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(Loans) Subject: Erroneous Data Appeal - Incorrect Borrower Enrollment

Posted Date:September 23, 2014

Author: Katrina Turner, Director, Operations Performance Division, Federal Student Aid

Subject: Erroneous Data Appeal - Incorrect Borrower Enrollment

In an Electronic Announcement dated September 22, 2014, we announced that the Department of Education had distributed FY 2011 3-Year official cohort default rates (CDRs) to schools. That announcement also provided information on the CDR appeal process available to schools. In this announcement, we provide information about a change in the circumstances that could result in approval of an Erroneous Data Appeal (ER) under the regulations at 34 CFR 668.211 for schools subject to loss of eligibility or provisional certification because of high CDRs.

During the draft CDR challenge process this past spring, some data managers rejected a school’s submission of a change in a borrower’s enrollment status under the Incorrect Data Challenge (IDC) process of the regulations at 34 CFR 668.204(b) because of the lack of “timeliness” of the requested change in relation to when the enrollment changed. We will be advising all data managers that receipt of an Erroneous Data Appeal based on incorrect enrollment information should, if otherwise correct, be approved without regard to when the enrollment change occurred.

Contact Information

For additional information regarding the school cohort default rate calculation or the challenge processes, please refer to the Cohort Default Rate Guide at

You may also contact us by e-mailing or by calling the Operations Performance Division's hotline at 202/377-4259.

Last Modified: 09/22/2014