150% Limit on Direct Loan Interest Subsidy Part Two

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1 150% Limit on Direct Loan Interest Subsidy Part Two FAPSC 2014 Annual Conference Aventura, Florida Rick Renshaw, FSA Training Officer Basic Formula Maximum Eligibility Period (MEP) Total Subsidized Usage Period (SUP) Remaining Eligibility Period (REP) Maximum Eligibility Period (MEP) Calculated by COD based on disbursement records. Calculated by NSLDS based on Enrollment Reporting Subsidized Usage Period (SUP) Calculated by COD and sent to NSLDS Remaining Eligibility Period (REP) Calculated by COD based on disbursement records. Calculated by NSLDS based on Enrollment Reporting 2 CPS Inform school of first-time borrower and progress toward limit Inform student that they are subject to a limit COD Determine who is a first-time borrower Calculate maximum and remaining eligibility period and subsidized usage period Reject loans for ineligible borrowers Inform schools NSLDS Calculate maximum eligibility period Determine eligibility for interest subsidy Inform schools Inform servicers Servicers Stop subsidy Communicate with borrower 3 1

2 Phase 1 COD Website & Reporting Enhancements Phase 1 of 150% Subsidized Loan Limitation In June of last year, COD implemented Phase 1 of the system modifications necessary to accommodate the legislation COD began to identify first-time borrowers for whom a new Subsidized Usage Limit Applies (SULA) flag was to be set The flag was displayed as a non-editable date on the COD Person Information screen Warning edit #200 was returned as well in the Common Record Response identifying that borrower as a firsttime borrower COD generated a report identifying first-time borrowers at your school 5 COD Person Information SULA Added 6 2

3 Phase 1 of 150% Subsidized Loan Limitation COD also made available an Excel utility that helped you identify any award year borrowers that could have lost eligibility AND Provided a means to track those first-time borrowers in a qualifying teacher certification program for the award year 7 COD Reporting Requirements Loan Period and Academic Year Reporting Loan Date Reporting to COD Effective for all loans, schools must Correctly report to COD the SAY/BBAY dates and the Loan Period dates; and Update such dates, when necessary For all loans for all borrowers where the loan has a first disbursement date of on or after July 1, 2013 Incorrect reporting could result in a borrower improperly losing eligibility for Direct Subsidized Loans 9 3

4 Loan Period and Academic Year Reporting Guidance and examples related to how schools must report a Direct Loan s academic year dates and loan period dates to COD are included in Dear Colleague Letter GEN-13-13,posted to IFAP on May 10, % Loan Period and AY Reporting Webinar #1 Recording posted to IFAP under ANN For all loans for all borrowers where the loan has a first disbursement date of on or after July 1, Academic Year Reporting A Direct Loan s academic year tags in the COD schema are <AcademicYearBeginDate> and <AcademicYearEndDate> Schools must populate these tags with the exact beginning and ending dates of the loan s academic year (the period to which the annual loan limit applies) A summer term that is treated as a header or trailer to a scheduled academic year may not be included in the academic year dates unless the student will actually be receiving a Direct Loan for the summer 11 Loan Period Reporting A Direct Loan s loan period tags in the COD schema are <FinancialAwardBeginDate> and <FinancialAwardEndDate> These tags must be populated with the exact dates of the loan period of the loan, and may need to be updated based on the student's actual enrollment or other eligibility issues 12 4

5 Borrower and Program Information Beginning with , 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 Sub Usage when payment period enrollment is less than full time 13 Phase 2 COD Website & Reporting Enhancements Phase 2 of 150% Subsidized Loan Limitation COD Release 13.0 brought Phase 2 New Schema 4.0a 150% SULA tags and data New edits Real-Time processing New system generated response 100% schema validation 100% Schema validation COD website enhancements Report Screens 15 5

6 Phase 2 of 150% Subsidized Loan Limitation Schema 4.0a brings new 150% data reporting Currently Academic Year and Loan Period start/end dates New for and used for SULA calculations Award Block <PublishedPgmLengthYears> <PublishedPgmLengthMonths> <PublishedPgmLengthWeeks> <WeeksProgramAcademicYear> <SpecialPrograms> <ProgramCredentialLevel> 16 Phase 2 of 150% Subsidized Loan Limitation For award year and forward, COD will perform 100% XML Common Record schema validation A new temporary Warning Edit #211 will be triggered and returned to indicate a schema validation issue On inbound common records with XML that doesn t meet 100% schema validation but would have been accepted under prior year rules The warning edit will be discontinued at a yet-to-be determined later date A new Reject Edit #210 will be triggered and returned if the schema validation fails COD Customer Service Representatives will reach out to schools with failed Common Record submissions to assist with resolution 17 Phase 2 of 150% Subsidized Loan Limitation Phase 2 COD reporting modifications includes a new SULA report The currently produced Direct Subsidized Loan Usage Limit School Report is being discontinued A new Direct Loan Subsidized Usage Change Report is being implemented Posted weekly in CSV format in NewsBox Option to opt out 18 6

7 Phase 2 of 150% Subsidized Loan Limitation The new SULA report will display subsidized loans when a change to a calculated SULA value occurs Maximum Subsidized Eligibility Period Actual Subsidized Usage Period Actual Non-Credential Teacher Certification Subsidized Usage Period Anticipated Subsidized Usage Period Anticipated Non-Credential Teacher Certification Subsidized Usage Period 19 Phase 2 of 150% Subsidized Loan Limitation COD will update screens to display SULA data and fields View Person Information screen Re-designed Pop-up on Personal History events give additional information Disbursement History Information screen Displays additional SULA data Enrollment Status Program CIP Code Payment Period Start Date 20 COD View Person Information 21 7

8 COD Disbursement History Information 22 Phase 2 of 150% Subsidized Loan Limitation COD will display two (2) new screens Subsidized Usage Information Screen Accessible via a link on the Person Direct Loan Information screen Subsidized Usage Request Allows a user to request the most recent SULA data via a new system generated acknowledgement Batch Tab Search by SSN or Entity ID 23 COD Subsidized Usage Information 24 8

9 COD SULA Request 25 NSLDS Reporting Requirements NSLDS Phases Identifying First-Time Borrowers Calculating Maximum Eligibility Periods Tracking Subsidized Usage Periods Loss of Subsidy 27 9

10 NSLDS Responsibilities 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 28 New NSLDS Reporting Requirements When reporting enrollment information to NSLDS, school must include for program in which the borrower is enrolled - CIP Code Credential Level Length of program in years, months, or weeks If applicable, preparatory coursework or teacher certification coursework for which school does not award an academic credential 29 Enrollment Reporting Changes Schools will be required to report individual student s program-level enrollment data to NSLDS Campus-Level (Record Type 1) 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 (Record Type 2) 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 Student (Record Type 3) Student Address 30 10

11 Enrollment Status Reporting Electronic Announcement - 8/30/13 Alternative method for COD to obtain enrollment statuses for loans made for the year NSLDS did not currently have a three-quarter time enrollment status (will add a 3/4 status for 14-15) All Subsidized Usage Periods for Direct Subsidized Loans with an enrollment status of H in NSLDS for any portion of a loan period will be prorated on the basis of half-time enrollment even if the borrower is or was actually enrolled on a 3/4 -time basis COD calculation of Sub Usage started March Identifying First-Time Borrowers COD, with help from NSLDS, is the primary identifier of first-time borrowers COD sends the Subsidized Usage Limit Applies (SULA) Flag to federal loan servicers Subsidized Usage Limit Applies (SULA) Flag is reported to NSLDS from federal loan servicers 32 Identifying First-Time Borrowers SULA flag will display on the NSLDSFAP Website SULA flag will be included on: Financial Aid History (FAH) Transfer Student Monitoring (TSM) Prescreening and Post screening Institutional Student Information Record (ISIR) Post screening Reason Code 25 will be added for changes to a SULA status for

12 New Loan Types D0 & D9 New Loan Types: D0 for Direct Subsidized (SULA Eligible) loans D9 for Direct Consolidation Subsidized (SULA Eligible) loans 34 New Loan Types D0 & D9 New D0 & D9 loan types will display on: NSLDS Websites NSLDS Reports Financial Aid History (FAH) Transfer Student Monitoring (TSM) Conversion of D0 loan type for the Central Processing System (CPS) and New D0 loan type will be converted as D1 for New D0 loan type will appear as D0 for NSDLSFAP SULA Information This icon will display on the Loan History, Grant History, Overpayment History, and Overpayment List pages. It will also display on the Student Access Interface page

13 NSLDS Student Access 37 Resources/References An IFAP webpage similar to GE webpage has been created containing: Training materials DCLs, EAs and policy guidance Q & As address for questions FSATC Sessions #28, also #12 and #15 Recorded 150% Loan Limit Webinars #1, #2, and #3 38 QUESTIONS? 13

14 My Contact Information Rick Renshaw Training Officer U.S. Dept. of ED Federal Student Aid Dallas Regional Office Atlanta TO Contact Information David Bartnicki Training Officer U.S. Dept. of ED Federal Student Aid Atlanta Regional Office Help with Title IV Questions For Schools & Other Professionals Research and Customer Care Center (RCCC) For Students Federal Student Aid Information Center (FSAIC) FED-AID 42 14

15 My Supervisor Requests Your Feedback Mark Gerhard Supervisor of Training Officers U.S. Dept. of ED/Federal Student Aid Please use this link to complete your evaluation: Session Name: FAPSC % Loan Limits Part