oasfaa-decoding cdr reports and correcting data … · decoding cdr reports and correcting data...

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“Financial Aid Evolution: Change

Agents”OASFAA Fall

Conference 2015

Decoding CDR Reports and Correcting Data

Administrative capability

Why Review Your CDR Data

A high CDR could result in Adverse publicity

Loss of Title IV eligibility

Loss of access to private loan funds

Extra work due to loss of benefits or added sanctions

“Financial Aid Evolution: Change Agents” OASFAA Fall Conference 2015


Better-quality decision-making


Capturing the right data, accurate data, and timely data is critical for making good policy and accurate decisions


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Better service to students


When borrowers default They pay more in interest and collections fees

The government can seize wages, tax refunds, and Social Securityand disability benefits

Better-quality decision-making


Agenda

Discuss the Cohort Default Rate (CDR) cycle

Decode the Loan Record Detail Report

Review how to comparing and correct data




Conference 2015

Understanding the Cohort Default Rate Cycle

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What Is a Cohort Default Rate?

The Numerator is the number of Stafford loan

borrowers from the denominator who default

within a cohort period

The Denominator is the number of Stafford loan

borrowers who enter repayment within a

cohort period

= Did not default in 2012-2014

= Defaulted in 2012

= Defaulted in 2013

= Defaulted in 2014

All borrowers entered repayment in 2012


What Is a Cohort Default Period?

Borrowers who entered repayment between

10/01/2011 and 9/30/2012

Borrowers who entered repayment between 10/01/2011

and 9/30/2012 and who defaulted between 10/01/2011

and 9/30/2014

3-year CDR Example FY2012


What Is a Cohort Default Rate Cycle?

The Department sends draft and official cohort default rates to all schools that Are eligible to participate in any of the Title IV programs

Have had a borrower in repayment in the current or any of the past cohort default rate periods

Source: CDR Quick Reference Guide

February August

Draft default rates released to schools only

Official rates released to schools and the general public

September JanuaryDraft Rate Cycle Official Rate Cycle


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What Is a Cohort Default Rate Cycle?

The official cohort default rates are available to the public through a searchable database at: ed.gov/FSA/defaultmanagement/cdr.html

Source: CDR Quick Reference Guide

February August

Draft default rates released to schools only

Official rates released to schools and the general public

September JanuaryDraft Rate Cycle Official Rate Cycle


No Sanctions or Benefits Associated with Draft CDR

Keep in mind Schools that fail to challenge the accuracy of draft cohort default rate data

through an incorrect data challenge may not contest the accuracy of the data used in the official rate


How Are Schools Notified?

CDR notification packages Sent electronically to all domestic schools (eCDR)

Using Student Aid Internet Gateway (SAIG)

Allowed five business days to report problems

Timelines for submitting challenges, adjustments and appeals begin six days following announced transmission date, as posted on IFAP (ifap.ed.gov)

IFAP notification establishes the “Timeframe Begin Date”


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What Is Included in the eCDR?

CDR package includes Cover letter

Loan Record Detail Reports (LRDR) Reader-friendly

Extract-type




Conference 2015

Decoding the Loan Record Detail Report

Loan Record Detail Report (LRDR)

Contains borrower information for Stafford (DL & FFELP) loans that were used to calculate a school’s draft or official cohort default rate

Includes borrower’s

Name, social security number

Date borrower entered repayment

Date of default (if applicable)

Loan type

Borrowers with multiple loans will be counted only once


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Review LRDR

Check for accuracy

Compare to school records Repayment Date

Default Status

Cancellations/Refunds


Submitting Challenges and Adjustments

Schools MUST use eCDR Appeals to prepare and submit challenges or adjustments


Loan Record Detail Report –Data Manager

Three-digit code used to identify entity reporting the information

Guaranty Agency Department of Education


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Reader-Friendly LRDR

Loan Record Detail Report –Repayment Date

Indicates when the borrower began repayment Determines if the loan is included in the denominator


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Loan Record Detail Report –Default Date

Indicates the date A Direct Loan is considered in default based on its past due status

- OR -

Guarantee agency paid a default claim to a lender for a FFELP Loan


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Loan Record Detail Report –CDR Usage

Indicates how the loan is included in the calculation “D” Denominator only

“B” Both Numerator and Denominator

“N” Not Used

“E” Eligible, but not counted

Important Codes to Know

Source: CDR Guide, page 2.3-7


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Important Codes to Know

Source: CDR Guide, page 2.3-8“Financial Aid Evolution: Change Agents” OASFAA Fall Conference 2015



Conference 2015

Collecting and Comparing Data

Collecting the Data

Determine data that needs to be captured Last date of attendance (LDA)

Less than half-time date (LTH)

Withdrawal date (WD)

Date entered repayment (DER)

Claim paid date/default date (CPD/DD)

Use a spreadsheet or database to collect this data Implement this process early


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Collecting the Data

Determine where to find data Internal resources available

on-campus

External resources NSLDS

Loan servicers

Guaranty agencies


Possible Errors on LRDR

LRDR incorrectly: Reports a data element and the data element should be changed

Includes a borrower whose repayment date does not fall within the cohort fiscal year and the borrower should be removed from the cohort rate calculation

Excludes a borrower who entered repayment within the cohort and the borrower should be added to the cohort rate calculation


Should the Loan be Included inFY 2012 CDR?

Mariah

Withdrew from school 11/4/2011

NSLDS reveals Mariah transferred to another school on 2/4/2012

LDA

11/4/2011

Add 6 months,

1 day

5/5/2012

Date entered

repayment

Actual DER5/13/2013

Default date

5/8/2014


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Mariah

If date of repayment is delayed by re-enrolling in school prior to the end of grace, inclusion in a CDR calculation is also delayed

Defaulted between 10/1/2011 – 9/30/2014• Defaulted 5/8/2014

FY 2012 (10/1/2011 – 09/30/2012)• Date Mariah entered repayment 5/13/2013



Katy

Withdrew from school 11/4/2011

Loans are deferred on 1/12/2013

LDA Add 6 months,

1 day

Date entered

repayment

05/05/2012(Loan deferred

1/12/2013)

Default date

11/4/2011 5/5/2012 N/A



Katy

Deferments or forbearances do not alter the date the borrower entered repayment

Defaulted between 10/1/2011 – 9/30/2014• No default

FY 2012 (10/1/2011 – 09/30/2012)• Date Katy entered repayment 05/05/2012


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Adele

Withdrew from school 6/1/2011; defaulted on loans 05/27/2013

Consolidated three loans 12/4/2013

LDA

6/1/2011

Add 6 months,

1 day

12/2/2011

Date entered

repayment

12/2/2011

Default date

5/27/2013



Adele

The date underlying loans entered repayment is the date used in the cohort default rate calculation

Defaulted between 10/1/2011 – 9/30/2014• Adele defaulted 5/27/2013

FY 2012 (10/1/2011 – 09/30/2012)• Date Adele entered repayment 12/02/2011



Taylor

Graduated from school 6/1/2011

Paid loan in full on 7/1/2011

LDA

6/1/2011

Add 6 months,

1 day

12/2/2011

Date entered

repayment

Loan paid in full 7/1/2011

Default date

N/A


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Taylor The paid-in-full date becomes the new repayment date Same is true for loans discharged due to death, bankruptcy,

disability


FY 2012 (10/1/2011 – 09/30/2012)• Date Taylor paid in full 07/01/2011


Should the Loan be Included in FY 2012 CDR?

Ariana

Entered repayment on 11/14/2011; defaults on 12/4/2012

Begins loan rehabilitation on 3/29/2013 and completes it on 12/29/2013

Date Entered

Repayment

Rehab Begins

3/29/2013

Rehab Completed

11/14/2011 12/29/2013

Default Date

12/4/2012



Ariana The borrower is included in the cohort fiscal year when they enter

repayment They are also included if they default during the same cohort

period but removed if they rehabilitate before the cohort ends


FY 2012 (10/1/2011 – 09/30/2012)• Date Ariana paid in full 07/01/2011


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Conference 2015

Correcting Data

Challenges of Draft CDR

Used to correct errors on the draft CDR

Submitted by school to guarantors (FFEL) and/or DL servicers via eCDR Appeals within 45 days of timeframe begin date Relevant information for each borrower challenged

Supporting documentation for each borrower challenged

CEO certification letter

34 CFR 668.185(b)34 CFR 668.204(b)

Incorrect Data Challenge (IDC)


Challenges of Draft CDR

Only available if a school is potentially subject to a loss of eligibility (or provisional certification) based on draft rates

School must send completed PRI Challenge to the U.S. Department of Education within 45 days of timeframe begin date PRI Challenge Spreadsheet (CDR Guide page 4.2– 8)

Letter

Participation Rate Index Challenge (PRI)

34 CFR 668.185(c)


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Adjustments of Official CDR

Ensures that a school’s official cohort default rate calculation reflects changes that were correctly agreed to as a result of an incorrect data challenge

School must submit its UDA to the Department within 30 calendar days of timeframe begin date via eCDR Appeals system

34 CFR 668.19034 CFR 668.209

Uncorrected Data Adjustment (UDA)



Allows a school to challenge the accuracy of “new data” included in most recent official CDR Compare LRDR of draft CDR to LRDR of official CDR to determine if new data is

reported correctly

New Data Adjustment (NDA)

34 CFR 668.19134 CFR 668.210



School must submit its NDA to Data Manager via eCDR Appeals within 15 days of timeframe begin date Relevant Information for each borrower challenged

Supporting documentation each borrower challenged

CEO Certification Letter

New Data Adjustment (NDA)

34 CFR 668.19134 CFR 668.210


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Appeals of Official CDR

Available if the school is subject to a loss of eligibility (or provisional certification) based on official rates; or

If the school previously challenged the accuracy of data as part of its Incorrect Data Challenge, or

If a review of loan record detail reports for draft and official rates show new data

Erroneous Data Appeal (ER)

34 CFR 668.19234 CFR 668.211



School must send the Erroneous Data Appeal allegations to Data Manager within 15 days of timeframe begin date Erroneous Data Appeal spreadsheet

Relevant pages of Loan Record Detail Report

Supporting documentation

Letter

Erroneous Data Appeal (ER)

34 CFR 668.19234 CFR 668.211



Alleges a school’s official cohort default rate includes defaulted loans that are considered improperly serviced for cohort default rate purposes

Example Borrower never made a loan payment and school can document that

lender/servicer failed to complete due diligence

Loan Servicing Appeal (LS)

34 CFR 668.19334 CFR 668.212


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School must send request for loan servicing records to Data Manager and to the Department within 15 days of timeframe begin date


34 CFR 668.19334 CFR 668.212



Data Manager notifies school and the Department within 20 days of receipt of request Fees for providing records

List of representative sample

Description of how sample was chosen

School must pay the fee, if charged within15 days of data manager notification


34 CFR 668.19334 CFR 668.212



Available based on a loss of eligibility or notice of second successive official rate potentially subjecting school to provisional certification

Economically Disadvantaged Appeal (EDA)

34 CFR 668.184


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School must submit management assertion to the Department within 30 days of timeframe begin date and the independent auditor opinion’s within 60 days Spreadsheet of students that qualify to be included

School’s low-income rate and placement rate (non-degree-granting school)

School’s low-income rate and completion rate (degree-granting school)

Economically Disadvantaged Appeal (EDA)

34 CFR 668.184



Only available if a school is subject to a loss of eligibility or provisional certification based on official rates

School must send completed Participation Rate Index Appeal to the Department within 30 days of timeframe begin date Participation Rate Index Appeal spreadsheet

Letter

34 CFR 668.19534 CFR 668.214

Participation Rate Index Appeal (PRI)



Not subject to sanctions based on three consecutive CDRs that meet or exceed the relevant threshold if At least two of their official cohort default rates are average rates; and

CDRs would have been less than the relevant threshold if they had been calculated as non-average rates

34 CFR 668.19534 CFR 668.214

Average Rates Appeal


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School must send completed Average Rates Appeal to the Department within 30 days of timeframe begin date Supporting documentation

Certification

34 CFR 668.19534 CFR 668.214

Average Rates Appeal



Department will automatically determine if school meets criteria for thirty or fewer borrowers appeal

34 CFR 668.19734 CFR 668.216

Thirty or Fewer Borrowers Appeal



If school disagrees with Department’s determination School must send completed Thirty or Fewer Borrowers Appeal to the

Department within 30 days of timeframe begin date

Supporting documentation

Certification

34 CFR 668.19734 CFR 668.216

Thirty or Fewer Borrowers Appeal


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Take Action

Review the LRDR

Compare defaulted borrowers to your own system to ensure borrowers are listed correctly

Submit timely appeals, if necessary

Analyze defaulted borrowers to see if changes are needed in your default management plan


Resources

Default Prevention and Management ifap.ed.gov/DefaultManagement/Default

Management.html

eCDR Appeals System ecdrappeals.ed.gov




Conference 2015

Thanks for Attending

Presented byDave Bowman, Regional Marketing DirectorGreat Lakes Educational Loan Services, Inc.

[email protected]

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