Cohort Default Rates: Tackling Your Institutions Default Rate

Head OnAndrew Harvey, Garrett College

http://ifap.ed.gov/DefaultManagement/guide/attachments/CDRMasterFile.pdf

Types of Appeals

Incorrect Data Challenge Uncorrected Data Challenge New Data Adjustment Erroneous Data Appeal Loan Servicing Appeal Economically Disadvantaged Appeal

Incorrect Data Challenge

a borrower’s data was incorrectly reported in the draft cohort default rate calculation,

a borrower was incorrectly included in the draft cohort default rate calculation, and/or

a borrower was incorrectly excluded from the draft cohort default rate calculation.

Incorrect Data Challenge

Checklists

School to eCDR Appeals

Determine

Does the loan record detail report for the draft cohort rate contain inaccurate data?

Submit to eCDR Appeals

Relevant information for each borrower challenged

Supporting Documentation for each borrower challenged

CEO Certification Letter

Uncorrected Data Adjustment

A school should submit an uncorrected data adjustment when:

it submitted a timely challenge of its draft cohort default rate data,

the data manager reviewing the incorrect data challenge agreed to make changes to the cohort default rate data, and

the agreed upon changes are not reflected in

New Data Adjustment

What is new data?

New data occurs when loan data reported to the National Student Loan Data System (NSLDS)changes during the period between the calculation of the draft and official cohort default rates. NSLDS is continuously provided with new or updated information. Because the draft cohort default rates are calculated approximately six months before the official cohort default rates are calculated, the data used to calculate the draft cohort default rates may be different from the data used to calculate the official cohort default rates.

New data can be identified by comparing the loan record detail reports (LRDRs) for the draft and official cohort default rates for the same cohort fiscal year and determining if any loan data is newly included, excluded, or changed in any manner. The school should then determine if the new data results in the loan data being reported incorrectly.

Erroneous Data Appeal

An erroneous data appeal alleges that because of “new data” and/or “disputed data” included in the official cohort default rate calculation, a school’s official cohort default rate is inaccurate.

Loan Servicing Appeal

A loan servicing appeal is an appeal that alleges a school’s official cohort default rate includes defaulted Federal Family Education Loans (FFELs) or William D. Ford Federal Direct Loans (Direct Loans) that are considered improperly serviced for cohort default rate purposes.

Economically Disadvantaged Appeal

An economically disadvantaged appeal alleges that a school should not be subject to loss of eligibility (or potential placement on provisional certification if based on two successive three-year rates of 30.0% or more ), because it has a high number of low-income students. There are two types of economically disadvantaged appeals: an economically disadvantaged appeal based on low-income rate and placement rate and an economically disadvantaged appeal based on low income rate and completion rate.

What does Garrett Do?

Things to remember… Don’t let the task overwhelm you.

“When life seems overwhelming, keep calm and carry on”

Take it one step at a time.

“Put one foot in front of the other, and soon you’ll be walking out the door”

The devil is in the DETAILS.

“It’s the little details that are vital. Little things make big things happen”

Fight, fight, fight.

“I have not yet begun to fight”

You can do it!

“I think I can, I think I can, I think I can”