Request for Adjustment - Federal Student Aid - IFAP: Home · PDF filea change to the data but ... submitting a request for adjustment? Timing is critical for a school when submitting

FY 1997 Official Cohort Default Rate Guide Page 65

Request forAdjustment

What is a request for adjustment?

A request for adjustment is a challenge submitted to the U. S.Department of Education (Department) that ensures a school’sofficial cohort default rate calculation reflects changes that werecorrectly agreed to as a result of a school's draft data challenge.

Which schools are eligible to submit a requestfor adjustment?

All postsecondary schools (schools) regardless of their cohortdefault rate may request that the Department adjust its FY 1997official cohort default rate. Schools do NOT have to be subject toany sanctions as a result of their cohort default rates.

Why should a school submit a request foradjustment?

A school should request an adjustment if:

(1) it submitted a timely challenge of its draft cohortdefault rate data after the release of the draft cohortdefault rates;

AND

(2) the entity reviewing the draft data challenge correctlyagreed to make changes to the cohort default ratedata;

BUT

QUALIFYING

Q.Q. What is a draft datachallenge?

A.A. A draft datachallenge is the processused by a school to correctcohort default rate databefore the official cohortdefault rates arecalculated.

Please refer to theDepartment's FY 1997Draft Cohort Default RateGuide for additionalinformation on draft datachallenges.

Request for Adjustment Information for Schools on Appeals

Page 66 FY 1997 Official Cohort Default Rate Guide

(3) the changes are not reflected in the school’s officialloan record detail report.

Can a school submit a request for adjustmentfor previous years?

No. A school can only request an adjustment for the most recentofficial cohort default rate data (in this case FY 1997). This alsoapplies to those schools that have average cohort default rates.

Is a request for adjustment a type of erroneousdata appeal?

No, a request for adjustment is not a type of erroneous dataappeal. Requests for adjustment concern changes to data errorsthat were correctly agreed to during the draft data challenge, butwere not made. Erroneous data appeals concern disputed datathat was not resolved prior to the release of the official cohortdefault rates and/or incorrect new data that appeared after therelease of the official cohort default rates.

A school may be eligible to submit both a request foradjustment and an erroneous data appeal. If a schoolis submitting both, the two have different deadlinesand standards, and they MUST be submittedseparately.

Please refer to the “Erroneous Data Appeal” section beginning onpage 77 for more information on erroneous data appeals.

What role does a guaranty agency have in arequest for adjustment?

A guaranty agency is not directly involved in a school’s request foradjustment. After the release of the official cohort default rates, aschool’s request for adjustment is submitted directly to theDepartment’s Default Management Division. The Departmentadjusts the school’s rate based on information correctly provided tothe school during the draft data challenge process. The adjustmentis NOT based on information received from a guaranty agency afterthe release of the official cohort default rates.

Q.Q. Can a schoolsubmit a request foradjustment becauseincorrect new dataappeared in the officialloan record detail report?

A.A. No, a school canonly submit a request foradjustment if the entityreviewing the school’sdraft data challengecorrectly agreed to makea change to the data butthe change was notreflected in the officialloan record detail report.

Q.Q. What is anaverage cohort defaultrate?

A.A. An average cohortdefault rate is a type ofcohort default ratecalculation used when aschool has 29 or fewerborrowers enteringrepayment during a fiscalyear.

Information for Schools on Appeals Request for Adjustment


How can a request for adjustment affect aschool’s cohort default rate?

If, as a result of a request for adjustment, the Departmentdetermines that a school’s cohort default rate is incorrect, theDepartment will recalculate the rate using corrected data. This maylower, raise, or not affect any of a school’s three most recentofficial cohort default rates.

Please refer to page 24 of the “Cohort Default Rates” section forinformation on adding and subtracting loans from the cohort defaultrate calculation.

Even though the Department may alter a school’scohort default rate calculation, subsequent copies ofthe school’s loan record detail report will not reflectthe change. Therefore, it is important to keep a copyof the Department’s final determination letter as theofficial record of the school’s cohort default rate.

What are the time frames and procedures forsubmitting a request for adjustment?

Timing is critical for a school when submitting a request foradjustment.

Step 1: Within 10 working days of receiving its official cohortdefault rate notification letter, if the school did notreceive the loan record detail report with itsnotification letter, it must submit a request for the loanrecord detail report to the Department using the“Request for Loan Record Detail Report” form onpage 53.

All schools with an FY 1997 official cohort default rateof 10.0 percent or greater will receive an FY 1997official loan record detail report with their FY 1997official cohort default rate notification letter.

TIMING AND SUBMITTING

Timeframesmayoverlap.ReadALLsteps.



Step 2: Within 30 calendar days of receipt of the official loanrecord detail report, a school must:

♦♦ compare the response(s) it received to its draftdata challenge with its official loan record detailreport;

AND

♦♦ ensure the changes correctly agreed to duringthe draft data challenge were made.

Example 1: School of Business compared theMay 5, 1999 response it receivedfrom the Direct Loan servicer withits official FY 1997 loan recorddetail report. School of Businessdiscovered that Roger Jones’non-defaulted unsubsidizedStafford loan was correctly addedto the school’s FY 1997 cohortdefault rate calculation as wasindicated in the Direct Loanservicer’s May 5, 1999 letter.

School of Business did NOTinclude Roger Jones’ loan on itsFY 1997 Request for Adjustmentspreadsheet because the loanwas correctly added to theschool’s FY 1997 cohort defaultrate.

Step 3: Within the time frame described in Step 2 (i.e.,within 30 calendar days of receipt of the official loanrecord detail report), a school must compile a list ofloans that should have been adjusted prior to therelease of the official cohort default rates but werenot.

A school should use the sample Request forAdjustment spreadsheet on page 75 to list thechanges that were correctly agreed to during the draftdata challenge BUT were NOT made.



Example 2: School of Business compared theApril 23, 1999 response itreceived from ABC guarantyagency with its official FY 1997loan record detail report. Schoolof Business discovered that eventhough the April 23, 1999 letterfrom ABC guaranty agencyagreed to remove Chris Smith’sdefaulted FFEL Stafford loanfrom the FY 1997 cohort defaultrate, Chris’ defaulted FFELStafford loan was still included inthe school’s FY 1997 cohortdefault rate calculation.

School of Business includedChris Smith’s defaulted FFELStafford loan on its FY 1997request for adjustmentspreadsheet because the agreedupon change was not made.

Step 4. Within the time frame described in Step 2 (i.e., with30 calendar days of receipt of the school’s official loanrecord detail report), submit the following to theDepartment using the address on page 71:

♦♦ a letter requesting an adjustment;

A school should use the sample Request forAdjustment cover letter on page 73;

♦♦ the Request for Adjustment spreadsheet asdescribed in Step 3;

AND

♦♦ copies of the relevant responses received as aresult of the school's draft data challenge thatidentify the changes that were correctly agreedto but not made.

The recommended tabs and materials for a requestfor adjustment are shown on the next page.

Q.Q. May a schoolsubmit its request foradjustment with itserroneous data appealand/or improper loanservicing and collectionappeal?

A.A. No. A school’srequest for adjustmentmust be submittedseparately and within30 calendar days ofreceiving its official loanrecord detail report.

Due date forsubmittingthe appeal totheDepartment.



The following material should be sent to the Department's DefaultManagement Division at the address shown on page 71.

The section behind Tab 1 contains:a letter on the school’s letterhead with—

♦ the school’s OPE ID number;

♦ a statement indicating that the school is submittinga request for adjustment;

♦ the fiscal year to which the adjustment applies;

♦ the signature of the school’s President/CEO/Owner, followed by a signature blockproviding the signer’s name and job title;

AND

♦ a notation that a copy of the cover letter is beingsent to the relevant guaranty agency and/or DirectLoan servicer.

Schools should use the sample Request forAdjustment cover letter on page 73.

The section behind Tab 2 contains:a spreadsheet listing all of the loans that qualify foran adjustment.

Schools should use the sample Request for Adjustmentspreadsheet on page 75 and instructions on how to createthe spreadsheet on page 74.

The section behind Tab 3 contains:a copy (or copies) of the original letter(s) andapplicable attachments from the relevant guarantyagency and/or Direct Loan servicer indicating that adata change was agreed to as a result of a school'sdraft data challenge .

Schools do NOT need to submit supporting documentation or a copy of its loan record detail report as a part of its request for adjustment.

The Department will review only the informationsubmitted with the request for adjustment and will notconsider information submitted after the school’sdeadline. The Department will send the school andeach involved entity written notification of its decision.The Department’s decision is final and no furtheradministrative review is provided.

Tab 3

Tab 2

Tab 1



If sent by commercial overnight mail/courier delivery, send theschool’s request for adjustment to:

U.S. Department of EducationDefault Management DivisionATTN: Request for AdjustmentROB-3, Room 39057th and D Streets, SWWashington, DC 20407

If sent by U.S. Postal Service, send the school’s request foradjustment to:

U.S. Department of EducationDefault Management DivisionATTN: Request for AdjustmentPortals Building, Room 6300400 Maryland Avenue, SWWashington, DC 20202-5353

The Department will not accept any appealcorrespondence by facsimile (fax) or e-mail.

The Department recommends that a school submit its request foradjustment return receipt requested or via commercial overnightmail/courier delivery. This will be useful to the school if it is askedto authenticate the timeliness of its appeal. A school shouldmaintain the documentation which verifies the receipt of the appealrelated material. In addition, the Department recommends that aschool retain copies of all appeal documents provided to theDepartment and other entities.





Sample Request for Adjustment Cover Letter

October 4, 1999

U.S. Department of Education OPE ID#: 111222Default Management DivisionATTN: Request for AdjustmentPortals Building, Room 6300400 Maryland Avenue, S.W.Washington, D.C. 20202-5353

Dear Default Management Division:

School of Business, OPE ID# 111222, wishes to request anadjustment to its official FY 1997 cohort default rate.

Please see the enclosed spreadsheet and the copies of the draft datachallenge responses.

Thank you for your consideration.

Sincerely,

Robert YoungRobert Young, President

Enclosures

cc: ABC Guaranty AgencyDirect Loan Servicer

Subject: FY 1997 Request for Adjustment

School of Business1212 Wedgewood LaneLeonardtown, Wisconsin 12345-6789123-456-7890

Sample Letter



Instructions for Request for Adjustment Spreadsheet

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Documents

Request for Adjustment - Federal Student Aid - IFAP: Home · PDF filea change to the data but ... submitting a request for adjustment? Timing is critical for a school when submitting