The Policies & Procedures (P&P) Builder, a module of NASFAA's Compliance Engine, guides you step-by-step through the creation of a centralized, accessible policies and procedures manual. Due to the timing of the release of the P&P Builder template each year, the U.S. Department of Education (ED) may provide new guidance which affects the existing template. In response, updates will be made to the P&P Builder template. 

The P&P Builder template for the 2021-22 award year was released in July and it provides references to guidance related to the COVID-19 national emergency, as well as any regulatory changes effective July 1, 2021. However, since the publication of the P&P Builder template, an additional Federal Register with early implementation was released, though the regulations will not be effective for all until July 1, 2022. Please see it summarized below:

Federal Register, 8/23/2021 - Total and Permanent Disability Discharge of Loans Under Title IV of the Higher Education Act

• ED has exercised its authority under HEA 482(c) to implement the regulatory changes to 34 CFR 674, 682, and 685 early on September 30, 2021. 

  • Loan borrowers who qualify for total and permanent disability (TPD) through Social Security Administration (SSA) data may receive an automatic discharge. Eligible borrowers include those who are eligible for Social Security Disability Insurance (SSDI) or Supplemental Security Income (SSI) benefits whose next disability review is within five to seven years.

  • Changes in regulations clarify that borrowers with a TPD determination from the Department of Veterans Affairs (VA) or the SSA do not have to complete a TPD application to have Federal Student Loans discharged.

  • The Federal Register details the contents of the notice ED sends to eligible borrowers.

  • Borrowers may also receive loan payments back if those payments were made on or after the effective date of the automatic TPD discharge.

• Though early implemented, the regulations are not effective until July 1, 2022, so they are not reflected in the Electronic Code of  Federal Regulations. NASFAA's Compiled Regulations will reflect the changes soon.

Publication Date: 11/9/2021

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