cdrc.pdf  Cohort Default Rate Calculation File Size: 89KB Number of Pages: 30 Requires 4.0 or greater of the free Adobe Acrobat Reader software. Cohort Default Rate Calculation What is an FFEL Program and Direct Loan Program cohort default rate? An FFEL Program and Direct Loan Program cohort default rate is the percentage of a school’s student borrowers who enter repayment on certain Federal Family Education Loan (FFEL) Program and/or William D. Ford Federal Direct Loan (Direct Loan) Program loans during a particular fiscal year and default within the fiscal year in which the loans entered repayment or within the next fiscal year (FY).1 The cohort default rate may be an FFEL Program cohort default rate, a Direct Loan Program cohort rate, or a Dual-Program cohort rate depending on the type or types of student loans that are considered in calculating the rate. A school does not select whether it has an FFEL Program cohort default rate, a Direct Loan Program cohort rate, or a Dual-Program cohort rate. The type of rate is determined on the basis of the types of loans made to students attending the school who enter repayment in a given fiscal year. An FFEL Program cohort default rate2 is the cohort default rate for schools whose students have only FFEL Program loans entering repayment during a particular fiscal year. It is the percentage of a school’s borrowers who enter repayment on certain FFEL Program loans during a particular fiscal year and default within the fiscal year in which the loans entered repayment or within the next fiscal year. A Direct Loan Program cohort rate3 is the cohort rate for schools whose students have only Direct Loan Program loans entering repayment during a particular fiscal year. It is the percentage of a school’s borrowers who enter repayment on certain Direct Loan Program loans during a particular fiscal year and default or meet other specified conditions within the fiscal year in which the loans entered repayment or within the next fiscal year.
______________________________ 1For schools with 29 or fewer borrowers entering repayment during a fiscal year, the data is averaged over a three year period. Please refer to page 116 for additional information on the averaging process. 2334 CFR Section 668.17(d) 3334 CFR Section 668.17(e) A Dual-Program cohort rate4 is the cohort rate for schools whose students have both FFEL Program and Direct Loan Program loans entering repayment during a particular fiscal year. It is the percentage of a school’s borrowers who enter repayment on certain FFEL Program and Direct Loan Program loans during a particular fiscal year and default or meet other specified conditions within the fiscal year in which the loans entered repayment or within the next fiscal year. The U.S. Department of Education’s (Department) regulations use the term “weighted average cohort rate” for cohort default rates for schools with student borrowers who have both FFEL Program and Direct Loan Program loans entering repayment during a fiscal year. This Guide uses the term “Dual-Program cohort rate” to describe the same rate and calculation. In addition, this Guide uses the term “cohort default rate” to refer to a school’s FFEL Program cohort default rate, Direct Loan Program cohort rate, or Dual-Program cohort rate, unless otherwise specified. Other specified conditions: For non-degree granting proprietary schools only, borrowers who have received Direct Loan Program loans are considered to be in default for the purposes of calculating a school’s cohort default rate if, for a specified period of time during the cohort period in question, the borrowers are in repayment under the income contingent repayment (ICR) plan with scheduled payments that are less than 15 dollars per month and less than the interest accruing on the loan. The period of time that determines whether a borrower will be included as a defaulted borrower due to the borrower’s ICR plan is based on which cohort default rate calculation the borrower is included. If the borrower is included in a cohort default rate calculation prior to FY 1998, the period of time is 270 days. If the borrower is included in the FY 1998 or a later cohort default rate calculation, the period of time is 360 days.5
_____________________________ 434 CFR Section 668.17(f) 564 Fed. Reg. 58974, 58979 (November 1, 1999) (Preamble to Final Rule) Which types of loans are included in the cohort default rate calculation? The FFEL Program loans included in the cohort default rate calculation are: Subsidized Federal Stafford Loans (FFEL Stafford Loans); Unsubsidized Federal Stafford Loans (FFEL Stafford Loans); AND Federal Supplemental Loans for Students (Federal SLS Loans). Federal SLS Loans have not been issued since July 1, 1994. However, it is possible for a Federal SLS loan to be included in a recent cohort default rate calculation if the borrower has recently entered into repayment on the Federal SLS loan. The Direct Loan Program loans included in the cohort default rate calculation are: Federal Direct Subsidized Stafford/Ford Loans (Direct Loan Program Loans); AND Federal Direct Unsubsidized Stafford/Ford Loans (Direct Loan Program Loans). The following loans are NOT included in the cohort default rate calculation: PLUS Loans; Federal Direct PLUS Loans; Federal Insured Student Loans; AND Federal Perkins Program Loans. Federal Consolidation Loans and Federal Direct Consolidation Loans are not counted directly in the cohort default rate calculation. However, the status of a consolidation loan may affect how the loan(s) that was paid off by the consolidation loan is included in the cohort default rate calculation. Please refer to page 24 for more information on how consolidation loans may affect the cohort default rate calculation. When are cohort default rates released? The Department releases cohort default rates twice a year. Generally, the Department releases draft cohort default rates before the end of March of each year. After schools receive their draft cohort default rate data and are provided an opportunity to identify and correct any inaccuracies, the Department releases the official cohort default rates. Official cohort default rates are released to schools and the public approximately six months after the release of the draft cohort default rates BUT must be released no later than September 30th of each year.6 Please note that the National Student Loan Data System (NSLDS), which contains the data used to calculate cohort default rates, is regularly updated. Therefore, a school’s draft data may differ from its official data, even if a school does not challenge its draft cohort default rate data. ________________________ 6HEA Section 435(m)(4)(D) Who receives cohort default rates? The draft cohort default rates are provided only to schools and are NOT released to the public. The draft cohort default rates are released to all schools that the Department’s records indicate: were participating in the FFEL Program and/or Direct Loan Program on the first day of the fiscal year on which the cohort default rate is based and may or may not have student borrowers who entered into repayment on one or more of the relevant types of loans during the fiscal year on which the cohort default rate is based; OR have at one time participated in either loan program and have student borrowers who entered into repayment on one or more of the relevant types of FFEL Program and/or Direct Loan Program loans during the fiscal year on which the cohort default rate is based. When the Department provides a school with a draft cohort default rate the school will also receive a copy of the most recent Draft Cohort Default Rate Guide and the draft loan record detail report listing all of the student borrowers contained in the school's draft cohort default rate calculation. The official cohort default rates are provided to schools and are released to the public. The official cohort default rates are provided to all schools that: are currently eligible to participate in any of the Title IV Student Financial Assistance Programs and were participating in the FFEL Program and/or Direct Loan Program on the first day of the fiscal year for which the cohort default rate is based and may or may not have student borrowers who entered into repayment on one or more of the relevant types of loans during the fiscal year on which the cohort default rate is based; OR are currently eligible to participate in any of the Title IV Student Financial Assistance Programs and have student borrowers who entered into repayment on one or more of the relevant types of FFEL Program and/or Direct Loan Program loans during the fiscal year on which the cohort default rate is based. When the Department provides a school with an official cohort default rate, the school will also receive a copy of the most recent Official Cohort Default Rate Guide. In addition, if the school's official cohort default rate is ten percent or greater, an official loan record detail report listing all of the student borrowers contained in the school's official cohort default rate calculation will be provided. The public can request a listing of all of the official cohort default rates in the form of a press package. The press package also contains a listing of those schools that are subject to sanctions as a result of official cohort default rates. For a copy of the most recent press package please call (202) 708-9396 or visit the Department’s website at http://www.ifap.ed.gov. Why are cohort default rates important? The draft cohort default rates are important because the data used to calculate the draft cohort default rate forms the basis of a school’s official cohort default rate. Although there are no sanctions or consequences associated with a draft cohort default rate, it is important to review the data used to calculate the draft cohort default rate to ensure the accuracy of the data. A school that fails to challenge the accuracy of its draft cohort default rate data through a draft data challenge may be precluded from challenging the accuracy of the data used in calculating its official cohort default rate. Therefore, it is critical that all schools review their draft cohort default rate data. In addition, because in certain circumstances a school may be able to avoid the consequences associated with its official cohort default rates by submitting a successful participation rate index challenge based on its draft cohort default rate, the school should review its enrollment data in relation to its draft cohort default rate to determine if it qualifies to submit a participation rate index challenge. Please refer to the Draft Cohort Default Rate Guide for more information on draft cohort default rates.
The official cohort default rates are important because they may affect a school’s eligibility to participate in certain Title IV Student Financial Assistance Programs and because the Department may take administrative actions against a school on the basis of its official cohort default rate(s). In addition, official cohort default rates below certain thresholds may qualify a school for certain benefits associated with the disbursement of loan program funds. Please refer to the “Cohort Default Rate Effects” section beginning on page 35 for more information on the administrative actions the Department may initiate against a school due to its official cohort default rate(s) and a description of the benefits associated with its official cohort default rate(s). What are the time frames of a cohort default rate? The time frames for a cohort default rate are based on federal fiscal years. Federal fiscal years begin on October 1 of a calendar year and end on September 30 of the following calendar year.7 Except for schools with 29 or fewer borrowers entering repayment, the cohort default rate is based on the number of borrowers who entered repayment in a single fiscal year (the denominator of the cohort default rate calculation), and of those borrowers, the number of borrowers who defaulted or met other specified conditions before the end of the next fiscal year (the numerator of the cohort default rate calculation).8 The cohort default rate for FY 1998 is based on the number of borrowers who entered repayment in FY 1998 and of those borrowers, the number who defaulted or met other specified conditions in FY 1998 or FY 1999. Therefore, the borrowers who entered repayment from October 1, 1997, through September 30, 1998, are included in the denominator of the FY 1998 cohort default rate calculation. Of those borrowers in the denominator of the cohort default rate calculation, the borrowers who defaulted or met other specified conditions from October 1, 1997, through September 30, 1999, are included in the numerator of the FY 1998 cohort default rate calculation. Please refer to the chart on the next page for a listing of the time frames associated with seven relevant cohort default rate calculations. ___________________________ 734 CFR Section 668.17(d)(2) 834 CFR Section 668.17(d), (e), and (f)
______________________________ 9Except for the FY 1994 cohort default rate, for non-degree granting proprietary schools only, borrowers who have received Direct Loan Program loans are considered to be in default for purposes of calculating a school’s cohort default rate if, for a specified period of time within the cohort period in question, the students are in repayment under the income contingent repayment (ICR) plan with scheduled payments that are less than 15 dollars per month and less than the interest accruing on the loan. Please refer to page 6 for an explanation regarding the period of time the borrower must be in an ICR plan prior to being treated as a defaulted borrower. How does the Department calculate a school’s cohort default rate? The formula the Department uses for calculating a school’s cohort default rate depends on the number of student borrowers from that school entering repayment in a particular fiscal year and the number of cohort default rates previously calculated for the school. The three types of formulas used to calculate a school's cohort default rate are: Non-Average Rate Calculation — for a school with 30 or more borrowers entering repayment during a fiscal year — (see pages 14 and 15); Average Rate Calculation — for a school with 29 or fewer borrowers entering repayment during a fiscal year that had a cohort default rate calculated for the two previous fiscal years — (see pages 16 and 17); AND Unofficial Rate Calculation — for a school with 29 or fewer borrowers entering repayment during a fiscal year that did not have a cohort default rate calculated for either or both of the two previous fiscal years — (see pages 18 and 19). The formulas and sample calculations are shown on the next six pages. Non-Average Rate Calculation: For a school with 30 or more borrowers entering repayment during FY 1998, a non-average rate is calculated.10 The FY 1998 non-average cohort default rate is calculated as follows:
The following page provides an example of a non-average cohort default rate. _____________________________ 1034 CFR Section 668.17(d), (e), and (f) Non-Average Rate Example: School A, a degree granting school, certified 117 loans for 90 borrowers that entered repayment in FY 1998 (denominator). Of those borrowers, 8 borrowers defaulted on a total of 16 loans in FY 1998 or FY 1999 (numerator). School A’s cohort default rate is calculated by dividing 8 by 90 and multiplying the result by 100 to produce a non-average cohort default rate of 8.9 percent.
Average Rate Calculation: For a school with 29 or fewer borrowers entering repayment during FY 1998 that had a cohort default rate calculated for FY 1996 and FY 1997, the Department calculates an average cohort default rate.11 The FY 1998 average cohort default rate is calculated as follows:
The following page provides an example of an average cohort default rate. ___________________________ 1134 CFR Section 668.17(d), (e), and (f) Average Rate Example: School B, a degree-granting school, certified loans for the following students: 50 borrowers who entered repayment in FY 1996, 44 borrowers who entered repayment in FY 1997, and 29 borrowers who entered repayment in FY 1998 (50+44+29=123, which represents the denominator). Of those 123 borrowers, 2 of the borrowers who entered repayment in FY 1996 defaulted in FY 1996 or FY 1997; 6 of the borrowers who entered repayment in FY 1997 defaulted in FY 1997 or FY 1998; and 4 of the borrowers who entered repayment in FY 1998 defaulted in FY 1998 or FY 1999 (2+6+4=12, which represents the numerator). School B’s average cohort default rate is calculated by dividing 12 by 123 and multiplying the result by 100 to produce an average cohort default rate of 9.8 percent.
Unofficial Rate Calculation: For a school with 29 or fewer borrowers entering repayment during FY 1998 that did not have a cohort default rate calculated for FY 1996 and/or FY 1997, the Department calculates an unofficial cohort default rate. The FY 1998 unofficial cohort default rate is calculated as follows:
Since an unofficial cohort default rate does not meet the statutory definition of a cohort default rate, it cannot be used to determine sanctions or benefits. The following page provides an example of an unofficial cohort default rate. Unofficial Rate Example: School C, a degree-granting school that began participating in the FFEL Program on October 1, 1997 (i.e., the beginning of FY 1998), certified loans for 21 borrowers who entered repayment in FY 1998. Of those borrowers, 2 of the borrowers who entered repayment in FY 1998 defaulted in FY 1998 or FY 1999. Because School C has 29 or fewer borrowers who entered repayment in FY 1998, a non-average rate calculation cannot be calculated for the school. However, because the school had not started participating in the FFEL Program on the first day of FY 1997 (i.e., October 1, 1996) and as a result did not have a cohort default rate calculated for FY 1997, School C does not have two previous rates with which to average its current year data. Therefore, School C’s cohort default rate is calculated based on one year of data by dividing 2 by 21 and multiplying the result by 100 to produce an unofficial cohort default rate of 9.5 percent.
How does the Department determine which loans are placed in the denominator of the calculation? Loans are included in the denominator of the cohort default rate calculation based on when the loans entered repayment. Except for an average cohort default rate calculation, loans included in the denominator of the FY 1998 cohort default rate calculation are the relevant FFEL Program and Direct Loan Program loans that entered repayment during FY 1998 (i.e., from October 1, 1997 through September 30, 1998). Different loan types enter repayment under different rules. FFEL Program Stafford Loans enter repayment on the day following six months of an uninterrupted grace period after a student drops below at least half-time enrollment PROVIDED that the school timely notified the lender and/or guaranty agency of the student’s change in enrollment status. If the school does not timely notify the lender and/or guaranty agency of a student's change in enrollment status, the lender will use the best information available to determine the student’s date entered repayment and this date will be used for purposes of calculating the school's cohort default rate. If the loan was converted into repayment before March 1, 1996, the repayment date for FFEL Program Stafford Loans may be date-specific (for example, 1/16/1996) or month-specific (for example, 2/1996). On or after March 1, 1996, the repayment date is date-specific. Direct Loan Program Loans enter repayment on the day following six months of an uninterrupted grace period after a student drops below at least half-time enrollment PROVIDED that the school timely notified the Direct Loan servicer of the student’s change in enrollment status. If the school does not timely notify the Direct Loan servicer of a student's change in enrollment status, the servicer will use the best information available to determine the student’s date entered repayment and this date will be used for purposes of calculating the school's cohort default rate. Unlike FFEL Program loans, the date entered repayment for Direct Loan Program loans has always been date specific.
Federal SLS Loans — if not reported in a cohort default rate prior to FY 1993, the following definitions apply. If a student has a Federal SLS Loan and an FFEL Program Stafford Loan that were both obtained in the same period of continuous enrollment, the date entered repayment for the Federal SLS Loan is the same as the date entered repayment for the FFEL Program Stafford Loan. OR In all other instances, the date entered repayment for the Federal SLS Loan is the day following the day a student is no longer enrolled on at least a half-time basis. Under these guidelines for Federal SLS Loans, which were implemented beginning with the FY 1993 cohort default rates, a loan that was reported as having entered repayment prior to FY 1993 might also meet the criteria to be included in FY 1993 or later. To prevent the possibility of double-counting loans, any Federal SLS Loan that was reported in a cohort default rate prior to FY 1993 will not be reported again. Please refer to the list of special circumstances affecting the cohort default rate calculation beginning on page 24. How does the Department determine which loans are placed in the numerator of the calculation? Loans must be included in the denominator of a cohort default rate calculation in order to be included in the numerator of the cohort default rate calculation. For FFEL Program loans, only defaulted loans are included in the numerator of the calculation. For cohort default rate purposes, a loan is considered to be in default only if the guaranty agency has paid a default claim on the loan to the lender.12 The date the guaranty agency reimburses the lender for the defaulted loan (the claim paid date or CPD) is used to determine if the loan will be placed in the numerator of the calculation. If the claim paid date falls within the same fiscal year in which the loan entered repayment or the next fiscal year, the loan is included in both the denominator and numerator of the cohort rate calculation. Effective October 7, 1998, the 1998 Amendments to the Higher Education Act of 1965, as amended (HEA), changed the definition of default for FFEL Program loans from 180 days of delinquency to 270 days of delinquency. Therefore, if a borrower’s first day of delinquency on a loan occurred before October 7, 1998, the borrower’s default will be based on 180 days of delinquency. However, if a borrower's first day of delinquency on a loan occurred on or after October 7, 1998, the borrower’s default will be based on 270 days of delinquency. When determining a borrower’s first day of delinquency, it is important to note that a borrower's first day of delinquency can change based on late payments made by a borrower (i.e., rolling delinquencies). Example: Harry’s first day of delinquency was September 15, 1998. If Harry makes two full monthly payments in October 1998, and subsequently becomes delinquent, Harry’s first day of delinquency would be after October 7, 1998 and Harry would only default if he remained delinquent for 270 days. Regardless of the number of days of delinquency used to determine a borrower's default date, if the date the claim is paid falls within the same fiscal year in which the loan entered repayment or the next fiscal year, the loan will be included in both the denominator and the numerator of the cohort default rate calculation. __________________________ 1234 CFR Section 668.17(d)(1)(i)(C) For Direct Loan Program loans, loans are included in the numerator of the cohort default rate calculation when a student defaults. As a result of the change in definition of default, the definition of default for cohort default rate purposes for Direct Loan Program loans was changed from 270 days of delinquency to 360 days of delinquency. This change was effective October 7, 1998. Therefore, if a borrower defaults on a Direct Loan Program loan based on a first day of delinquency that occurred before October 7, 1998, the default will be based on 270 days of delinquency. If a borrower defaults on a Direct Loan Program loan based on a first day of delinquency that occurred on or after October 7, 1998, the default will be based on 360 days of delinquency. As with FFEL Program loans, it is important to note that the first day of delinquency may change based on late payments made by borrowers. The change in the borrower's first day of delinquency may affect whether or not the borrower is considered in default after 270 days or 360 days of delinquency. In either circumstance, if the borrower’s default date falls within the same fiscal year in which the loan entered repayment or the next fiscal year, the loan will be included in both the denominator and the numerator of the cohort default rate calculation. In addition, for non-degree granting proprietary schools only, borrowers who have received Direct Loan Program loans are considered to be in default for purposes of calculating a school’s cohort default rate if, for a specified period of time during the cohort period in question, the borrowers are in repayment under the income contingent repayment (ICR) plan with scheduled payments that are less than 15 dollars per month and less than the interest accruing on the loan. The period of time that determines whether a borrower will be included as a defaulted borrower due to the borrower’s ICR plan is based on the cohort default rate calculation in which the borrower is included. If the borrower is included in a cohort default rate calculation prior to FY 1998, the period of time is 270 days. If the borrower is included in the FY 1998 or a later cohort default rate calculation, the period of time is 360 days.13 Please refer to the list of special circumstances affecting the cohort default rate calculation beginning on page 24.
___________________________ 1364 Fed. Reg. 58974, 58979 (November 1, 1999) (Preamble to Final Rule) How do consolidation loans affect the numerator of the cohort default rate calculation? A defaulted Federal Consolidation loan and/or Federal Direct Consolidation loan may cause a non-defaulted FFEL Program and/or Direct Loan Program loan to be included in the numerator of the cohort default rate calculation. This occurs if the Federal Consolidation loan and/or Federal Direct Consolidation loan, which was used to consolidate the FFEL Program and/or Direct Loan Program loan(s), defaults within the cohort period that is associated with the cohort default rate calculation in which the FFEL Program and/or Direct Loan Program loan is included. Example: Elizabeth entered into repayment on an FFEL Program loan on January 3, 1998. Because Elizabeth entered into repayment on the FFEL Program loan on January 3, 1998, Elizabeth will be included in the denominator of the FY 1998 cohort default rate calculation. After entering into repayment on the FFEL Program loan, Elizabeth elects to consolidate the FFEL Program loan using a Federal Consolidation loan. Elizabeth fails to make payments on the Federal Consolidation loan and the claim was paid on the Federal Consolidation loan on March 15, 1999. Even though the FFEL Program loan did not default, the FFEL Program loan will be included in the numerator of the FY 1998 cohort default rate calculation because a claim was paid on the Federal Consolidation loan, which consolidated the FFEL Program loan, before the end of the FY 1998 cohort period, which is the cohort period in which Elizabeth's FFEL Program loan was included. Are there any special circumstances which affect how a loan will be included in the cohort default rate calculation? There are several special circumstances that will affect how a loan is included in the cohort default rate calculation. The table beginning on the next page addresses many of these circumstances but is not intended to be representative of all of the special circumstances.
______________________________ 1434 CFR Section 682.402 and 685.212 15HEA Section 435(m)(2)(B), 34 CFR Section 668.17(d)(1)(ii)(B), (e)(2)(ii), and (f)(2)(ii)
__________________________________ 16HEA Section 428 F(a), 435(m)(2)(C), and 34 CFR Section 682.405(a) An FFEL Program loan is rehabilitated if a borrower has made 12 consecutive, voluntary, on-time monthly payments before the end of the cohort period in which the student entered repayment and the loan is sold to a lender. HEA Section 451(b)(2), 455(a)(1), and 34 CFR Section 685.211(e) A Direct Loan Program loan is rehabilitated if a borrower has made 12 consecutive on-time monthly payments before the end of the cohort period in which the borrower entered repayment.
How does adding and subtracting loans from the cohort default rate calculation affect a school’s cohort default rate? The following chart describes the effect that the movement of a loan has on a cohort default rate calculation. |
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