By NASFAA Training & Regulatory Assistance Staff and Policy & Federal Relations Staff

Sessions held Wednesday at the 2017 Federal Student Aid Training Conference in Orlando offered some important updates for financial aid administrators on a wide array of topics including: Subsidized Usage Limit Applies (SULA) calculations, PTAC guidance on the release of information, the Additional Eligibility Indicator for year-round Pell Grants, Form G-845, and the Fiscal Operations Report and Application to Participate (FISAP). Below you will find key takeaways from the pertinent sessions.

SULA Misunderstandings and Misreporting Session
In this session, U.S. Department of Education (ED) officials, Eric Hardy and Chuck Hirman reviewed the Subsidized Usage Limitation calculation and expanded on some common misunderstandings and frequently misreported items.

Presenters explained that when a school gets an unexpected result when originating a subsidized loan, it is often due to one of the following misunderstandings of the calculation:

1. There is an overlapping loan period, for which ED’s Common Origination and Disbursement system (COD) has already made an adjustment in subsidized usage period (SUP).
2. A prior loan has been returned or repaid by the school within 120 days, thus removing the loan disbursement from COD. In this case, the borrower is not considered to have used any SUP for the returned loan.
3. A student who has paid a loan in full does not have an adjustment in SUP.
4. A student whose loan was discharged would have the SUP adjusted downward.

A school may receive a COD reject code 206 when the remaining eligibility period (REP) is less than or equal to zero, presenters explained. ED encourages schools to resubmit such a loan using a shorter loan period, if possible, keeping in mind that for term-based schools, the shortest possible loan period is one term in length. Reconfiguring the loan in this way may allow the loan to be accepted.

Presenters also reminded attendees that schools must award subsidized loan eligibility prior to awarding unsubsidized loan eligibility. This, however, does not mean the school must get the REP down to zero. Due to minimum loan period requirements, there may be a small percentage of SUP remaining, for which the school cannot originate a subsidized loan, due to minimum loan period restrictions. In these cases, the school can originate unsubsidized loan up to any remaining annual limit, taking into consideration cost of attendance minus other aid.

While there has been a marked improvement in the occurrence of reporting errors since the start of SULA, according to ED officials, some of the more common errors that still exist include:

1. Failure to update the loan amount and/or loan period when a loan had only one disbursement
2. Loan periods that do not conform with the academic year dates
3. Incorrect loan proration
4. Payment period start dates that are not equal to the loan period start dates
5. Enrollment status being reported based on a date other than disbursement date
6. Adjusting the academic year dates when you shorten a loan period
7. Incorrectly including an optional summer term in the academic year. See GEN 13-13 for more information.

ED presenters discouraged the use of stock SULA reference charts, which tend to generalize when estimating the amount of SUP remaining for a student, and instead recommended that trusting COD to calculate the remaining eligibility by originating the loan. If it is rejected, there is no problem with adjusting the parameters of the loan to one term if needed. Another option is to use the SULA calculator available on COD.

Reporting program length is another common error, presenters noted, advising schools to bear in mind that a 2-year program should not be reported as a 24-month program, a 1-year program is not necessarily a 12-month program, etc. Presenters also warned against reporting a program of enrollment for a student who is enrolled during the summer for purposes of picking up a course or two, as it can jeopardize the student’s remaining eligibility period and cause the student to lose interest subsidy on prior loans.

The session closed with a reminder that prior to closing out a program year, schools should zero out any pending disbursements, reduce loan amounts to the sum of the actual disbursements, shorten the loan periods to remove any payment periods where no disbursement was made, and make sure correct academic year dates have been reported. Although COD can edit certain pieces of information, it is ultimately the school’s responsibility to correctly report the information.

Still Awaiting Guidance on Information Sharing From PTAC
In a session titled “Using Financial Aid Information for Program Evaluation and Research,” staff from ED’s Privacy and Technical Assistance Center (PTAC) reviewed the basic rules governing the release of information for various purposes. Attendees had many questions regarding release of FAFSA information to third parties for purposes other than those allowed by section 483(a)(3)(E) of the Higher Education Act, as outlined in a NASFAA letter to ED earlier this month. Various departments within ED are currently in discussion on these questions and when answers are known, they will be widely distributed, according to PTAC staff.

ED Closely Monitoring AEI Field for Year-Round Pell Grants
In Wednesday afternoon’s “A Guide to Year-Round Federal Pell Grants” session, presenters reminded attendees that the Additional Eligibility Indicator (AEI) for year-round Pell (YRP) must be used correctly in Pell reporting. The AEI tag should be used to indicate eligibility in instances where a student’s total awarded Pell Grant amount exceeds 100 percent of their Scheduled Federal Pell Grant (SFPG). FSA will be keeping a close eye out for schools that provide information stating the AEI is “true” for students who have not been awarded or disbursed Pell Grants over the 100 SFPG amount. This code must be used correctly or there will be program compliance issues and sanctioning, ED officials cautioned.

Paper G-845 Form to Be Replaced With Online Version
When students file a FAFSA and indicate they are an eligible noncitizen, but the data provided in the Central Processing System (CPS) doesn't match up with Department of Homeland Security (DHS) data after primary and secondary match attempts, the school must perform a cumbersome manual confirmation by submitting a Document Verification Request, or G-845 Form, to the DHS. Upon submitting the form, along with copies of the applicant’s DHS documentation, financial aid administrators may not receive a response for up to 10-20 business days. Additionally, many reported having experienced issues with paperwork getting lost in transit. In a session on Wednesday, presenters announced ED would be replacing the paper form with an online process. The automated process will be available starting in spring 2018 and expected to lower response times to 3-5 days.

Big Changes Coming for eCampus-Based System and FISAP
In the "eCB Is Moving to COD" session, ED announced that the eCampus-Based system and Fiscal Operations Report and Application to Participate (FISAP) are moving to COD in spring 2018. The eCampus-Based system as we know it will be gone entirely. When COD for Campus-Based goes live, schools will process campus-based aid using much of the same functionality they currently use for Federal Pell Grants and Direct Loans. While the content of the FISAP will not change, schools will be completing next year’s FISAP in the COD System. Stay tuned to Today’s News and IFAP for Electronic Announcements as ED rolls out the new system.

Publication Date: 11/29/2017

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