2016 is off to a bang and everyone’s got questions. For those not asking, it could cost you. Answers are not always easy to come by. Fortunately, I’ve got answers to share with you.
Q: Our Program Participation Agreement expires this year and our school is coming up for recertification. Any tips?
A: Other than completing and submitting an Electronic Application (E-App) for Recertification (Recert), along with the required supporting documentation, make sure your school catalog and other publications have up to date and accurate SAP, Admissions, Refund, and R2T4 policies. Also, consumer information disclosures, including the disclosures you have on your schools website should be up to date.
Q: Can we provide commissions or bonuses to an admissions employee that only recruits foreign students, residing in foreign countries?
A: YES – this is the only exception to the ban on incentive compensation.
Q: Our Fiscal Year Ends December 31, so our EZ-Audit isn’t due until June 30th, when do we have to tell ED if we didn’t meet 90/10?
A: Schools are responsible for calculating their own 90/10 and must report to ED within 45 days after the end of its fiscal year if they fail to meet the metric. A school’s CPA is not responsible (to ED) for tracking or calculating a schools rate, but rather verifying the school’s calculation.
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We are all waiting for Ed to release the first ever Draft Gainful Employment (GE) Completers list. Schools should be prepared to challenge data on this report if there are errors. To do so, it must use the Data Challenges and Appeals Solution (DCAS) Online Service to submit a challenge or correction. The Data Challenges and Appeals Solution (DCAS) system provides schools, third party servicers, guaranty agencies, federal loan servicers and ED the functionality to accept, process, resolve, and archive student and loan level data challenges and appeals for both Gainful Employment (GE) and Cohort Default Rate (CDR).
Refer to GE Electronic Announcement #67 for instructions on how to enroll in DCAS.
GE Electronic Announcement #67 can be found here:
For more essential info about the next steps for GE, see the headline “Next Steps for Gainful Employment” below.
Also, in the coming weeks, the U.S. Department of Education is due to release draft Cohort Default Rates the Fiscal Year 2013 cohort of borrowers. At publishing time, Ed has not yet provided an exact release date for the Draft 2013-CDR. While these rates have been traditionally made available to institutions by the end of February each year, last year, the reports weren’t released until mid-March. Schools have 45 days from receipt of the report to submit challenges and appeals. Although there are no sanctions associated with the draft rates, schools should review the data used to calculate the rate for accuracy, because this data forms the basis of a school’s official cohort default rate. A school that fails to challenge the accuracy of its draft cohort default rate data through an Incorrect Data Challenge may not contest the accuracy of the same cohort data when it receives its official cohort default rate when it comes out in September.
What are the sanctions?
- When a school’s three most recent official cohort default rates are 30.0 percent or greater for the three year calculation:
- A school will lose Direct Loan and Federal Pell Grant Program eligibility for the remainder of the fiscal year in which the school is notified of its sanction and for the following two fiscal years.
- When a schools current official cohort default rate is greater than 40.0 percent, for the three year CDR calculation:
- A school will lose direct Loan Program eligibility fort the remainder of the fiscal ear in which the school is notified of its sanction and for the following two years.
It’s a good thing this is a leap year, that extra day is going to come in handy!
Make a Great Day!