Attachment_A_Amended_DCAS_SOO_v5_1_Rev_1_Final.pdf

DATA CHALLENGES AND

APPEALS SOLUTION

(DCAS)

STATEMENT OF OBJECTIVES

November 18, 2014

Version 5.1

Amended Attachment A Rev 1 Page 2 of 20

Executive Summary

U.S. Department of Education (ED), Federal Student Aid (FSA) has a variety of program metrics that are or will be published on a frequent basis. Current and proposed regulations allow for institutions to challenge and appeal those metrics based on detailed student level data included in the metric calculation.

FSA currently publishes cohort default rates (CDR) annually. The CDR Regulations allow for multiple data challenge types.

In addition, on March 25, 2014, ED published a Notice of Proposed Rulemaking (NPRM) for Gainful

Employment (GE) 79 FR 16426. It is expected that final GE regulations, resulting from this NPRM, will be published no later than November 1, 2014. The new GE Regulations may include provisions that will allow for multiple data challenge types.

In the future, there may be additional student level data correction mechanisms needed for institutions as a result of other metrics developed in response to the Administration’s transparency initiatives such as the College Scorecard.

I. Overview

FSA is seeking a new solution to support current known challenges and appeals, as well as any future student level data challenges and appeals through workflow processing application/system and case intake/case management staffing services.

FSA currently conducts a challenge process in support of the CDR regulations in

Subpart N of the Student Assistance General Provisions regulations (34 CFR Part 668).

For the most recent cohort year, 2011, over 357 institutions submitted data challenges on the three year draft CDR. Of the 357 institutional challenges, each submission could range from data challenges on as few as 10 loans to more than 1,000 loans.

With the proposal of new regulations and new metrics for public use, FSA will be responsible for many more data challenges in coming years. The current NPRM for

Gainful Employment was used as a basis to estimate the possibility of over 300,000 loan level challenges during the first metric calculation year.

FSA has a current intake process that allows institutions to electronically submit data challenges in relation to CDR. Those data challenges are reviewed and resolved on a case-by-case basis by FSA staff. The volume of challenges continues to increase with new regulations and the possibility of additional metrics compounds the issue.

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II. Background

The GE initiative is in support of the implementation of proposed new regulations that, when finalized, will apply to all postsecondary institutions that have GE programs. The

Higher Education Act of 1965 (as amended) states that in order to be eligible for funding under the Title IV programs, an educational program at a non-profit or public institution must lead to a degree (associate, bachelor's, graduate, or professional) that prepare students for "gainful employment in a recognized occupation" at all types of institutions. We estimate that there are over 5,000 institutions with GE programs that are currently participating in the Title IV programs for a total of over 64,000 GE programs.

The current Electronic Cohort Default Rate (eCDR) Appeals System supports institution level CDR challenges. Once a challenge is initiated it becomes a case1. With the number of data challenges increasing each year and the addition of proposed GE metrics at the program level, the current eCDR Appeals System cannot support the expected volume increase. Therefore, it is not a viable system to meet this requirement. The eCDR

Appeals System maintains information throughout the case's life cycle namely key dates and specific to student level data challenges to clarify actions taken by the institution and the data providers/managers.

College Scorecard in the U.S. Department of Education’s College Affordability and

Transparency Center (CATC) was designed by the U.S. Department of Education to meet requirements in the Higher Education Opportunity Act and to provide better information to student and parent consumers about college costs. It serves as a central point to several tools that allow users to compare colleges’ tuition and fees, net price, and other characteristics. College Scorecard is maintained by the Office of

Postsecondary Education with support and technical assistance from the National

Center of Education Statistics and Federal Student Aid.

Unlike GE and CDR, there are currently no data challenges in relation to the College

Scorecard; however, any proposed solution should be robust and adaptable in the event there are future challenge requirements from this or other initiatives.

Goal

Any proposed solution should include both the workflow processing application/systems and case management staffing required to review, research, analyze, and process challenges and appeals that, at minimum provides the following:

1 Refer to Exhibit B for additional information on eCDR Appeals System (page 16 of this SOO).

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Operations processing to handle case intake/case management of data challenges and appeals as well as contractor staffing to review, research, analyze, and process these challenges and appeals initiated by institutions in order to determine the resolution and recommended outcomes of completed cases for submission to the

Department for final approvals by FSA staff.

Regular operational and management reporting to FSA management and staff on a standard, on-demand, and ad-hoc basis. Some example metrics on which to report are institution and program level data; accuracy and consistency of staff resolution recommendations; number of challenge and appeal cases received; breakdown by number and type of loan allegations in each case; current case status; and time-to-resolution statistics.

Through trend and root cause analyses, incorporates operational and performance efficiencies into the challenge and appeals case intake/case management functions to streamline classification of case complexity and enhance timely resolution of data challenges and appeals.

Customer services to support end users (including institutions, data managers and

FSA) with technical assistance and challenge processing inquiries on the status of cases, open questions, research items and general operations support.

Capability to transfer data corrections to the calculation system (National Student

Loan Data System (NSLDS)) based on a fixed schedule of dates to be determined by the Department.

The current CDR metric is used to determine eligibility of an institution to participate in the

Title IV, HEA programs. Draft CDR metrics are published for institutional review and challenge in February of each year. These metrics will be promulgated by the Department.

As stated in the proposed Gainful Employment regulations, there will be an additional two

(2) independent measures used to determine program eligibility with the implementation dates as follows:

1) Debt-to-Earnings (D/E) Metric - anticipated implementation date to accept, process, resolve, and archive data challenges beginning by September 1, 2015 for pre-draft2 and beginning by June 1, 2016 for draft.

2) Program Cohort Default Rate (pCDR)/Cohort Default Rate (CDR) – anticipated implementation date to accept, process, resolve, and archive data challenges and appeals beginning by February 1, 2016.

The Government will consider a phased implementation with just-in-time functionality to meet these dates.

2 Refer to Exhibit 1 for examples of data challenges types (page 14 of this SOO).

Amended Attachment A Rev 1 Page 5 of 20

The proposed regulations will require FSA to calculate additional metrics that will be disclosed to the public. The proposed regulation anticipates calculation and disclosure of a program’s:

1) Median Earning for Disclosures - anticipated implementation date to accept, process, resolve, and archive data challenges beginning by September 1, 2015.

2) Completion/Withdrawal Rates - anticipated implementation date to accept, process, resolve, and archive data challenges beginning by December 1, 2016.

3) Repayment Rate - anticipated implementation date to accept, process, resolve, and archive data challenges beginning by December 1, 2016.

4) Median Loan Debt for Disclosures - anticipated implementation date to accept, process, resolve, and archive data challenges beginning by December 1, 2016.

5) Through collaboration with and approval by FSA's project team, the contractor’s proposed solution shall meet the timeframes indicated above. The proposed solution may be implemented in multiple iterations at earlier timeframes than those noted above.

Based on CDR appeals’ historical volumes, the notional schedule for the anticipated data challenges’ seasonal volume trends are as follows:

1) Institution Cohort Default Rate (iCDR) and pCDR draft season: March through May

2) iCDR and pCDR official season: October through December 2016

3) Debt-to-Earning pre-draft season: September through November 2015

4) Debt-to-Earning draft season: June through August 2016

5) Disclosures: December 2016 through March 2017

These dates may change after the regulation is published.

Performance Objectives

Contractor’s proposed solution shall meet or exceed the following performance objectives and ensure expected outcomes are realized.

Objectives Outcomes

I. Case Intake

Services

a. Institutions initiate/open a challenge and/or appeal case easily.

b. Institutions prepare their case including all loan level allegations for the various data challenge types easily and update as needed.

c. Institutions initiate, prepare, and submit cases for the various challenge and appeal types within the timeframes mandated by

Amended Attachment A Rev 1 Page 6 of 20

Objectives Outcomes regulation.

d. Contractor accesses and uploads underlying backup detail data from the calculation system National Student Loan Data System

(NSLDS) to initiate a case.

e. Institution requests information and obtains clarification from the appropriate data managers, as needed.

f. Contractor classifies and sorts the allegations within each case based on the appropriate data manager.

g. Institution updates and reviews the case prior to submission;

then certifies and submits the completed case to the Department for formal review.

h. Contractor manages multiple users’ access to data, cases, and case requests from various solution users, based on the principles of least privilege with access controlled by user type and role (if necessary).

i. Contractor allows users to access cases, review allegations and research data requests prior to formal submission of the case to the Department.

j. Contractor creates, implements, and manages new and/or additional data based business rules drivers as determined by the

Department.

k. Contractor accepts all data and documentation supporting challenges and appeals in various agreed-upon file formats such as PDF, TIF, JPEG, XML, etc.

II. Case Management

Services

(Review, research, process, and submit to FSA staff for final approval/ resolution)

a. Contractor reviews submitted cases for completeness and performs research through communication with institutions and/or data managers as needed.

b. Contractor processes allegations and submits inquires to appropriate data managers and/or institutions as needed.

c. Contractor performs analysis of allegations and supporting documentation to determine and recommend a disposition for each allegation to the Department.

d. Contractor submits completed cases to the Department for final resolution of the challenge or appeal outcome including final transfer of challenge outcomes to the calculation system via extract, transform, and load (ETL) interface.

e. Contractor tracks and provides audit trail of data challenges and appeals from submission to resolution.

Amended Attachment A Rev 1 Page 7 of 20

f. Contractor provides staffing levels sufficient to process cases within timeframes mandated by regulation and that align with peak and non-peak processing periods.

g. Contractor incorporates business process improvements and efficiencies based on trends and analysis of challenge and appeal volumes.

h. Contractor utilizes workflow to process data challenges at the initial implementation along with potential future implementation of new challenge and appeal types using new or revised workflows.

i. Contractor identifies redundant and repetitive data challenges to address anomalies in work flows that require multiple submissions of data corrections.

j. Contractor provides standard and ad-hoc reporting with unlimited access to customized data queries, on both a self service and on demand basis, to obtain analytical information regarding challenge and appeal data on agreed-upon frequency

(weekly, monthly, etc.). Examples include Case Aging reports, Monthly Volumes Report, Open Cases Report, etc.

k. Contractor provides grammatically and syntactically correct communications and notifications to end users via: email, fax or paper correspondence, alerts, text, instant message; triggered by calendar based dates (or events) defined by regulations and/or business rules.

III. Training Services

(Virtual/Web-based, Instructor-led, and Train-the-

Trainer Methods)

a. Contractor develops and delivers a variety of instructional methods and media that are appropriate to the target audience

(i.e., FSA staff, institutions’ personnel, and data managers’ personnel) and achieve stated training objectives. Examples include, but are not limited to, interactive webinars, just-in-time virtual classrooms that promote attendees’ participation and collaboration, as well as instructor-led classroom sessions including group presentations and/or briefing, etc.

b. Contractor develops and provides core training materials that are accurate, current, and contain job-related information for each user group. Examples include, but are not limited to, user guides/manuals, workflow screen shots, job aides, FAQs, etc.

c. Contractor provides revisions and updates to all training materials and manuals for each phased-in implementation of the

Amended Attachment A Rev 1 Page 8 of 20 challenge and appeal processes.

d. Contractor develops and delivers any additional training sessions, as needed, to support regulatory initiatives and business enhancements.

IV. Technical/

Helpdesk Support

Services

a. Contractor provides technical support services to manage user access, system log on, and other solution related technical issues.

b. Contractor provides staffing for case-related support services to institutions, data managers, and FSA staff regarding open/in process challenges and appeals.

c. Contractor submits monthly production operations reports related to solution performance (such as call center metrics, help desk support, system performance, service level agreements, etc.). In addition, contractor provides quarterly reporting on help desk tickets including information on type of issue/problem, description, resolution, and lessons-learned.

Assumptions and Constraints

Contractor shall adhere to and/or fulfill the following:

1) GE regulations are expected to be finalized and promulgated by November 1, 2014.

2) Capability to receive backup detail data from the calculation system (NSLDS) to initiate case and ability to transfer any changed data back to NSLDS in order to revise, update, and distribute as final calculations via bidirectional interface.

a) Extract, transform, and load (ETL) does not need to be in real-time but rather by batch to NSLDS as well as any new interfaces that may be needed in the future.

b) Batch interfaces will be based on a fixed schedule of dates as determined by the Department.

3) Proposed data challenges and appeals solution shall utilize FSA’s Participation

Management (PM)/ Access & Identification Management System (AIMS), which includes providing a traditional password and Two-Factor Authentication (TFA)

One-time Password (OTP) generated by a registered token device that is in the physical possession of the user.

a) Currently, institution and data provider personnel use this capability to access necessary applications/systems.

b) The Government will furnish additional tokens to the users, as needed.

Amended Attachment A Rev 1 Page 9 of 20

4) If the proposed solution will be COTS based development new or existing application/system, Offeror shall provide all required documentation outlined in amended Attachment C including compliance with Earned Value Management

System (EVMS) requirements. FSA shall retain ownership of all data residing in this application/system.

5) Proposed data challenges and appeals solution shall include contractor staffing complement for case intake and case management (review, research, processing, and submission for FSA resolution) services, as well as technical/helpdesk support services including training, to assist FSA staff, institutions, and data managers.

6) In accordance with the Office of Management and Budget (OMB) Circular No. A-13, all Government websites must be within a specific domain; in this case, it shall be

‘ed.gov’. FSA will register the appropriate domain name and address.

7) Migration of key data elements from eCDR Appeals System into the proposed data challenges and appeals solution. Identification of these key data elements will be performed during the requirement gathering phase.

8) Initial go-live date including successful completion of necessary training of the proposed solution users shall be by no later than September 1, 2015. (Initial group to receive this training will be FSA staff, with training for institutions and data managers to follow.)

9) If existing or new COTS-based solution will not be hosted at the contractor’s facility, it shall be hosted at the Government’s Virtual Data Center (VDC).

10) If cloud-based Software as a Service (SaaS) solution proposed, it shall hold a

Federal Risk and Authorization Management Program (FedRAMP) Authority to

Operate (ATO) certificate.

11) Proposed data challenges and appeals solution shall comply with all Federal

Statutes, Standards and Guidelines for Security such as Federal Information

Security Management Act (FISMA) of 2002, Computer Security Act (1987), Privacy

Act (1974), Federal Information Processing Standards (FIPS) Pub 199, FIPS Pub

200, FIPS Pub 140-2, National Institute of Standards and Technology (NIST) Special

Publication (SP) 800-34, NIST SP 800-18, NIST SP 800-30, NIST SP 800-37, NIST

Pub 800-47, NIST SP 800-50, NIST SP 800-53, NIST SP 800-88, NIST SP 800-137, OMB Circulars A-130 and A-123, OMB Memorandum M-08-05 (Trusted Internet

Connection), 508 Compliance, Department of Education technical and security policies, FSA’s Project Governance Model and Lifecycle Management Methodology

(LMM)).

12) Case intake and management services shall be billable at 75% of the total incurred expenses when the completed case is submitted to the Government. Remaining

Amended Attachment A Rev 1 Page 10 of 20

25% may be billed after the successful completion of the batch interface with the calculation system, NSLDS.

a) FSA’s Talent Management System (TMS) may be utilized for FSA staff to publicize all DCAS training, manage registration, capture participants’ feedback via electronic survey, and manage participants’ completed/pending training appointment. However, the mechanism to be used for institution and data manager users must be established and maintained by the DCAS contractor at a Not Separately Priced (NSP) basis.

b) In addition to TMS, FSA has a training registration and webinar capability within its Business Operations Office that the DCAS contractor may use to register its course offerings, deliver trainings via webinar, and track input from the institution and data manager user community. Webinars can accommodate up to 3,000 participants, so if more are needed then multiple webinars will be necessary. To leverage this capability, DCAS contractor must submit written notice within sixty (60) business day to set up registration and schedule the webinar.

Place and Period of Performance

It is anticipated that the contractor shall perform the majority of the work at its facility;

however, the contractor may be required to attend meetings in person at FSA’s headquarters located at 830 First Street, NE, Washington, DC, 20202 or participate via conference calls to discuss project status and other matters.

Base period performance shall commence on the date of award (anticipated start date of

January 29, 2015) and conclude on August 31, 2015 with anticipated four (4) option periods. Total contract term shall not exceed five (5) years.

Option Periods Dates OPT #1 September 1, 2015 through August 31, 2016 OPT #2 September 1, 2016 through August 31, 2017 OPT #3 September 1, 2017 through August 31, 2018 OPT #4 September 1, 2018 through January 31, 2019

Contract Type

This is a hybrid contract on a Fixed Labor-Hour (LH) and Fixed-Unit Priced (FUP) basis.

Scope of Services

The Government expects that the following services will be performed to meet its goals and performance objectives:

Amended Attachment A Rev 1 Page 11 of 20

1) Development of high-level business and general/detailed technical requirements through stakeholder sessions with key FSA subject matter experts (SMEs) including individuals from NSLDS, eCDR, Policy, Gainful Employment Operations, and, other contractors.

2) Review and analysis of all relevant artifacts/documentation provided by FSA.

3) Implementation of the applicable iteration of Case Intake and/or Case Management

Services including training and technical/helpdesk support services.

4) Development of a comprehensive training plan for base and option periods as well as the execution of training sessions for all designated solution users within each challenge period.

a) During the base period: four (4) instructor-led training sessions including all required training material for FSA staff.

b) During the option periods: FSA anticipates at minimum two (2) instructor-led sessions including all required training materials for new Institutional and/or Data Manager users.

5) Production, maintenance, and update of all training materials including job aides, screenshots, FAQs, documents, as well as training presentations and/briefings as necessary to ensure that all authorized DCAS users understand the functions and data of the proposed solution.

a) Updates, revisions, and upload of all training materials including webinars, just-in-time virtual classroom, etc. at a Not Separately Priced (NSP) basis.

6) Ongoing operations and maintenance support services including all mandated legislative and/or regulatory enhancements.

a) There shall be no charges for any solution improvements and/or enhancements that costs $3,000 or less or requires 100 hours or less to complete, whichever is greater.

b) Proposed solution improvements/enhancements shall be approved using the established FSA Change Request Process. The Contractor shall obtain approval from FSA before analyzing and sizing the proposed system enhancement(s).

c) Once a system enhancement analysis and sizing results have been approved by the FSA and authorized by the Contracting Officer, the Contractor shall develop and implement the system enhancement.

Amended Attachment A Rev 1 Page 12 of 20

7) Ongoing program/project management support services, not separately priced

(NSP), by the contractor’s personnel include the creation of all relevant artifacts in accordance with PMI’s PMBOK®.

8) Participation and collaboration with FSA staff, institutions, data managers, and other contractors, as needed.

Contractor Staffing and Responsibilities

Any access to necessary facilities, IT systems, and/or data will be based on the contractor personnel’s ability to obtain the requisite security clearance in accordance with EDAR

Clause 3452.239.72: Department Security Requirements (Mar 2011).

Ownership of information and documents prepared in accordance with this contract shall become and remain property of FSA. It is the contractor’s responsibility to ensure system and data security as well as all individual personnel data security.

Key Personnel Requirement

The Contractor shall propose key personnel who are committed to this project and available as needed in accordance with the solicitation instructions.

The Department anticipates that the staff assigned to provide case intake and case management services have the minimal qualifications as noted in the following position titles and job descriptions:

a) Program Director (PD): Bachelor’s degree from an accredited college or university in areas of business management, information technology or other related fields of study with at least fifteen (15) years of demonstrated relevant experience in a major

IT implementation and/or case management operations. This individual must hold an active Project Management Professional® (PMP) credential from Project

Management Institute (PMI) or an equivalent industry-recognized certification.

The Program Director (PD) is the cornerstone of the DCAS contractor’s program management staff thus requires a full-time commitment; and as such, is solely responsible for the overall program including technical, case processing, and operational tasks, and in coordinating the team’s efforts to maximize the system’s benefits to ED. The Program Director plans, organizes, and directs the team’s activities for the successful execution of the Government’s performance objectives and outcomes. Additionally, this individual shall serve as the single point of contact for FSA Gainful Employment Operations team and DCAS Contracting Officer’s

Representative (COR) and shall be accessible to the ED staff during normal working hours to discuss all problems and areas of concern. Finally, the PD shall champion

Amended Attachment A Rev 1 Page 13 of 20 the implementation of best-in-class business processes and foster an environment of consistent operational efficiencies and continual improvement.

b) Case Processing Specialist I: Associate’s degree or 60 hours of credit earned towards a Bachelor’s degree from an accredited college or university with at least two (2) years of relevant demonstrated experience in case management services such as performing initial case reviews using differentiated timelines, researching, and analyzing information/data from various sources.

c) Case Processing Specialist II: Bachelor’s degree from an accredited college or university in finance or related field with at least eight (8) years of relevant demonstrated experience in the student loan industry and/or case management services such as reviewing and researching data errors or omissions using supporting documentation/records submitted with an initial case, and analyzing complex and detailed information/data from various sources. Knowledge of or familiarity/experience in Title IV programs preferred.

d) Certified Senior Trainer: Master’s degree from an accredited college or university in training-related disciplines or equivalent with at least fifteen (15) years of relevant demonstrated experience in building effective training and performance support tools using industry-recognized Instructional Systems Design (ISD) such as the

ADDIE model and proven track record for successful delivery of tailored training sessions for a variety of audiences with various training objectives.

The Department may consider years of experience of key personnel in lieu of the education requirement.

Applicable References and Standard

a. Subpart M and Subpart N of Section 668 of the Code of Federal Regulations.

b. Subpart A of section 668 of the Code of Federal Regulations for reporting and disclosure requirements.

c. Additional default prevention and management information available on ifap.ed.gov.

d. Gainful Employment (GE) Information Resources website.

e. NSLDS User Guide for reporting GE data.

f. GE Operations Manual.

g. White House College Scorecard.

h. FSA Information Technology (IT) Standards Library.

http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&rgn=div5&view=text&node=34:3.1.3.1.34&idno=34#34:3.1.3.1.34.13 http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&rgn=div5&view=text&node=34:3.1.3.1.34&idno=34#34:3.1.3.1.34.14 http://www.ecfr.gov/cgi-bin/text-idx?c=ecfr&rgn=div5&view=text&node=34:3.1.3.1.34&idno=34#34:3.1.3.1.34.1.39.6 http://www.ifap.ed.gov/DefaultManagement/DefaultManagement.html http://www.ifap.ed.gov/GainfulEmploymentInfo/GEResources.html http://ifap.ed.gov/nsldsmaterials/attachments/NSLDSGainfulEmploymentUserGuide.pdf https://www.ifap.ed.gov/GainfulEmploymentOperationsManual/GainfulEmploymentOperationsManual.html http://www.whitehouse.gov/issues/education/higher-education/college-score-card https://studentaid.ed.gov/about/contracting-info/it-standards

Amended Attachment A Rev 1 Page 14 of 20

Exhibit 1: Examples of Data Challenges

Type Description Pre-Draft Debt-to-Earnings (D/E) and Median Earnings to Disclosure Challenges

Allows institutions to add or remove students from the Completer List. The Completer List is provided to the Social Security Administration to obtain mean/median earnings information used in calculating D/E measures and used in disclosures.

Draft Debt-to-Earnings (D/E) Challenge - Annual Earnings

Allows institutions to challenge the draft Debt-to- Earnings Annual Earnings rate. The Annual D/E rate is the percentage of a GE program’s annual loan payment compared to the annual earnings of the students included in the calculation.

Draft Debt-to-Earnings (D/E) Challenge – Discretionary Earnings

Allows institutions to challenge the draft Debt-to- Earnings Discretionary Earnings rate. The Discretionary D/E rate is the percentage of a GE program’s annual loan payment compared to the discretionary income of the students included in the calculation.

Transitional Period – Draft Debt-to- Earnings (D/E) – Challenge (Applies to both Annual and Discretionary D/E rates)

Allows institutions to challenge draft transitional D/E rates for a GE program failing or in the zone.

For any of the first 4 award years for which D/E rates are calculated, a transitional D/E rate is calculated using the median loan debt of students included in the calculation during the most recently completed award year prior to the calculation of the D/E rates.

Draft CDR and pCDR – Incorrect Data Challenge (IDC)

Allows institutions to challenge default date information on individual borrower records.

Draft CDR and pCDR – Participation Rate Index Challenge (PRI)

Allows institutions to challenge loss of eligibility (applies to sanctioned institutions only).

Final CDR and pCDR – Uncorrected Data Adjustment (UDA)

Allows institutions to challenge default date information on individual borrower records.

Final CDR and pCDR – New Data Adjustment (NDA) Appeal

Allows institutions to challenge default date information on individual borrower records.

Final CDR and pCDR – Erroneous Data Appeal

Allows institutions to challenge default date information on individual borrower records.

Final CDR and pCDR – Loan Servicing Appeal

Allows institutions to challenge their rate for loans improperly serviced for cohort default purposes.

Final CDR and pCDR – Economically Disadvantaged Appeal (EDA)

Allows institutions to challenge their CDR for low-income rate purposes.

Amended Attachment A Rev 1 Page 15 of 20

Type Description Final CDR and pCDR – Participation Rate Index Appeal

Allows institutions to challenge loss of eligibility (applies to sanctioned institutions only).

Final CDR and pCDR – Average Rate Appeal

Allows institutions to challenge their CDR for average rate purposes.

Final CDR and pCDR – 30 or Fewer Borrowers Appeal

Allows institutions to challenge their rate for fewer than 30 borrowers over three most recent cohorts.

Draft Disclosures Challenge to Repayment Rate

Allows institutions to challenge loan level information on individual borrower records used for the calculation of repayment rate.

Draft Disclosures Challenge to Completion Rate

Allows institutions to challenge completion rate information on individual student records.

Draft Disclosures Challenge to Withdrawal Rate

Allows institutions to challenge withdrawal rate information on individual student records.

Amended Attachment A Rev 1 Page 16 of 20

Exhibit B: Current eCDR Appeal System General Information

I. Roles and Responsibilities

Within the current workflow process, below is list of user roles and primary responsibilities:

Institution Case Preparer – responsible for preparation of the data challenge case, including gathering of student loan level information and supporting documents for each data challenge.

Institution Case Manager – same duties as Institution Case Preparer with additional responsibility for certification and submission of the data challenge case for the Institution.

Data Provider (DP) Response Preparer - responsible for review of data challenge/corrections to determine validity of the request. Also responds to data challenge/correction inquiries and provides DP’s opinion.

DP Manager – same duties as Data Provider Response Preparer with additional responsibility to submit the case formally for review by Case

Response Preparer.

Case Response Preparer/Manager – responsible for review of institution’s data challenge requests and preparing final recommended decision on the case. Also, provides responses to inquiries or requests for additional information from both the Institution and Data Providers. It is expected that this role will be handled by the vendor providing the data challenge solution.

Federal Student Aid (FSA) Case Reviewer/Manager – responsible for review of all case information, including responses/information provided by the

Case Response Preparer, Data Provider and Institution. Resolves the case and issues the final decision on the case outcome.

II. Process Steps

(a) Institution Submission of Data Challenge Case

The institution accesses the data challenge system for the purpose of creating a case.

To initiate the case, the institution must first request the back-up data file

(loan level data) that supports the data for the challenge. This back-up data file is maintained by the calculation system (NSLDS).

Once the back-up data is available, the institution can begin to enter the data challenge information for each institution’s borrower loan level data being

Amended Attachment A Rev 1 Page 17 of 20 challenged. The type of information being entered into the challenge system will differ depending on the type of data challenge.

Using the challenge system, the following elements are examples of the type of data that may be entered by the institution:

Institution Code (OPEID)

GE Program Code/CIP Code

Credential Level

Student Identifier Information (SSN)

Loan Type

Loan Date

Loan Period Begin Date

Loan Period End Date

Enrollment Data

Loan Status

Type of Data Challenge

Reason for Data Challenge

Correct Data for Data Fields Being Challenged

The institution inputs the data challenge information for the case and certifies and submits the information to the Case Response Preparers. The challenge system tracks the timeliness of the case submission and determines if the case was submitted before the challenge deadline expired.

(b) Case Preparation, Review and Decision Workflow

Case Response Preparers and FSA are alerted that a new case has been submitted, which is then reviewed for completeness. Requests for additional information, clarification, or supporting documentation may be sent between the Case Response Preparers, Data Providers, Institutions and FSA.

Case Response Preparers review the case to determine merit of the data challenge by ensuring appropriate supporting data and information have been received from the Institution and/or the Data Providers.

Case Response Preparers may request additional information, clarification or supporting documentation from the Institution and/or the Data Providers.

Once these requests for information/documentation are sent to the

Institution or Data Providers, the challenge system notifies the appropriate party of an open work item that requires follow up and response.

Inquiries, information and responses are sent back and forth between the

Institution, Data Providers, and Case Response Preparers using the workflow tools in the challenge system.

Amended Attachment A Rev 1 Page 18 of 20

Once all data and information is collected, the Case Response Preparers input their final determination into the challenge system for each loan in the data challenge. Case Response Preparers submit case to FSA Case Managers for final decision.

(c) FSA Review and Decision

FSA Case Managers are notified by the system of receipt of completed case for review.

FSA Case Managers review the case, including loan level information, case history and supporting documentation. FSA Case Managers determine if they agree or disagree with the final determination submitted by the Case

Response Preparers.

If open questions remain, FSA Case Managers submit questions and requests for clarification back to the Case Response Preparers for resolution.

If FSA Case Managers agree with the final determination, FSA Case Managers finalize the case, send notifications to the Institution and Data Providers, and close the case.

Final detailed case outcomes are captured by the data challenge system as a data file to be sent to the calculation system (NSLDS) once all data challenges for the cycle have been completed.

III. Statistics

Based on the current system statistics, there are over 3,700 active users in more than 6,000 institutions that participate in the Title IV programs and have the potential to receive metrics that may have associated loan-level challenges submitted in a case.

Each institution may have no more than 2 staff members who will work these cases, in addition to approximately 100 data managers and 25 FSA staff personnel.

The estimated resolution timeframes for loan-level challenges per institution case are as follows3:

Low Complexity: half an hour to 1 hour (60% of all cases initiated) Medium Complexity: from one hour to 3 hours (30% of all cases initiated) High Complexity: from 3 hours to 20 hours (10% of all cases initiated)

3 These are only estimated resolution timeframes. Actuals to completing cases are dependent upon the complexity of the allegation type, number of underlying loans and borrower/students, and number of loan level allegations within each case.

Amended Attachment A Rev 1 Page 19 of 20

Exhibit C: Examples of Allegations and Required Analysis

Challenge/ Appeal Type

Allegation Impact Analysis Required

Pre-Draft Debt-to-Earnings Challenge

Student Died Student/borrower to be removed from Completer List.

Review allegation and documentation to determine if evidence supports student died and student/borrower should be removed.

Pre-Draft Debt-to-Earnings Challenge

Identifier Conflict

Student/borrower to be included on Completer List.

Review identifier conflict information to determine what issues the School had in reporting borrower to NSLDS and student/borrower should be included.

Draft Debt-to- Earnings Challenge

Incorrect Median Loan Debt

Incorrect student/ borrower loan balances identified in GE underlying data.

Review information and documentation to verify if loan balance(s) used in calculation was incorrect. Determine corrected loan balance to be included.

Draft CDR and pCDR – Incorrect Data Challenge

In-School Deferment

Student/borrower received an in-school deferment and did not default during the cohort default period.

Review information and documentation to determine if evidence of timely reporting of in-school deferment was supplied by the School. Review Data Manager recommendation and determine if appropriate.

Draft CDR and pCDR – Incorrect Data Challenge

Wrong Social Security Number

Student/borrower has been included more than once in the CDR rate calculation because of two different social security numbers.

Review information and documentation provided by School and Data Manager to support the correct social security number. Research to determine where the student/borrower’s loan(s) have been incorrectly included or excluded from the calculation. May require identification of duplicate loan entries.

Amended Attachment A Rev 1 Page 20 of 20

Challenge/ Appeal Type

Allegation Impact Analysis Required

Draft CDR and pCDR – Incorrect Data Challenge

Student/borro wer has multiple loans in one cohort default rate calculation that belong to several cohort default rate calculations

Student/borrower had one or more breaks in enrollment and used the entire grace period before obtaining more loans.

Review for completeness of documentation provided by the School and Data Manager for the change to the date entered repayment. Based on the revised date, determine accuracy of the removal of one or more loans from the same cohort fiscal year and the addition of those loans to the correct cohort year.