Posted Date:October 21, 2016
| Author: | Pamela Eliadis, Service Director, System Operations & Aid Delivery Management, Federal Student Aid |
Subject: Gainful Employment Electronic Announcement #94 - Draft GE Debt-to-Earnings (D/E) Rates Challenge Period: October 24 to December 7, 2016
The purpose of this Electronic Announcement is to inform the community that the 45-day draft Gainful Employment (GE) Debt-to-Earnings (D/E) rates challenge period will begin on October 24, 2016, and end on December 7, 2016. In the sections below we provide important information on the (D/E) rates challenge process.
Challenge Period
In a series of recent communications we have provided detailed information about the distribution of the draft GE D/E rates. Refer to Gainful Employment Electronic Announcement #93 for complete information about the October 20, 2016 distribution of the GE Debt Measures Backup Data detail files from NSLDS to institutionally-designated Student Aid Internet Gateway (SAIG) mailboxes. These detail files contain the draft GE D/E rates for each GE program at the institution as well as the data used to calculate the rates.
Beginning Monday, October 24, 2016, institutions will have 45 days to submit challenges to certain underlying loan data used to calculate the draft GE D/E rates, using new functionality on the NSLDS Professional Access website. The final day of the draft GE D/E rates challenge period will be Wednesday, December 7, 2016.The challenge submission functionality in NSLDS will be available until 11:59 P.M. (ET) on December 7, 2016.
Note: The NSLDS screens to challenge the loan data are now viewable on the NSLDS Professional Access website; however, the functionality to submit challenges will not be active until Monday, October 24, 2016.
Due to the requirement for institutions to submit supporting documentation to substantiate a challenge, as described in the “Supporting Documentation” section below, we strongly encourage institutions to begin their review of their draft GE D/E rates data immediately and begin gathering the supporting documentation that will be required to submit a challenge during the 45-day challenge period.
Challenge Instructions
As described in Gainful Employment Electronic Announcement #92, during the 45-day challenge period institutions may challenge certain Title IV loan data that is used to calculate the median debt for the students in a GE program. The three primary reasons why an institution may want to submit a challenge are as follows:
The loan does not belong to the student or to the institution;
Incorrect loan period dates;
The Loan Debt Amount is incorrect (although the Loan Debt Amount is not challengeable, the Loan Debt Amount can be updated by challenging the Loan Amount, Cancellation Amount, and/or Refund Amount).
After reviewing the GE Debt Measures Backup Data detail file, if an institution determines that some of the data is in error, the institution will need to submit a challenge using the NSLDS Professional Access website. For detailed instructions on submitting these challenges, refer to Chapter 9 of the updated NSLDS Gainful Employment User Guide, available on the NSLDS User Documentation page on the IFAP website.
Once the challenge has been entered in NSLDS, the system will prompt the institution to enter a detailed comment explaining the reason for the challenge for each loan challenged. Note that there will only be one comment box per student. If the student has multiple loans that the institution wants to challenge, the institution must enter all comments for each loan within the maximum allotted space of 500 characters. In order to easily tie each explanation to the specific loan being challenged, the institution must include in the comment the GE Record ID – Loan Record ID (e.g., 0AACC-0AKYE) for each loan being challenged before entering the detailed comment.
Supporting Documentation
Institutions will need to submit supporting documentation that substantiates the challenges being submitted. The Department will deny challenges submitted without supporting documentation. A detailed list of the acceptable and unacceptable forms of documentation and examples of the comments institutions must enter can be found in the document titled “” available in the "Resources" section of the Gainful Employment Information Page on the IFAP website.
Before submitting a challenge in NSLDS institutions should first obtain supporting documentation from NSLDS or from the Common Origination and Disbursement (COD) System. If the documentation is not available from those systems, the institution may obtain the supporting documentation from the current loan servicer. If the loan is currently serviced by a federal loan servicer, the institution should use the servicer’s self-service website. In an attachment to this Electronic Announcement we provide a table that includes each federal loan servicer’s self-service website and email address.
Loan servicer information is available in the Loan Holders portion of the GE Debt Measures Backup Data detail file and can also be viewed on the borrower-specific Loan Detail screens on the NSLDS Professional Access website, on the Aid tab. Specific contact information for a loan servicer can be found on the Org tab.
If the loan holder/servicer fields indicate 555 or 556 for the Department’s Debt Management and Collection System (DMCS), the institution will need to obtain the documentation from the servicer that handled the loan prior to assignment. The institution should review the loan history record on NSLDS to determine which loan holder/servicer assigned the loan. The prior servicer will need to be contacted to request appropriate documentation for the loan data challenge.
Once all documentation has been obtained and challenges have been submitted to NSLDS, the institution must email all supporting documentation to GE.Operations@ed.gov. Because of the need to ensure the privacy of borrower information, before emailing the supporting documentation to the Department, institutions must follow the step-by-step instructions that are included as an attachment to this Electronic Announcement. Failure to submit supporting documentation for all challenges entered as described in the step-by-step instructions will result in the automatic denial of the challenge.
Attribution Rules
The Department uses the reported enrollment dates to attribute a student’s loan amounts to the relevant GE program. In instances where a student was enrolled in more than one GE program during a loan period, we attribute a portion of the loan to each program in proportion to the number of days the student was enrolled in each program. In instances where a loan was made for a period that included enrollment in both a GE program and in a non-GE program, the loan will be attributed to the GE program under the assumption that the student would have taken out the loption that the student would have taken out the loram. Application of the attribution rules may result in a lower loan debt for a particular student.
Since there may be instances when a Title IV loan has been attributed to more than one GE program, if the institution determines that the data for that loan is incorrect the institution must submit separate challenges for each program. If the challenge is approved, the updated data will not carry over to the same loan in the other program.
Resources and Training Opportunities
As a reminder, the GE Debt-to-Earnings Backup Data Viewer Tool is available to import, view, and sort draft GE D/E rates data. This tool is available for download from the "Resources" section of the Gainful Employment Information Page on the IFAP website. Refer to Gainful Employment Electronic Announcement #93 for more information.
Finally, we remind the community that we will offer the webinar “Reading Your Draft GE Debt-to-Earnings (D/E) Rates Files” on October 25 and the webinar “Submitting Draft GE Debt-to-Earnings (D/E) Challenges” on October 27, 2016. Refer to Dear Colleague Letter ANN-16-14 for complete information, including how to register for the webinars.
Contact Information
If you have questions about how to read your GE Debt Measures Backup Data detail file, the GE Debt-to-Earnings Backup Data Viewer Tool, or access to NSLDS, please contact the NSLDS Customer Support Center at 800/999-8219. You can also contact Customer Support by email at nslds@ed.gov.
For questions about how to submit challenges in NSLDS, supporting documentation, or what to include in your comments, please contact the GE Customer Support Center at 877/281-1995. You can also contact the Gainful Employment Operations Team by email at GE.Operations@ed.gov.
The Gainful Employment Information Page on the IFAP website contains publications and resources on GE as well as Frequently Asked Questions (FAQs). If you have a policy question about the GE regulations that has not already been addressed in the FAQs section of the Gainful Employment Information Page, please submit the question to ge-questions@ed.gov.