ED will release Fiscal Year (FY) 2015 Official Cohort Default Rates (CDR) to all eligible institutions in September. Schools will receive their CDR electronically via their SAIG mailbox, sometime on or after September 25. The Cohort Rates are an important metric used to determine school or program quality.
This year’s Cohort includes three years; FY 2015, 2014 and 2013.
Schools with low cohort default rates can receive their funds more timely than schools with rates above certain thresholds. Schools with a 3-year cohort default rate less than 15% enjoy the benefit of the ability to deliver disbursements to first-year, first-time undergraduate borrowers without delay. Schools with rates greater than 15% must delay the delivery of loans for 30 days.
Schools with 3-year CDRs of 30% or greater for three consecutive years, or with CDRs greater than 40% for just one year may face federal sanctions including loss of Direct Loan or Pell Grant Program eligibility. Institutions may challenge, appeal, or have their rate adjusted in certain circumstances.
Be on the lookout for more information such as an Electronic Announcement announcing the official release dates of the 2015 CDR package from FSA’s Operations Performance Division in the forthcoming days. In the meantime, check out the Default Management Web site which contains resources for Financial Aid Professionals, Data Managers and Students.
In a message to the Financial Aid Community posted by Federal Student Aid yesterday, FSA reminded schools the Fiscal Year 2015 Draft Cohort Default Rate Challenge Appeal Deadline is April 19, 2018.
On February 26, 2018, the Department of Education (the Department) distributed the FY 2015 Draft Electronic Cohort Default Rate (eCDR) notification packages to all Title IV eligible schools.
As a reminder, the 45-day timeline for schools to challenge their FY 2015 Draft Cohort Default Rate (CDR) data began on March 6, 2018 and will end on April 19, 2018. During this period, schools have the option to submit an incorrect data challenge, an uncorrected data adjustment (UDA), a loan servicing appeal (LSA), or a new data adjustment (NDA).
On February 26, 2018, the Department of Education distributed the FY 2015 3-Year Draft Cohort Default Rate (CDR) notification packages to schools via their Student Aid Internet Gateway (SAIG) mailbox. The package includes a cover letter and Loan Record Detail Report (LRDR). It’s important for schools to review their draft data because there are sanctions for schools with high cohort default rates and benefits for schools with low ones and the draft cycle is one of the only opportunities to challenge certain data.
The Fiscal Year 2015 3-Year Draft CDR is calculated by dividing the number of borrowers who entered repayment in 2015 by the number of borrowers who entered repayment in 2015 and defaulted in 2015 2016 or 2017.
Although there are no sanctions or benefits associated with the draft rates themselves, the draft rates become official in September. During the draft cycle, schools have an opportunity to challenge incorrect data or challenge their (low) participation rate. The challenge and appeals cycle begins on March 6, 2018 and lasts for 45 days. More information about submitting an Incorrect Data Challenge or a Participation Rate Index Challenge can be found in the Cohort Default Rate Guide
There’s good reason for schools to keep their default rates low. Schools with low default rates enjoy special benefits such as the ability to disburse loans without delaying the disbursement date for 30 days for first time borrowers and the ability to single loan disbursements for students in study abroad programs.
On the other hand, schools with Three-Year CDRs of 30% or greater for three consecutive years or with CDRs greater than 40% for one year may face federal sanctions.
Some schools have a small number of borrowers entering repayment which can really make their rates look awful. At other schools only a small portion of the student body takes out student loans. If only three students chose to borrow loans, and one defaults, a school’s default rate would be 33% and subject to sanctions.
Facing sanctions over your school’s High Cohort Default Rate but don’t have many borrowers in your cohort? Check out the Participation Index Rate Challenge to see if your school qualifies to have its rates adjusted!
If a school is facing sanctions, schools with a low loan “participation rate” may be able to appeal sanctions through the Participation Rate Index Appeal. To qualify a school can’t have more than 21% of students borrowing loans in a cohort.
To determine if your school might qualify check out the Templates and Spreadsheets section of FSA’s Default Management website and navigate to the Participation Rate Index Worksheet. This worksheet is intended to help schools understand whether their student loan volume is low enough to meet the criteria of a PRI Challenge or Appeal.
On September 25, 2017, the Official Cohort Default Rates were released for the 2014 Fiscal Year. For the first time in several years, the national default rate has risen to more than 11.5%. According to Federal Student Aid’s National Default Briefing the 2014 Cohort Default Rate is over 18% at Public Colleges with programs less than 4 years, followed by For-profits schools at 15.5%. Public and Private Nonprofit institutions still have the lowest Cohort Default Rates, roughly 7.5%.
The official Three-Year rates were sent to all schools via their Student Aid Internet Gateway (SAIG) mailbox. Federal Student Aid’s Operations Performance Management Services calculates the rates which measure the ratio of students who enter repayment during a cohort year and who later default on those loans. Since the data isn’t always right, schools have the ability to challenge and appeal their Cohort Default Rate calculation to have their rates adjusted.
The Fiscal Year 2014 Three-Year Cohort Default Rate is calculated by dividing the number of borrowers who entered repayment in 2014 by the number of borrowers who entered repayment in 2014 and defaulted in 2014, 2015 or 2016. A school with a high default rate will face sanctions and may lose its eligibility to participate in Federal Student Aid Programs or expand their scope of participation with ED. Schools with Three-year CDRs of 30% or greater for three consecutive years or with CDRs greater than 40% for one year are subject to federal sanctions.
Nearly fifty institutions with at least one year of cohort default rates over 30% will be required to submit a formal default management plan to ED. High cohort default rates are also a trigger for program reviews and can lead to heightened cash monitoring. According to the National Association of Financial Aid Administrators, “This year, ten institutions may lose Title IV eligibility for high default rates”.
Schools that participate in the Direct Loan Program but have very few borrowers, may be able to challenge their Cohort Default Rate based on the number of students participating in the loan program at their school.
Generally, schools with 3-year CDRs of 30% or greater for three consecutive years or with CDRs greater than 40% for one year may face federal sanctions. However, schools where fewer than 21% of students borrow federal loans may be able to challenge or appeal sanctions through the PRI Challenge or Appeal (a challenge is based on a draft CDR and an appeal is based on an official CDR). This worksheet is intended to help schools understand whether their student loan volume is low enough to meet the criteria of a PRI Challenge or Appeal. http://bit.ly/2d6kvGx