loan Type – D0

− Identifies Direct Subsidized Loan where 150% Subsidized

Usage Limit Applies (SULA)

− NSLDS treats similar to existing D1 loan type − Included in calculation of annual and maximum aggregates

  • CPS was not ready to process D0 loan types until

processing begins for 14-15 FAFSAs

− NSLDS will convert D0 to D1 when transferring loan data

to CPS for 13-14

− Some D1 loans on CPS outputs during this period will

actually be D0 loan types

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For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 19

NSLDS Updates

  • School Portfolio Report

− Update to include Subsidized Usage Limit Applies (SULA)

flag

  • Y = Borrower subject to 150% Direct Subsidized Loan limit

provision

  • N = Borrower not subject to 150% loan limit provision
  • Blank = Not reported by servicer or not applicable

− D0 loan type added to report output as an option for the

loan type field.

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NSLDS Role

  • NSLDS will determine when continued or new

enrollment results in loss of interest subsidy benefits.

− If yes, NSLDS will notify federal loan servicer that borrower

is responsible for accruing interest

− Federal loan servicer will notify borrower of interest

responsibility

56

Other Changes to NSLDS

  • Modify professional access and student view to

display 150%-related information

  • Modify reports available to schools to include

150%-related information

  • Pass information about student’s current

Subsidized Usage Period and whether the student has lost interest subsidy to CPS, for inclusion on the SAR/ISIR

  • Inform Direct Loan servicers of borrowers

enrollment and loss of interest subsidy

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For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 20

Resources and References

  • Interim final regulations published in Federal

Register May 16, 2013

  • Final regulations published in Federal Register

January 17, 2014

  • Dear Colleague Letter

− GEN-13-13, May 10, 2013

  • IFAP 150% Subsidized

Direct Loan Information

58

Questions?

E-mail: 150Percent-Questions@ed.gov Subject: Include organizational affiliation

59

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

Please provide any comments regarding this training

  • r the trainer to:

Jo Ann Borel, Title IV Training Supervisor joann.borel@ed.gov 409-579-3776

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For training/discussion purposes only April 2014 Byron Scott U.S. Department of Education 21

Contact Information

Your Chicago regional trainers

  • Byron Scott, Training Officer

byron.scott@ed.gov 312-730-1534

  • Angela Smith, Training Officer

angela.smith@ed.gov 312-730-1552

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