Posted Date:September 4, 2015
|Author:||Jeff Baker, Director, Policy Liaison and Implementation, Federal Student Aid|
Subject: Gainful Employment Electronic Announcement #60 - GE Reporting and Resolving Incorrect Credential Level Data in NSLDS and in COD
On August 29, 2015, we sent warning letters to institutions that had reported at least one 2014-2015 origination record to the Common Origination and Disbursement (COD) system where the record indicated that the award was for the student’s enrollment in a GE program, but the institution did not submit GE data to the National Student Loan Data System (NSLDS) by the July 31, 2015 GE reporting deadline.
With few exceptions, all non-degree programs at non-profit and public institutions are GE programs and all programs are GE programs at for-profit institutions. See Gainful Employment Electronic Announcement #53.
Since sending those warning letters we have been contacted by some institutions telling us that the reason they had not reported was that they have no GE programs. Upon researching a number of these cases, we determined that the problem was that institutions had submitted incorrect Program Credential Level codes when reporting to COD. For example, one institution reported to COD a Program Credential Level code of ‘08’ – graduate certificate – for students enrolled in more than 100 different programs. In fact, the programs are master’s degree programs and, therefore, should have been reported to COD with a Program Credential Level code of ‘05’ – master’s degree. Because a program that awards a graduate certificate is a GE program, this misreporting resulted in the unreported GE program warning letter being sent to the institution’s president.
Because this issue appears to be a problem for more than a few institutions (both those who received our warning letter and others) all institutions must review their COD reporting for the 2014-2015 award year (as well as for any COD records submitted for the current 2015-2016 award year) and, using the guidance provided below, correct in both NSLDS and COD where any Program Credential Level codes are in error. Those institutions must also determine what program or process at their institution (or at their third-party servicer) created the incorrect reporting and ensure that the process is immediately fixed.
Using the NSLDS GE Program Tracking List Page
Institutions must log into the NSLDS Professional Access Web site and review the entries on the GE Program Tracking List page. This page includes a listing of the institution’s programs that, based on COD reporting, appear to be GE programs. Refer to Gainful Employment Electronic Announcement #59 and the instructions in Chapter 4 in the recently-revised NSLDS Gainful Employment User Guide for assistance with NSLDS GE Program Tracking functionality. If the Program Credential Level code that appears on the GE Program Tracking List page for the program is not correct due to inaccurate COD reporting, select ‘I2’ (Program Was Not Title IV Eligible) for a status code.
Correcting Data in the COD System
If an institution determines that it had reported a Program Credential Level Code value to the COD System incorrectly, the data must be corrected, by either:
Sending a maintenance record that contains the updated values for the <ProgramCredentialLevel> tag in the award information using a Common Record document from the school’s software; or by
Making the appropriate updates to the Program Credential Level code values online using the COD Web site. For online corrections, an authorized user must complete the following steps:
Log in to the COD Web site.
Search for the Borrower on the Person Search Page, located under the “Person” link in the blue navigation bar.
Click on the “Direct Loan” link in the left-side navigation panel.
Select the award year from the “Award Year” Drop down menu.
Select the appropriate award from the Person Direct Loan Information page by clicking on the “Award ID”.
From the Award Detail Information page, click on “Update Award.”
Update the Program Credential Level value as applicable and click on “Submit.”
Note: All updates made to the COD System will be validated for errors upon submission. Any errors resulting from the attempted changes will need to be corrected.
When making corrections to the data in the COD System, it is only necessary to correct entries that are inaccurate, such as a student being reported at the wrong credential level, not entries that have changed, such as a student beginning one program and switching to another program between disbursements.
Accurate Reporting Reminder
As we noted in the gainful employment warning letters, the information for GE programs that are listed as unreported on the NSLDS GE Program Tracking List page must be resolved, either by reporting on the program or by correcting errors such as those described in this announcement. Whether an institution is subject to sanctions, and the severity of those sanctions, will be partially dependent on how quickly the institution becomes compliant by properly reporting to NSLDS. Therefore, institutions that have not yet reported their GE information to NSLDS, those that did not report completely, and those that have not resolved discrepancies on the GE Program Tracking List page must do so without any further delay.
If you have questions about the COD System, contact the COD School Relations Center at 800/474-7268 for Grants or 800/848-0978 for Direct Loans. You may also e-mail CODSupport@ed.gov.
If you have questions about NSLDS, contact the NSLDS Customer Support Center at 800/999-8219. You can also contact Customer Support by e-mail at email@example.com.
The Gainful Employment Information Page on the IFAP Web site contains publications and resources on GE as well as Frequently Asked Questions (FAQs). If you have a question about the GE regulations that is not addressed in the FAQ section of the Gainful Employment Information Page, please submit the question to firstname.lastname@example.org.