uncorr~1.pdf  uncorr data adj-89.pdf uncorr data adj 96-100.pdf Uncorrected Data Adjustment File Size: 104KB Number of Pages: 18 Requires 4.0 or greater of the free Adobe Acrobat Reader software. Uncorrected Data Adjustment This section is divided into two parts. The first part (pages 83 through 93) provides background information on the uncorrected data adjustment process, formerly referred to as a request for adjustment, and outlines the process and procedures for submitting an uncorrected data adjustment. The second part (pages 94 through 100) provides an example of a situation that would warrant the submission of an uncorrected data adjustment and sample material as it would pertain to an uncorrected data adjustment. To understand the uncorrected data adjustment process, the U.S. Department of Education (Department) recommends that the reader review both parts of this section.
What is an uncorrected data adjustment? An uncorrected data adjustment, formerly referred to as a request for adjustment, is a request submitted to the Department that ensures a school’s official cohort default rate calculation reflects changes that were correctly agreed to as a result of a school's draft data challenge. Which schools are eligible to submit an uncorrected data adjustment? Any postsecondary school that receives an official cohort default rate may request that the Department adjust its official cohort default rate. This includes a school whose official cohort default rate is below 25.0 percent.
Why should a school submit an uncorrected data adjustment? A school should submit an uncorrected data adjustment if: it timely submitted a challenge of its draft cohort default rate data; AND the entity reviewing the draft data challenge correctly agreed to make changes to the cohort default rate data; AND the agreed upon changes are not reflected in the school’s official loan record detail report. For which cohort default rates may a school submit an uncorrected data adjustment? A school can only request an adjustment of the most recent (in this case FY 1998) official cohort default rate data as part of an uncorrected data adjustment. Schools that have 29 or fewer borrowers entering repayment are also limited to submitting an uncorrected data adjustment for only the current year's official data. Is an uncorrected data adjustment the same as a new data adjustment or an erroneous data appeal? No, an uncorrected data adjustment is not the same as a new data adjustment or an erroneous data appeal. An uncorrected data adjustment addresses changes to data that were correctly agreed to during the draft data challenge process, but were not made. Any school, regardless of its cohort default rate, may submit an uncorrected data adjustment PROVIDED that the adjustment is timely submitted and the guaranty agency/Direct Loan servicer correctly agreed to change the data during the draft data challenge process. A new data adjustment addresses data that were correctly reported in the draft loan record detail report BUT were incorrectly reported in the official loan record detail report (i.e., new data). Any school, regardless of its cohort default rate, may submit a new data adjustment PROVIDED that the adjustment is timely submitted and the guaranty agency/Direct Loan servicer agreed to change the data after the release of the official cohort default rates. An erroneous data appeal addresses data that was challenged during the draft data challenge process but was not resolved during the draft data challenge process and/or new data that appears in the school’s official cohort default rate. An erroneous data appeal may only be submitted by a school that is subject to sanctions as a result of the school’s official cohort default rates. When submitting an erroneous data appeal the guaranty agency/Direct Loan servicer does not need to agree that a change to the data is warranted. A school may be eligible to submit an uncorrected data adjustment, a new data adjustment, and/or an erroneous data appeal. If a school is submitting one or more of the adjustments/appeals, it is important to note that each appeal has different eligibility, deadline, and documentation requirements. For more information on new data adjustments and/or erroneous data appeals, please refer to the “New Data Adjustment” section and/or “Erroneous Data Appeal” section beginning on pages 101 and 141, respectively. What if a school does not submit an uncorrected data adjustment? If a school does not submit an uncorrected data adjustment after the release of the official cohort default rates, the school may not have the opportunity to challenge the data at a later time.
What role does a guaranty agency/Direct Loan servicer have in an uncorrected data adjustment? A guaranty agency/Direct Loan servicer is not directly involved in a school’s uncorrected data adjustment. After the release of the official cohort default rates, a school’s uncorrected data adjustment is submitted directly to the Department’s Default Management Division. The Department adjusts the school’s cohort default rate according to the correctly agreed upon changes noted by the guaranty agency/Direct Loan servicer during the draft data challenge process. The uncorrected data adjustment is NOT based on information received from a guaranty agency/Direct Loan servicer after the release of the official cohort default rates. What role does the Department have in a school’s uncorrected data adjustment? The Department is responsible for reviewing a school's uncorrected data adjustment submitted after the release of the official cohort default rates. In reviewing the adjustment – If the Department determines that a guaranty agency/Direct Loan servicer correctly agreed to make a change to a school's cohort default rate data during the draft data challenge process, but failed to make the change, the Department will recalculate the school's cohort default rate based on the correct data and notify the school of the revised cohort default rate. Please refer to page 33 of the "Cohort Default Rate Calculation" section for information on adding and subtracting loans to and from the cohort default rate calculation. If the school was previously notified that it was subject to sanctions due to its cohort default rates and the Department determines that the school's revised cohort default rate is below the applicable sanction threshold(s), the Department will withdraw the notice that the school is subject to the loss of eligibility to participate in any Title IV Student Financial Assistance Programs due to the school's cohort default rates. If the school is subject to initial or extended loss of eligibility to participate in the FFEL Program, Direct Loan Program, and/or Federal Pell Grant Program, and the Department determines that the school's revised cohort default rate(s) is NOT below 25.0 percent and the school does not have any other cohort default rate adjustments/appeals pending before the Department, the Department will notify the school of the effective date of its loss of eligibility to participate in the FFEL Program, Direct Loan Program, and/or Federal Pell Grant Program and any liabilities that the school may have incurred during the adjustment/appeal process. If a school is subject to initial loss of eligibility to participate in the FFEL Program and/or Direct Loan Program, and the school’s adjustment/appeal of that loss is unsuccessful, the school will be liable for certain costs associated with FFEL Program loans certified and delivered and Direct Loan Program loans originated and disbursed by the school. A school’s period of liability with regard to these costs begins 30 calendar days after the school receives notice that it is subject to initial loss of eligibility to participate in the FFEL Program and/or Direct Loan Program. The period of liability ends upon the earlier of the withdrawal of the school’s adjustment/appeal, the resolution of the school’s adjustment/appeal, or the 45th calendar day after the date the school submitted its completed adjustment/appeal to the Secretary for review.1 If the school is subject to possible limitation, suspension, and/or termination (LS&T) due to its official cohort default rate and the school's revised cohort default rate is not below 40.1 percent, and the school does not have any other cohort default rate adjustment/appeals pending before the Department, the school will be referred to the Department's Administrative Actions and Appeals Division for possible LS&T of all Title IV Student Financial Assistance Programs. ____________________________ 1 HEA Section 435(a)(2)(A) and 34 CFR Section 668.17(b)(6)(ii) Please refer to page 37 of the " Cohort Default Rate Effects" section for more information on the effects of sanctions associated with official cohort default rates. What if a school’s uncorrected data adjustment is sent to the wrong entity or address? If a school submits an uncorrected data adjustment to the wrong entity or address, the uncorrected data adjustment may NOT be reviewed and the school could miss the deadline for submitting the uncorrected data adjustment. An uncorrected data adjustment should be submitted to Department’s Default Management Division at the address found on page 93. How can an uncorrected data adjustment affect a school’s cohort default rate? If, as a result of an uncorrected data adjustment, the Department determines that a school’s official cohort default rate is incorrect, the Department will recalculate the official cohort default rate using the corrected data. This may lower, raise, or not affect any of a school’s three most recent official cohort default rates. Please refer to page 33 of the “Cohort Default Rate Calculation” section for information on adding and subtracting loans to and from the cohort default rate calculation. Even though the Department may alter a school’s official cohort default rate calculation(s), subsequent copies of the school’s official loan record detail report(s) will not reflect the change. Therefore, it is important to keep a copy of the Department’s final determination letter as the official record of the school’s cohort default rate(s).
What are the time frames and procedures for submitting an uncorrected data adjustment? Timing is critical for a school when submitting an uncorrected data adjustment. An overview of the time frames associated with the uncorrected data adjustment process is shown below. uncorrected data adjustment process File Size: 105KB; Number of Pages: 1 Requires 4.0 or greater of the free Adobe Acrobat Reader software. The following pages provide a step-by step description of the time frames and procedures associated with an uncorrected data adjustment. Step 1: Within 10 working days of receiving its official cohort default rate notification letter, if the school did not receive a copy of its official loan record detail report with its official cohort default rate notification letter and the school believes it may need to submit an uncorrected data adjustment, it must request its official loan record detail report. Please refer to page 69 of the "Electronic Loan Record Detail Report” section for instructions on requesting a copy of the loan record detail report. All schools with an FY 1998 official cohort default rate of 10.0 percent or greater will receive an FY 1998 official hardcopy loan record detail report with their FY 1998 official cohort default rate notification letter. If a school receives a hardcopy official loan record detail report and it subsequently requests an electronic loan record detail report, the time frames to submit the uncorrected data adjustment are based on the school's receipt of the hardcopy official loan record detail report. Step 2: Within 30 calendar days of receipt of the official loan record detail report, a school must: compare the response(s) it received to its draft data challenge(s) with its official loan record detail report; AND ensure that the changes correctly agreed to by the guaranty agency/Direct Loan servicer during the draft data challenge process were made. Step 3: Within the time frame described in Step 2 (i.e., within 30 calendar days of receipt of the official loan record detail report), a school must compile a list of loans that the guaranty agency/Direct Loan servicer correctly agreed to change as a result of its draft data challenge but the changes did not appear in the school's official loan record detail report. Time frames may overlap. Read ALL steps.
A school should refer to the Sample Uncorrected Data Adjustment SPREADSHEET and SPREADSHEET INSTRUCTIONS on pages 99 and 98, respectively, to assist in developing the list. Step 4: Within the time frame described in Step 2 (i.e., within 30 calendar days of receipt of the school’s official loan record detail report), submit the following to the Department using the address on page 93: a letter requesting an adjustment; A school should refer to the Sample Uncorrected Data Adjustment LETTER on page 100 to develop the letter; the Sample Uncorrected Data Adjustment SPREADSHEET as described in Step 3; copies of the relevant guaranty agency/Direct Loan servicer DRAFT DATA CHALLENGE RESPONSES that support the school's contention that the changes were correctly agreed to during the draft data challenge process. If a school fails to timely submit its uncorrected data adjustment to the Department's Default Management Division, the Department will not review the adjustment and will return all adjustment-related material to the school. Step 5: Within the time frame described in Step 2 (i.e., within 30 calendar days of receipt of the school’s official loan record detail report), send the relevant guaranty agency/Direct Loan servicer a copy of the uncorrected data adjustment cover letter and spreadsheet submitted to the Department. A school does NOT need to send copies of the guaranty agency/Direct Loan servicer draft data challenge responses to the guaranty agency/Direct Loan servicer. The following page provides an overview of the MATERIAL that should be included in a school's uncorrected data adjustment. Within the time frames described in Step 2 on page 90, the following MATERIAL, to support an uncorrected data adjustment, should be sent to the Department's Default Management Division at the address shown on page 93.
The Department will review only the information submitted with the uncorrected data adjustment and will not consider information submitted after the applicable deadline. The Department will send the school and each involved entity written notification of its decision. The Department’s decision is final and no further administrative review is provided.
If sent by commercial overnight mail/courier delivery, send the school’s uncorrected data adjustment to: U.S. Department of Education Default Management Division ATTN: Uncorrected Data Adjustment Portals Building, Room 6300 1250 Maryland Avenue, SW Washington, DC 20024 If sent by U.S. Postal Service, send the school’s uncorrected data adjustment to: U.S. Department of Education Default Management Division ATTN: Uncorrected Data Adjustment Portals Building, Room 6300 400 Maryland Avenue, SW Washington, DC 20202-5353 The Department will not accept any appeal correspondence by facsimile (fax) or e-mail. The Department recommends that a school submit its uncorrected data adjustment return receipt requested or via commercial overnight mail/courier delivery. This will be useful to the school if it is asked to authenticate the timeliness of its adjustment. A school should maintain the documentation, which verifies the receipt of the adjustment related material. In addition, the Department recommends that a school retain copies of all adjustment-related documents provided to the Department and other entities.
Part II of the Uncorrected Data Adjustment section outlines a situation where a school would benefit from submitting an uncorrected data adjustment. This part also provides sample material that should be referenced by a school when compiling the material that must be submitted by a school during the uncorrected data adjustment process. CONTENT REFERENCE FOR PART II EXAMPLE of a situation that warrants the submission of an Uncorrected Data Adjustment 95 Sample LOAN RECORD DETAIL REPORTS 96 Sample Draft Data Challenge Response 97 Uncorrected Data Adjustment SPREADSHEET INSTRUCTIONS 98 Sample Uncorrected Data Adjustment SPREADSHEET 99 Sample Uncorrected Data Adjustment LETTER 100 EXAMPLE of a situation that warrants the submission of an Uncorrected Data Adjustment
Sample Loan Record Detail, Data Adj. Spreadsheet Inst. and etc. File Size: 41KB; Number of Pages: 5 Requires 4.0 or greater of the free Adobe Acrobat Reader software. |