1. Federal Update ISFAA 2010 Jeff Baker Federal Student Aid December 16, 2010 1

2.  Appropriations and Budget  Legislative Update  Cohort Default Rates  IRS Data Retrieval  Direct Loan Transition  Two Pells In One Award Year  Regulatory Update  Other Today’s Topics 2

3. Appropriations and Program Budget 3

4. Title IV Aid Available 4

5. Legislative Update 5

6. 6

7. FFEL/Direct Loan Cohort Default Rates 7

8. National Student Loan Default Rates 9

9. Indiana Default Rates (FY 2006 - FY 2008) 2006 2007 2008 Rate 4.4% 6.3% 7.0% Borrowers in Repayment 86,783 83,988 Borrowers in Default 5,496 5,896 10

10. What is the CDR Calculation? Currently, a school’s cohort default rate is: The percentage of the number of the school’s FFEL and Direct Loan borrowers who enter repayment in one Federal Fiscal Year who default in that Federal Fiscal Year or by the end of the next Federal Fiscal Year. Beginning with the 2009 cohort will be: Borrowers who default in that Federal Fiscal Year or by the end of the next two Federal Fiscal Years. 10

11. 11 2-Year Versus 3-Year Calculation The Numerator is the number of borrowers from the denominator who default within a cohort period The Denominator is the number of borrowers who enter repayment within a cohort period 355 5000.071 or 7.1% 605 5000.121 or 12.1% 5,000 FY-09FY-10 125 230 5,000 FY-09FY-11FY-10 125230250

12. 12 HEOA Changes Increases CDR monitoring period from two to three years –Increases sanction threshold default rate from 25 percent to 30 percent –Establishes transition period to implement sanctions

13. Transition Period 13

14. 14 IRS Data Retrieval

15. IRS-FSA Concept  FSA and the Internal Revenue Service (IRS) developed a non-consent based solution to simplify FAFSA completion.  Will allow some applicants to retrieve their income tax data from the IRS.  Tax filer voluntarily retrieves own data.  Tax filer can choose to automatically transfer IRS data to FOTW. 19

16. IRS Data Retrieval Tool  Available Jan. 30, 2011  Initial FAFSA  FAFSA Corrections  English and Spanish 16

17. Get My Federal Income Tax Information 17

18. Federal Income Tax Information Provided 18

19. 19

20. ISIR Codes and Flags  CPS will set flags and comment codes to indicate that the student and/or parent transferred IRS data into FOTW.  Comment codes will appear in –  FAA Information section of the ISIR  Student Inquiry section of FAA Access  Flags and codes set based on certain conditions.

21. IRS Request Flag Values IRS Request Flag on ISIR will begin to be populated 21

22. IRS Data and Verification  An institution may consider as acceptable documentation IRS retrieved information if the Secretary has identified those items as having come from the IRS and not been changed – IRS Request Flag = 02. 22

23. Enhancements  Process for the 2011-12 processing year (2010 IRS Data) –  Will begin in late January of 2011  Will include Corrections on the Web. 23

24. Direct Loan Transition 24

25. Direct Loan Transition  Origination and disbursement transition implemented successfully  Next Test: Reconciliation 25

26. Direct Loan Transition Contracted with 4 additional servicers –ACS (current servicer) –Nelnet –Sallie Mae –Great Lakes Education Loan Services –AES/PHEAA Additional non-profit servicers coming Will “service” borrowers only…no origination responsibility 26

27. “Split “ Borrowers  When a borrower has Title IV loans serviced by two or more servicers.  More about ECASLA FFEL loans purchased by ED than Direct Loan transition.  Direct Loans and ED-owned FFEL loans are federal assets.  Non ED-owned FFEL loans are not federal assets. 27

28. “Split “ Borrowers  By law, federal assets cannot be combined with non-federal assets.  FSA is working to have all loans that it holds (Direct Loans and ED-owned FFEL loans) for a borrower serviced by one servicer.  One bill, one payment  Consolidation can combine all loans into one federal asset (Direct Consolidation Loan. 28

29. Two Pells in an Award Year 29

30. Two Pells In An Award Year  Authorized by the Higher Education Opportunity Act (HEOA).  If eligible, student able to receive all or a portion of a second Scheduled Award within an Award Year.  Objective is to help needy students accelerate their academic progress.  Effective beginning with the 2009-2010 Award Year. 30 4

31. 31 Regulations  Team V-General and Non-loan Programmatic Issues in 2009  Notice of Proposed Rulemaking: August 21, 2009  Final regulations: October 29, 2009  Effective beginning with the 2010-2011 Award Year 31

32. 32 Unchanged Pell Rules Scheduled Award – Amount that full-time student would receive for a full academic year based on the student’s EFC and COA. –Prorated by payment period based on hours and weeks of instructional time attended – Pell Formulas. Payment periods Payment for a payment period calculations

33. 33 Changed Pell Rules Scheduled Award – –Old: Student may receive only one Scheduled Award in an award year –New: Student may receive more than one Scheduled Award in an award year.

34. 34 Changed Pell Rules Enrollment Status - –Old: Less than half-time enrollment eligible at all times. –New: Must be at least half-time for second scheduled award.

35. 35 Changed Pell Rules Cross-Over Payment Periods –Old: Institution may assign a crossover payment period to either award year as a general policy or on a case-by-case basis. –New: Must assign to award year that will produce higher payment amount.

36. 36 Award Amount  No change in calculation of award for payment period  Awarding formulas have not changed  Award by payment period based on Scheduled Award  School continues to pay until reaching 200% of Scheduled Award –Payment period may include awards from both first Scheduled Award and second Scheduled Award.

37. 37 New Regs for Cross-Over Term  Effective with the 2010-2011 Award Year -  Must assign to award year in which student receives greater payment for the term - based upon information available at initial calculation.

38. 38 Spring 2011 $2,775 Summer 2011 $2,855 Fall 2010 $2,775 Fall 2011 $2,855 2010-11 Award Year 2011-12 Award Year Spring 2012 $2,855 Summer 2011 $0 100% 2010-11 AY 150% 2011-12 AY Student may receive up to TWO Scheduled Awards. Assume student’s 2010-11 Scheduled Award is $5,550 and $5,710 for 2011- 2012 and student eligible for either. New Law – Assign Cross-Over To Higher Payment Semester Example

39. 39 New Regs for Cross-Over Term Monitoring –  Until date published in Federal Register.  For summer of 2010 the date was September 10, 2010. Will likely be similar date for summer of 2011.  Must reassign payment period if information received showing greater payment from other Award Year.  Must compare again if re-calculating for any reason.  May monitor and adjust after Federal Register date up to February 1, 2011.

40. 40 Academic Year Progression At least one credit or clock hour (or partial hour if school uses partial hours) in the payment period when award will be from a second Scheduled Award must be attributable to the student’s next academic year. Total of hours earned in award year plus hours enrolled in upcoming payment period must be greater than number of hours in school’s definition of academic year. Not “grade progression”. Must be applied for any required recalculation. 40

41. 41 Spring 2011 50% Paid 12 Hours Earned Fall 2010 50% Paid 12 Hours Earned First Scheduled Award Summer 2011 Enrolled in 6 Hours ELIGIBLE Second Scheduled Award Semester Academic Year Progression Zero Hours to prior academic year Six Hours to next academic year or 12 hours earned plus 12 hours earned plus 6 hours enrolled equals 30 which is greater than 24 Assumes academic year defined as 24 hours

42. 42 Spring 2011 50% Paid 9 Hours Earned Fall 2010 50% Paid 12 Hours Earned First Scheduled Award Summer 2012 Enrolled in 6 Hours ELIGIBLE Second Scheduled Award Semester Academic Year Progression Three hours to prior academic year Three hours to next academic year or 12 hours earned plus 9 hours earned plus 6 hours enrolled equals 27 which is greater than 24 Assumes academic year defined as 24 hours

43. 43 Spring 2011 50% Paid 9 Hours Earned Fall 2010 50% Paid 9 Hours Earned First Scheduled Award Summer 2011 Enrolled in 6 Hours INELIGIBLE Second Scheduled Award Semester Academic Year Progression Six hours to prior academic year Zero hours to new academic year or Nine hours earned plus 9 hours earned plus 6 hours enrolled equals 24 which is not greater than 24 Assumes academic year defined as 24 hours

44. 44 Transfer Student  Final regulations: Two options  Assumption method  Based on disbursements received  Do not consider hours earned at other institutions to be conflicting information  Hours-earned method  Based on actual hours earned in award year  Method at option of institution: Apply on a student-by-student basis or to all students

45. 45 Special Circumstances Academic Year completion requirement can be waived if – –FAA determines that student was unable to complete the hours of the first academic year due to ‘circumstances beyond the student’s control’. –Determination must be documented and made on a student by student basis. 45

46. Regulatory Update 46

47. Program Integrity Regs  NPRMs published June 18 - To improve the integrity of the Title IV student assistance programs.  Comment Period Ended August 2, 2010  Final regulations published on Oct. 29, 2010  Generally effective July 1, 2011 (2011-2012 AY)  Verification effective with the 2012-2013 AY 47

48. Program Integrity Regs – Part 1  Policy Objectives –  Ensuring that only eligible students receive federal funds.  Protecting consumers (students and families).  Clarifying eligible coursework.  A few others. 48

49. Program Integrity Regs - Part 1  Ensuring that only eligible students receive federal funds.  High School Diploma: Requires institutions to develop and follow procedures to evaluate the validity of a student's high school diploma if the institution or the Secretary has reason to believe that the diploma is not valid or was not obtained from an entity that provides secondary school education. 49

50. Program Integrity Regs - Part 1  Ensuring that only eligible students receive federal funds.  High School Diploma: FAFSA will ask student to indicate high school. First-year students only Being on the list does not mean “approved” Not being on the list does not mean “unapproved” or “questionable” 50

51. Program Integrity Regs – Part 1  Ensuring that only eligible students receive federal funds.  Ability to Benefit:  Extends eligibility for federal student aid to students without high school diplomas after they successfully complete six credit hours or 225 clock hours of college work.  Improved oversight of test publishers, test administrators, and testing centers. 51

52. Program Integrity Regs – Part 1  Ensuring that only eligible students receive federal funds.  Satisfactory Academic Progress: Requires a structured and consistent approach to evaluating a student's academic work, while continuing to provide flexibility to institutions in establishing their policies.  If SAP monitored each payment period, can use warning first time, then probation.  If SAP monitored only once each year, can only probation or suspension.  Probation requires a plan for resolution. 52

53. Program Integrity Regs – Part 1  Ensuring that only eligible students receive federal funds.  Verification:  Replaces the five verification items for all selected applicants with a targeted selection of items based upon each student’s characteristics.  Eliminates the 30 percent institutional verification cap.  Requires the processing of all changes and corrections to an applicant’s FAFSA information. 53

54. Program Integrity Regs – Part 1  Protecting consumers.  Misrepresentation: Strengthens the Department's authority to take action against institutions engaging in deceptive advertising, marketing, and sales practices.  State Authorization: Clarifies this important state responsibility.  Credit Hour: Defines a credit hour and establishes procedures for accrediting agencies to determine whether an institution's assignment of a credit hour is acceptable. 54

55. Program Integrity Regs – Part 1 Protecting consumers. Incentive Compensation: Removes the "safe harbor" provisions and generally relies on the statutory language for guidance and enforcement. Institutional requirement— School will not provide a commission/bonus or other incentive payment based, in any part directly or indirectly, on success in securing enrollments or financial aid to any person or entity engaged in any student recruiting or admission activities or in making decisions regarding awarding Title IV funds 55

56. Program Integrity Regs – Part 1  Clarifying eligible coursework:  Written Agreements(Consortiums):  Limits the amount of a program that can be provided by another school.  Requires disclosures to students and potential students.  Prohibits arrangements between ineligible institutions that have had their federal student aid participation revoked. 56

57. Program Integrity Regs – Part 1  Other:  Return of Title IV Aid:  Modifies and clarifies the definition of when a student is considered to have withdrawn from a program.  Clarifies the circumstances under which an institution is required to take attendance for the purpose of determining last date of attendance. 57

58. Program Integrity Regs – Part 1  Other:  Disbursing Federal Student Aid Funds: Requires institution to ensure that Pell Grant recipients have resources to obtain books and supplies by the seventh day of payment period.  Retaking Coursework: Allows repeated coursework to count toward enrollment status. 58

59. Program Integrity Regs GAINFUL EMPLOYMENT NPRM published on July 26, 2010.  Final regulations for some provisions published on October 29, 2010.  Effective July 1, 2011  More final regulations scheduled to be published early in 2011.  Effective July 1, 2012 58

60. Program Integrity Regs – Part 1 Protecting consumers. Gainful Employment (GE):  Under the HEA programs at for-profit institutions and occupationally specific training at other institutions must lead to gainful employment in a recognized occupation.  Currently there is no standard to measure “gainful employment”. These rules will establish such a standard.  Public comment received along with a number of studies, reports, and media reports point to the need to regulate in this area. 58

61. GE –Covered Programs Proprietary Institution of Higher Education and Postsecondary Vocational Institution –All programs must prepare students for gainful employment in a recognized occupation Exceptions –Program leading to baccalaureate degree in liberal arts (proprietary institution) –Comprehensive transition program for students with intellectual disabilities (vocational institutions) 60

62. GE –Covered Programs Public and Private Non-profit Institutions –Non-degree/certificate programs must prepare students for gainful employment in a recognized occupation –Two exceptions Transfer program Comprehensive transition program for students with intellectual disabilities 60

63. Program Integrity Regs – Part 1 GE Reporting  Institutions with “gainful employment” programs must report to ED information on students enrolled in gainful employment programs.  Student Identifiers  Enrollment Status  Non-Title IV educational debt  Effective July 1, 2011 63

64. Program Integrity Regs – Part 1 GE Disclosures  Institutions with “gainful employment” programs must provide prospective students with each eligible program's graduation and job placement rates, and provide the Department with information that will allow for the determination of student debt levels and incomes after program completion.  Effective July 1, 2011 64

65. Program Integrity Regs – Part 2 Additional Gainful Employment Programs  Institutions seeking to add a “gainful employment” program must inform ED before beginning program.  Must document an employment need in their community for graduates of the program.  Effective July 1, 2011 65

66. Program Integrity Regs – Part 3 Gainful Employment Metrics  Final rule expected to be published in early 2011  Effective July 1, 2012  Defines “gainful” to be when a substantial number of the program’s students –  Are repaying their Title IV loans (Repayment Rate)  Have a reasonable debt burden (Debt to Earnings Ratio). 66

67. Repayment Rate The percentage of the outstanding principal balance of the federal loans taken by the academic program’s former students who entered repayment in the previous four years that has been repaid. Gainful Employment Metrics 63

68. Debt to Earnings Ratio For the academic program’s completers, the average educational loan payments (federal, private, and institutional financing plans) as a proportion of the borrower’s income (either discretionary income or average annual earnings). Loan payment amount based on a 10- year amortization schedule at 6.8 percent. Gainful Employment Metrics 64

69. Other Information 69

70. Parent PLUS and FAFSA  Beginning 2011-2012 student must file FAFSA for Parent PLUS Loan  98 percent already file  COD will monitor  Need to perform database matches to verify that student is eligible  Social Security Number  Citizenship Status  Selective Service  NSLDS for defaults and overpayments 70

71. ATB Reporting  Beginning 2011-2012 school must report to COD if student received aid based on Ability-to-Benefit.  See COD Technical Specifications 71

72. 72