This is the first in a series of letters to postsecondary education institutions, servicers, lenders, State education agencies, State guaranty agencies, and accrediting agencies regarding the implementation of a new numbering system for entities participating in the Federal student financial assistance programs.
Title IV of the Higher Education Act of 1965, as amended (HEA), contains the major Federal student financial assistance programs in which postsecondary education institutions participate. These student financial assistance programs have been enacted by the Congress at different times during the past 30 years, and this has resulted in many instances where these programs use different identification numbers for the same institution.
A single postsecondary education institution, participating in multiple student financial assistance programs, may have been assigned by the Department of Education (ED):
An Office of Postsecondary Education Identifier (OPEID), an eight digit random number for oversight ("gatekeeping") functions;
A six digit random number for the Federal Family Education Loan Programs;
A six digit random number as an identification number for the Federal Perkins Loan, Federal College Work-Study, and Federal Supplemental Educational Opportunity Grant Programs;
A six digit random number as an identification number for the Federal Pell Grant Program;
A six digit alphanumeric identification number for the Federal Direct Student Loan Program; and
One or more six digit alpha/numeric Title IV school code(s) for the purposes of the Free Application for Federal Student Aid (FAFSA).
In addition, the same institution will have received -
A nine digit Tax Identification Number (TIN) from the Internal Revenue Service;
A twelve digit Central Registry Service Number from ED that is a conversion of the TIN assigned by the Internal Revenue Service that the institution uses for certain purposes with ED;
A four digit alphanumeric Payee Identification Number; and
A nine digit random Data Universal Numbering System (D-U-N-S) identifier issued to the institution by the Dun & Bradstreet Corporation which is used by the institution in electronic commerce with various federal agencies.
As part of its reauthorization of the HEA in 1992, the Congress sought to streamline this system and in Section 487B mandated that:
The Secretary shall assign to each participant in title IV programs, including institutions, lenders, and guaranty agencies, a single Department of Education identification number to be used to identify its participation in each of the title IV programs. [20 USC 1094b]
In seeking to carry out this mandate, the Department assembled a Title IV Single Identifier Initiative Team to manage the implementation of a new numbering scheme. The work of the initiative has been divided into two phases:
Phase One, to determine a new numbering system while resolving multiple or conflicting identifiers held by participants.
Phase Two, to implement the new numbering system with due allowance for systems redesign in computer systems maintained by institutions, lenders, servicers, guaranty agencies, and the Office of Student Financial Assistance.
To pursue Phase One of the initiative, the Department convened a Focus Group to implement an open process of developing the new identifier. The Focus Group was composed of representatives of financial aid, business, and admissions offices of large and small colleges and universities, national and State guaranty agencies, the Student Loan Marketing Association (SALLIE MAE) and other loan servicers, several associations (National Association of Student Financial Aid Administrators, American Association of Collegiate Registrars and Admissions Officers, National Association of College and University Business Officers), the U.S. Office of Management and Budget, and ED's Chief Information Officer and Chief Financial Officer.
The Focus Group met six times between February and September 1996. At its last meeting on September 30, 1996, the Focus Group made the following recommendation for phasing in the use of a single identifier for each institution:
The eight-digit random OPEID would be revised to identify all ED approved locations of an institution and the Title IV school codes used for FAFSA purposes. This revised OPEID would be implemented by the award year 1999-2000 as the Title IV single identifier throughout the Title IV communities.
The Focus Group took cognizance of the fact that over the next decade the Federal Government will determine whether the nine digit random TIN or the nine digit random D-U-N-S will be used for all electronic commerce transactions. The Focus Group agreed that if and when such determination is made, the revised OPEID may be superseded.
In sum, the Focus Group did not adopt the D-U-N-S as the Title IV identifier at this time because of 1) the inherent risk in anticipating which identifier ultimately may be chosen for electronic commerce, and 2) the significant costs in computer programming (in excess of $35 million) that would be incurred by participating colleges and schools, loan servicers and guaranty agencies implementing an identifier that may not be the Federal Government-wide electronic commerce identifier.
Therefore, the Office of Student Financial Assistance will proceed to implement the Focus Group's recommendation for the new numbering system called the revised OPEID. Implementation of Phase Two will take place through a series of activities of which the following is a broad overview:
May 1997 - September 1997: Each Title IV participating postsecondary education institution will be notified of all existing program identifiers assigned to the institution; all previous identifiers (for student loan purposes) that were
assigned to the institution, and all Title IV school codes used by the institution. The institution will be asked to provide ED with whatever corrections are appropriate through a web site, facsimile, or regular mail.
October 1997: Each Title IV participating postsecondary education institution will be notified of its new revised OPEID identifiers for its main campus, its non-main campus educational sites, and the Title IV programs in which the institution participates.
November 1997: The SFAP data systems and the data systems of guaranty agencies and other servicers will be provided with an electronic file containing a crosswalk of all old, current identifiers and the institution's identifiers under the new revised OPEID numbering system.
November - December 1997: Rough draft of records layout containing the 8 digit revised OPEID will be provided to postsecondary education institutions, State education agencies, guaranty agencies, servicers, destination points, and other interested higher education entities.
Summer 1998: Each Title IV WAN participating institution will receive an "Action Letter" describing the Title IV Wide Area Network, its services, and applicable enrollment procedures. Through this process, institutions are allowed to reaffirm/change their listing(s) in the "Title IV School Code List 1999-2000" as it is finalized and distributed to institutions, lenders, high schools, etc.
Fall 1998: Each participating Title IV institution will be notified regarding the date(s) the new revised OPEID numbering system should be used for each Title IV program.
January 1999: The new revised OPEID numbering system is used as institutional identifiers in the processing of FAFSAs for the 1999-2000 award year.
Throughout the new revised OPEID numbering system implementation process, SFAP is committed to providing Title IV participating entities with accurate and up-to-date information of our progress through frequent conference presentations, "action letters" to all participants, and web site information.
I encourage each of you to share your thoughts and suggestions for the successful implementation of this new initiative. You may contact the Title IV Single Identifier
Initiative through -
electronic mail, firstname.lastname@example.org,
voiceline, 202.708.4608, or
regular post at Title IV Single Identifier Initiative
U.S. Department of Education
600 Independence Avenue, S.W.
Washington, D.C. 20202.5132
We are committed to implementing the new OPEID numbering system while maintaining an undisturbed Title IV student aid delivery system.
Elizabeth M. Hicks
Deputy Assistant Secretary for
Student Financial Assistance Programs