1. 150 % - it’s now more than just SAP Subsidized Loan Limits and new COD & NSLDS Reporting Requirements Christian Zimmermann College of Southern Maryland 2014 Tri-State Fall Conference November 11, 2014

2. The 150% Limit Who does this effect & what are the consequences? Determining Interest Subsidy Usage Maximum Eligibility Period vs. Subsidized Usage Period Loss of Interest Subsidy – Triggers COD Reporting Requirements New requirements in 2014-15 Other COD changes NSLDS Reporting Requirements New requirements in 2014-15 Other NSLDS changes Additional Resources

3. Implemented as part of the Moving Ahead for Progress in the 21 st Century Act (MAP-21, Public Law 112-141) Two major components: Added a new provision to the Direct Loan statutory requirements that “limits a first-time borrower’s eligibility for Direct Subsidized Loans to a period not to exceed 150 percent of the borrower’s educational program (“the 150% limit”). In addition, the provision also causes “borrowers who have exceeded the 150 percent limit to lose the interest subsidy” on their Direct Subsidized Loans.

4. First Time Borrowers on or after July 1, 2013 An individual who no outstanding balance on a Direct Loan or FFEL Program loan as of July 1, 2013, or On the date the borrower obtains a Direct Loan after July 1, 2013 Who is responsible for determining “first-time borrowers”? ED will determine who is a “first-time” borrower This information will be communicated to borrowers and institutions

5. Student has never borrowed before Student enrolls in August 2013 Student receives a Direct Loan Student is a first-time borrower Student received FFEL / Direct Loans prior to July 1, 2013 Student pays off all FFEL / Direct Loans in 2014 Student enrolls in January 2015 Student receives a new Direct Loan in Spring 2015 Student is a first- time borrower Example A Example B

6. Student A Graduated with Bachelor’s Degree in 2003 Borrowed through FFEL program As of July 1, 2013 has $5,000 in remaining loan balance Enrolls in a undergraduate certificate program for Fall 2013 Is he considered a first time borrower? Student B Graduated with Bachelor’s Degree in 2003 Borrowed through FFEL program As of July 1, 2013 has $5,000 in remaining loan balance Pays off remaining loan balance Nov 1, 2013 Enrolls in a undergraduate certificate program for Spring 2014 Is she considered a first time borrower?

7. Student A Graduated with Bachelor’s Degree in 2012 Received the equivalent of 400% Pell LEU Never borrowed through Direct Loan or FFEL Program Enrolls in a undergraduate certificate program for Fall 2013 Is he considered a first time borrower? Student B Graduated with Bachelor’s Degree in 2003 Borrowed through FFEL program As of July 1, 2013 has $5,000 in remaining loan balance Pays off remaining loan balance Nov 1, 2013 Enrolls in a graduate certificate program for Spring 2014 Is she considered a first time borrower?

8. A borrower loses eligibility for additional Direct Subsidized Loans when the borrower has received Direct Subsidized Loans for 150% of their current academic program. Generally measured in time, not dollars If Subsidized Loan eligibility is lost, borrower remains eligible for Unsubsidized Loans.

9. Maximum Eligibility Period All Subsidized Usage Periods Remaining Eligibility Period 150% limit is met and further eligibility is lost when Remaining Eligibility Period is zero (or less).

10. Maximum Eligibility Period is 150% of the published length of the borrower’s current or upcoming academic program Varies by program Multiply published length of program by 1.5 Measured in academic years or portions ED will calculate using school –reported information Maximum Eligibility Period Examples 1 year certificate program 2 year Assoc. Degree 4 year Bachelor Degree

11. If program’s published length is in months or weeks, ED will convert to years (or portions of years): Month = 30 days Week = 7 days Days in Program Days in Title IV Academic Year = Program Length

12. A Subsidized Usage Period is the period of time for which a borrower receives a Direct Subsidized Loan Calculated on a loan-by-loan basis Measured in academic years or portions Rounded down to the nearest quarter of a year Includes only periods when a Direct Subsidized Loan received ED will calculate using school-reported information Ensure your institution is providing accurate information to COD / NSLDS

13. Days in Loan Program Days in Title IV Academic Year Subsidized Usage Period = Loan Period: Period of enrollment for which the loan is intended Academic Year: Period used to track annual loan limits (SAY/BBAY)

14. Program is semester-based. Scheduled academic year includes the fall and spring semesters. Student receives loan for fall semester only. Days in Loan Program Days in Title IV Academic Year Subsidized Usage Period = Begin DateEnd DateNumber of Days Loan PeriodAugust 27, 2014December 21, 2013117 Academic YearAugust 27, 2014May 17, 2014264 117 264 Subsidized Usage Period == 0.44 Years Round down to nearest quarter year = 0.25 Years

15. Calculated subsidized usage period is prorated by enrollment status Proration occurs before rounding Full Time = 1.0 ¾ Time = 0.75 ½ Time = 0.50

16. Program is semester-based. Scheduled academic year includes the fall and spring semesters. Student receives loan for both semesters while enrolled half-time for both semesters. Days in Loan Program Days in Title IV Academic Year Subsidized Usage Period = Begin DateEnd DateNumber of Days Loan PeriodAugust 27, 2014May 17, 2014264 Academic YearAugust 27, 2014May 17, 2014264 Subsidized Usage Period == 1.00 Year Prorate due to enrollment = 0.50 Years

17. Only circumstance when dollars are considered is when a student receives a Direct Subsidized Loan in the amount of the annual loan limit. Can only occur for standard-term programs or for non-standard-term programs that are substantially equal and are each at least 9 weeks in length Received for less than 1 AY Subsidized Usage Period = 1 Year Borrow full annual loan limit

18. Program is semester-based. Scheduled academic year includes the fall and spring semesters. Second year student receives loan of $ 4,500 for fall semester only. Days in Loan Program Days in Title IV Academic Year Subsidized Usage Period = Begin DateEnd DateNumber of Days Loan PeriodAugust 27, 2014December 21, 2013117 Academic YearAugust 27, 2014May 17, 2014264 117 264 Subsidized Usage Period == 0.44 Years annual loan limit = 1.00 Years

19. The Department of Education will calculate Subsidized Usage Period based on information submitted by school. The school needs to ensure they are submitting the correct information to COD. If loan period changes from original submission to COD, school must update loan record (Examples: student doesn’t enroll for 2 nd semester of loan, student cancels all of a disbursement in a payment period, student borrows loan funds in summer term after borrowing in fall &/or spring)

20. MAP-21 established circumstances in which a new borrower may lose eligibility for interest subsidy for previously disbursed Subsidized Loans. From the Federal Register: “ Establishing new Direct Loan Program regulations that provide that new borrowers who are ineligible for Direct Subsidized Loans as a result of these provisions and enroll in a program for which the borrower would otherwise be eligible for a Direct Subsidized Loan become responsible for accruing interest on all previously received Direct Subsidized Loans during all future periods, beginning on the date of the triggering enrollment.”Federal Register What does that mean?

21. No Remaining Eligibility Period No Program Completion Enroll in a new payment period Subsidy Loss

22. 123 Student lost eligibility Student had remaining eligibility Enrolled at least ½ time in same undergraduate program Enrolled at least ½ time in an undergraduate program of equal or lesser length Student enrolled at least ½ time in shorter undergraduate program where usage > maximum

23. Does the student become responsible for paying the interest that accrues on my Direct Subsidized Loans because... YesNo They are no longer eligible for Direct Subsidized Loans and stay enrolled in their current program? They are no longer eligible for Direct Subsidized Loans, did not graduate from their prior program, and are enrolled in an undergraduate program that is the same length or shorter than their prior program? They transferred into the shorter program and lost eligibility for Direct Subsidized Loans because they have received Direct Subsidized loans for a period that equals or exceeds their new, lower maximum eligibility period, which is based on the length of the new program? They were no longer eligible for Direct Subsidized Loans, did not graduate from their prior program, and are enrolled in an undergraduate program that is longer than their prior program? They lose eligibility for Direct Subsidized Loans and immediately withdraw from their program? They graduated from their prior program prior to or upon meeting the 150% limit, and enroll in an undergraduate program that is the same length or shorter than their prior program? They enroll in a graduate or professional program? They enroll in preparatory coursework that they are required to complete to enroll in a graduate or professional program? They enroll in a teacher certification program (where their school does not award an academic credential)? X X X X X X X X X

24. Borrower with interest subsidy: Borrower who lost interest subsidy: In SchoolGraceRepay – Std.DefermentForbearance Repay IBR/PAYE In SchoolGraceRepay. – Std.DefermentForbearance Repay IBR/PAYE Subsidized Period Unsubsidized Period

25. 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.

26. Prior to 2014-15 schools were responsible for reporting: Loan Period Dates Academic Year Dates Starting in 2014-15 schools must report the following: CIP Credential Level Program Length Length of Title IV Academic Year Flag for Prep Coursework / Teacher Certification Enrollment Status (full-time ¾ time, ½ time) Payment Period Begin Date Effective date: July 1, 2014

27. Institutions must ensure academic programs are properly set up in student information system (Banner, Colleague, Powerfaids, etc.) Are your academic programs Title IV “eligible”? Do the program lengths in SIS match the catalog? Do the academic programs have the correct CIP codes? Use the CIP 2010 Crosswalk (http://nces.ed.gov/ipeds/cipcode/crosswalk.aspx?y=55)http://nces.ed.gov/ipeds/cipcode/crosswalk.aspx?y=55 If institution has Gainful Employment programs, similar setup.

30. If the borrower is subject to 150% subsidized usage period: Loan will be rejected at the origination if Subsidized Usage Period > Remaining Eligibility Period Whenever a school submits an origination or disbursement record COD will Calculate Subsidized Usage Periods, including the new loan Inform school of borrower’s Maximum Eligibility, Subsidized Usage, and Remaining Eligibility Periods COD will inform the borrower in a disclosure statement

31. Previous Reporting Requirements Enrollment Status – ½ time and Full-time New Program Level Reporting Requirements – Effective October 1, 2014 CIP Credential Level Program Length Length of Title IV Academic Year Flags for Prep Coursework & Teacher Certification Enrollment Status – ½ time, Full-time & ¾ time 60-day enrollment reporting requirement – Effective July 1, 2014 Dear Colleague Letter GEN-14-07

32. Modified professional access and student view to display 150%- related information Modified reports available to schools to include 150%-related information Pass information about student’s current Subsidized Usage Period and whether the student has lost interest subsidy to CPS, for inclusion on the SAR/ISIR Inform Direct Loan servicers of borrowers enrollment and loss of interest subsidy

34. IFAP 150% Direct Subsidized Loan Limit Info (right column) of homepage (http://ifap.ed.gov/150PercentDirectSubsidizedLoanLimitInfo/index.html)http://ifap.ed.gov/150PercentDirectSubsidizedLoanLimitInfo/index.html Loan Period & Academic Year Information: DCL GEN-13-13, GEN-14-07, GEN-14-17 150% Direct Subsidized Loan Limit – Electronic Announcements: #1-15 Additional COD System Implementation for the 2013-2014 Award Year (updated June 28, 2013) 2014-2015 COD Technical Reference Updated NSLDS Enrollment Reporting Guide (July 23, 2014) 150% Limit Training http:// ifap.ed.gov/150PercentDirectSubsidizedLoanLimitInfo/Training.html http:// ifap.ed.gov/150PercentDirectSubsidizedLoanLimitInfo/Training.html