Default Management Frequently Asked Questions

These Frequently Asked Questions provide information and operational guidance on default management. The questions also address information about the cohort default rate guide.

Note: In the following FAQs, "the Department" refers to the U.S. Department of Education, "FFEL" refers to Federal Family Education Loan, and "FDSLP" or "Direct Loan" refers to William D. Ford Federal Direct Loan. "NSLDS" refers to National Student Loan Data System.

The Cohort Default Rate Guide (CDRG), which is a link on the Default Management website, is a comprehensive reference tool. Click on the CDRG page 1.1-3 to determine how to best use the CDRG based on different situations or level of knowledge and experience with the cohort default rates.

The FSA Assessments Default Management module is designed to assist schools in managing cohort default rates and to help prevent students from defaulting on Federal students loans. This is done through a series of statements, questions and links to additional resources. The FSA Assessments Default Management module is located at FSA Assessments Default Prevention Website.

The Partner Eligibility and Oversight Services Group (PEOS) can provide help or direction on a full range of default management questions and services. Call 202-377-4259 or send an email to For questions regarding default prevention, send an email to

Defaulted federal student loans cost taxpayers money. By calculating cohort default rates, sanctioning schools with higher rates, and providing benefits to schools with lower rates, the Department creates an incentive for schools to work with borrowers to reduce defaults. As a result, cohort default rates help save taxpayers money.

  • For schools having 30 or more borrowers entering repayment in a fiscal year, the school’s cohort default rate is the percentage of a school’s borrowers who enter repayment on certain William D. Ford Federal Direct Loans (Direct Loans) and Federal Family Education Loans (FFELs) during that fiscal year and default (or meet the other specified condition) before the end of the second fiscal year following the fiscal year that the borrower entered repayment.

  • For schools having 29 borrowers or fewer enter repayment the Average Rate Formula is used to calculate the official cohort default rate during a cohort fiscal year if that school had a cohort default rate calculated for the two previous cohort fiscal years.

Average Rate Calculation: The denominator for the average cohort default rate is the number of borrowers who entered repayment in the current cohort fiscal year and the two preceding cohort fiscal years. The numerator for the average cohort default rate is the number of borrowers who entered repayment in the current cohort fiscal year or either of the two preceding cohort fiscal years and who defaulted or met the other specified condition in the cohort default period for the cohort fiscal year in which they entered repayment.

The Department releases cohort default rates twice each year. Generally, the Department releases draft cohort default rates in February. After schools receive their draft cohort default rate data, schools are provided an opportunity to identify and correct any inaccuracies by submitting an Incorrect Data Challenge. The Department then releases the official cohort default rates. Official cohort default rates are generally released to schools and the public approximately six months after the release of the draft cohort default rates. However, the official cohort default rates must be released no later than September 30th of each year. Schools also have the opportunity to appeal official cohort default rates and/or loss of eligibility after they are released in September.

Yes, the draft and official cohort default rates may differ if the data used to calculate the official cohort default rate in NSLDS changed between the time the draft and the official cohort default rates were calculated. This may be a result of the school initiating an incorrect data challenge via the e-appeals system or may simply be a result of new data which is continually coming into NSLDS from lenders and data managers.

The Knowledge Center provides information on cohort default rates along with other Title IV federal student aid information. Schools should check this site regularly for updates regarding financial aid. In addition schools should check the Default Management Topic Page website, which provides specific information regarding cohort default rates.

You may find this information on the Default Management website. Note: The figures on the national reports cannot be derived from the 300 reports available for download.

Repayment information is a default management report provided to schools by the Department through NSLDS. These reports (DRC015/24 Month and DRC016/36 Month) provide, on a monthly basis, school-specific repayment information regarding students who have obtained Direct Loans to attend school and have entered into repayment on those loans in the first 12 months of the most recent 24 or 36-month period.

All schools that participate in any of the Title IV Federal Student Aid (FSA) programs and have students who meet the above criteria may access the repayment information. This information does not represent a school's cohort default rate; rather it is provided solely as a service to help schools track loans and correct errors associated with loans that recently entered into repayment. By monitoring when borrowers enter repayment, a school can make students aware of all the repayment options available to them to help a borrower avoid default. Schools can also use the repayment information to ensure the data reported to NSLDS is accurate. If errors in data are found, schools can contact their data manager immediately instead of waiting until the release of the draft cohort default rates to correct inaccuracies.

The purpose of releasing draft cohort default rates is to allow schools the opportunity to review their data and notify the applicable Data Manager (DM) if there is any erroneous data on the Loan Record Detail Report (LRDR). Schools should compare the data on their LRDR to the data in their files for each student listed. If any students are incorrectly included or excluded in the cohort period or have not defaulted during that cohort period, then you notify the DM. If they agree with your findings, the DM will make the appropriate corrections to the data. When the official rate is calculated in the fall, the data will have been corrected. If you do not challenge the incorrect data via an Incorrect Data Challenge, you will not be able to do so when the official rates are released.

Additionally, even if your cohort default rate is low, the number of borrowers in default and/or the dollars in default may be significant. This costs the schools, taxpayers, and the borrowers themselves in the long run. Also, your school's official cohort default rate may be inaccurate due to errors in underlying data, and the Department may make decisions based on that data. Schools are required to provide accurate data to the Department via NSLDS Enrollment Reporting.

The Delinquent Borrower Report (DELQ01) is available for both Direct Lending and FFEL Program schools. The DELQ01identifies and focuses on students who are delinquent on their loan repayment obligation. With DELQ01, we ask schools to act as liaison between borrowers and loan servicers. Once the connection is made, there is help available to prevent the loan from entering default. For more information, contact

You may find archived 2-year and 3-year cohort default rates on the Default Management website.

Go to the Federal Student Aid School Participation Divisions web page for information. You may also contact the Case Team at 202-377-3173. Know that there are specific guidelines and requirements for schools that wish to withdraw or reapply for participation in the Title IV programs.

Your school will not receive a CDR notification package if your school has NOT enrolled in eCDR notification, or if your school has never had a borrower enter into repayment in the FFEL or Direct Loan programs. If neither of the above applies, then your school should have received an eCDR notification package. Contact the SAIG Helpdesk (1-800-330-5947) for assistance in enrolling in the eCDR notification process. Schools may also now request a copy their notifications letter via NSLDS. If your school is enrolled in the eCDR notification process but did not receive its CDR notification package, contact PEOS at 202-377-4259 or via email at

The Department provides draft cohort default rates to schools. Although the Department does not release individual school rates to the public, aggregate draft information is released.

The Department sends draft cohort default rates to all schools that the Department's records indicate:

  1. Are eligible to participate in any of the Title IV programs and
  2. Have borrowers that entered repayment on FFELs or Direct Loans during the current or any prior cohort fiscal years.

The Department provides official cohort default rates to schools and also makes them available to the public.

The Department releases official cohort default rates for all schools that the Department's records indicate:

  1. Are eligible to participate in any of the Title IV programs and
  2. Have borrowers that entered repayment on FFELs or Direct Loans during the current or any prior cohort fiscal years.

A school may download an electronic copy of its Loan Record Detail Report (LRDR) for the draft cohort default rate or official cohort default rate periods. The public can also download a listing of all of the official cohort default rates in the form of a press package, 300 Report. This press package also contains a listing of those schools that are subject to sanctions, 304 and 305, as a result of high official cohort default rates.

Note: If your school did not receive any data on the LRDR pages (just a heading), it means that your school did not have any students in default or repayment for the applicable cohort periods; however, your school did have at least one borrower in repayment in one of the past cohort periods.

Instructions for downloading and reviewing the eCDR notification package can be found on the SAIG Enrollment Site. If you need additional help, you can contact the SAIG Help desk at 1-800-330-5947.

If your school has less than 30 borrowers entering repayment, and has data from the previous two cohort years, then an average rate will be calculated for your school, and this average rate will be your school’s official cohort default rate used to determine eligibility for all relevant cohort default rate sanctions/benefits. However, if your school has less than 30 borrowers entering repayment, and does not have data for the previous two cohort years, then a non-averaged rate will be calculated for your school based only on the current year data. This non-averaged rate is considered unofficial and cannot be used to determine all relevant cohort default rate sanctions/benefits.

Cohort default rates include Direct Loan and FFEL Program loans. While the FFEL Program has been eliminated there may still be FFEL loans included in the cohort default rate calculation.

The type of FFEL and Direct Loans included in the cohort default rate calculation are:

  1. Subsidized FFEL and Unsubsidized FFEL (collectively referred to as FFEL) and
  2. Federal Direct Subsidized Loans and Federal Direct Unsubsidized Loans (collectively referred to as Direct Loans).

All of a borrower's loans that entered into repayment within a cohort fiscal year are listed on a school's Loan Record Detail Report (LRDR) for that cohort period. The data on a school's LRDR is obtained from NSLDS and is used to calculate a school's cohort default rate. Although one of your borrower's may have more than one loan listed on your LRDR, because several of the borrowers’ loans entered into repayment in the same cohort period, the borrower (per social security number) is only counted once in the calculation. The loan that is counted in the calculation will have the letter "D" (denominator) or "B" (both numerator and denominator) listed on the LRDR under the column title "usage 1 code." All other loans for that student were eligible to be counted but were not. They will be listed on the LRDR and the letter "E" (eligible but not counted in the calculation) noted in the "usage 1 code" column. See Chapter 2.3 in the CDRG for illustrations of how to read the LRDR.

Note: One exception to this might be that a borrower may be counted twice if the borrower took out loans at two different schools and subsequently these two schools merge.

Yes, if your school has 30 or more borrowers, and has a cohort default rate that is equal to or greater than 30 percent it must establish a default prevention task force. This task force must prepare a plan to identify the factors causing the school’s cohort default rate to exceed 30 percent and submit to the Department for review. In addition, schools with cohort default rates of 30 percent or greater for two consecutive years will have to revise their plans to implement additional procedures and also could be subject to provisional certification. For more information, read 34 CFR 668.217 and Chapter 2.4 of the CDRG or contact for assistance.

Yes, there are benefits available to schools with a low official cohort default rate. For more information, refer to Chapter 2.4 of the CDRG.

A school involved in a merger, acquisition or other change in status should be aware that the change may affect the application and calculation of its cohort default rates and that certain sanctions may be applicable to the school after the change in status. After a change in status, cohort default rates are applied to a school according to the type of change in status. See chapter 2.5 in the CDRG, "Change in Status and Evasion." Also refer to 34 CFR 668.203, "Determining cohort default rates for schools that have undergone a change in status."

You may find information about special circumstances and how they affect cohort default rates in Chapter 2.1 of the CDRG.

eCDR Appeals is the vehicle for schools to electronically submit certain challenges, adjustments, and appeals of cohort default rate data to the Department and/or to the Data Managers. eCDR Appeals is a single web-based user interface for all users. This process applies to the Federal Family Education Loan and Direct Loan Programs only. To access eCDR Appeals, go to the eCDR Appeals website. To access the different types of User guides for eCDR Appeals, refer to the eCDR Appeals user guide linked below. Each user guide provides instructions to your school regarding how to submit an Appeal via the eCDR Appeals system. There are different user guides for each kind of Appeal.

Yes, all the templates/spreadsheets you need to prepare challenges/appeals are located on the CDRG homepage. These forms should facilitate the process for you.

No, timeframes are mandated by regulation; therefore no extensions are granted. However if a school believes that a technical problem that was caused by the Department resulted in the school not being able to access its electronic cohort default rate information, it must notify us no later than five business days after the transmission date announced on the IFAP website. By doing so and if we agree that the Department caused the problem, we will extend the challenge, appeal, and adjustment deadlines and timeframes to account for a re-transmission of the information after the technical problem is resolved.

Refer to Chapter 4 of the CDRG for complete information on all of the cohort default rate challenges/adjustments/appeals that are available to schools. Additionally, schools may reference the eCDR Appeals User Guide linked below.

The Department requests for schools to submit any appeal traditionally mailed to the PEOS Group to be submitted via email to Ensure that Participation Rate Appeals, Economically Disadvantages Appeals, and Erroneous Data Appeals containing PII data are submitted securely using a password-protected program, (i.e. Winzip).