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1 150% Direct Subsidized Loan Limit, Training Officer U.S. Department of Education First-time borrower and consequences 2 First-Time Borrower Applies only to first-time borrowers as of July 1, 2013: Student who has no outstanding balance on a FFEL or Direct Loan when receiving a Direct Loan on or after July 1, Example A Student has never borrowed before Student enrolls in August 2013 Student receives a Direct Loan Student is a first-time borrower Example B Student received FFEL and Direct Loans prior to July 1, 2013 Student pays off all FFEL and Direct Loans in 2015 Student enrolls in 2017 Student receives a new Direct Loan in 2017 Student is a firsttime borrower 3 U.S. Department of Education 1

2 Consequence: Eligibility Loss Borrower loses eligibility for additional Direct Subsidized Loans when borrower has received Direct Subsidized Loans for 150% of their current academic. Generally measured in time, not dollars. If eligibility is lost, borrower still eligible for Direct Unsubsidized Loans. 4 Consequence: Interest Subsidy Loss Lost eligibility due to 150% limit Did not complete Enrolls in of equal or shorter length Subsidy loss Based on enrollment, not borrowing, or requesting aid. 5 Loss of eligibility 6 U.S. Department of Education 2

3 Determining When Eligibility is Lost Maximum Eligibility All Subsidized Usage s Remaining Eligibility 150% limit is met and further eligibility is lost when Remaining Eligibility is zero (or less). 7 Maximum Eligibility Maximum Eligibility All Subsidized Usage s Remaining Eligibility 150% limit is met (eligibility is lost) when remaining eligibility period is zero (or less). 8 Maximum Eligibility Maximum eligibility period is 150% of the published length of borrower s current or upcoming academic Varies by Multiply published length of by 1.5 Two exceptions Measured in academic years or portions ED will calculate using school-reported information 9 U.S. Department of Education 3

4 Converting Months/Weeks To Years 10 Exception 1: Bachelor s Completion Bachelor s degree-completion s will have a Maximum Eligibility of six years Definition: Only admits students who have completed Associate degree or Two years of prior undergraduate coursework 11 Exception 2: Special Admission Special admission associate degree s will have a Maximum Eligibility of six years Definition: Only admits students who have completed Associate degree or Two years of prior undergraduate coursework Admits students on a competitive basis (i.e., no open enrollment) Prepares students for occupation requiring licensure from state Example: Nursing 12 U.S. Department of Education 4

5 Subsidized Usage Maximum Eligibility All Subsidized Usage s Remaining Eligibility 150% limit is met (eligibility is lost) when remaining eligibility period is zero (or less). 13 Subsidized Usage A Subsidized Usage is the period of time for which a borrower receives a Direct Subsidized Loan Calculated loan-by-loan Measured in academic years or portions Rounded up/down to nearest tenth of a year Includes only periods when Direct Subsidized Loan received ED will calculate using school-reported information Two exceptions 14 Calculating Subsidized Usage Loan : of enrollment for which loan is intended Academic Year: used to track annual loan limits (SAY/BBAY) 15 U.S. Department of Education 5

6 Exception 1: Enrollment Status Full-time = 1.00 Calculated subsidized usage period is prorated by enrollment status Proration occurs before rounding ½-time = 0.50 ¾-time = 0.75 Prorate Subsidized Usage based on enrollment status. 16 Exception 2: Annual Loan Limit Only circumstance where dollars are considered is when a student receives a Direct Subsidized Loan in the amount of the annual loan limit Borrow full annual loan limit Received for less than 1 AY Subsidized Usage = 1 Can only occur for standard-term s or for nonstandard-term SE9W s 17 Determining When Limit Is Met Maximum Eligibility All Subsidized Usage s Remaining Eligibility 150% limit is met and further eligibility is lost when Remaining Eligibility is zero (or less). 18 U.S. Department of Education 6

7 Remaining Eligibility How much eligibility a borrower has left under the 150% limit Accounts for Direct Subsidized Loans received for all enrollment in all s (except teacher certification s) Eligibility lost when remaining eligibility is zero or less ED will calculate using school-reported information 19 Loss of interest subsidy Loss of Interest Subsidy No Remaining Eligibility No Completion Enroll Subsidy loss Subsidy loss is effective on the date of the triggering enrollment. 21 U.S. Department of Education 7

8 Enrollment Types & Subsidy Loss Student lost eligibility Student lost eligibility Student had remaining eligibility Enrolled at least ½ time in same undergraduate Enrolled at least ½ time in an undergraduate of equal or lesser length Enrolled at least ½ time in shorter undergraduate where usage maximum 22 s of Interest Subsidy Borrower with interest subsidy: In school Grace Std. Repay Defer. Forbear. IBR & PAYE Borrower who lost interest subsidy: In school Grace Std. Repay Defer. Forbear. IBR & PAYE Subsidized Unsubsidized 23 Which interest is the borrower s? ED s responsibility Interest accrued before subsidy loss Interest accrued after subsidy loss Borrower s responsibility Subsidy loss is not retroactive to the date of disbursement or from the date of the loss of eligibility. Loss of subsidy is from the date of the enrollment that caused the loss of subsidy. 24 U.S. Department of Education 8

9 Example 1 Student received 3 years of Subsidized Loans while enrolled in a 2-year AA. Student does not complete at the end of the 3 rd year, and enrolls for a 4 th year. Maximum Eligibility All Subsidized Usage s Remaining Eligibility Subsidy Loss 3 Years 3 Years 0 Years Yes, enrolled with no remaining eligibility and without completing 25 Example 2 Student received 3 years of Subsidized Loans in a 2-year. After completing 3 rd year but not completing the, student transfers into a 4-year. End of year 3 of 2-year Upon transfer to 4-year Maximum Eligibility 3 Years 6 Years All Subsidized Usage 3 Years 3 Years s Remaining Eligibility 0 Years 3 Years Subsidy Loss No, borrower has not reenrolled. No, borrower has remaining eligibility. 26 Example 3 Student is enrolled in a 2-year and received 3 years of Subsidized Loans for enrollment in that. Student enrolls for one more semester in the 2-year, and then transfers to a 4-year. Before transfer to 4-year Upon transfer to 4-year Maximum Eligibility 3 Years 6 Years All Subsidized Usage 3 Years 3 Years s Remaining Eligibility 0 Years 3 Years Subsidy Loss Yes, borrower enrolled after eligibility loss. No, borrower enrolled in a longer. Student regains eligibility for Subsidized Loans upon transfer. Any new Subsidized Loans will have interest subsidy. Prior Subsidized Loans that lost subsidy do not regain subsidy. 27 U.S. Department of Education 9

10 Example 4 Student received 5 years of Subsidized Loans while enrolled in a 4-year BA. The student completes the and then enrolls in a 2-year AA. End of year 5 of 4-year Upon transfer to 2-year Maximum Eligibility 6 Years 3 Years All Subsidized Usage 5 Years 5 Years s Remaining Eligibility 1 Year -2 Years Subsidy Loss No, borrower has remaining eligibility. No, borrower graduated from prior on time. 28 Example 5 Student received 5 full years of Direct Subsidized Loans while enrolled in a 4-year BA. The student does not complete the and then enrolls in a 2-year AA. End of year 5 of 4-year Upon transfer to 2-year Maximum Eligibility 6 Years 3 Years All Subsidized Usage 5 Years 5 Years s Remaining Eligibility 1 Year -2 Years Subsidy Loss No, borrower has remaining eligibility. Yes, transfer caused borrower to exceed maximum eligibility. 29 Special provisions 30 U.S. Department of Education 10

11 Preparatory Coursework For Enrollment in an Undergraduate Program For Enrollment in a Grad/Professional Program Maximum Eligibility is 150% of for which coursework is preparing the student. Maximum Eligibility is 150% of for which borrower most recently received Direct Subsidized Loan. Subsidized Usage s count against maximum eligibility. Subsidized Usage s count against maximum eligibility. Enrolling could result in loss of interest subsidy. NOT possible to lose interest subsidy by enrolling. 31 Teacher Certification Programs Programs that do not lead to a degree/certificate at institution, but lead to State credential that is required for teaching Total subsidized usage period attributable to loans received for teacher certification s Total subsidized usage period attributable to loans received for all other undergraduate s and preparatory coursework Not only does the "clock restart", but the borrower cannot lose interest subsidy by enrolling in teacher certification 32 Loan & Academic Year 33 U.S. Department of Education 11

12 Basics Loan period Payment periods for which student received and kept DL funds Keep: If student withdraws and keeps even $1 of loan disbursement for PP If student cancels portion of disbursement but keeps at least $1 Academic year Dates tied to how school tracks annual loan limits Single-term AY is never correct SAY, BBAY1, BBAY2, BBAY3 For SAY schools: If summer is a required, always include summer If summer is not required, only include summer if student attends, receives, and keeps loan 34 Example 6 Student at SAY (fall/spring) is graduating at end of fall term. Loan period Fall term only Academic year Fall and spring term Even though student is not enrolled in both terms 35 Example 7 Student starts at BBAY 1 school in spring term. SAY is fall/spring. Loan period Spring term only Academic year Spring and summer term BBAY is comprised of number of terms in SAY 36 U.S. Department of Education 12

13 Example 8 Student starts at BBAY 3 school at 30 clock-hours/week. Title IV AY is 900 clock-hours and 30 weeks. Program is 540 clock-hours and 18 weeks. Loan period of time it will take the student to complete greater of: 540 clock-hours 18 weeks of instructional time Academic year of time it would take student to complete: 900 clock-hours 30 weeks of instructional time 37 Minimum Loan s For credit-hour, standard-term or non-standard term SE9W s, minimum loan period is the term For clock-hour, non-term or non-standard term NSE9W s, minimum loan period is the lesser of: The length of the The remaining portion of the The academic year 38 Overlapping Academic Years If student transfers into your school and an academic year reported by prior school has not elapsed: For credit-hour s using standard terms or non-standard terms but that are SE9W, report your own academic year and ignore prior school s For non-term or clock-hour s, use prior school s academic year dates 39 U.S. Department of Education 13

14 Example 9 Student attended School A and received $1,750 in subsidized loans as a firstyear student (the loan was originally fall/spring for $3,500, but the student withdrew and School A modified the existing loan). School A uses SAY to track annual loan limits and defines its SAY as fall and spring. 8/25/ /17/2014 8/25/2014-5/10/2015 Student transfers to School B for spring, which uses BBAY 1 to track annual loan limits. Student can only receive remaining $1,750 until SAY from prior school ends. 1/5/2015-5/15/2015 1/5/2015-8/21/2015 After SAY from prior school ends, student can receive another $1,750 before the end of the BBAY. Though the $1,750 from School A not longer counts, the first $1,750 from School B counts. 40 Example 10 Student attended School A and received $1,750 in subsidized loans as a firstyear student. 8/25/ /17/2014 8/25/2014-5/10/2015 Student transfers to School B to start a 1-year clock-hour. Student can only receive remaining $1,750 until SAY from prior school ends. 1/5/2015 5/10/2015 8/25/2014-5/10/2015 After SAY from prior school ends, student progresses to next annual loan limit. 41 Reporting COD & NSLDS 42 U.S. Department of Education 14

15 New Reporting Requirements Schools are required to report information about a student s of study to COD & NSLDS. In COD, new tags are mixed between award-level and disbursement-level tags. These are required tags for loans and forward. In NSLDS, -level reporting is a new record type altogether. These are required fields for any roster generated on/after October 1, Program-level enrollment is required retroactive to July 1, 2014 Schools must report the most recent enrollment status for any student who is or was enrolled in on/after July 1, New Data Elements Data Item COD NSLDS Program Length X X CIP Code X X CIP Code Year X Credential Level X X Title IV Academic Year X X Special Program Indicator X X Payment Start Date X Program Indicator X Enrollment Status X X Enrollment Status Effective Date X Program Begin Date X 44 What is a? A is defined as the unique combination of: OPEID CIP Code Credential Level Program Length To the extent that a student is enrolled in coursework that is associated to multiple CIP Codes, credential levels, or lengths, the student is in multiple s. See DCL GEN U.S. Department of Education 15

16 NSLDS Who Must You Report Students who appear on your roster NSLDS will place students on your roster if: You award/disburse aid to the student at your school You add the student to transfer student monitoring You certify an in-school deferment form for a student 46 Which s to report? COD Longest DL-eligible NSLDS All s Except defermentonly schools Program Indicator Coursework that does not lead to a degree or certificate at the school is not a and should not be reported unless it is: Preparatory coursework, teacher certification coursework, or Part of a 2+2 transfer at a community college 47 Program Length COD Tags Award-Level NSLDS Program-Level In COD, you can only send one tag. Pick one unit to report length in. PublishedProgramLengthYears PublishedPorgramLengthMonths Published Program Length Published Program Length Unit PublishedPorgramLengthWeeks 48 U.S. Department of Education 16

17 Program Length GE Program Report what is in GE disclosure All others Report what is on website, in catalog, or other promotional materials School determines length to report using definition of normal time Normal time Amount of calendar time is designed to take a full-time student 4 years for typical bachelor s degree 2 years for typical associate degree 49 CIP Codes COD Tag Disbursement- Level NSLDS Program-Level CIPCode CIP Code You must report valid CIP Codes. Decimal is express in COD; implied in NSLDS. CIP Code Year 50 CIP Codes You decide what CIP Code to report Must be from CIP 2010 list Undeclared majors = general studies ( ) If there is not a more specific CIP Code that fits, use a more general CIP Code, but be as specific as possible 51 U.S. Department of Education 17

18 Credential Level Description COD NSLDS Undergraduate certificate 1 01 Associate degree 2 02 Bachelor s degree 3 03 Post-baccalaureate certificate 4 04 Master s degree 5 05 Doctoral degree 6 06 Professional degree 7 07 Graduate/professional certificate 8 08 Non-credential coursework Difference between 4 and 8 is that 4 is undergraduate and 8 is graduate. 52 Title IV Academic Year COD Tag Award-Level NSLDS Program-Level WeeksProgramAcade micyear Weeks of Instructional time in Title IV Academic Year Only required for s in weeks/months or preparatory coursework (grad.) Title IV Academic Year 34 CFR 668.3: Minimum of 26 weeks of instructional time for clock-hour s Minimum of 30 weeks of instructional time for credit-hour s Report your definition, not the minimums 53 Special Program Indicator Description COD NSLDS Special Admission Associate Degree Program A A Bachelor s Degree Completion Program B B Not Applicable N N Preparatory Coursework Graduate Professional Program P P Non-Credential Teacher Certification Program T T Preparatory Coursework Undergraduate Program U U 54 U.S. Department of Education 18

19 Reporting Special Programs Special Admission Associate Degree Programs SPI Program Length A 4 years Bachelor s Degree Completion SPI Program Length B 4 years 55 Reporting Special Programs Preparatory Coursework required for admission to graduate/professional : Field COD NSLDS CIP Code Of requiring coursework Of requiring coursework Credential level Published Program Length N/A Length of requiring coursework Title IV Academic Year Always; report your school s definition If length is in weeks/months; report your school s definition Special Program Indicator P P 56 Reporting Special Programs Preparatory Coursework required for admission to undergraduate : Field COD NSLDS CIP Code Of requiring coursework Of requiring coursework Credential level Published Program Length Title IV Academic Year Length of requiring coursework If length is in weeks/months Length of requiring coursework If length is in weeks/months Special Program Indicator U U 57 U.S. Department of Education 19

20 Enrollment Status Report enrollment status as it stood on the date that you made the first disbursement of the loan for the payment period Subsequent disbursements within payment period may either use: Enrollment status from first disbursement for payment period or Enrollment status as of the date of the disbursement To COD, non-term or clock-hour s always report full-time 58 Enrollment Status: Example You disburse more frequently than required and believe the student will enroll full-time for the duration of the LP. Loan Payment 1 Payment 2 Disb. 1 Disb. 2 Disb. 3 Disb. 4 8/25/ /5/2014 1/3/2015 2/28/2015 F F F F 8/25/2014 8/25/2014 1/5/2015 1/5/2015 Anticipated Anticipated Anticipated Anticipated Loan Payment Disbursement No. Disbursement Date Enrollment Status Payment Begin Date Anticipated/Actual Disbursement 59 Enrollment Status: Example You disburse for the first payment period and the student is not actually full-time. When reporting disbursement, change enrollment status. Loan Payment 1 Payment 2 Disb. 1 Disb. 2 Disb. 3 Disb. 4 8/25/ /5/2014 1/3/2015 2/28/2015 Q F F F 8/25/2014 8/25/2014 1/5/2015 1/5/2015 Actual Anticipated Anticipated Anticipated 60 U.S. Department of Education 20

21 QUESTIONS? Subject: Include organizational affiliation 61 Contact Information For questions about this training, contact me:, Training Officer For comments on training, contact: Annmarie Weisman, Training Supervisor Thank you for coming! Training Feedback To ensure quality training we ask all participants to please fill out an online session evaluation Go to Evaluation form is specific to This feedback tool will provide a means to educate and inform areas for improvement and support an effective process for listening to our customers 63 U.S. Department of Education 21