Monday, October 29, 2012

FA Shopping Sheet

If you've been following any Financial Aid information that involves the VA, then you're probably aware of the Financial Aid Shopping Sheet. But if you're not aware of it or aren't sure about it, the first thing you're probably wondering is what is it and where did it come from.

The FA Shopping Sheet can trace itself to Executive Order 13607. This Presidential Order urged schools that receive federal funds for veterans and military personnel to comply with a "principles of excellence". If you signed these principles, then for veterans and military personnel, you have to use a stadardized form "to help those prospective students understand the total cost of the educational program, including tuition and fees; the amount of that cost that will be covered by Federal educational benefits; the type and amount of financial aid they may qualify for; their estimated student loan debt upon graduation; information about student outcomes; and other information to facilitate comparison of aid packages offered by different educational institutions."

The one plus to this form is that you can use it for everyone and not only the military/veteran students. You can use it as an award letter for any student. Here is a link to the annotated Financial Aid Shopping Sheet as of August 30. This may change before it is implemented July 1, 2013.

Monday, October 22, 2012

Two-Factor Authentication Tokens

Welcome to the new era of the Dept of Ed's websites! Not a terribly long time ago (a year maybe?) the NSLDS, FAA Access, and other Dept of Ed websites went to a single login User ID and Password. This made things so much easier when trying to login without having to remember your five passwords and IDs, or even worse having to reset them and have to wait for that to go through. On the other hand, one can assume that a persnickety password and ID apparently weren't enough to make the government feel safe, so this year, the TFA has been introduced.

What's the TFA? By the time you read this, most states will already have had this dealt with, but if you haven't had the luxury of dealing with this, here's your intro.

TFA stands for Two-Factor Authentication, and it's basically another hoop that you'll have to jump through to access your Dept of Ed login sites. You will still use your UserID and Password, but then it will take you to another screen where you have to input a temporary password. All it has is a power button and that's it. Once you push the button, it will countdown using some dashes, then display a 6-digit temporary password. After 30 seconds, the screen goes blank. Type in this password and you will be able to access your site as normal.

TFA Token
For 2012, the Dept of Ed has been making these available in groups of states. Each month on the ifap website, there have been electronic announcements stating which states were coming out that month.

Monday, October 15, 2012

New Subsidized Loan Rules

On July 6, 2012, President Obama signed Public Law 112-141, which includes some new restrictions on Direct Subsidized loans. Specifically, this deals with the insterest subsidies on the Subsidized loans for new borrowers on or after July 1, 2013.

Any new borrower on or after this date will no longer be eligible for a new Direct Subsidized loan if they are past the 150% of their program length. Most Satisfactory Academic Progress policies state that you must complete the program within 150% of the program length (so if your program length is 2 years, then you must complete in 3 years). If you're fulltime, then the length will be different than if you're halftime all the way through. However, the 150% is typically the same. On the other hand, you may go beyond that 150% in some schools if you are on an academic plan from a Financial Aid Warning. Not every school does that the same, and some schools this new rule will not affect.

The new rule also has language that says that the borrower will no longer be eligible for interest subsidy benefits on all Subsidized loans first disbursed on or after July 1, 2013, who have reached that 150% threshhold.

If you want to read the Dept of Ed's electronic announcement, click here.

Monday, October 8, 2012

Clery Act Violations Increased

This is for all you FA, compliance, and administrators out there. There is big news on the Clery Act front as of October 2.

Before October 2, violations of the Clery Act carried a maximum fine of $27,500 per infraction. However, the Dept of Ed posted a change to that in the Federal Register declaring that the fine was going up to $35,000, which is a huge increase. The cited reason is to increase due to inflation.

The silver lining in this is that this will only affect violations that occurred after October 2. If the violations were before October 2, then they will be at the old $27,500 rate. If an investigation is ongoing currently and it started before October 2, then it will be at the old rate as well.

This is just another good reason (as if there aren't enough already) to make sure you are in compliance with Clery Act issues.

Monday, October 1, 2012

Selective Service and FA (Part 2)

Last week's post dealt with mostly exemptions from Selective Service and the few scenarios that could come up where registration isn't required. How do you prove that registration wasn't a requirement? If it's obvious that the student wasn't required to register, then the student doesn't need to obtain a letter from the Selective Service. Instead, all the students needs is some piece of documentation that would clear them from registration. The list below would exempt eligible noncitizens:
  • proof of birth date on passport, driver's license, birth certificate, etc.
  • proof of immigration date on I-94 form, passport, or a letter from USCIS stating the date
  • members in the US on a valid visa and between the ages of 18-25, then an I-20 form (student visa form), other valid U.S. passport visa stamp with expiration date (but the expiration date must be after the student turns 26)
If a student who hasn't registered yet and hasn't reached 26 yet fills out a FAFSA, then the student can be registered with Selective Service through the CPS. But if the student hasn't registered and is past 26, a C code will come back on the ISIR (SAR for the student). What do you do if the student hasn't registered yet?

Unfortunately, this is a very tricky situation. The student has to prove to the school that they did not "knowingly and willfully fail to register". The school is in a very tight predicament because it is really up to them as to if the student is eligible or not. Many schools have chosen to create policies on this subject, and some honestly find it less scary to just use the older, stricter rules of "you didn't register, then you get no aid". Some schools will have a process as to determine how to figure out if the student didn't register on purpose.

To start out with, if the student doesn't meet one of the criteria from above or from last week's post, then they have to write to the Selective Service and get a status information letter showing the failure to register. In writing to the Selective Service, the student should give as much detial as possible. If the status information letter comes back as a general exemption letter (which will have a code between E1-E8) or a "DOB before 1960" letter (which uses code NR), then the student was exempt. If there is any other code, then the school has to make the determination. Sometimes, information in the letter can be used to help with the decision. In the letter, it will say that "the final decision regarding the student’s eligibility rests with the agency awarding funds", which is the school on behalf of the Dept of Ed.

There are three things to consider when trying to make the determination if the students "knowingly and willfully failed to register". Those questions are where the student lived between the ages of 18-25, whether the student thought they'd already registered, and why the student claims they weren't aware of the requirement.

If the school makes their decision, then there is no appeal process. The only appeals a student can make is if they have provided the school with documentation the proves they are eligible and the school denies them, then the Dept of Ed will hear an appeal proceeding for that one reason. This regulation can be found in 34 CFR 668.37(f).