2015 Fall OASFAA Conference

Angela Smith, Training Officer

U.S. Department of Education

Federal Update

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Prior Prior Year (PPY)

Prior-Prior Year

• President’s Announcement –• FAFSA Start-Up on October 1• Use of Prior-Prior Income Data

• Beginning with the 2017-2018 FAFSA• October 1, 2016• 2015 Tax Year

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Questions?

FAFSA CHANGES FOR 2017-18

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Prior-Prior

• Issues• Verification • Conflicting information• Outreach• Professional Judgement• State grant agencies• Early awarding• Deadlines

• Beginning with the 2016-2017 FAFSA the names colleges listed by applicants on FAFSAs will not be included on ISIRs provided to institutions.

• Will continue to be included on ISIRs provided to state grant agencies

• Will be on the SAR provided to the FAFSA applicant.

FAFSA – List of Schools

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2016-17

and policy updates

2016-17 Verification – Overview

• Same data elements as for 2015-2016 award year

• Some modifications and clarifications to acceptable documentation

• In limited circumstances, an applicant’s Verification Tracking Group could change

• Resources• GEN-15-11• Federal Register Notice – June 26, 2015• Suggested Text – Coming soon!

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2016-17 Verification

• Verification Tracking Group changes:• Verification Tracking Group V3 (Child

Support Paid) has been removed• Applicants placed in V1, V4, V5, and V6 must still verify child support paid if reported on ISIR

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2016-17 Verification

• Verification Tracking Group changes:• Applicants may be moved from previously

assigned Groups V1, V4, and V6 to Verification Tracking Group V5• Applicant is only required to verify the additional items in

V5 that were not previously verified• If the applicant is moved to Verification Tracking Group

V5, no additional disbursements of any Title IV aid may be made until verification is satisfactorily completed

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2016-17 Verification

• Verification Tracking Group changes:• Applicants moved to Verification Tracking Group

V5• If Title IV aid had been disbursed prior to receiving an

ISIR with the new V5, and the applicant does not complete verification, the applicant is liable for the full amount of TIV aid disbursed for 2016-2017

• The institution is not liable

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2016-17 Verification

Income Information for Non-IRS Tax Filers • Tax filers who filed an income tax return with a taxing

authority in a U.S. territory (Guam, American Samoa, the U.S. Virgin Islands) or commonwealth (Puerto Rico and the Northern Mariana Islands) or with a foreign central government, must submit a copy of a transcript of their tax information • A signed copy of the applicable 2015 income tax return

that was filed with the taxing authority is only acceptable if tax filers are unable to obtain a free copy of a transcript of their tax information

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2016-17 Verification

Income Information for Non-IRS Nontax Filers • Residents of the Freely Associated States (Republic of

the Marshall Islands, the Republic of Palau, the Federated States of Micronesia), and a U.S. territory or commonwealth or a foreign central government who are not required to file an income tax return under that taxing authority’s rules must submit:• a copy of their Wage and Tax Statement (or equivalent

documentation) for each source of employment income and• a signed statement identifying all of the individual’s income and

taxes

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Verification Policy Updates

• Tax filers and Nontax filers—if a copy of the tax return was not retained and cannot be located by the IRS must submit:

• Copy of all relevant W-2s• Signed statement that individual did not retain a copy of his or her tax account information, and

• Documentation from the IRS that indicates that the individual’s tax account information cannot be located

• Child support paid• Removed a separation agreement or divorce decree from acceptable documentation

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Verification Policy Updates

High School Completion Status • For V4 and V5, if institution successfully verified and

documented applicant’s high school completion status for a prior award year, verification of high school completion status is not required for subsequent years

• An institution may not accept as alternative documentation an applicant’s self-certification, nor a DD Form 214 Certificate

Identity/Statement of Educational Purpose • The valid government-issued photo identification used to

verify an applicant’s identity must not have expired

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Verification Policy Updates

Victims of IRS tax-related identity theft must submit:• Statement signed and dated by tax filer indicating they

were victims of IRS tax-related identity theft and the IRS has been made aware of the tax-related identity theft; and

• A Tax Return DataBase View (TRDBV) transcript obtained from the IRS • Tax filers who cannot obtain a TRDBV transcript may instead

submit another official IRS transcript or equivalent document provided by the IRS if it includes all of the income and tax information required to be verified

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Guidance applies to 15/16 and subsequent years • Posted in 6/26/15 Federal Register Notice

Verification Policy Updates

Individuals who filed an amended tax return must submit the following documents to the institution:

• an IRS Tax Return Transcript, or any other IRS tax transcript(s) that include all of the income and tax information required to be verified; and

• a signed copy of the IRS Form 1040X that was filed with the IRS

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Guidance effective 8/13/15 for 15/16 and subsequent years • Posted on Program Integrity Q & A website

EA dated October 2, 2015

• Alternative documentation allowed when tax filer RECENTLY requested but unable to obtain an IRS Tax Return Transcript using the IRS paper or on-line request process • No alternative documents for telephone requests • Exception not permitted for –

• transcripts unable to be obtained simply because the IRS has not had time to process the data due to a recent filing

• saying the "Get Transcript Online" tool is not available

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For 2015-2016 award year

2015-2016 – Transcripts Unavailable

Alternative documentation includes:

Signed copy of relevant 2014 IRS tax return

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Statement from tax filer, on or attached to the return, certifying same data submitted to the IRS

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Communication from IRS stating request unsuccessful – Letter from IRS (signed and dated by tax filer); or– Screen shot print (signed and dated by tax filer)

AND

Completed and signed IRS Form 4506 T-EZ or 4506-T listing institution as third party – only send to IRS if doubt accuracy

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Federal Perkins Loan

program

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Perkins Loan Program

•Dear Colleague Letter GEN-15-03•No congressional action - program ended on September 30, 2015

•Schools may not make Federal Perkins Loans to new borrowers after September 30, 2015.

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Perkins Loan Program

• If prior to October 1, 2015, a school makes the first disbursement of a Federal Perkins Loan to a student for the 2015-2016 award year, the school may make any remaining disbursements of that 2015-2016 loan after September 30, 2015.

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Perkins Loan Program

• Narrow “grandfathering” provision• Allows schools to make Perkins Loans to certain students for up to five additional years (through September 30, 2020) to enable students who received loans for award years “to continue or complete courses of study.

• Loans can be made only if ALL of the following conditions are met:

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Perkins Loan Program: Grandfathering provision• The school made at least one loan disbursement

to the student on or before June 30, 2015.• The student is enrolled at the same institution

where the last Perkins Loan disbursement was received.

• The student is enrolled at the same academic program for which the last Perkins Loan disbursement was received.

• Need remains after Direct Sub awarded

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Must I liquidate my Perkins portfolio?

NONote: While currently the Department cannot require schools liquidate, Section 466(c) of the Higher Education Act requires

institutions to return to the Department of Education (Department) the Federal share of any Excess Liquid Capital (ELC) in the institution’s Federal Perkins Loan Revolving Fund

(Fund). This statutory requirement for institutions to return ELC is not directly related to the wind-down of the Perkins Loan

program.

See DCL GEN-15-19, published September 29, 2015 for details.

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Perkins Loan Program: Excess Liquid Capital• DCL GEN-15-19• Attached Excel Work-Sheets

• Calculate Excess Cash• Calculate Federal/School Shares

• Return Federal Funds by December 31, 2015

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http://ifap.ed.gov/ifap/cbp.jsp

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Recent Federal

Registers

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Final Rule:Title IV Student Loan programs

• Final regulations published on October 30• Revised Pay As You Earn (REPAYE)

• Extends the 10 percent payment cap to an additional 6 million loan borrowers.

• Early implementation in December 2015

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Final Rule:Title IV Student Loan programs• Final regulations published on October 30• Implemented on July 1, 2016

• Creates a streamlined process to identify military service members who hold FFEL program loans and who are eligible for lower interest rates

• Require guaranty agencies to provide FFEL borrowers in the process of rehabilitating a defaulted loan with information on repayment plans

• Allows lump sum payments made through student loan repayment programs administered by the DoD to count as multiple qualifying payments for purposes of the Public Service Loan Forgiveness Program

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Final Rule:Title IV Student Loan programs• Final regulations published on October 30• Expands the circumstances under which an institution

may challenge or appeal a draft or final cohort default rate• Will be effective in February 2017

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Final Rule: Cash Management

• Negotiations held in early 2014• NPRM published in May of 2015• Public comment period closed July 2, 2015

• Received over 200 comments

• Final regulations published on October 30• Effective July 1, 2016

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Final Rule: Cash Management

• Updated regulations include tougher standards and greater transparency around agreements between colleges and companies providing prepaid/debit cards to students• Meaningful choice of products• Clear and neutral information• Looking at fees charged

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Final Rule: Cash Management

• Other regulations modified• §668.162 (c) and (d) Reimbursement and HCM• §668.163 Maintaining and accounting for funds• §668.164 Disbursing funds

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Proposed Rule: Borrower Defenses

• Rules to allow borrowers to request loan discharge based on a borrower defense of school misrepresentation

• August 20, 2015 - Federal Register Notice: Public Hearings• September 10, 2015, in Washington, DC,• September 16, 2015 in San Francisco, California

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Proposed Rule: Borrower Defenses

• October 20, 2015 – Federal Register Notice: Negotiator Nominations and Schedule of Committee Meetings

• Schedule for Negotiations• Session 1: January 12–14, 2016• Session 2: February 17–19, 2016• Session 3: March 16–18, 2016

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Notice: Experimental Sites

• Notice published November 3• Institutions selected will test dual enrollment and Pell

Grant eligibility• Letters of interest to participate in the experiment must be

received February 1, 2016

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Notice: 2016-17 Federal Student Aid Application• Notice published October 28• Requesting comments from the community regarding the

2016-17 process for applying for Federal Student Aid• Comments due by November 26, 2015• Find related documents, and submit Comments via

www.regulations.gov• ED-2015–ICCD–0101

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Potpourri…

Confirmation of TG#s and User Accts

• EA dated October 26, 2015 • Required by December 11, 2015 • Some of the impacted SAIG Mailboxes are

• NSLDS Professional Access Web site• COD Web site• eCampus-Based (eCB) Web site• FAA Access to CPS Online• EDconnect user accounts

• Primary DPA of the primary TG number (Destination Point/mailbox) must actively confirm mailboxes and user accounts

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The HEA turned

2015 FSA Training Conference!!

• Tuesday, December 1 – Friday, December 4, 2015

• Mandalay Bay, Las Vegas, Nevada

• fsaconferences.ed.gov (right-hand side of IFAP website)

• Conference and lodging registration are open now!

• Tentative agenda is posted.

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Your Feedback is Requested

To ensure quality training, we ask all participants to complete an online evaluation for each session. Using the link below, please complete an evaluation of my presentation. https://s.zoomerang.com/s/AngelaSmith-Reg5

Thank you!

Or, feel free to contact my supervisor:JoAnn BorelJoann.borel@ed.gov

Questions about this presentation?

Feel free to contact me:

Angela Smith, Training Officer

Angela.smith@ed.gov

312-730-1552