150% Direct Loan Regulations Update
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1 150% Direct Loan Regulations Update CCCSFAAA Conference April 2 nd, 2014 Mark Koveleski, Technical Specialist 4/16/2014 1
2 Agenda What is 150%? What does it mean? Who does it effect? What are the new data elements? Challenges and Resources? Questions? 4/16/2014 2
3 150% Direct Loan Regulations: What is it? May 16 th, 2013 an announcement was released from the DOE On July 6 th, 2012 the Moving Ahead for Progress in the 21 st Century Act (MAP-21) was enacted. With this came new provisions for load indebtedness for students. Essentially, new borrowers (meaning students who have no outstanding loan balance on or after July 1, 2013) will be measured on their progress per each program. 150% is the amount of time allotted for a student to complete their degree while maintaining their subsidized loan eligibility. The idea is to get students to finish their degrees more timely. E.g. 150% of a 4 year BA program = 6 years. The student is eligible for subsidized loans for those 6 years only. 4/16/2014 3
4 150%? What Does That Mean? Maximum eligibility period is 150% of the published length of borrower s current educational program. Varies program-by-program Multiply published length of program by 1.5 Measured in academic years NSLDS will calculate using Enrollment Reporting information COD will calculate using Origination and Disbursement Records 4/16/2014 4
5 150 % Maximum Eligibility Period Program Length 5-Year Bachelor s Degree 4-Year Bachelor s Degree 2-Year Associate s Degree 2-Year Certificate 1-Year Certificate 18-Week Certificate 10-Week Certificate Maximum Eligibility Period 7.50 Years 6.00 Years 3.00 Years 3.00 Years 1.50 Years 27 Weeks 15 Weeks 4/16/2014 5
6 150%: Who Does This Effect? Software Vendors Schools (Compliance Reporting) NSLDS Clearinghouse Systems Students (First Time Borrowers) 4/16/2014 6
7 What does 150% Direct Loan Legislation Mean for Schools? Schools will have to begin capturing and reporting new data elements. These elements include: Three-Quarter Time (Q) Status Program Level Published Program Length Weeks Title IV Academic Year Special Program Indicator Program Enrollment Status Program Enrollment Status Effective Date Student's Program Begin Date Student's Address (optional) 4/16/2014 7
8 Record Type Reporting 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 (new) Student Address 4/16/2014 8
9 Campus Level Reporting Campus-Level Enrollment will continue to provide the same level of detail needed for loan holders to accurately convert loans to repayment. 4/16/2014 9
10 Program Level Reporting Program-Level Reporting is designed to augment the existing data that is reported in Campus-Level Record Type to support 150% Sub Loan Limit. Basic Reporting Rules: Schools will provide details for all programs that a student enrolls until the student is no longer enrolled in that program Unique program is the combination of Classification of Instructional Program (CIP) code and Program Credential Level Schools will be required to report a Campus-Level Record Type when reporting a Program-Level Record Type 4/16/
11 Program Level (Continued) Who to report Program-Level data for: All undergraduate and graduate Title IV Recipients Students with any Subsidized Loans, Unsubsidized Loans, Graduate PLUS Loans, Perkins Loans, Pell Grants, Academic Competiveness Grants or SMART Grants or any Overpayments SULA Eligible Borrowers and SULA Not-Eligible Borrowers Student recipients of Parent PLUS loans Which programs to report: All programs for which a Title IV Recipient is enrolled Title IV Recipients that are enrolled in a single program Title IV Recipients that are enrolled in multiple programs concurrently must have all programs reported Title IV Recipients that are enrolled in multiple programs sequentially must have all programs reported 4/16/
12 More Program Level. Fields Used to Identify a Unique Program CIP Code Six-digit Classification of Instructional Program code (without decimal) identifying a program s academic content Program Credential Level - Level of credential for the educational program indicated on the record Fields Used to Set the Maximum Eligibility Period Published Program Length -The length of the educational program indicated on the record Publish Program Length Measurement Indicates if the measure of time in Published Program Length is years, months, or weeks. Weeks Program Title IV Academic Year - Weeks of instructional time in program's definition of academic year Special Program Indicator - Indicates borrower is enrolled in a special Program 4/16/
13 Just a Little Bit More Fields Used to Collect Enrollment Status Program Enrollment Status Current status for the student at the reported program as of the certification date Program Enrollment Status Effective Date - Date when the program enrollment status took effect Student s Program Begin Date - Date when the student first attended the reported program 4/16/
14 Record Type Record Type will be used to collect student address only Basic Reporting Rules address is an optional field. If not reporting an address, school should not submit an Record Type Multiple addresses may be reported by reporting multiple Record Types Schools will be required to report a Campus-Level Record Type when reporting an E- mail Record Type 4/16/
15 What Will the Challenges be for Schools? Capturing these new data elements Programming Establishing enrollment status by program Maintaining compliance 4/16/
16 The Clearinghouse Supports You Even though FSA is making changes to its enrollment reporting process, the Clearinghouse continues to be your institution s third-party servicer for enrollment reporting. The Clearinghouse has published a new file layout containing all of the newly required fields for enrollment reporting. All major SIS system vendors have been provided the new Clearinghouse file layout. The Clearinghouse recommends that you consult with your SIS vendor for updates and implementation timeframes. It may be necessary to upgrade to a newer version of your SIS to obtain the updated Clearinghouse extract. 4/16/
17 When Can We Start Sending This New Data? You can begin sending us test files on June 16 th, Once you are ready to send a test file of the new layout, you should notify the Clearinghouse by calling our Customer Service department at Please ask to speak with a School Operations Analyst and indicate that you are sending a test file for the new 150% requirements. 4/16/
18 Resources 150% Direct Subsidized Loan Limit Frequently Asked Questions Clearinghouse Programming and Testing Guide More Questions?? ( ) 4/16/
19 Questions? 4/16/
150% SUB LOAN RULES. Implementing regulations 05/16/13; 11/01/13 and 01/17/14
Moving Ahead for Progress in the 21 st Century Act (PL 112-141, 07/12) Limit on Subsidized loan eligibility of 150% of published program length Consolidated Appropriations Act of 2014 (01/14) Directive
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