Greetings from Atlanta
where it is finally beginning to feel like spring. I hope everyone’s
spring semester, quarter or payment period has been going well and not
generating too many unique situations. If it has, I am sure we have
talked about it.
Title IV News:
2015-2016 UEH Flag
Updates
On March 16, 2015 ED posted the long awaited Dear Colleague Letter GEN-15-05
that discusses the expanded criteria when reviewing Unusual Enrollment History
(UEH) for selected students in the 2015-2016 processing year. The new
changes include: (1) an applicant’s prior receipt of, in addition to a Federal
Pell Grant, a Federal Direct Loan (not including a Direct Consolidation Loan or
parent PLUS Loan) and (2) reviewing the prior four, instead of three, award years
(15-16 UEH review includes the 2011-2012, 2012-2013, 2013-2014 and 2014-2015
award years).
Though GEN-15-05 provides a summary of how to review and resolve UEH
selected students, we remind schools to review GEN-13-09 for a more detailed
and thorough discussion. This resolution process applies to any
student, including graduate students, who get selected for review under the UEH
flag.
Please note that it may take some time for the SAR comments and ISIR Guide
to be updated with these new requirements so schools should resolve 15/16 UEH
flags as outlined in the Dear Colleague Letters mentioned above.
Ability to Benefit (ATB)
The number one question I am still getting is about the reinstatement of
Ability to Benefit (ATB) alternatives that were put in place by the
Consolidated and Further Continuing Appropriations Act of 2015. I have
been told that a Dear Colleague Letter has been written and is currently going
through the final clearance process. I hope to see the new DCL posted to
IFAP very soon.
Educational Tax Benefits for Students and Families
Though there are a number of tax provisions, including the American
Opportunity Tax Credit (AOTC) and the Lifetime Learning Tax Credit, designed to
reduce or partially offset the costs of higher education for students and
families, we believe many students and their families do not take advantage of
these tax credits that could save them thousands of dollars.
To help address this problem, the IRS has prepared a flyer to alert students
of these potential tax benefits called, “Students and Parents – Why Form 1098-T
is important to you?” We have provided a copy of the flyer as a ‘PDF’
attachment to a March 17, 2015 electronic announcement.
We are asking all high school and college counselors, advisors, and financial
aid administrators to make these flyers as widely available to student and
families as is possible. This could include posting the flyers to websites,
using other social media, or for postsecondary schools and colleges, including
them in students’ admissions letters, registration materials, and financial aid
award packets.
National Student Clearinghouse (NSC)
I have been getting a few questions around whether schools can still use the
NSC to submit student enrollment data to NSLDS. The answer is yes,
schools may still use NSC to submit student enrollment data to NSLDS.
These questions appear to have been generated due to recent comments in a March
12, 2015 electronic announcement where we indicated that FSA had recently
terminated an enrollment reporting contract with NSC. Please note that
this was a separate and distinct contract between FSA and NSC and had nothing
to do with individual school contracts with NSC.
Aggregate Loan Limits and Dependent Students whose Parents are denied a
PLUS
I have talked about this topic in the past but since I have recently
received several questions around aggregate loan limits for dependent students
whose parents are denied a PLUS loan I thought we could revisit this topic.
If a dependent student’s parent is denied a PLUS, the dependent student can
now borrow up to the annual independent student loan levels. In this
limited instance, we are now treating a dependent student as an independent
student. In fact, if you review the loan limit charts in the 14/15 FSA Handbook,
Volume 3, Chapter 5 page 97 you will note that the aggregate limits for an
independent student also includes dependent students whose parents are denied a
PLUS loan.
It can be a little confusing to figure out what a student can borrower if
the dependent student’s parent is denied a PLUS one year but not in other
years. Remember, that whatever additional amounts they were able to
borrow because they were considered an independent student does not count
against their dependent aggregate loan limits (of course they can never exceed
the overall undergrad aggregate totals). However, whatever amounts
they would be able to borrow as a dependent student (i.e. 1
st year
dependent student can borrow $3500 – base sub/unsub and $2000 additional unsub)
would still count against their dependent aggregate loan limits.
One good example a school asked was how much could a 4
th year
dependent student whose parent was denied a PLUS loan borrow if they had
reached their dependent undergrad aggregate loan limits of $31,000 (including
$23,000 in sub). The student in this case as a 4
th year
student (and assuming the COA and EFA supported the loan amounts), could borrow
up to $12,500 since they are treated as an independent student for DL purposes
and can borrow against the independent aggregate loan amount of
$57,500. Remember that the $12,500 is made up of $5500 base
sub/unsub and $7000 additional unsub. If the student has used up all of
his sub eligibility (as in my example) then the entire amount would be unsub
aid.
And of course no undergraduate student can borrow above the independent
aggregate loan limit of $57,500.
FSA ID
A lot of schools have been asking me if the Department plans on sharing any
information with schools about the FSA ID process that they can then share with
their students. The answer is yes. The Department plans on sharing
a step-by-step guide on the FSA ID registration process that you can then share
with students, parents and borrowers.
Remember that we are not providing information to students on the new FSA ID
process until shortly before implementation to hopefully reduce any potential
confusion. In fact, until we actually transition to the new FSA ID, there
is nothing for a student, parent or borrower to do. In addition, I have
been informed that the FSA ID implementation date is now May 10, 2015.
Third Party Servicers
On February 12, 2015, the Department posted an electronic announcement
requiring all third party servicers as defined under 34 C.F.R § 668.2 and
GEN-15-01 to submit a Third Party Servicer Data Form (attached to the
announcement) within 30 days of the date of the announcement or within 30 days
of receiving notification of the requirement from the Department. In addition,
third party servicers are required to update information within 10 days of the
date, if:
·
The servicer changes its name;
·
The servicer changes the address or contact information for its primary
location or additional location;
·
The servicer adds or terminates a contract with an eligible Title IV
institution; or
·
The servicer buys, sells, or merges with another third party servicer. 34
C.F.R. § 668.25(e)(1)(i).
Any questions about the 2/12/15 electronic announcement or the Third Party
Servicer Data Form, should be directed to the Third Party Servicer Oversight
Group (816) 268-0543;
fsapc3rdpartyserviceroversight@ed.gov.
Training
For those that may have missed it, I am happy to report that we announced in
a March 3, 2015 electronic announcement that FSA will be hosting a FSA Training
Conference in 2015. The 2015 FSA Training Conference will be held from
December 1 – December 4, 2015 at the Mandalay Bay Hotel, 3950 Las Vegas Blvd.
South, Las Vegas, Nevada, 89119.
Conference and lodging registration will open this summer. Additional
information regarding the 2015 FSA Training Conference will be posted at
http://fsaconferences.ed.gov as it
becomes available.
Retirements
A couple of our colleagues in the Department have or will be retiring
shortly and I just wanted to pass on their information in case some of you have
had the chance to work with them directly.
Pam Moran, manager and program specialist, in the Office of Postsecondary
Education recently retired. Pam worked closely on all ED policy matters
that dealt with the FFEL and DL programs. Her knowledge and experience
will be greatly missed.
Barbara Mroz, manager over our QA program and experimental sites, will be
retiring shortly. I know many of our schools in the Southeast have had an
opportunity to talk to and work with Barbara either through the QA program or
by volunteering in our experimental sites initiatives.
We wish them both a fun and relaxing retirement (with no regulations to
worry about).
It appears that we are in for a little cold snap in the Southeast so bundle
up with a warm blanket, a hot cup of cocoa and your favorite federal register.
Your FED,
DAVE
David Bartnicki
Federal Training Officer
ED/FSA/Atlanta
