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(GEN-97-09) (GEN-97-09) UPDATE ON THE SSCR PROCESS OF THE NSLDS: describes a series of letters that will be sent to institutions in connection with the SSCR process.

DCLPublicationDate: 8/1/97
DCLID: GEN-97-9
AwardYear:
Summary: UPDATE ON THE SSCR PROCESS OF THE NSLDS: describes a series of letters that will be sent to institutions in connection with the SSCR process.


August, 1997

GEN-97-9

Summary: UPDATE ON THE SSCR PROCESS OF THE NSLDS:
This letter discusses recent activities the Department has
taken and activities it will take in its implementation of
the SSCR process of the NSLDS. It also describes a
series of letters that will be sent to institutions in
connection with the SSCR process.

Dear Colleague:

As you are aware, the Department is completing the implementation
of the Student Status Confirmation Report (SSCR) process of the
National Student Loan Data System (NSLDS). Over the past several
months, we have developed and shared with schools our plans for the
transition of the SSCR process from one that required schools to
respond to SSCR rosters sent to them by guaranty agencies to a
unified single source NSLDS SSCR process. Those plans
include informing schools of their obligation to prepare for and
implement the SSCR process. As we said in our earlier letters,
institutions participating in any Title IV student aid program
must participate in the NSLDS SSCR function.

To implement the regulatory requirement that schools respond to
SSCR requests received from the NSLDS (See 34 CFR 682.610(c)
(FFEL) and 685.309(b) (Direct Loans)) the Department created
various implementation steps as discussed in a series of Dear
Colleague Letters (GEN-96-5 and GEN-96-17 that dealt specifically
with the SSCR process, and GEN-96-20 that explained the Title IV
Wide Area Network (TIV WAN)). In addition, the Department
provided information on implementation steps in Computer Based
Training materials sent to all schools in April 1996. These steps
include:

(1) Signing up for participation in the TIV WAN and submitting
registration documents for access to the NSLDS in general and
the SSCR process specifically.

(2) Designating a destination point and contact person for SSCR
processing and establishing a calendar for receipt of SSCR
rosters from the NSLDS.

(3) Retrieving the SSCR practice roster from the TIV WAN
electronic mailbox.

(4) Completing and returning to the NSLDS the SSCR with required
information and updates.

(5) Retrieving the SSCR error roster from the TIV WAN mailbox.

(6) Correcting and returning to the NSLDS any error records
returned on the SSCR error roster.

We are now about to enter a new phase of SSCR implementation
where we will:

(1) Acknowledge and reward those schools that have successfully
completed their implementation of SSCR processing through the
NSLDS.

(2) Assist those schools that have shown evidence of complying, but
still have outstanding problems in meeting the SSCR compliance
requirements.

(3) Begin the process of taking enforcement action against those
schools that have not responded to our efforts to ensure their
participation in this important endeavor.

Schools will soon be receiving one or more of the letters described
below:

CURRENT STATUS LETTERS:

SUCCESSFUL COMPLETION LETTER - This letter will be sent
to all schools that successfully retrieved, completed, and returned
the SSCR practice roster. The school must have had accepted into
the NSLDS at least 90% of the student records on its roster (either
initially or as a result of resubmission of error records). This letter
will inform the school that, since it has successfully completed the
NSLDS SSCR process, it is relieved of the responsibility to process
SSCR rosters received from guaranty agencies. The guaranty
agencies will receive a listing of all schools that have achieved this
success level. These schools will begin to receive SSCRs from
NSLDS according to the schedule they established when they
registered with NSLDS through TIV WAN and will be expected to
complete and return the electronic rosters to the NSLDS within 30
days of their being placed in the school's TIV WAN mailbox by
the NSLDS. The first such rosters were sent at the end of February
of this year.

UNSUCCESSFUL COMPLETION LETTER - This letter will be
sent to schools that have had SSCR rosters placed in their TIV
WAN mailboxes, but have not successfully completed and returned
the roster with at least a 90% success rate. The letter will inform
the school that, not only must it continue to process SSCRs
received from guaranty agencies, it must also work to complete
successfully the NSLDS SSCR roster sent to its TIV WAN
mailbox. As soon as the NSLDS produces a new SSCR roster
according to the schedule established by the school, the school will
no longer be able to return an earlier roster. The Unsuccessful
Completion Letter will also inform the school that if it is unable to
return successfully the NSLDS SSCR roster within the regulatory
30-day timeframe, it may be subject to appropriate enforcement
action by the Department, including fines or other administrative
sanctions.

NON-PARTICIPATING LETTER - This letter, which will be
addressed to the school's president or CEO, will be sent to those
schools that have not signed up with TIV WAN or designated a
third-party servicer to process their SSCR rosters. The letter will
describe the enforcement actions that may be taken against the
school, including the initiation by the Department of a fine or a
limitation, suspension, or termination action.

ON-GOING OVERDUE LETTERS:

On an on-going basis we will monitor the return of SSCRs to the
NSLDS. If a school fails to return an SSCR within the required
timeframe, it will receive one of a series of Overdue Letters.
These letters, described below, will remind the school of its
obligation to process and to return the SSCR. The letters will also
inform the school of the Department's enforcement options if the
submission is not made promptly.

FIRST OVERDUE LETTER - This letter will be sent to the
financial aid administrator at a school when an SSCR roster that
was placed in the school's TIV WAN mailbox has not been
returned within the required 30-day timeframe.

SECOND OVERDUE LETTER - This letter will be sent to the
president or CEO of a school whose return of an SSCR roster is
more than 21 days late. It will inform the president that failure to
return the completed roster to the NSLDS could result in
enforcement actions against the school.

THIRD OVERDUE LETTER - This final demand letter will be
sent to the president or CEO of any school whose return of an
SSCR roster is more than 28 days late. This letter will notify the
school that the matter will be referred to the Department's
Administrative Actions and Appeals Division with a request for
initiation of an administrative action. Such actions could include
the initiation of a fine action or a limitation, suspension, or
termination action that could affect the school's participation in all
Title IV programs.

We remain very concerned with the number of schools that have
still not successfully made the transition to the new NSLDS SSCR
process. While we are committed to assisting those schools that
demonstrate an intent to comply with the SSCR requirements, we are
prepared to take whatever enforcement actions are necessary and
appropriate against schools that consistently fail to make an effort to
comply. Needless to say, we are also extremely grateful to the large
number of schools that have worked with us to make this transition
successful and we congratulate those that will be receiving our
"Successful Completion Letter."

If you have any questions related to the NSLDS SSCR process please
contact the NSLDS Customer Service Center at (800) 999-8219.
Questions concerning registration with the TIV WAN can be
answered by the TIV WAN Customer Service Center at
(800) 615-1189.

Sincerely,



Elizabeth M. Hicks
Deputy Assistant Secretary for
Student Financial Assistance Programs