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ANN-97-4 (MAR-97) Title IV Single Identifier

PublicationDate: 3/15/97
Summary: ANN-97-4 (MAR-97) Title IV Single Identifier
Author: OPE - Office of the Assistant Secretary for OPE



Title IV Single Identifier Initiative
U.S. Department of Education
Washington, DC 20202-5132

Information Bulletin
ANN-97-4
March, 1997


Subject: To provide general information concerning the forthcoming
changes in Title IV program numbers used by participating
institutions of postsecondary education.

Publication Reference: Section 487b, Higher Education Act of 1965,
as amended in 1992, P.L. 102-325 [20 U.S.C. 1094b].


Dear Colleague:

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, title4sii@ed.gov,
- facsimile, 202.260.5909,
- 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.


Sincerely,


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