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FAFSA Verification Updates · 12/04/2016 · 2016-2017 Messaging to Explain Rollovers ... • Many...
Transcript of FAFSA Verification Updates · 12/04/2016 · 2016-2017 Messaging to Explain Rollovers ... • Many...
FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
FASFAA Annual Conference
May 24-27, 2016
FAFSA
&
Verification Updates
David Bartnicki
U.S. Department of Education
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College List
• Issue: FSA has received requests from public to stop sharing full
list of colleges on student’s FAFSA with every school listed.
• Resolution: ISIR sent to colleges will only include the Federal School
Code and associated housing code for the school to whom
the ISIR is sent.
• Applicants will continue to receive SARs that list all the Federal
School Codes selected on each transaction in order
• State grant agencies will continue to receive the full list of the
colleges but, beginning with the 2017-2018 FAFSA that listing
will be provided in a random order
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FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
Change to Marital Status
• Issue:
When a student or parent changes his/her marital
status on a renewal application or correction, the
corresponding marital status date isn’t always
updated.
• Resolution:
When a student or parent changes his/her marital
status and does not change the corresponding date,
an edit displays.
4 2016-2017
Messaging to Explain Rollovers
• Issue:
Students and parents who report untaxed portions
of IRA distributions or pensions on the FAFSA
sometimes fail to subtract rollover amounts despite
FAFSA and IRS help text.
• Resolution:
When an amount greater than $0 is reported, a
message will display.
5 2016-2017
Rollover Message
6 2016-2017
FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
Guidance For Legal Guardianship
• Issue:
Applicants sometimes answer the legal
guardianship question incorrectly.
• Resolution:
FAFSA question 55 has been reworded and help
text has been modified.
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Legal Guardianship Messaging
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IRS DRT Messaging
• Issue:
Applicants and parents don’t
understand the purpose of the
IRS DRT filtering questions.
• Resolution:
Text that precedes these
questions has been enhanced.
9 2016-2017
FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
IRS DRT Messaging
10 2016-2017
Other 2016-17 FAFSA Changes
• Income threshold for an Automatic Zero EFC
increased to $25,000
• Change tax line references in taxes paid questions
• Updated the question to read, “Enter your (and spouse’s)
income tax for 2015. Income tax amount is on IRS Form
1040—line 56 minus line 46; 1040A—line 28 minus line 36; or
1040EZ—line 10.”
• Excess Advance Premium Tax Credit Repayment and the
Health Care Individual Responsibility line items should not
be included as taxes paid for Title IV purposes
• Reorder text in FAFSA questions 26, 28, 29, and 30
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2017-2018
FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
Paper FAFSAs
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More than 99 percent of FAFSAs are filed
electronically.
Beginning with the 2017-2018 FAFSA we
will no longer print the FAFSA as a color
packet.
PDF FAFSA available on-line to be printed
Call 1-800-4FEDAID to request a copy
2017-2018 Application
• 2017-2018 Processing Announcements
– Beginning with 2017-2018, the FAFSA cycle will
begin October 1 instead of January 1
• 2017-2018 FAFSA filing will begin October 1, 2016
• Gives more time to review, submit & update FAFSA data
– Beginning with 2017-2018, FAFSA income
information will come from the “prior, prior year”
• 2017-2018 FAFSA will collect tax year 2015 income
information
– Added an applicant’s receipt of Medicaid as a
qualification for the Simplified Needs Test (SNT)
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• Benefit #1: Alignment • Many college application deadlines occur in the fall
• Alignment of FAFSA availability = less confusion
• Benefit #2: Certainty • No need to estimate tax information
• IRS Data Retrieval Tool available at launch
• Earlier receipt of Expected Family Contribution (helps with
assessing net costs)
• Benefit #3: Less Pressure • More time before (most) state and school financial aid
deadlines
• More time to compare school offers before College Signing
Day
Benefits of FAFSA Changes
FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
Questions?
FAFSA CHANGES FOR 2017-18
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• August 2016 • EFC Formula Guide
• SAR Comments Code and Text Guide
• ISIR Guide
• September 2016
• CPS Web Applications Demo System availability
• October 2016 • FAFSA on the Web available (10/1/16)
• FAA Access to CPS Online availability (10/1/16)
• IRS Data Retrieval Tool available (10/1/16)
• Student Aid Report distribution begins (10/3/16)
May 6, 2016 Electronic Announcement
2017-2018 Important Dates
Early FAFSA/Prior-Prior Year: Issues We’ve heard your concerns about….
• Outreach
– Early FAFSA Webpage (right-hand side of IFAP)
• http://ifap.ed.gov/EarlyFAFSA/indexV1.html
• Periodic EAs, DCLs, training, Resources on IFAP
• Q & As recently added
– Student websites, publications, communications will be
updated appropriately and as timely as possible
– "Early FAFSA" mailbox for the community to contribute
thoughts, ideas, and concerns on the implementation of the
2017-2018 Early FAFSA
• "Early FAFSA" mailbox - [email protected]
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FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
Early FAFSA/Prior-Prior Year: Issues
• Materials and Resources for Outreach
– FAFSA: FinancialAidToolkit.ed.gov/fafsa
– Resources: FinancialAidToolkit.ed.gov/resources
– FAFSA Changes: FinancialAidToolkit.ed.gov/fafsa-
changes
• Talking points
• Table of FAFSA launch dates and tax years
• Fact sheets for counselors and parents & college students
• Outreach calendar
• PowerPoint presentations
• Information about upcoming webinars
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We’ve heard your concerns about….
• Professional Judgement (GEN-16-03)
• Reminded schools of their ability to use PJ and
encourages schools to use PJ when appropriate (and
properly document)
• ED acknowledges likely increase in use of PJ
• ED will modify risk-based compliance models to
account for PJ increase
• Reminded schools to set Professional Judgment Flag
to 1 (EFC Adjustment Processed) to indicate that the
CPS submission was the result of a PJ determination
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Early FAFSA/Prior-Prior Year: Issues
We’ve heard your concerns about….
• Verification
• May be some changes but overall process will be the same
• In most cases financial data processed by IRS
• Conflicting information (16/17 vs. 17/18 data)
• ED working to determine how to handle conflicting
information during transitional year (e.g. 2015 financial data)
• 2/18/16 EA encourages use of IRS DRT in 16/17 and 17/18
to reduce likelihood of conflicting information
• Further conflicting information guidance with be shared
though IFAP in the near future
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Early FAFSA/Prior-Prior Year: Issues
FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
G-Q8: Will institutions have to review all of their students 2016-17
and 2017-2018 ISIRs to determine if there might be conflicting
information since supposed to be completed using same 2015
income and tax information?
G-A8: No….the Department has developed a process where CPS
will review a 2016-2017 FAFSA if filed for a 17-18 applicant. CPS
will flag only those 2017-2018 ISIRs where any potential conflict,
could have a significant impact on the student’s 2017-2018 EFC…
…The most effective ways to prevent conflicting information from
occurring is for the FAFSA applicant to use the IRS Data Retrieval
Tool (IRS DRT) when completing both their 2016-2017 and 2017-
2018 FAFSAs. [April 12, 2016]
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Early FAFSA/Prior-Prior Year: Q & As
Early FAFSA/Prior-Prior Year: Items
Electronic Announcement #4 - March 18, 2016
• Outlines income related items on FAFSA that will
be based on 2015 data (prior-prior year)
• Tax filing status, tax return status, type of return, return
eligibility, AGI, taxes paid, exemptions, income earned
from work, income exclusions, untaxed income
• FAFSA items current at time FAFSA completed or
for current award year (Not prior-prior year data)
• Dislocated worker, household size, number in college,
assets, certain means-tested benefits
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2016 FSA Webinar Series
Online registration is available at:
http://fsaregistration.ed.gov/d/vfqcw2
FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
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Prior-Prior Year – What ISN’T changing…
• When Pell amounts are
finalized/announced
• When Pell charts are released
• When Pell origination/disbursement
records can be sent to COD
• When Pell funds will be available in G5
Sec. 482 of the HEA
Described in detailed in the Early FAFSA Q & As
Award Letters
Are we expected to award financial aid earlier?
Schools are encouraged to
award earlier, but are not expected
to change institutional deadlines
and processes
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Electronic Announcement: April 12, 2016
G-Q1: Will FAFSA applicants have an option to use tax year
2016 income and tax information?
G-A1: NO. Beginning with the 2017-2018 FAFSA, students and
parents will be required to use income and tax information from
the 2015 tax year. However, a financial aid administrator (FAA)
may use professional judgment to change any of the income or
tax items by using the 2015 (or any other recent 12 month period)
income and tax information, if the FAA determines that there are
extenuating circumstances that justify the use of information other
than the 2015 tax year information. The fact that the student might
be eligible for more aid based upon the use of 2016 information is
not, by itself, sufficient reason for an FAA to make a professional
judgment decision to use 2016 income. [April 12, 2016]
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Early FAFSA/Prior-Prior Year: Q & As
FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
• G-Q4: Since the 2017-2018 FAFSA will use information from
2015, will the 2017-2018 expected family contribution (EFC)
calculation use the same need analysis tables that are
used for the 2016-2017 EFC calculations?
G-A4: No. The 2017-2018 EFC calculation will use updated
need analysis tables. [April 12, 2016]
• G-Q5: Will the 2017-2018 EFC need analysis tables be
available earlier?
G-A5: Yes. The Department expects to publish in the Federal
Register the 2017-2018 EFC calculation tables by the end of
May. [April 12, 2016]
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Early FAFSA/Prior-Prior Year: Q & As
G-Q9: Will the 2017-2018 FAFSA (either initial or renewal) be pre-
populated with information from the applicant’s 2016-2017
FAFSA since the information should be the same?
G-A9: NO. There are too many instances where such pre-populating
would result in incorrect information being included on the 2017-2018
FAFSA – e.g., changes in dependency status, changes in marital
status, professional judgment. However, institutions are reminded
that most 2017-2018 FAFSA filers who have filed an IRS income tax
return will be able to use the IRS Data Retrieval Tool (IRS DRT) to
import their 2015 income and tax information directly from the IRS
into their 2017-2018 FAFSA. Using the IRS DRT is the fast and most
accurate way to input income and tax information into the FAFSA.
Use of the IRS DRT will dramatically reduce the likelihood that the
applicant will be selected for verification. [April 12, 2016]
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Early FAFSA/Prior-Prior Year: Q & As
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FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
2016-17 Verification – Overview
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• Same data elements as for 2015-2016
award year
• Some modifications and clarifications to
acceptable documentation
• Eliminated Child Support Paid (V3) as a
separate verification group
• In limited circumstances, an applicant’s
Verification Tracking Group could change
2016-17 Verification - Changes
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Verification Tracking Group changes:
• Verification Tracking Group V3 (Child
Support Paid) has been removed
• Applicants placed in V1, V4, V5, and V6
must still verify child support paid if reported
on ISIR
2016-17 Verification - Changes
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Verification Tracking Group changes:
• Applicants may be moved from previously
assigned Groups V1, V4, and V6 to Verification
Tracking Group V5
– Applicant is only required to verify the additional
items in V5 that were not previously verified
– If the applicant is moved to Verification Tracking
Group V5, no additional disbursements of any
Title IV aid may be made until verification is
satisfactorily completed
FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
2016-17 Verification - Changes
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Verification Tracking Group changes:
• Applicants moved to Verification Tracking
Group V5
– If Title IV aid had been disbursed prior to
receiving an ISIR with the new V5, and the
applicant does not complete verification, the
applicant is liable for the full amount of TIV aid
disbursed for 2016-2017 (not FWS funds)
– The institution is not liable
• Except school must return any Title IV funds as
required in any R2T4 calculations
Applicants moved to Verification Tracking Group
V5
• Verification can be set on the application or
correction
• Verification Selection Change Flag
• Y: indicates verification was not set and now record
is selected for verification
• C: indicates the verification tracking group has
changed
– This “C” is transaction specific
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2016-17 Verification - Changes
2016-17 Verification
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Income Information for Non-IRS Tax Filers
• Tax filers who filed an income tax return with a taxing
authority in a U.S. territory (Guam, American
Samoa, the U.S. Virgin Islands) or commonwealth
(Puerto Rico and the Northern Mariana Islands) or
with a foreign central government, must submit a
copy of a transcript of their tax information
– A signed copy of the applicable 2015 income tax return
that was filed with the taxing authority is only
acceptable if tax filers are unable to obtain a free copy
of a transcript of their tax information
FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
2016-17 Verification
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Income Information for Non-IRS Nontax Filers
• Residents of the Freely Associated States
(Republic of the Marshall Islands, the Republic of
Palau, the Federated States of Micronesia), and a
U.S. territory or commonwealth or a foreign
central government who are not required to file an
income tax return under that taxing authority’s rules
must submit:
– a copy of their Wage and Tax Statement (or equivalent
documentation) for each source of employment income and
– a signed statement identifying all of the individual’s income
and taxes
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• For V4 and V5, if institution successfully verified and
documented applicant’s high school completion status
for a prior award year, verification of high school
completion status is not required for subsequent years
• DD Form 214 Certificate of Release or Discharge From
Active Duty may serve as alternative documentation to
verify a student's high school completion if it indicates
that the individual is a high school graduate or
equivalent
• An institution may not accept as alternative
documentation an applicant’s self-certification
High School Completion Status
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In rare cases where it is impossible for a refugee, an asylee or a
victim of human trafficking to obtain documentation of his or her
completion of a secondary school education in a foreign country,
an institution may accept self-certification from these applicants
• Q&A FHD-Q2/A2 (program integrity Q & A website under HSD)
• Required information included:
– Proof of attempt to obtain documentation of their completion of a
secondary school education in a foreign country
– Signed/dated statement that indicates applicant completed secondary
school education in a foreign country along with - name and address
of foreign high school and date foreign HS diploma was awarded
– Copy of entry status documentation showing status as a refugee,
asylee, or victim of human trafficking and who entered the US after
the age of 15
High School Completion Status
FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
2016-2017 IRS Tax Return
Transcript Matrix
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Electronic Announcement – March 23, 2016 • Cross-walk of IRS tax financial information between:
FAFSA questions
IRS Tax Return Transcripts
IRS Tax Returns
• Specifically states do NOT use amounts from any
line items on transcripts for verification purposes that
use the word “RECOMPUTED”
Electronic Announcement – 3/23/16
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New Announcement - May 4, 2016
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• New Matrix effective May 4, 2016
• Updated the Income Tax Paid line items for Tax Return
Transcripts
• Taxes and credits related to the Affordable Care Act are
not to be included in the amount of U.S. Income Tax that is
used in the calculation of a student’s EFC
• Also indicate for all transcripts, if taxes paid is negative,
enter '0' (zero)
• Specifically states do NOT use amounts from any line
items on transcripts for verification purposes that use
the word “RECOMPUTED” OR “VERIFIED”
FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
2016-2017 Verification
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• Contains 4 appendices to assist with crafting school
verification documents to gather verification data
• Appendix A – Suggested Text
• Not required to use ED’s suggested text and formats
• ONE EXCEPTION – institutions must use the exact
language provided in the “Statement of Educational
Purpose” (Groups V4 & V5)
• “Notary’s Certificate of Acknowledgement” section, does not
require the use of the exact language provided, although it
must include a copy or description of the identification
presented by the applicant to the notary
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Electronic Announcement – 11/18/15
• Appendix B – Table of verification items
• Appendix C – Verification tracking groups and
FAFSA verifiable information
• Appendix D – Timeline Availability of 2015 IRS
Tax Information
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Electronic Announcement – 11/24/14
FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
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V4/V5 Tracking Results:
2016-2017
• The V4 and V5 tracking process in FAA
Access that began in the 2014-15 processing
year WILL CONTINUE for 2016-17
• Schools need to select the proper award year
for which they are providing results
• 2015-16, 2016-17, etc.
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V4/V5 Tracking Results – 2016-2017
https://faaaccess.ed.gov
Use the Identity Verification Results section on the FAA Access home page
V4/V5 Tracking Results – 2016-2017
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FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
V4/V5 Tracking Results – 2016-2017
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Whom to report: student for whom school received an
ISIR with a Verification Tracking Group of V4 or V5 AND
for whom school requested verification documentation • Do NOT include students the school selected for
verification of identity or high school completion status
When to report: 60 days following the institution's first
request to the student to submit the required V4 or V5
identity and high school completion documentation • Changes to previously submitted Identity Verification
Results must be updated within 30 days
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Resources
• Federal Register Notice – April 1, 2016
• GEN-16-07 – April 5, 2016
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4/1/16 Federal Register • Updates
– DD Form 214 Certificate of Release or Discharge From
Active Duty that indicates an individual is a high school
graduate/equivalent can be used as alternative
documentation to verify high school completion status
– Individual selected for verification required to file a 2015 IRS
income tax return and granted a filing extension by the IRS
or any nontax filer selected for verification (parent, student,
etc.) regardless if they earned any income from work, MUST
provide:
• Confirmation of non-filing from the IRS or other relevant taxing
authority dated on or after October 1, 2016
• If person never filed a tax return before, can get letter of
nonfiling from the IRS through 4506-T document (box 7)
FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
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2017-2018 Verification
• GEN-16-07
– Verification Tracking Group V6 is eliminated
• Schools reminded they can still select items of their
choosing for verification
– SNAP and Child Support Paid removed as
individual verification items under V1, V4 or V5
– Suggested Test for 2017-2018 will be provided in
a future electronic announcement
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2017-2018 Verification • GEN-16-07
– School can use verification documents from 2016-2017 for
following items if meet 2017-2018 requirements:
• Adjusted Gross Income (AGI); U.S. Income Tax Paid ; Untaxed
Portions of IRA Distributions; Untaxed Portions of Pensions;
IRA Deductions and Payments; Tax Exempt Interest Income;
Education Credits; Income Earned from Work
– Documentation of high school completion obtained prior to
the 2017–2018 award year is acceptable
– Must obtain new documentation each award year for:
• Number of Household Members
• Number in College
• Identity/Statement of Educational Purpose
Verification Policy Reminders
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FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
October 2, 2015 Electronic Announcement
• Alternative documentation allowed when tax filer
RECENTLY requested but unable to obtain an IRS
Tax Return Transcript using the IRS paper or on-line
request process
• No alternative documents for telephone requests
• Exception not permitted for –
– transcripts unable to be obtained simply because the IRS
has not had time to process the data due to a recent filing
– saying the "Get Transcript Online" tool is not available
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*For 2015-2016 award year*
2015-2016 – Transcripts Unavailable
Alternative documentation includes:
• Signed copy of relevant 2014 IRS tax return
AND
• Statement from tax filer, on or attached to the return, certifying
same data submitted to the IRS
AND
• Communication from IRS stating request unsuccessful
– Letter from IRS (signed and dated by tax filer); or
– Screen shot print (signed and dated by tax filer)
AND
• Completed and signed IRS Form 4506 T-EZ or 4506-T listing
institution as third party – only send to IRS if doubt accuracy
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Tax Filers - Extensions
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• Person is required to file, but obtained extension, must
submit:
• Program Integrity Q & A Website (DOC-Q16)
– IRS form 4868 or IRS approval to extend beyond October 15
deadline
– W-2 for each source of employment income
– Signed statement by a self-employed individual certifying
amount of AGI & US income tax paid
– When above documentation reviewed, verification is
considered complete (disbursements are valid)
• School may request transcript/IRS DRT when taxes are
filed; must re-verify income information
FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
Verification Policy Updates
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Individuals who filed an amended tax return
must submit the following documents to the
institution:
• an IRS Tax Return Transcript, or any other IRS tax
transcript(s) that include all of the income and tax
information required to be verified; and
• a signed copy of the IRS Form 1040X that was filed
with the IRS
Guidance effective 8/13/15 for 15/16 and subsequent years
• Posted on Program Integrity Q & A website
Verification Policy Updates
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Victims of IRS tax-related identity theft must submit:
• Statement signed and dated by tax filer indicating they
were victims of IRS tax-related identity theft and the IRS
has been made aware of the tax-related identity theft; and
• A Tax Return DataBase View (TRDBV) transcript obtained
from the IRS
– Tax filers who cannot obtain a TRDBV transcript may instead
submit another official IRS transcript or equivalent document
provided by the IRS if it includes all of the income and tax
information required to be verified
Guidance applies to 15/16 and subsequent years
• Posted in 6/26/15 Federal Register Notice
Verification Q & A
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• VI-Q9. Must an institution complete verification of all
FAFSA information identified in Verification Tracking
Groups V1, V5 or V6 even if the selected applicant is
eligible for … an Automatic Zero EFC (Auto Zero EFC) …
• VI-A9. …For dependent applicants, only the following
FAFSA information must be verified:
– The parents' AGI if they were tax filers;
– The parents' income earned from work if they were nontax
filers; and
– The receipt of SNAP benefits (food stamps) by any
household member if the receipt of these benefits qualified
the applicant for Auto Zero EFC.
FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
Verification Q & A cont.
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• VI-A9. …For independent applicants, only the following
FAFSA/ISIR information must be verified:
– The applicant's and spouse's AGI if they were tax filers;
– The applicant's and spouse's income earned from work if they
were nontax filers;
– The number of household members to determine if the
independent applicant has one or more dependents other than a
spouse; and
– The receipt of SNAP benefits (food stamps) by any household
member if the receipt of these benefits qualified the applicant for
Auto Zero EFC.
Also dependent and independent applicants placed in Verification
Tracking Group V5 must also verify their high school completion
status and identity/statement of educational purpose.
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Resources
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• Federal Register Notice - June 26, 2015 (16/17)
• DCL GEN-15-11 - June 29, 2015 (16/17)
• EA 11/18/15 – Suggested Text and Appendices (16/17)
• EA – 5/4/16 – REVISED Tax Return Transcript Matrix (16/17)
• Federal Register Notice - April 1, 2016 (17/18)
• DCL GEN-16-07 – April 5, 2016 (17/18)
• Program Integrity Q & A Website (“verification”)
• http://www2.ed.gov/policy/highered/reg/hearulemaking/2009
/integrity-qa.html
• Federal Student Aid Handbook
– Application and Verification Guide – Chapter 4
• Federal Regulations
– 668 Subpart E (668.51 – 668.61); 668.16(f)
FASFAA Annual Conference May 24-27, 2016
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FAFSA & Verification Updates
For discussion purposes only
Contacts
• Atlanta School Participation Division
• Main Number: 404-974-9303
• Ask for your Point-of-Contact
• Arva Thomas (IIS) – 404-974-9412
• Cassandra Weems (IIS) – 404-974-9305
• Atlanta Training Officer
• David Bartnicki – 404-974-9312
• Email – [email protected]
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Training Feedback
To ensure quality training we ask all participants to
please fill out an online session evaluation
• Go to http://s.zoomerang.com/s/DavidBartnicki
• Evaluation form is specific to David Bartnicki
• This feedback tool will provide a means to educate and
inform areas for improvement and support an effective
process for “listening” to our customers
• Additional feedback about training can be directed to
65
Questions
66
David Bartnicki
404-974-9312