800.242.0977 [email protected] 3000 W Kellogg Drive Wichita, KS 67213 IMPORTANT DATES: April 1 DJA Monthly Webinar Satisfactory Academic Progress 11:00 a.m. – 12:00 p.m. April 8-10 KASFAA Conference April 13-14 PCCS Conference Philadelphia, Pennsylvania April 27 FWS Community Service Waiver Deadline APRIL 2015 NEWSLETTER Annual DJA Financial Aid Training The Spring DJA Financial Aid Training Session is just around the corner! It is being held on Monday, April 27, 2015 at the Harrah’s North Kansas City Casino and Hotel located at One Riverboat Drive, Kansas City, MO. The session will start at 8:30 a.m. and end at 4 p.m. on the 27th. This session is free to DJA clients. Other interested institutions are welcome to attend for a fee of $125 per person at the door, or $95 per person, pre-paid in advance of the seminar. All attendees will need to register in advance by contacting Kim Onderek at DJA at (800) 242-0977 or via email at [email protected] You can make room reservations directly with Harrah’s by calling 800-427-7247. April 27 DJA Annual Client Training Kansas City, MO To receive the Group rate, you must make your reservation on or before Sunday April 5, 2015. Make sure you identify yourself as part of the DJA Financial Aid Services Group and use the Group Code S04DJA5. IN THIS ISSUE: I look forward to seeing you as we certainly have a lot to talk about as we move into the 2015/2016 award year! 2015-2016 Unusual Enrollment History (UEH) Procedures for Adding or Changing Alien Registration Numbers 2015-2016 FWS Community Service Waivers Educational Tax Benefits Paper In-School Deferment Forms Program Reviews DJA Calendar Thank you and until next time, have fun! Deborah John, President 2015-2016 UNUSUAL ENROLLMENT HISTORY (UEH) Beginning with the 2015-2016 award year both grants and loans will be considered in determining unusual enrollment patterns. Selection of applicants for a UEH Flag has been expanded to consider: (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). (2) The prior four, instead of three, award years. For 2015-2016 FAFSA processing, UEH Flag evaluation includes the 2011-2012, 2012-2013, 2013-2014, and 2014-2015 award years. April 2015 2 This change addresses the concern that the review of three prior award years could result in a student not receiving a UEH Flag because of not enrolling for one year, even with a continuing unusual enrollment history. Therefore, institutions must consider all four award years when evaluating if the student completed any academic credit for which Pell or Federal Direct Loan funds were provided, or whether the student had a valid reason for not earning any credit. There may be instances where an institution suspects that a student for whom the Department did not assign a UEH Flag may be one whose past enrollment suggests that the student’s prior academic history should be reviewed. In such instances, the institution may choose to treat the student as though the Department had assigned the student a UEH Flag with a value of ‘3.’ The institutional resolution guidance for UEH Flags that was provided in Dear Colleague Letter GEN-13-09 is applicable for both the 2014-2015 and 2015-2016 FAFSA processing years. The summary of that guidance is provided below but you should review the full guidance provided in the earlier Dear Colleague Letter at http://ifap.ed.gov/dpcletters/GEN1309.html ISIR Unusual Enrollment History Flags The UEH Flag on the ISIR indicates whether the student has an unusual enrollment history with regard to the receipt of Federal Pell Grant and Federal Direct Loan funds. UEH Flag values of ‘2’ or ‘3’ generate a ‘C’ Code to indicate to institutions that the student’s records must be reviewed. Resolving Unusual Enrollment History Flags An institution must take the following steps to resolve a UEH Flag. UEH Flag value is ‘2’: The institution must review the student’s enrollment and financial aid records to determine if, during the four award year review period (award years 2011-2012, 2012-2013, 2013-2014, and 2014-2015), the student received a Pell Grant and/or Federal Direct Loan at the institution that is performing the review. If so, no additional action is required. However, if the institution has reason to believe that the student is one who remains enrolled just long enough to collect student aid funds, the institution must follow the guidance that is provided below for a UEH Flag of ‘3.’ If not, the institution must follow the guidance provided below for a UEH Flag of ‘3.’ UEH Flag value is ‘3’: The institution must review the student’s academic records to determine if the student received academic credit at the institutions the student attended during the four award year period (award years 2011-2012, 2012-2013, 2013-2014, and 2014-2015). Using information from the National Student Loan Data System (NSLDS), the institution must identify the institutions where the student received Pell Grant and/or Federal Direct Loan funding over the past four award years (2011-2012, 2012-2013, 2013-2014, and 20142015). Based upon academic transcripts the institution may already possess, or by asking the student to provide academic transcripts or grade reports, the institution must determine, for each of the previously attended institutions, whether academic credit was earned during the award year in which the student received Pell Grant April 2015 3 and/or Federal Direct Loan funds. Academic credit is considered to have been earned if the academic records show that the student completed any credit hours or clock hours. Academic Credit Earned: If the institution determines that the student earned any academic credit at each of the previously attended institutions during the relevant award years, no further action is required unless the institution has other reasons to believe that the student is one who enrolls just to receive the credit balance. In such instances, the institution must require the student to provide the additional information discussed below under “Academic Credit Not Earned.” If it is determined that academic credit was not earned at one or more of the previously attended institutions, the institution must follow the “Academic Credit Not Earned” guidance below. Academic Credit Not Earned: If the student did not earn academic credit at a previously attended institution and, if applicable, at the institution performing the review, the institution must obtain documentation from the student explaining why the student failed to earn academic credit. The institution must determine whether the documentation supports (1) the reasons given by the student for the student’s failure to earn academic credit; and (2) that the student did not enroll only to receive credit balance funds. Denial of Continued Eligibility If a student did not earn academic credit at one or more of the relevant institutions and does not provide, to the financial aid administrator’s satisfaction, an acceptable explanation and documentation for each of those failures, the institution must deny the student any additional Title IV, HEA program assistance. The student must be provided with an opportunity to question and appeal the decision. The institution must also provide the student with information regarding how the student may subsequently regain eligibility. http://ifap.ed.gov/dpcletters/GEN1505.html PROCEDURES TO FOLLOW WHEN ADDING OR CHANGING ALIEN REGISTRATION NUMBERS In an electronic announcement posted to the IFAP website on March 9th. FSA reminds schools about the procedures to follow when adding or correcting a student’s Alien Registration Number (ARN) on the Free Application for Federal Student Aid (FAFSA®) to confirm eligible noncitizen status with the U.S. Department of Homeland Security (DHS). Following these procedures will reduce the number of unnecessary G-845 forms Financial Aid Administrators (FAAs) are completing and submitting to DHS. Social Security Administration Citizenship Status Match All applications are matched with SSA records to verify name, date of birth, U.S. citizenship status, the Social Security number (SSN), and, if applicable, the date of death. If the SSA match is successful, the student’s citizenship status will be confirmed and a comment code will not be displayed. April 2015 4 If the SSA is unable to confirm that the student is a U.S. citizen or national, the ISIR will display a C code and comment code 146. In these cases, resolution is required (see the SAR Comment Codes and Text Guide for resolution). If the student claims to be a U.S. citizen or national, your school must decide what documents are acceptable to prove U.S. citizenship or nationality. The Department doesn’t specify which documents are acceptable but some documents your school might choose include (but are not limited to): a copy of the student’s birth certificate showing that the student was born in the United States or its territories, a U.S. passport, a Consular Report of Birth Abroad, a Certificate of Citizenship, and/or a Certificate of Naturalization. Note that a driver’s license or voter registration cards are not adequate proof of citizenship since some localities do not require proof of citizenship to possess these IDs. DHS Primary Verification Match If the student provides an eligible noncitizen document, instruct the student to correct question 14 on the FAFSA (to indicate that they are an eligible noncitizen) and add their ARN in question 15. This correction will tell CPS to send the record to DHS. An updated ISIR will be available to the school within three days, with a DHS Match flag response of Y(es) or N(o), since CPS identifies records that contain an ARN and sends the Name, SSN, Date of Birth and ARN to DHS for eligible noncitizen matching. The DHS system uses the ARN, rather than name or SSN to identify individuals in their system. Procedure for Comment Code 144 and C Flag: Comment Code 144 appears on an ISIR when the DHS Match Flag equals “N.” Eligible noncitizen status was not confirmed when matching with the DHS primary database. FAAs need to determine whether the ARN on the ISIR matches the ARN on the student’s eligible noncitizen documentation. If the ARN on the ISIR does not match the ARN on the noncitizen documentation, the ARN must be corrected on the student’s FAFSA. The G-845 form should not be completed and submitted in this case, because the DHS Match Flag on the ISIR is associated with the incorrect ARN. Instead, once the ARN is corrected CPS will send the corrected ARN to DHS for matching. The record will go through the DHS primary confirmation process because DHS identifies the corrected ARN as a new record in their system. CPS will produce a corrected ISIR within three days with the corrected ARN. The DHS Match Flags on the corrected ISIR are applicable to the corrected ARN. FAAs should follow the procedures for the Match flags and code, and complete a G-845 form only if the DHS Match Flag = “N” and the DHS Secondary Match Flag = “N” (see comment code 46) or “X” (see comment code 109). If the DHS Secondary Match Flag = “C” (see comment code 105), wait ten business days for another system generated ISIR with an updated DHS Secondary Match flag before beginning the mandatory paper (G-845) Secondary Confirmation process. See the “Electronic Announcements” section of the IFAP Web site, located at ifap.ed.gov for the most recent G-845 form and mailing addresses. If the requested documentation includes a U.S. Department of Health and Human Services (HHS) Eligibility or Certification letter and/or the student provides a copy of a T-visa, follow the instructions in Dear Colleague Letter GEN 06-09 in lieu of completing and submitting the G-845 form. April 2015 5 If the DHS Match Flag OR the DHS Secondary Match Flag = “Y” (see comment code 120), continue processing the student’s financial aid. Do not complete a G-845 without evidence of eligible noncitizen status. If a student submits documentation that does not provide evidence that the student is an eligible noncitizen, the FAA should not complete and submit a G-845 form. Page 1-32 of the Federal Student Aid Handbook (click on link below) describes documents that do not prove a student’s eligibility for federal student aid. Examples are: a Social Security Card stamped “Employment Authorized”, and “U” or “F” Visas. FAAs should inform these students that they are ineligible for federal student aid, and should keep a copy of the student’s documentation and an explanation of the determination in the student’s file. If the student indicates that he or she has obtained an eligible status, but has lost the documentation to prove it, the student must call the USCIS National Customer Service Center at 1-800-375-5283 FREE to replace the lost document. More information about eligible and non-eligible citizen documentation, SSA and DHS matches, codes and the G-845 form can be found in the Federal Student Aid Handbook, Volume 1, Chapter 2: Citizenship at: http://ifap.ed.gov/fsahandbook/attachments/1415Vol1Ch2.pdf. http://www.ifap.ed.gov/eannouncements/030915ProcedurestofollowWhenAddingChangingAlienRegNumbers.h tml 2015-2016 FEDERAL WORK-STUDY PROGRAM COMMUNITY SERVICE WAIVER REQUESTS DEADLINE APRIL 27, 2015 Each school that participates in the FWS Program is required to expend at least seven percent of its total FWS federal allocation to compensate students employed in community service activities. Also, in meeting that seven percent community service expenditure requirement, one or more of the school's FWS students must be employed as a reading tutor for children in a reading tutoring project or performing family literacy activities in a family literacy project. One or both of the community service requirements may be waived for a school if the school has demonstrated that enforcing the requirement(s) would cause a hardship for the students at that school. The fact that it may be difficult for the school to comply with the requirement(s) is not in and of itself a basis for granting a waiver. In the past, a limited number of waivers have been approved when schools were able to demonstrate an exceptional circumstance. For example: Small FWS Allocation - The school had a very small FWS allocation. The supporting information submitted by the school noted that seven percent of the school's allocation only provided enough funds for a student to work in a community service job for a short period of time. Therefore, the school was unable to find placement for a student in community service. April 2015 6 Rural Area - The school is in a rural area that is located far from the type of organizations that would normally provide community service jobs. The school provided information that showed that its students lacked the means of transportation to get to the location of the community service jobs. In a similar waiver request in which transportation did exist, a school provided documentation that showed that the transportation costs were extremely high for the students. Specialized Program - The school offered only a single program of specialized study that required its students to spend extensive amounts of time in classroom and non-classroom academic activities. The school provided information that demonstrated that this specialized educational program did not allow its students to have time for performing community service jobs at the time those work opportunities were available. A school must submit its waiver request to the Department of Education (the Department) electronically via the eCampus-Based (eCB) Web site at the "Community Service Waiver" link at the top of the "Setup - Change Years/Schools" page. The school's waiver request must specify whether the school is requesting a waiver of the seven percent community service requirement, the reading tutors of children or family literacy project requirement, or both. It must also include detailed information to demonstrate that complying with the requirement(s) would cause hardship for the school's students. The deadline for electronic submission of a school's 2015-2016 FWS Community Service waiver request is 11:59 P.M. (ET) on Monday, April 27, 2015. Transmissions must be completed and accepted by 12:00 midnight. A waiver request that is received after April 27, 2015 will not be considered. The Department plans to notify, via e-mail, each school that submitted a 2015-2016 FWS Community Service waiver request that a decision has been made regarding its waiver request by July 1, 2015. In the e-mail, the school will be informed that the Secretary's decision to approve or deny the school's waiver request has been posted to the eCB Web site. This e-mail will be sent to the school's Financial Aid Administrator, as provided in the school's most recently submitted Fiscal Operations Report and Application to Participate or as updated via the "Contact Info" page on the eCB Web site. To access the decision following receipt of this e-mail, log in to the eCB Web site, select the "Self-Service" link from the top navigation bar, and scroll to the "Campus-Based Notifications for All Available Award Years" section. Then, scroll to the "Community Service Waiver" bullet and select the "2015-2016" link next to it. http://www.ifap.ed.gov/eannouncements/032715FWSCommunitySvcWaiver1516.html EDUCATIONAL TAX BENEFITS The Federal tax code includes a number of provisions designed to reduce or partially offset the costs of higher education for students and families. Among those are the American Opportunity Tax Credit (AOTC) and the Lifetime Learning Tax Credit, both designed to help families pay for at least a portion of higher education April 2015 7 tuition and fees and related costs. However, 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 for high schools and college financial aid offices to use to alert students of these potential tax benefits. The flyer, called, “Students and parents – Why Form 1098T is important to you?” is directed to students and provides a brief explanation of the credits and where to get additional information. FSA is asking all high school and college counselors, advisors, and financial aid administrators to make these flyers as widely available to students 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. A link to the flyer can be found at http://www.ifap.ed.gov/eannouncements/031715SharingInfoonEducationTaxBenefitsStudentsandFamilies.html For more information about these tax credits go to: http://www.irs.gov/Individuals/Education-Credits-AOTC-LLC PAPER IN- SCHOOL DEFERMENT FORMS Schools are seeing an increased number of requests for completion of paper in-school loan deferment forms. It has been suggested that this increase is the result of the termination of the contract between Federal Student Aid (FSA) and the National Student Clearinghouse (NSC). Federal Loan Servicers should send paper in-school deferment forms to schools only when the borrower’s enrollment cannot be verified using information in NSLDS. In addition, the Department’s loan servicers have the capability of adding a new school to a student’s NSLDS record when the servicer receives information (usually from the student) of enrollment. This will result in the student being included on the next enrollment roster provided to the school or to its third-party servicer. Thus, in most instances there would be no need for the servicer to request a school to complete a deferment form. As long as a school is fully compliant with enrollment reporting requirements, borrower enrollment information should generally be accurate and up to date in NSLDS. The only time a servicer may need to request completion of an in-school deferment form by a school will be for a Title IV borrower who indicated to the servicer that he or she has transferred to that school, the borrower’s enrollment has not yet been reported to NSLDS by the school, and there is some urgency to confirm that enrollment (e.g., borrower is past due and/or close to defaulting on a Title IV loan). In instances where a servicer does send a school a paper in-school deferment form, FSA recommends that instead of the labor-intensive process of completing the paper form, school staff simply log on to the NSLDS Professional Access Web site, and use the Enrollment Maintenance function to add the student or update the student’s enrollment information. 8 April 2015 Enrollment Reporting File Requirements It is important to note that enrollment reporting is required for all students included on the NSLDS Enrollment Reporting File provided by NSLDS. That file will only include students for whom NSLDS has information indicating that the student is enrolled at the school (e.g., current or prior Title IV aid received or a loan deferment granted). Therefore, NSLDS may not initially include on the roster a Title IV recipient who transferred into a school and who is not receiving Title IV aid at the new school or has not yet been granted an in-school deferment. Schools are urged to add a student to an enrollment roster or to update NSLDS using the online enrollment reporting methods if the school has identified an incoming student as one who had previously received Title IV assistance. As a reminder, NSLDS assists schools in building more complete enrollment rosters by adding to a school’s roster any student with Title IV aid that appears on the school’s Transfer Student Monitoring file or on a Financial Aid History Report request. More information on these processes is available in the NSLDS Transfer Student Monitoring/ Financial Aid History User Guide and Batch File Layouts. Full details can be found at http://www.ifap.ed.gov/eannouncements/031215SchoolResponsibilitiesUponReceivingPaperInSchoolDefermen tForms.html COMPLIANCE CORNER Program Reviews As part of its oversight duties, Federal Student Aid (FSA) routinely conducts program reviews to confirm that a school meets FSA requirements for institutional eligibility, financial responsibility, and administrative capability. The overall purpose of a Program Review is to evaluate the school’s compliance with FSA requirements, assess liabilities for errors in performance, and identify actions the school must take to improve its future administrative capabilities. During this process the reviewers typically: analyze the institution’s data and records and identify any weaknesses in the institution’s procedures for administering Title IV, HEA program funds; frame required actions and recommendations that will strengthen the institution’s future compliance with Title IV rules and regulations; quantify any harm resulting from the institution’s impaired performance and identify liabilities where noncompliance results in loss, misuse, or unnecessary expenditure of federal funds; 9 April 2015 determine the extent to which any weaknesses in the institution’s administration of Title IV, HEA program funds may subject students and taxpayers to potential or actual fraud, waste, and abuse; and refer institutions for administrative action to protect the interests of students and taxpayers, when necessary. As part of a program review, reviewers examine financial aid, academic, and fiscal records, interview institution staff and students, and review relevant consumer information (e.g., the school’s Web site, student catalogs, pamphlets, etc.), among other things. This is usually done at the institution (on-site review) to allow the reviewers to have direct contact with students, and institution officials and employees, and to give the reviewers first-hand knowledge of the institution’s administration of the Title IV, HEA programs. In most cases, institutions are asked to submit copies of selected records to the School Participation Team (SPT) for review at its office before the on-site review begins. Occasionally, the SPT may review only relevant data stored in Department databases before coming on site. The SPT may also conduct an off-site review. After completing a program review, Federal Student Aid issues a Final Program Review (FPR) and, ultimately, a Final Program Review Determination (FPRD), which is a report that includes each finding identified in the program review report, the school's response, and the Department’s final determination. The FPRD also identifies liabilities, if any, calculated based on the findings of the program review; provides instructions for the payment of liabilities, as appropriate; notifies the institution of its right to appeal the existence and amount of any liabilities identified, as appropriate; and closes the program review, if appropriate. The FPRD may or may not require additional action by the institution. Institutions should be prepared at all times for the possibility of a program review. Your school needs to stay on top of ever changing regulations. Attending training and staying current with changes to the law and regulations are the best ways for an institution to prepare. The Information for Financial Aid Professionals (IFAP) website is a must! Make sure you and your financial aid staff are signed up for IFAP notifications. Go to the IFAP Website at www.ifap.ed.gov, click on My IFAP and register. Once you are registered you will automatically begin receiving the weekly email notifications. You should also take advantage of the FSA Assessments modules (available at www.ifap.ed.gov) to conduct a self-assessment of your management of the Title IV programs. The Program Review Guide for Institutions serves as a first point of reference for postsecondary academic institutions regarding the Title IV program review process. The Guide provides information about the general guidelines established by the U.S. Department of Education for Department personnel tasked to conduct program reviews of institutions participating in the Title IV student financial assistance programs. The Guide also provides information to assist institutions in preparing for and participating in a program review. This document is available on the IFAP Web site at http://ifap.ed.gov/programrevguide/attachments/2009ProgramReviewGuide.pdf So….. What are some of the “triggers” for a program review at your school? How do you prepare for a program review? What are the top ten findings? Pat Edelson of Hogan Marren, LTD has prepared and presents a wonderful presentation on program reviews that will answer these questions and many more. We are very 10 April 2015 excited that she has agreed to allow us to provide a link to the presentation. This is valuable information, so please make some time to take a look. Just double click on the box below. WHAT’S NEW IN PROGRAM REVIEWS What to Expect, How to Respond Private Colleges and Career Schools Conference DJA CALENDAR Monthly DJA Webinar: Satisfactory Academic Progress—Wednesday, April 1st at 11 a.m. CDT Next Month’s DJA Webinar: Return of Title IV Funds—Wednesday, May 6th at 11 a.m. CST NOTE: There may be a difference between DJA local time and your time zone. To determine your time zone equivalent, click on this link to view a time zone map: http://www.worldtimezone.com/time-usa12.php Webinars are free to clients. There is a $45 fee for all others who may be interested in joining us for these presentations. Invitations are automatically sent to all clients, however all other participants must register by sending an email to Kim Onderek at [email protected]. After registering, you will receive the log-in information. Questions can be directed to Kim by email or by calling toll free at 1-800-242-0977. JAN FEB MAR APR MAY JUN JUL AUG SEP OCT NOV DEC 7 4 4 1 6 3 1 5 2 7 4 2 2015 DJA Monthly Webinar Schedule Cohort Default Rate Consumer Information, Record Keeping and Disclosures Administrative Capabilities Satisfactory Academic Progress Return of Title IV Funds (Including LOA) General Participation Requirements Campus Crime Report Entrance and Exit Counseling Cash Management Enrollment Reporting Using NSLDS Program Integrity (Audits, Program Review) 1098-T Reporting 11 April 2015 ANNUAL DJA FINANCIAL AID TRAINING – APRIL 27, 2015 The Spring DJA Financial Aid Training Session is being held on Monday, April 27, 2015. Once again, we will meet at the Harrah’s North Kansas City Casino and Hotel located at One Riverboat Drive, Kansas City, MO. Registration is from 8 a.m. to 8:30 a.m. with complimentary coffee and danish in the morning. This session is free to DJA clients. All other interested institutions are welcome to attend. The cost is $125 per person at the door, or $95 per person, prepaid in advance of the seminar. All attendees will need to register in advance by contacting Kim Onderek at DJA at (800) 242-0977 or via email at [email protected]. You will be making reservations directly with Harrah’s by calling 800-427-7247. To receive the Group rate, you must make your reservation on or before Sunday April 5, 2015. Make sure you identify yourself as part of the DJA Financial Aid Services Group and use the Group Code S04DJA5. KANSAS ASSOCIATION OF STUDENT FINANCIAL AID ADMINISTRATORS (KASFAA) CONFERENCE – APRIL 8-10, 2015 The Spring KASFAA conference will be held at the Hotel at Old Town Conference Center in Wichita, Kansas. DJA will be exhibiting at this conference on April 8th and 9th. Please stop by our booth and say hello! 2015 PRIVATE CAREER COLLEGES AND SCHOOLS (PCCS) FINANCIAL AID CONFERENCES The PCCS conferences are open to all postsecondary schools. This month’s conference will be held in Philadelphia on April 13th and 14th. DJA will be presenting the following topics at this workshop and will also be an exhibitor. Please stop by and visit our booth! Administrative Capability 150% Subsidized Loan Limitation Additional session for owners - The Program Participation Agreement – What did you agree to when your signed on for Title IV?? For more information about the PCCS conferences, please go to http://regionspccs.com/ or, contact the Region VII Chairman, Larry Prather, at: 316-682-1838 or by email at [email protected] Disclaimer: The information presented in this Newsletter is provided as a service and represents our best efforts to assist institutions with federal student aid regulations. We have collected information we believe to be important in finding and obtaining the resources for administering federal student aid; however, we assume no liability for the use of this information. The information in this newsletter does not constitute, and should not be construed as, legal advice.
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