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FY 1997 Official Cohort Default Rate Guide Page 20

Economically

Disadvantaged andCompletion RateAppeal

What is an economically disadvantaged rate?

An economically disadvantaged rate is the percentage of thestudents enrolled in a schools Title IV eligible programs who areeligible to receive at least half the maximum Federal Pell Grantaward or who have an adjusted gross income below the povertylevel.1

Please refer to page 205 for a more in depth discussion of how tocalculate an economically disadvantaged rate.

What is a completion rate?

A completion rate is the percentage of a school's regular studentsthat completed their program of study, as defined in the HigherEducation Act of 1965, as amended (HEA) 435(a)(4)(A)(ii).

Please refer to page 209 for a more in depth discussion of how tocalculate a completion rate.

1 HEA 435(a)(4)(A)(i)

QUALIFYING


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Economically Disadvantaged and Completion Rate Appeal Information for Schools on Appeals

Page 202 FY 1997 Official Cohort Default Rate Guide

Which schools are eligible to submit aneconomically disadvantaged and completionrate appeal?

To file an exceptional mitigating circumstances appeal based oneconomically disadvantaged and completion rates, a schoolmust2:

be subject to sanctions;

be a degree-granting school;

demonstrate that at least 66 percent of its studentscame from economically disadvantaged

backgrounds as defined in HEA 435(a)(4)(A)(i);

AND

demonstrate that at least 70.0 percent of its regularstudents completed their programs of study as

defined in HEA 435(a)(4)(A)(ii).

The checklist on the next page summarizes the eligibility criteria foran economically disadvantaged and completion rate appeal.

2 HEA 435(a)(4)(A)

QQ . What if theschoolis not sure whether it isclassified as a degree-granting or non-degree-granting school?

A .A . A school shouldrefer to its Eligibility andCertification ApprovalReport generated bythe Departments CaseManagement Division.

If additional assistanceis needed in makingthis determination,please contact theCase ManagementDivision at 202-205-

0183.

23

QQ . What is aregular student?

A .A . A regularstudent is defined asa person who isenrolled, or acceptedfor enrollment, at aninstitution for thepurpose of obtaining adegree, certificate, orother recognizededucational credentialoffered by thatinstitution as defined

in 34 CFR 600.2.


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Information for Schools on Appeals Economically Disadvantaged and Completion Rate Appea


EconomicallyDisadvantaged and

Completion Rate AppealEligibility Checklist

To be eligible to submit an economically disadvantagedand completion rate appeal, a school must meet ALL ofthe following criteria:

oThe school is subject to one or more of thefollowing sanctions:

m initial loss of eligibility to participate in theFFEL Program and/or Direct Loan Programand Federal Pell Grant Program;

m extended loss of eligibility to participate in theFFEL Program and/or Direct Loan Programand Federal Pell Grant Program;

AND/OR

m possible action to limit, suspend, and/orterminate (LS&T) participation in one or moreTitle IV Student Financial AssistancePrograms.

oThe school is a degree granting school that:m enrolls at least 66 2 3 percent of its students

from economically disadvantagedbackgrounds as defined in HEA 435(a)(4)(A)(i);

AND

m can demonstrate that at least 70.0 percent ofits students completed their programs asdefined in HEA 435(a)(4)(A)(ii).


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An economically disadvantaged andcompletion rate must be based on whichcohort period?

A school must base its economically disadvantaged and completionrate on its most recent cohort period (in this case FY 1997).3 The12-month period on which the schools appeal is based must endwithin the six months preceding FY 1997.

Please refer to page 146 for more information on selecting an

acceptable 12-month period.

How can an economically disadvantaged andcompletion rate appeal affect a schools lossof eligibility to participate in Title IV StudentFinancial Assistance Programs?

If a degree granting school submits a successful economicallydisadvantaged and completion rate appeal, the Department willwithdraw its notification of loss or extension of loss of the schoolseligibility to participate in the FFEL Program and/or Direct LoanProgram and Federal Pell Grant Program.4 In addition, theDepartment will NOT initiate an action to limit, suspend, orterminate the school's participation in any or all of the Title IVStudent Financial Assistance Programs due to the school's official

cohort default rate.

5

A successful exceptional mitigating circumstancesappeal does NOT change a schools official cohortdefault rate. Therefore, if a school submits asuccessful economically disadvantaged andcompletion rate appeal, the Department will onlywithdraw its notification that the school is subject toloss for one year. If the schools subsequent cohortdefault rate is once again equal to or greater than25.0 percent, the school will be notified that it is once

again subject to loss of FFEL Program and/or DirectLoan Program and Federal Pell Grant Programeligibility. The school may then choose to submitanother economically disadvantaged and completionrate appeal based on the most recent cohort period.

3 HEA 435(a)(4)(A)4 34 CFR 668.17(c)(5)5 34 CFR 668.17(a)(5)


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X

A school must select a 12-month period thatends during the six months immediatelypreceding FY 1997. Information on how toselect an acceptable 12-month period is

provided on page 146 in the "ExceptionalMitigating Circumstances Appeal" section.

How is the economically disadvantaged ratecalculated?

The economically disadvantaged rate6

is calculated as follows:

As a part of a successful exceptional mitigating circumstancesappeal, a school must have an economically disadvantaged rate ofat least 66 percent.

6 HEA 435(a)(4)(A)(i)

100

number of regular students enrolled on at least ahalf-time basis in a Title IV eligible program duringthe selected 12-month period who were eligible toreceive at least one-half the maximum Federal PellGrant award or who had an adjusted gross incomeless than the U.S. Department of Health and HumanServices poverty level during an award year/calendar year that overlaps the selected 12-month

period

number of regular students enrolled on at least ahalf-time basis in a Title IV eligible program during aselected 12-month period

23


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X =

Example: College University had a total of 250 students enrolled

on at least a half-time basis in a Title IV eligibleprogram during an acceptable 12-month period. Ofthose 250 students, 80 students received at leastone-half the maximum Federal Pell Grant award and

100 different students had an adjusted gross incomeless than the U.S. Department of Health and HumanServices poverty level during an award year/calendaryear that overlaps the selected 12-month period by atleast one day. College Universitys economicallydisadvantaged rate is calculated as follows:

Which students are included in the denominatorof the economically disadvantaged ratecalculation?

To be included in the denominator of the economicallydisadvantaged rate, a student must have been

enrolled in a Title IV eligible program;AND

enrolled on at least a half-time basis for one or moredays during the selected 12-month period.7

A students entire enrollment period does not have tofall within the selected 12-month period. A studentwho enrolled prior to the 12-month period butcompleted/withdrew during the 12-month period is

considered to have been enrolled during the 12-

month period. In addition, a student who enrolledduring the 12-month period but completed/withdrewafter the 12-month period is considered to have beenenrolled during the 12-month period. Finally, a studentthat enrolled prior to the 12-month period andcontinued to be enrolled until after the 12-month

period is considered to have been enrolled during the12-month period.

7 HEA 435(a)(4)(A)(i)

100

80 (Pell) + 100 (AGI) = 180

250

72.0%


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Which students are included in the numeratorof the economically disadvantaged rate?

To be included in the numerator of the economically disadvantagedrate, the student must first be included in the denominator of the

rate. If a student is included in the denominator of the economicallydisadvantaged rate and meets either of the following conditions, thestudent will be included in the numerator of the economicallydisadvantaged rate:

the student has an expected family contribution (EFC)of 1200 or less for an award year that overlaps the12-month period selected by the school;8

A student with an EFC of 1200 or less is consideredto be eligible to receive at least one-half of themaximum Federal Pell Grant award.

OR

the student has an adjusted gross income and familysize that is below the U.S. Department of Health andHuman Services poverty level for a calendar year thatoverlaps with the 12-month period selected by theschool.9

Please refer to page 225 for the poverty levelguidelines established by the U.S. Department ofHealth and Human Services.

In order for a student to be included in the numeratorof the economically disadvantaged rate, the studentsapplicable expected family contribution or adjustedgross income must be associated with anaward/calendar year that overlaps the 12-monthperiod chosen by the school.

8 HEA 435(a)(4)(A)(i)(I)9 HEA 435(a)(4)(A)(i)(II)


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How does a school determine if an award yearoverlaps the selected 12-month period?

An award year begins on July 1 of one year and ends on June 30 ofthe next year. An award year overlaps a 12-month period if anyportion of the award year overlaps any portion of the 12-monthperiod.

Example: Forrest University selected May 1, 1995, through April30, 1996, as its 12-month period. The 1994/95 and1995/96 award years overlap the selected 12-monthperiod. Therefore, Forrest University can useestimated family contributions associated with bothaward years to determine if students are economicallydisadvantaged.

How does a school determine if a calendaryear overlaps the selected 12-month period?

A calendar year overlaps a 12-month period if any portion of thecalendar year overlaps any portion of the 12-month period.

Example: Lane University selected June 1, 1995, through May31, 1996, as its 12-month period. The 1995 and 1996calendar years overlap the selected 12-month period.Therefore, Lane University can use adjusted grossincomes associated with both calendar years todetermine if students are economically

disadvantaged.

7/1/94

94/95 Award Year 95/96 Award Year

7/1/956/30/95 6/30/965/1/95 4/30/96

12-month period

1/1/95 1/1/9612/31/95 12/31/966/1/95 5/31/96

1995 Calendar Year 1996 Calendar Year

12-month period


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A school must select a 12-month period thatends during the six months immediatelyproceeding FY 1997. Information on how toselect an acceptable 12-month period isprovided on page 146 in the "ExceptionalMitigating Circumstances Appeal" section.

How is the completion rate calculated?

The completion rate10 is calculated as follows:

As part of a successful economically disadvantaged and completionrate appeal, a school must have a completion rate of at least 70.0percent.

10 HEA 435(a)(4)(A)(ii)

X100number of regular students who were initially enrolledon a full-time basis in a Title IV eligible program andwere originally scheduled to complete their programsduring the same 12-month period selected for theeconomically disadvantaged rate.

number of regular students, included in thedenominator of the completion rate calculation whoeither:

received degrees; transferred to higher level programs; at the end of the 12-month period, remained

enrolled and making satisfactory academicprogress toward completion of their educationalprograms;

AND/OR entered active duty in the U.S. Armed Forces

within a year of leaving the school.


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X =

Example: College University had a total of 300 regular students

initially enrolled on a full-time basis in a Title IVeligible program that were originally scheduled tocomplete their programs during the 12-month periodused to determine the economically disadvantaged

rate. Of those 300 students, 80 students receiveddegrees, 70 students transferred to higher levelprograms, 45 students were making satisfactoryacademic progress toward completion of theireducational programs at the end of the 12-monthperiod, and 45 students entered active duty in theU.S. Armed Forces within a year of leaving theschool. College University's completion rate iscalculated as follows:

Which students are included in the denominatorof the completion rate calculation?

To be included in the denominator of the completion ratecalculation, a regular student must have been

initially enrolled on a full-time basis;11

enrolled in a Title IV eligible program;

AND

scheduled to complete his/her program of studyduring the same 12-month period used to calculatethe economically disadvantaged rate.

11 HEA 435(a)(4)(A)(ii)

100

80 + 70 + 45 + 45 = 240

300

80.0%

QQ . What is a regularstudent?

A .A . A regular studentis defined as a personwho is enrolled, oraccepted for enrollment,at an institution for thepurpose of obtaining adegree, certificate, orother recognizededucational credentialoffered by that institutionas defined in 34 CFR

600.2.


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Even though the same 12-month period isused to calculate both the economicallydisadvantaged and completion rates, thestudents included in the denominator of eachrate will not be the exact same group of

students. Students who were enrolled duringthe 12-month period and qualify to be includedin the denominator of the economicallydisadvantaged rate may not have beenscheduled to complete their programs duringthe same 12-month period (i.e., thedenominator of the completion rate).

Which students are included in the numeratorof the completion rate?

In order to be included in the numerator of the completion rate, theregular student must first be included in the denominator of therate. If the student is in the denominator of the completion rate andmeets any of the following criteria, the student is included in thenumerator of the completion rate:

the regular student received a degree;

Example: A regular student who received adegree on September 9, 1997, qualifies

to be included in the numerator of thecompletion rate if the student wasincluded in the denominator of thecompletion rate.

the regular student transferred to a higher levelprogram;

Example: A regular student that transferred to ahigher level program on April 15, 1996qualifies to be included in the numeratorof the completion rate if the student wasincluded in the denominator of thecompletion rate.

The students graduation and/or transfer datedoes NOT need to fall within the selected 12-month period. Only the students originalscheduled to complete date must fall within theselected 12-month period.


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the regular student remained enrolled and wasmaking satisfactory academic progress at the end ofthe 12-month period used to calculate the completionrate.

Example: A regular student remained enrolled andheld a GPA of 3.8 at the end of the 12-month period.

AND/OR

the regular student entered active duty in the U.S.Armed Forces within one year of leaving the school.

What is an independent auditors attestation?

A school's economically disadvantaged and completion rate appealmust be reviewed and attested to by an independent auditor.

The report of the independent auditor must state whether, in theauditor's opinion, the school's management's written assertionsdemonstrated exceptional mitigating circumstances based on theeconomically disadvantaged and completion rate criteria. Thereport must also indicate if management's written assertions arefairly stated in all material respects. The engagement, which formsthe basis of the independent auditor's opinion, must be anexamination-level compliance attestation engagement performed inaccordance with the American Institute of Certified PublicAccountant's (AICPA) Statement on Standards for AttestationEngagements, Compliance Attestation (AICPA, ProfessionalStandards, Volume 1, AT sec. 500), as amended, and GovernmentAuditing Standards issued by the Comptroller General of the UnitedStates.

How does a school prepare and submit aneconomically disadvantaged and completionrate appeal?

Timing is critical when submitting an economically disadvantagedand completion rate appeal.

TIMING AND SUBMITTING


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Step 1: Within 30 calendar days of receiving official

notification that the school is subject to sanctions,review the schools official cohort default ratenotification letter and this Guide to determine ifthe school is eligible to submit an economically

disadvantaged and completion rate appeal.

Please refer to page 202 for a detailed discussionregarding which schools are eligible to appeal basedon economically disadvantaged and completion rates.

Step 2: If a school is eligible to submit an economicallydisadvantaged and completion rate appeal, withinthe time frame described in Step 1 (i.e., within 30calendar days of receiving notice that the school issubject to sanctions), submit a letter to theDepartment at the address on page 224 that

indicates that the school intends to submit aneconomically disadvantaged and completion rateappeal.

Use the sample Notice of Intent to File AnEconomically Disadvantaged and CompletionRate Appeal cover letter on page 227 or itsequivalent.

Step 3: Prior to 60 calendar days after receiving notice thatthe school is subject to sanctions, a school must

develop a written assertion for submission to theschool's independent auditor that demonstratesthat the school's economically disadvantaged rateis at least 66 percent.

The school's written assertion should be developedusing the sample Economically DisadvantagedRate spreadsheet on page 231 or its equivalent andmust include the following:

the schools name and OPE ID Number;

the 12-month period on which the school isbasing its economically disadvantaged rate;

For information on selecting an acceptable 12-month period, please refer to page 146 in the"Exceptional Mitigating Circumstances Appeal"section.

23

TimeframesmayoverlapRead

ALLsteps.


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the Social Security numbers, in numericalorder, of all the schools students enrolled in aTitle IV eligible program on at least a half-timebasis during any part of the selected 12-monthperiod;

These are the students that will beincluded in the denominator of theeconomically disadvantaged rate.

the students name;

the beginning and ending enrollment dates foreach student [include the month, day and year(MM/DD/CCYY)];

No student should be counted morethan once in the calculation, even if thestudent re-enrolled.

an X next to the student's name if the studentis from an economically disadvantagedbackground as defined on page 207;

These are the students that will beincluded in the numerator of the

economically disadvantaged rate.

if the student is from an economicallydisadvantaged background, either:

v the student's expected familycontribution and applicable award year;

The expected family contributionmust be 1200 or less for anaward year that overlaps the

selected 12-month period in orderfor the student to qualify aseconomically disadvantaged.

OR

QQ . Which awardyears/calendar yearscoincide with a selected12-month period?

A .A . An awardyear/calendar yearcoincides with a 12-month period if the award

year/calendar yearoverlaps the 12-monthperiod by at least oneday.

Please refer to page 208for a more in depthdiscussion on coincidingaward years and

calendar years.


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v the students, and if applicable thestudents parents/spouses adjustedgross income, family size, andapplicable calendar year.

The annual gross income andfamily size must be less than theU.S. Department of Health andHuman Services poverty levelsfor a calendar year that coincideswith the selected 12-monthperiod in order for the student toqualify as economicallydisadvantaged. The U.S.Department of Health and HumanServices' poverty levels areshown on page 225.

Step 4: Within the time frame described in Step 3 (i.e.,prior to 60 calendar days after receiving notice thatthe school is subject to sanctions), a school mustcalculate the school's economicallydisadvantaged rateand include the rate on itswritten assertion.

Count the number of students identified aseconomically disadvantaged on thespreadsheet. These are the students thatwill be included in the numerator of theeconomically disadvantaged rate.

Count the number of students listed on thespreadsheet. These are the students thatwill be included in the denominator of theeconomically disadvantaged rate.

Divide the total number of students fromeconomically disadvantaged backgrounds (i.e.,the numerator) by the total number of students

listed on the spreadsheet (i.e., thedenominator) and multiply the result by 100.This is the school's economicallydisadvantaged rate.

As part of a successful appeal, theschools economically disadvantagedrate must be at least 66 percent.2 3


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Step 5: Within the time frame described in Step 3 (i.e.,

prior to 60 calendar days after receiving notice thatthe school is subject to sanctions), a school mustdevelop a written assertion for submission to theschool's independent auditor that demonstrates

that the school's completion rate is at least 70.0percent.

The school's written assertion should be developedusing the sample Completion Rate spreadsheet onpage 233 or its equivalent and must include thefollowing:

the schools name and OPE ID Number;

an indication that the same 12-month period isbeing used for the schools completion rate aswas used for the schools economicallydisadvantaged rate;

the Social Security numbers, in numericalorder, of all the schools regular students whowere:

v initially enrolled on a full-time basis;

v enrolled in a Title IV eligible program;

AND

v originally scheduled to complete their

program of study during the selected 12-month period.

These are the students that will beincluded in the denominator of thecompletion rate calculation.

Please refer to page 210 for a more in-

depth description of the students thatshould be included in the schoolscompletion rate calculation.

the regular students full name;

QQ . What is a regularstudent?

A .A . A regular studentis defined as a personwho is enrolled, oraccepted for enrollment,in an eligible program at

an institution for thepurpose of obtaining adegree, certificate, orother recognizededucational credentialoffered by that institutionas defined in 34 CFR

600.2.


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the date that each regular student wasoriginally scheduled at the time ofenrollment to complete his or her program ofstudy;

The original scheduled to complete datefor a full-time student will be based onthe amount of time normally required bya full-time student to complete theprogram, as specified in the school'senrollment contract, catalog, or othermaterials.

the beginning and ending enrollment dates foreach regular student;

an X next to the regular student's name if thestudent meets the following conditions:

These are the students that will beincluded in the numerator of thecompletion rate.

A regular student is considered to havesuccessfully completed the program if:

v the regular student received a degree at

the school;

v the regular student transferred from theschool to a higher level educationalprogram;

v the regular student remained enrolled atthe school at the end of the selected 12-month period and was makingsatisfactory academic progress towardcompletion of his or her educational

program;

OR


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v the regular student entered active dutyin the U.S. Armed Forces within a yearof leaving the school.

Please refer to page 211 of this sectionfor a more detailed discussion of whichstudents are considered successfullycompleted.

for each regular student successfullycompleting the program because the studentreceived a degree from the school, the date adegree was received;

for each regular student successfullycompleting the program because the studenttransferred to a higher level educationalprogram,

v the student's program of study at the

school the student transferred from (doNOT use abbreviations);

v the date the student transferred;

v the name and address of the schoolto which the student transferred;

AND

v the name of the higher leveleducational program to which thestudent transferred. Do NOT use

abbreviations;

for each regular student that successfullycompleted the program because the studentremained enrolled and was making satisfactoryacademic progress at the end of the selected12-month period, the student's GPA;

AND


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for each regular student that successfullycompleted the program because the studententered active duty in the U.S. Armed Forceswithin a year of leaving school, the date thestudent entered the U.S. Armed Forces.

Step 6: Within the time frame described in Step 3 (i.e.,prior to 60 calendar days after receiving notice thatthe school is subject to sanctions), a school mustcalculate the school's completion rate and includethe rate on its written assertion.

Count the number of regular students thatreceived a degree, transferred to a higher levelprogram, maintained satisfactory academicprogress, or entered active duty in the U.S.Armed Forces within a year of leaving school.These are the students who will be includedin the numerator of the completion rate.

Count the number of regular students listed onthe spreadsheet. These are the studentswho will be included in the denominator ofthe completion rate.

Divide the total number of regular studentssuccessfully completed (i.e., the numerator) by

the total number of regular students listed onthe spreadsheet (i.e., the denominator). Thisis the school's completion rate.

As part of a successful appeal, the schoolscompletion rate must be at least 70.0 percent.

Step 7: Within the time frame described in Step 3 (i.e.,

prior to 60 calendar days after receiving notice thatthe school is subject to sanctions), a school mustsubmit the school's Economically DisadvantagedRate and Completion Rate written assertions tothe school's independent CPA for review.

The independent CPA should perform a reviewand provide a report that states whether, in theauditor's opinion, the school's management'swritten assertions demonstrated exceptionalmitigating circumstances based on theeconomically disadvantaged and completionrate criteria.


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The auditors opinions must indicate ifmanagement's written assertions are fairlystated in all material respects.

The engagement which forms the basis of theindependent auditor's opinion must be anexamination-level compliance attestationengagement performed in accordance with theAmerican Institute of Certified PublicAccountant's (AICPA) Statement on Standardsfor Attestation Engagements, ComplianceAttestation (AICPA, Professional Standards,Volume 1, AT sec. 500), as amended, andGovernment Auditing Standards issued by theComptroller General of the United States.

The attestation must be in the form of a letterwith

v the school's name;

v the school's OPE ID number;

v the fiscal year to which the appealapplies;

v the auditor's opinions on management'sassertions;

AND

v the independent auditor's signature,followed by a signature block providingthe signer's name and title.

An independent auditor should use the sampleIndependent Auditors Attestation letteron

page 235.

Step 8: Within 60 calendar days of receiving notice that the

school is subject to sanctions, a school must submitthe following to the Department at the address on

page 224:

a cover letter using the sample EconomicallyDisadvantaged and Completion RateAppeal cover on page 229;

Due date forsubmittingthe appeal tothe

Department.


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a copy of the school's written assertionswhich includes:

v a list of students who are included in theeconomically disadvantaged rate using

the sample EconomicallyDisadvantaged Rate spreadsheetcreated in Step 3;

AND

v a list of regular students who areincluded in the completion rate using thesample Completion Rate spreadsheetcreated in Step 5.

AND

the auditor's opinions on management'sassertions.

The Department recommends that the school submit its properlycompleted economically disadvantaged and completion rate appealin a single, tabbed binder, and mail it return receipt requested or viacommercial overnight delivery. The recommended tabs andmaterials are shown on the next page.


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The following material should be sent to the Department's DefaultManagement Division at the address shown on page 223.

The section behind Tab 1 contains:

A letter on the schools letterhead with

the schools OPE ID number; a statement indicating that the school is submitting an

exceptional mitigating circumstances appeal based upon itseconomically disadvantaged and completion rates;

the current fiscal year to which the appeal applies; a certification sentence that indicates that the information

provided in the appeal, under penalty of perjury, is true andcorrect;

AND

the signature of the schools President/ CEO/Owner, followedby a signature block providing the signers name and job title

Schools should refer to the sample Economically Disadvantaged andCompletion Rate Appeal cover letter on page 229.


The school's written assertion on its economically disadvantagedrate.

Schools should use the sample Economically Disadvantaged Ratespreadsheet on page 231 and detailed instructions on how to createthe spreadsheet on page 230 to develop the written assertion.


The school's written assertion on its completion rate.

Schools should use the sample Completion Rate spreadsheet on page233 and detailed instructions on how to create the spreadsheet on page232 to develop the written assertion.


The auditor's opinions on the school's management's writtenassertions.

Please refer to the sample Independent Auditors Attestation letter onpage 235.

The Department will not consider informationsubmitted after the 60 calendar day deadline. TheDepartment will send the school written notification ofits decision. The Departments decision is finaland no further administrative review is provided.

Tab 1

Tab 2

Tab 3

Tab 4


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U. S. Department of Health and HumanServices Poverty Levels

Based on Family Size

State YearFamily Size

One person Each additional personAlaska 1993 $8,700 +$3,080

1994 $9,200 +$3,1001995 $9,340 +$3,2001996 $9,660 +$3,280

Hawaii 1993 $8,040 +$2,8201994 $8,470 +$2,8501995 $8,610 +$2,9401996 $8,910 +$3,010

All OtherStates

1993 $6,970 +$2,460

1994 $7,360 +$2,4801995 $7,470 +$2,5601996 $7,740 +$2,620


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Sample Notice of Intent to File An Economically Disadvantaged and CompletionRate Appeal Cover Letter

October 20, 1999

U.S. Department of Education OPE ID#: 222111

Default Management DivisionAttn: Economically Disadvantaged and Completion Rate IntentROB-3, Room 3905600 Independence Avenue, S.W.Washington, D.C. 20202-5353

Dear Default Management Division:

College University, OPE ID# 222111, intends to file an FY 1997

exceptional mitigating circumstances appeal based on oureconomically disadvantaged and completion rates.

Sincerely,

R obert Y oungR ober t Y oungRobert Young, President

Enclosures

College University1212 Wedgewood LaneLeonardtown, Wisconsin 12345-6789(123) 456-7890

Sample Letter

Subject: FY 1997 Notice of Intent to File An EconomicallyDisadvantaged and Completion Rate Appeal


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Sample Economically Disadvantaged and Completion Rate Appeal Cover Letter

November 19, 1999

U.S. Department of Education OPE ID#: 222111Default Management Division

Attn: Economically Disadvantaged and Completion Rate AppealROB-3, Room 3905600 Independence Avenue, S.W.Washington, D.C. 20202-5353


College University, OPE ID# 222111, is submitting its FY 1997

exceptional mitigating circumstances appeal based on oureconomically disadvantaged and completion rates.

I, the undersigned, certify under penalty of perjury, that oureconomically disadvantaged rate is 72.0%, our completion rate is80.0%, and that all other information submitted in support of thisexceptional mitigating circumstances appeal is true and correct.

Please see the attached written assertions for the economicallydisadvantaged and completion rates, along with the independentauditor's attestations on our school's management's assertions.

Sincerely,

R obert Y oungR ober t Y oungRobert Young, President

Enclosures

College University1212 Wedgewood LaneLeonardtown, Wisconsin 12345-6789

(123) 456-7890

Sample Letter

Subject: FY 1997 Economically Disadvantaged andCompletion Rate Appeal


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Sample Economically Disadvantaged Rate Spreadsheet

6

c.Ifcolumn

6a

hasanAGI,

en

tercalendar

year

1995

6b.Ifcolumn

6ahasanAGI,

enterfamily

size

1

6a.Ifcolumn4

ismarkedand

economically

disadvantaged

isbasedon

AGI,enter

AGI

$4,2

00.0

0

5b.Ifcolumn

5ahasanEFC,

enterEFC's

awardyear

1995/1996

5a.Ifcolumn4

ismarked

and

economically

disadvantaged

isbasedonEFC,

enterEFC

$1,0

00.0

0

4.Ifstuden

t

qualifiesa

s

economically

disadvantag

ed

enterX

X X

3.Student's

enrollmentdates

(fromMM/DD/CCYY

toMM/DD/CCYY)

3/15/1995-3/10/1996

6/16/1995-10/3/1995

12/15/1995-3/4/1996

2.Student

's

name

JaneSmith

JohnDoe

ChrisJone

s

1.Student's

SSN

(sortinnumerical

order)

111-11-1111

222-22-2222

333-33-3333

11/01/1999

[sendtoU.S.

Dep

artmentofEducation'sDefault

Pag

e1of10pages

ManagementDivisionattheaddresslocatedonpage224.]

BoxB

#ofEconomicallyDisadvan

tagedStudents(fromColumn4)[B1]

180

#ofStudents(fromColumn

1)[B2]

250

EconomicallyDisadvantagedRate[100xB1/B2]

72.0

%

FY1997

EconomicallyDisadvantaged

Rate

SchoolName:CollegeUniversity

OPEIDNumber:222111

12-monthPeriod:10/1/1995-9

/30/1996

AwardYears:1995/1996and

1996/1997

CalendarYears:1995and1996

Note:Thisisas

ample

spreadsheet.(S

eeinstructions).


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Sample Completion Rate Spreadsheet

9.The

datethe

student

enteredthe

U.S.Armed

Forces

(MM/DD/CCYY)

10/30/1995

8.The

student's

grade

point

average

3.8

7d.Thename

andaddress

oftheschool

towhichthe

student

transferred

Psychology

7c.Thename

andaddress

oftheschool

towhichthe

student

transferred

MindSchool

Erie,

ME55555

7b.Date

thestudent

transferred

toahigher

levelprogram

(MM/DD/CCYY)

03/10/1995

7a.Student's

programo

f

study

Sociology

6.Date

thestudent's

degreewas

received

(MM/DD/CCYY)

01/10/1996

5.Ifstudent

metthe

successful

completion

conditions,

enterX

X X X

4.Student's

enrollment

dates

(fromMM/DD/CCYY

toMM/DD/CCYY)

1/15/1995-

01/10/1996

05/16/1995

07/15/1995

4/10/1994-

present

6/26/1992-

03/10/1995

10/01/1993

10/05/1995

3.Datethat

studentwas

originally

scheduledto

complete

program

ofstudy

(MM/DD/CCYY)

02/20/1996

03/26/1996

12/06/1995

05/27/1996

10/02/1995

2.Student's

Name

JudyJones

JamesSmith

HelenCarr

TonyPaine

JimBrown

1.Student's

SSN

(sortin

numerical

order)

111-11-1111

222-22-2222

333-33-3333

444-44-4444

555-55-5555

BoxD

#ofRegularStudentsWhoMetSuccessfulCompletionConditions(fromColumn5

)[D1]

240

#ofRegularStudentsOriginallySchedu

ledtoCompletePrograms(fromColumn1)[D2]

300

CompletionRate[100xD1/D2]

80.0

%

11/01/1999

[sendtoU.S.

Department

ofEducation'sDefault

Page1of11

pages

ManagementDivisionattheadd

resslocatedonpage224.]

FY1997

CompletionRate

SchoolName:CollegeUnive

rsity

OPEIDNumber:222111

12-monthPeriod:10/1/1995-9/30/1996

Note:Thisisa

sample

spreadsheet.(

Seeinstructions).


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Sample Independent Auditors Attestation Letter

November 18, 1999

U.S. Department of EducationDefault Management Division OPE ID#: 222111Attn: Economically Disadvantaged and Completion Rate AppealROB-3, Room 3905600 Independence Avenue, S.W.Washington, D.C. 20202-5353


We have examined managements assertions that the information contained in CollegeUniversitys OPE ID# 222111 exceptional mitigating circumstances appeal based on itseconomically disadvantaged and completion rates, is complete, accurate and determinedin accordance with the requirements of HEA 435(a)(4)(A). Management is responsiblefor College Universitys compliance with those requirements. Our responsibility is toexpress an opinion on managements assertions about the institutions compliance basedon our examination.

Our examination was made in accordance with standards established by the American

Institute of Certified Public Accountants and, accordingly, included examining, on a testbasis, evidence about College Universitys compliance with HEA 435(a)(4)(A) andperforming such other procedures as we considered necessary in the circumstances. Webelieve our examination provides a reasonable basis for our opinion. Our examinationdoes not provide a legal determination on College Universitys compliance with specifiedrequirements.

In our opinion, managements assertion that the information contained in CollegeUniversitys assertions, which reports that College University has an economicallydisadvantaged rate of 72.0% and a completion rate of 80.0% for the twelve-month periodbeginning on October 1, 1995 and ending on September 30, 1996, with the award years1995/1996 and 1996/1997 and the calendar years 1995 and 1996 is complete, accurate,and determined in accordance with the requirements set forth in HEA 435(a)(4)(A), isfairly stated, in all material respects.

This report is intended solely for the information of an audit committee, management, andthe U.S. Department of Education. However, this report is a matter of public record and itsdistribution is not limited.

Respectfully submitted,

M a ry S mi th

Mary Smith, CPAPresident, Global Accounting, Inc.

Global Accounting

1212 Hickory LaneHughesville, Florida 12345-6789(123) 456-7890

Sample Letter

Subject: Independent Auditors Attestation


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