GHEAC Mardi Gras:

Parade of Service

2003 GHEAC Annual ConferenceMarch 4 - 5, 2003

Default Appeals Process

Marcia Coleman, Default Prevention Coordinator

Session Outline

• Cohort Default Rate (CDR)• eCDR• Cohort Default Rate Calculation• Draft Cohort Default Rate Process• Quick Steps for Appealing Your Default

Rate• Default Analysis Software

2003 GHEAC Annual Conference

A cohort default rate is the percentage of a school’sborrowers who enter repayment on certain Federal

FamilyEducation Loan (FFEL) Program and/or William D. Ford

Federal Direct Loan (Direct Loan) Program loans during a

particular Federal fiscal year (FY), October 1 – September

30, and default or meet other specified conditions prior to

the end of the next fiscal year.

Cohort Default Rate

2003 GHEAC Annual Conference

FY is October 1 – September 30

Ex. FY 2001October 1, 2000 through September 30, 2001

Ex. FY 2002October 1, 2001 through September 30, 2002

Fiscal Year (FY)

2003 GHEAC Annual Conference

• Began February 2003• Schools must sign up for it at

www.sfawebenroll.ed.gov • Customer Service• Easier to manipulate and sort data• Requirement – Paperwork Reduction Act• Save taxpayer’s money• Saves the environment

eCDR

2003 GHEAC Annual Conference

• Customer Service• Easier to manipulate and sort data• Requirement – Paperwork Reduction Act• Save taxpayer’s money• Saves the environment

eLRDR

2003 GHEAC Annual Conference

• Published August 2001• Draft & Official Guides combined• Designed to assist schools with FFELP and Direct

Loan cohort • default rate data• Used as reference tool in understanding rates and

processes• Will remain effective until further notice• Electronic version located at

http://sfa4schools.sfa.ed.gov or http://www.ifap.ed.gov

• Changes inserted into booklet as supplements

Cohort Default Rate Guide

2003 GHEAC Annual Conference

• Calculated twice per year

• 2003 Calculation and Rate Release ScheduleDraft FY 2001 rates:

Calculate – January 11, 2003Release – February 18, 2003

Official FY 2001 rates: Calculate – August 2, 2003

Release – September 15, 2003

Cohort Default Rate Calculation

2003 GHEAC Annual Conference

Non-Average Rate Calculation:

Number of Borrowers who entered repayment in the cohort fiscal year and defaulted or met other specified

conditions in the cohort default period.

Number of Borrowers who entered repayment in the cohort fiscal year

Average Rate Calculation:

Number of Borrowers who entered repayment in the cohort fiscal year and the two years preceding cohort fiscal years and who defaulted or met other specified conditions in the cohort

default period

Number of Borrowers who entered repayment in the cohort fiscal year and the two preceding

cohort fiscal years.

Cohort Default Rate Calculation

2003 GHEAC Annual Conference

Incorrect Data ChallengeWho: Any school that received a draft cohort default rateWhen: During the DRAFT release periodWhat: Enables a school to request a correction to what it

believes to be inaccurate data contained in the LRDR or eLRDR

Participating Rate Index ChallengeWho: Any school that can demonstrate that the # of

students who obtains loans is very low in relation to the # of regular students at the school

When: During DRAFT release periodWhat: School not subject to sanction when next official

cohort default rate is published.

Types of CDR Appeals

2003 GHEAC Annual Conference

Uncorrected Data AdjustmentWho: Any school that submitted a timely challenge of its draft

rateWhen: During OFFICIAL release period only after data manager

has agreed to make changes and the changes are not reflected on the official LRDR or eLRDR.

What: Schools cohort default rate will be recalculated using corrected data.

New Data AdjustmentWho: Any school that submitted a timely challenge of its draft

rateWhen: During OFFICIAL release period only after data manager

has agreed to make changes and the changes are not reflected on the official LRDR or eLRDR.

What: Schools cohort default rate will be recalculated using corrected data.

Types of CDR Appeals

2003 GHEAC Annual Conference

Erroneous Data AppealWho: Any school whose official CDR includes new and/or

disputed data, must be subject to rate sanctions, or other successful appeals will result in a recalculated CDR below sanction threshold.

When: During the OFFICIAL release periodWhat: Will result in the recalculation of CDR using corrected

data.

Loan Servicing AppealWho: Any school receiving official CDRWhen: During the OFFICIAL release periodWhat: Loan may be removed from CDR which may or may not

lower CDR.

Types of CDR Appeals

2003 GHEAC Annual Conference

Other types of Appeals:(During OFFICAL Rate Release Period)

Economically Disadvantage AppealParticipation Rate Index AppealAverage Rates AppealThirty-or-Fewer Borrowers Appeal

Types of CDR Appeals

2003 GHEAC Annual Conference

• Gather your dataLRDR or eLRDRNSLDS

• Determine if you will appeal your CDR• Establish network of key players and

responsibilities• Develop a school’s records spreadsheet (see

example)• Use school’s internal data systems and NSLDS to

compare data• Use monthly repayment reports to verify data

Quick Steps for Appealing Your Default

Rate

2003 GHEAC Annual Conference

• Compare Your Data– Change in enrollment status– Canceled loans– Student delinquency status– Student transfers– Cured loans– NSLDS reports– Old SSCR’s

• Data Sharing• Correcting Data

Quick Steps for Appealing Your Default

Rate

2003 GHEAC Annual Conference

See Display

Default Analysis Software

2003 GHEAC Annual Conference

Webhttp://www.ed.gov/offices/OSFAP/defaultmanagement/cdr.html

Guidehttp://ifap.ed.gov/drmaterials/FinalCDRG.html or

http://ifap.ed.gov.drmaterials/changelog.html

Default Management Contact info:Email: fsa.schools.default.management@ed.gov

Phone: 202.377.4258

Mail: 400 Maryland Avenue, SW, Washington, DC 20202-5353

Commercial: 830 First Street, NE, Washington, DC 20002-5353

CDR Resources

2003 GHEAC Annual Conference

Regulations34 CFR 668.181-668.198, App A & B to Subpart M of Part 668

Handbook2001-2002 pages 2-56, 2-81. 2-82, 8-5, 8-6, 8-36

Partner Lettershttp://ifap.ed.gov/dpcletters/gen0108.html and http://198.77.160/eannouncements/0119stuhbkbestprectice.html

CDR Resources

2003 GHEAC Annual Conference

Georgia Higher Education Assistance CorporationU.S. Department of EducationSchools Portal and IFAPDefault CollectionsPartner Services and PortalStudents PortalNSLDSCase Management

Other Resources

2003 GHEAC Annual Conference

Contact GHEAC’s Default Prevention Area

Contact: Marcia Coleman, CoordinatorPhone: 770.724.9174Address:2082 East Exchange Place, Suite 220

Tucker, GA 30084Email: marciac@mail.gsfc.state.ga.usWeb: www.gsfc.org

CONTACT

2003 GHEAC Annual Conference

THANK YOU FOR ATTENDING

Q & A’s

2003 GHEAC Annual Conference