150% SUB LOAN RULES. Implementing regulations 05/16/13; 11/01/13 and 01/17/14



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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 for ED to report to Congress on enrollment and graduation of Pell recipients Implementing regulations 05/16/13; 11/01/13 and 01/17/14 1

Limit on Subsidized loan eligibility Does not affect Unsub or PLUS loan eligibility Does not apply to graduate students 150% of published program length Schools report enrolled program data to COD with loan awards and disbursements 2

First-time borrowers only As of July 1, 2013 No outstanding balance on a FFEL or Direct Loan 3

When is eligibility lost? Student has borrowed Sub loans for 150% of the length of the program in which s/he is enrolled and continues to attend current program or another program of equal or lesser length 4

When is eligibility lost? When that triggering enrollment occurs, the student loses the subsidy on loans going forward AND on all Sub loans disbursed since July 1, 2013 5

When is eligibility lost? If student has borrowed Sub loans for 150% of the length of the program in which s/he is enrolled and then graduates, or enrolls in a longer length program, s/he does NOT lose eligibility 6

150% of Program Length Varies by program School reports program length to ED Required to report published program length Calendar time required for program completion at full time enrollment, unless program design is halftime or other enrollment status (report as separate program) 7

150% of Program Length 4 year BA degree 6 years 2 year AA degree 3 years 1 year certificate 18 months 20 week diploma 30 weeks 8

150% of Program Length ED calculates Subsidized Usage Period based on the length of the loan period for which the student borrows Sub loans, compared to the program s definition of the academic year 9

How will students know? Flags on ISIRs, data on NSLDS SULA limit applies SLEU eligibility used (%) ED will monitor and track, will notify students of the loss of subsidy 10

NSLDS Enrollment Reporting DCL GEN-14-07 (April 14, 2014) Enrollment reporting required every 60 days as of 07/01/14 New reporting file layouts 07/01/14 Must be implemented by 10/01/14, and report program-level enrollment information retroactive to 07/01/14 11

NSLDS Enrollment Reporting: Program-Level Reporting Enrollment status (F/Q/H) Program credential level Program CIP code Published program length Report in years, months or weeks 12

NSLDS Enrollment Reporting: Program-Level Reporting Number of weeks in program s Title IV academic year Date student began enrollment in the program Special program indicator Teacher certification; selective admission degrees 13

NSLDS Enrollment Reporting: Enrollment Record Types Campus-level record 8 digit OPEID code Student s primary enrollment campus location Program-level record Student s email address record (optional) 14

NSLDS Enrollment Reporting: Grad Status If a school reports a student as W (withdrawn) while graduation requirements are being reviewed, the school must change the enrollment status from W to G (graduated) with the same effective date as was initially reported for the W status 15

NSLDS Enrollment Reporting: Attended Campus Enrollment must be reported by the student s attended campus (8 digit OPEID) Use the move to process if the student changes locations Enrollment should not be certified at more than one campus location 16

NSLDS Enrollment Reporting: Transfer Students Schools must add transfer students for enrollment reporting if the student received aid at a prior institution, even if s/he does not receive aid at the current institution Check with third-party servicer, if utilized 17

Questions? kstrom@choiceconsulting.com 18