800.242.0977

djainfo@gotodja.com

3000 W Kellogg Drive

Wichita, KS 67213

OCTOBER 2020 NEWSLETTER

all of us at DJA, we send our warmest wishes for an especially bright and beautiful holiday season to all of our friends, clients and their families.

Celebrate, Be Merry and Have Fun!

Deborah John, President

FY 2017 OFFICIAL COHORT DEFAULT RATES RELEASED SEPTEMBER 28th

On Monday, September 28, 2020, USDE distributed the FY 2017 official

cohort default rate (CDR) notification packages and accompanying

documentation via the Student Aid Internet Gateway (SAIG) to all eligible

schools.

Each eCDR package contained the following information:

IMPORTANT DATES:

October 1

October 7

DJA Webinar

Enrollment Reporting/NSLDS

11:00 a.m. CDT

October 12

Columbus Day – DJA Open,

Federal Offices Closed

October 21

Happy National Financial Aid

Day!

October 27-29

AACS Virtual Annual

Convention

October 31 Happy Halloween!

November 2nd FISAP Submission Deadline

IN THIS ISSUE:

FY 2017 Cohort Default

Rates

Department Issues Email on

CARES Act Update

CARES Act Institutional

Reporting

Comments Requested: New

HEERF Data Collection

Direct Loan Fee Change

Phase Two of COD System

Implementation to Support

CARES Act

Reminder: FISAP Due

Compliance Corner

DJA Calendar

It’s October! Anybody else feel like taking a deep breath now that a lot of the

major deadlines due in the month of September have passed?! Unfortunately,

the Financial Aid Industry rarely offers down time and October 1st marks the

date students can begin completing the 2021/2022 FAFSA. Now it is time to

start focusing on preparing for another award year. Additionally, in this

newsletter, we will cover all the new updates regarding the CARES Act and the

HEERF reporting requirements.

We also discuss the newly published Cohort Default Rates you should have

received last month. October 1st has also brought about a new Direct Loan fee.

Typically in October, we are finalizing FISAP submission, but the COVID

pandemic the deadline was extended to November 2nd. Be sure to read our

reminder in this newsletter and be sure you comply with the deadline.

Lastly, be sure to review our Compliance Corner regarding how to utilize a

joint tax return to figure individual AGI and taxes paid in the event the filer of

a joint return has become widowed, divorced or separated. This step can be

crucial to the verification process.

Thank you and until next time, stay safe and take care!

Deborah John, President

October 2020 2

Cover Letter (message class SHDRLROP)

Reader-Friendly Loan Record Detail Report (message class SHCDRROP)

Extract-Type Loan Record Detail Report (message class SHCDREOP)

Comma Delimited-Type Loan Record Detail Report (message class CDRCSVOP)

The official cohort default rate is found on the first page of a school’s official notification letter and the

last page of the Loan Record Detail Report (LRDR).

eCDR notification packages were not sent to any school not enrolled in eCDR. These schools may download

their cohort default rate and accompanying Loan Record Detail Reports from the National Student Loan Data

System (NSLDS) via the NSLDS Professional Access Web site.

Any school that did not have a borrower in repayment, during the current cohort default rate period will not

receive an Official Cohort Default Rate notification package. These schools are considered to have no cohort

default rate data and no default rate.

Important Note: Some schools have a small number of borrowers entering repayment. At other schools, only a

small portion of the student body takes out student loans. In such cases, the cohort default rate should be

interpreted with caution.

After the release of the 2017 Official rates, the Department of Education (the Department) publicly posted the

2017 Official Cohort Default Rates to the Default Management Website FSA Data Center on Wednesday,

September 30, 2020.

LRDR File review: The LRDR Import Tool can be used to easily load data generated from the LRDR into the

Microsoft Excel spreadsheet application, which is designed to assist schools with reviewing and analyzing their

LRDR extract files.

To download the LRDR Import Tool, go to the Default Management website at https://ifap.ed.gov/dm, and

choose “CDR Guide” from the left-hand navigation bar. The LRDR Import Tool can be found in the

"Templates/Spreadsheets" section. If you have questions about using the LRDR Import Tool or NSLDS, contact

the NSLDS Customer Support Center at 800-999-8219. You can also contact Customer Support by email at

nslds@ed.gov.

Note: Any school that did not have a borrower in repayment, during the current or any of the past cohort default

rate periods, will not receive a FY 2017 official CDR notification package. These schools are considered to

have no cohort default rate data and no cohort default rate.

Guaranty agency and lender rates can be obtained through the NSLDS website.

Begin Date for Appealing FY 2017 Official Cohort Default Rates

The time period for appealing the FY 2017 Official Cohort Default Rates begins on Tuesday, October 6, 2020

for all schools.

October 2020 3

All Uncorrected Data Adjustments (UDA) and New Data Adjustments (NDA) must be made through the eCDR

Appeals application. Additionally, the Loan Servicing (LS) Appeal process is now available electronically

through the eCDR Appeals application. All other adjustments/appeals will continue to be submitted via hard

copy. As a reminder, eCDR Appeals is a web-based application that allows schools to electronically submit

certain adjustments/appeals requests during the specified timeframes. The application allows data managers

(guaranty agency or federal loan servicer) and Federal Student Aid personnel to electronically view and respond

to these adjustments/appeals. The application tracks the entire life cycle of each request from the time the case

is submitted until the time a decision is made and the case is closed.

If a technical problem caused by the Department results in an inability to access the data, schools have five

business days from the receipt of the eCDR notification package to notify the Operations Performance

Division at the email address given below. As stated above, the time period for challenging the FY 2017

Official Cohort Default Rates begins on Tuesday, October 6, 2020 for all schools.

To complete an adjustment or appeal, you may need the data manager’s contact information. Click on the “Data

Manager Information” link from the home page of the Cohort Default Rate Guide at

https://ifap.ed.gov/dm/finalcdrg.

If the Department revises a school’s cohort default rate based on its adjustment or appeal submission, the

revised cohort default rate will be available on Operations Performance Division’s website at

https://ifap.ed.gov/dm.

For specific information regarding eCDR Appeals, visit the eCDR Appeals website, where you will find user

guides for each of the challenge and adjustment processes, as well as a user guide for the registration process.

Additionally, you will find links to recordings of eCDR Appeals demonstration sessions to assist first-time

users.

Contact Information For additional information regarding the school cohort default rate calculation or the challenge processes, please

refer to the Cohort Default Rate Guide at https://ifap.ed.gov/dm/finalcdrg.

You may also email fsa.schools.default.management@ed.gov or call the Operations Performance Division’s

hotline at 202-377-4259.

DJA Clients: This information was sent to the SAIG mailbox for the destination point designated by the

school. If your school had designated DJA’s SAIG mailbox for receipt of these files, they were sent to clients

upon receipt in our SAIG mailbox on September 28th. However, if you are enrolled in the eCDR system

under your own SAIG mailbox, you will need to look for your file there. Any school not enrolled in the

eCDR process may download their cohort default rate and accompanying documentation from the National

Student Loan Data System (NSLDS) via the NSLDS Professional Access Web site.

https://ifap.ed.gov/electronic-announcements/092820FY2017OfficialCDRDistributedSept282020

October 2020 4

DEPARTMENT ISSUES CARES ACT EMAIL ON HEERF UPDATE The Department recently issued an email to grantees of the CARES Act Higher Education Emergency Relief

Fund regarding additional reporting requirements. The purpose of the email was to inform institutions of several

recent updates to the HEERF programs. The email clarified the following:

1) Personal Protective Equipment (PPE) is an allowable expenditure under HEERF Just to clarify, purchases to ensure the physical safety of students on campus is an allowable use of a

grantee’s Institutional Portion of its allocation under section 18004(a)(1) of the CARES Act, when these

costs are new or added and needed to implement “significant changes to the delivery of instruction due

to the coronavirus.”

This may include the reasonable costs of PPE, cleaning supplies, facility cleaning, or the purchase of

items to help detect or prevent the spread of COVID-19 (e.g., thermometers, plastic barriers, or face

masks). Grantees may also use these funds to make non-permanent changes to existing instructional

facilities to ensure social distancing.

The purchase of PPE, cleaning supplies, facility cleaning, or the purchase of items to help detect or

prevent the spread of COVID-19 items is also an allowable use of funds for grants received under

sections 18004(a)(2) and 18004(a)(3) of the CARES Act.

(2) Federal Funding Accountability and Transparency Act of 2006 (FFATA) reporting not

required for HEERF Following the Department’s July 9 statement (published as an Electronic Announcement (EA) to

institutions of higher education on July 10, 2020) regarding the use of the FFATA Subaward Reporting

System (FSRS) for purposes of reporting the use of HEERF funds, the Department received a number of

questions and concerns raised about reporting for HEERF grantees. It has since been concluded that

institutions receiving HEERF formula funding will not likely have subawards and will not be able to use

FSRS for reporting their use of HEERF funds.

Therefore, the Department will be using the authority provided by Section 18004(e) of the CARES Act

to specify how institutions will publish certain information on a quarterly basis on their websites. To this

end, they have released a draft information form to accomplish this and also publish the form in the

Federal Register for public comment for a first report due October 30, 2020, covering the period from

the date of the first HEERF grant award through September 30, 2020. The draft form published in the

FR is covered in the article below.

More information is available at our HEERF Reporting webpage

https://www2.ed.gov/about/offices/list/ope/heerfreporting.html.

(3) Changes to the section 18004(a)(1) Student Aid allocation public reporting requirement The Department recently revised the May 6th Electronic Announcement (EA) on institutional reporting

for the emergency financial aid grants to students made with institutions’ allocations under section

October 2020 5

18004(a)(1), Student Aid Portion, of the CARES Act. This EA has been superseded by the August 31st

EA found here in the Federal Register. It can also be found on the CARES Act HEERF homepage.

This revised EA, in conjunction with approved information collection under OMB control number 1801-

0005, requires grantees receiving awards under section 18004(a)(1) of the CARES Act to publicly post

certain grant information on the institution’s primary website as part of the reporting requirements under

section 18004(e) of the CARES Act. This revised EA maintains the same seven reporting elements, but

it adds a clarifying footnote for reporting item four and decreases the frequency of reporting after the

initial 30-day period from every 45 days thereafter to every calendar quarter.

Grantees posting a 45-day report on or after August 31, 2020 should instead post a report every calendar

quarter, with the next calendar quarter report due by October 10, 2020 and covering the period from

after their last 45-day or 30-day report through the end of the calendar quarter on September 30, 2020.

If you have any questions regarding this revised notice, please send them to Jack Cox at

Jack.Cox@ed.gov. Please also remember to check the HEERF Reporting webpage

(https://www2.ed.gov/about/offices/list/ope/heerfreporting.html) regularly for future CARES Act

reporting requirements and updates.

(4) HEERF Annual Reporting Form 60-day public comment period closing soon

The HEERF Annual Information Collection Form was posted for a 60-Day public comment period.

Please see the Federal Register Notice and Form and Instructions and Supporting Statement. Public

comments for this notice were accepted through September 28, 2020, via Regulations.gov.

For additional information about HEERF programs, please visit THE HEERF website. If you have any

questions regarding these announcements, please contact the Department of Education’s HEERF Call Center at

(202) 377-3711 or HEERF@ed.gov.

CARES ACT INSTITUTIONAL QUARTERLY REPORTING

On Monday September 28, 2020, a new quarterly budget and expenditure reporting form was released by the

Department of Education. The new form is to report CARES Act institutional funding. First reports are to be

posted on the school’s website by October 30, 2020, covering the period from the date of the first HEERF grant

award through September 30, 2020. This form must be conspicuously posted on the institution’s primary

website on the same page the reports of the school’s activities as to the emergency financial aid grants to

students made with funds from the CARES Act.

On each form, fill out the institution name, the date of the report, the appropriate quarter the report covers

(September 30, December 31, March 31, June 30), the original total amount of funds awarded by the

Department, and check the box if the report is a “final report”, if applicable. In the chart, IHE’s must specify the

October 2020 6

amount of expended CARES Act funds for each funding category: Sections 18004(a)(1) Institutional Portion,

18004(a)(2), and 18004(a)(3), if applicable. Provide explanatory notes for how funds were expended, including

the title and brief description of each project or activity allotted funds. Explanatory footnotes help clarify certain

reporting categories. Calculate the amount of the Section 18004(a)(1) Institutional Portion (referred to as

“(a)(1)” in the chart), Section 18004(a)(2) (referred to as “(a)(2)” in the chart), and Section 18004(a)(3)

(referred to as “(a)(3)” in the chart) funds in the “Quarterly Expenditures for each Program” row, and the grand

total of all three in the “Total of Quarterly Expenditures” row. Blank responses are considered $0 for that

category or column.

To access the form, click here: https://www2.ed.gov/about/offices/list/ope/heerf-quarterly-reporting.pdf

FEDERAL REGISTER RELEASED SOLICITING COMMENTS FOR A NEW CARES ACT HEERF DATA COLLECTION

Additionally, on Monday the Department of Education released a Federal Register soliciting comments for a

new CARES Act HEERF data collection. They are seeking emergency processing approval by September 3030.

This new HEERF data collection is to be called Quarterly Budget and Expenditure Reporting (QBER) and

differs from the 30-day Fund Report and from the annual reporting previously proposed. This data collection

would presumably satisfy the CARES ACT Section 15011 quarterly reporting requirements applying to

recipients of more than $150,000 of any type of CARES Act funding.

The QBER would apply to recipients of CARES Act funds under Sections 18004(a)(1), (2), & (3) and section

18004(c). Reports would be posted to institutions’ primary websites, on the same page as they post their 30-day

Fund Reports, either as text or as a link to a .pdf of the report. Reports would be due no later than 10 days

following the end of the calendar quarter, with the exception that the first report would be due on Oct. 30, 2020

as opposed to Oct. 10. The initial report would include cumulative expenditures through Sept. 30, 2020.

Subsequent reports would include data only for the quarter being reported, and each quarterly report would need

to be separately maintained on the institution’s website.

Quarterly submission of the QBER would be required until Sept. 30, 2022.

To view the Federal Register, click here: https://www.federalregister.gov/documents/2020/09/28/2020-

21355/agency-information-collection-activities-comment-request-quarterly-budget-and-expenditure-reporting

REMINDER - DIRECT LOAN ORIGINATION FEES CHANGE OCTOBER 1, 2020

The origination fees for Direct Subsidized Loans, Direct Unsubsidized Loans, and Direct PLUS Loans (for both

parent and graduate student borrowers) change as of October 1, 2020. Additional operational guidance is

provided in a June 23, 2020 Electronic Announcement at https://ifap.ed.gov/electronic-

announcements/062320FY21SequesterRequiredChangesTitleIVStudentAidPrograms

October 2020 7

Loan Type First Disbursed Loan Fee Percent

Fee Example

Direct Subsidized Loans and Direct

Unsubsidized Loans

FY 20 On or after October 1, 2019 and before October 1, 2020

1.059 $58.24 on a $5,500 loan.

FY 21 On or after October 1, 2020 and before October 1, 2021

1.057 $58.13 on a $5,500 loan.

Direct PLUS Loans (Parent and Grad/Prof

Student)

FY 20 On or after October 1, 2019 and before October 1, 2020

4.236 $423.60 on a $10,000 loan

FY 21 On or after October 1, 2020 and before October 1, 2021

4.228 $422.80 on a $10,000 loan

Loan fee calculations that result in more than two decimal places must be truncated (not rounded) to two digits after the decimal point (cents).

COD SYSTEM IMPLEMENTATION INFORMATION FOR ADDITIONAL COD SYSTEM CHANGES TO SUPPORT THE CARES ACT- PHASE TWO

The second phase of the Common Origination and Disbursement (COD) System implementation occurred on

September 27, 2002 and made additional changes to the COD System to support the reporting requirements for

withdrawn students who qualify for a Title IV waiver under the CARES Act. These changes supplement the

work completed on Aug. 2, 2020 and are explained in a July 30, 2020 Electronic Announcement. The

Department released a second announcement, July 23, 2020 Electronic Announcement providing the following

important information about this next round of changes:

High-Level Schedule and Summary of COD System Changes for the CARES Act (Phase Two)

COD System Outage Information

Technical Information and Document Availability

Contact Information

October 2020 8

High-Level Schedule and Summary of COD System Changes for the CARES Act (Phase Two) As noted in the July 30th announcement, the first phase of COD System functionality was implemented on Aug.

2, 2020. Phase two was completed on Sept. 27, 2020. This phase included:

New and modified reports

Modifications to the Return of Title IV (R2T4) calculator on COD website

Technical Information and Document Availability An updated version of the 2020–21 COD Technical Reference was posted in a September 30, 2020 Electronic

Announcement. As noted in previous announcements, there are no changes to the COD Common Record XML

Schema.

COD System Changes

The following changes will impact COD System processing for the Federal Pell Grant (Pell Grant), Iraq and

Afghanistan Service Grant, Teacher Education Assistance for College and Higher Education (TEACH) Grant,

and William D. Ford Federal Direct Loan (Direct Loan) programs.

Changes to the Payment Period Start Date for the Coronavirus Indicator In the July 30, 2020 Electronic

Announcement, it was noted that one of the requirements for the Coronavirus Indicator was that the

disbursement’s payment period start date is a date inclusive of or between Jan. 1, 2020 and Dec. 31, 2020.

Beginning Sept. 27, 2020, payment period start date window has been expanded, and the Coronavirus Indicator

will be accepted when the payment period start date is a date inclusive of or between July 1, 2019 and Dec. 31,

2020.

Note: While the payment period start date window has been expanded, all other requirements related to the

Coronavirus Indicator must be met.

Subsidized Usage Calculator Updates

Beginning Sept. 27, 2020, the Subsidized Usage Limit Applies (SULA) calculator was updated to include a

Coronavirus Indicator field. Once selected, the disbursements flagged with the Coronavirus Indicator will be

excluded from the subsidized usage calculation. As a result, users can view the effect of the added Coronavirus

Indicator on the following types of calculations:

• Subsidized Usage Period

• Sum Actual Subsidized Usage Periods

• Maximum Subsidized Eligibility Period

• Remaining Subsidized Eligibility Period

COD School Report – Weekly Coronavirus Report

The Weekly Coronavirus Report will provide cumulative data for students who have received Coronavirus

Disaster relief (have disbursements flagged with the Coronavirus Indicator) by program (Direct Loan, TEACH

October 2020 9

Grant, and Pell/Iraq and Afghanistan Service Grant) and award year. The reports will be generated on a weekly

basis and in comma delimited (.csv) format.

Schools will retrieve the reports from the COD Reporting website; the report will not be sent via the Student

Aid Internet Gateway (SAIG).

The file layout for the Weekly Coronavirus Report will be available in the COD Technical Reference.

Direct Loan Rebuild

While the Direct Loan Rebuild was not be updated with the Coronavirus Indicator, changes were made to the

content provided in the report. Specifically, to minimize the impact to schools and vendors that have internal

system edits on loan period dates, Direct Subsidized Loans that have a disbursement marked with the

Coronavirus Indicator will be excluded. This is because of the potential systematic updates to the award begin

and end dates for flagged disbursements.

For schools that may need a Direct Loan Rebuild and have excluded Direct Subsidized Loan records (due to the

Coronavirus Indicator), they can work with the COD School Relations Center for assistance with those specific

records.

National Student Loan Data System Interface

Following this system release, information about disbursements flagged with the Coronavirus Indicator will be

passed to the National Student Loan Data System (NSLDS®). Note: Following additional system work and a

separate NSLDS implementation planned for Nov. 22, 2020, NSLDS will use the Coronavirus Indicator

information for SULA processing on NSLDS, such as calculating the Remaining Eligibility Period (REP) for

the interest subsidy. In addition, NSLDS will label loan discharges due to COVID-19 as “Coronavirus”

(currently these discharges are only marked with the discharge type code of “HC02”.

Return of Title IV (R2T4) Changes

With this release, changes were made to the Return of Title IV (R2T4) calculator to allow schools to perform an

RT24 calculation specifically for aid recipients who withdrew due to COVID-19-related circumstances. The

updated tool provides schools with a mechanism for reporting the amount of Title IV grant or loan assistance

not returned due to the CARES Act provisions.

In response to feedback from the community, additional options are being examined (besides the R2T4

calculator) for reporting Title IV grant or loan assistance not returned due to the CARES Act provisions, but

those options will likely not be available until early 2021. In the meantime, schools may use the R2T4

calculator for any aid recipients who withdrew due to COVID-19, but there is no requirement to do so, and

some schools may opt to wait until other options are available. As noted previously, calculations for COVID-19

withdrawals will be used for reporting purposes only.

As of Sept. 27, 2020, the following updates were put in place—

October 2020 10

• The COD R2T4 calculator was updated to incorporate a new R2T4 Coronavirus Indicator checkbox.

The checkbox will be available for the 2018–19 Award Year and forward. o Once the indicator is selected, the user will be required to select a “Calendar Profile” that has a

payment period or period of enrollment state date within the valid date range.

• The R2T4 Review Calculation page and Student Record Management page was updated to include an

R2T4 Coronavirus Indicator field (on student records that were previously marked as such). It is an

informational field only; users are not able to update the field on these pages.

• The R2T4 Reports page were updated to allow users to search for calculations with disbursements

marked with the new R2T4 Coronavirus Indicator and allow users to run reports to show the amount of

aid by program that would have been returned for disbursements marked with the new Coronavirus

Indicator. The search dropdown box includes an R2T4 Coronavirus Indicator option. Users are able to

select “Yes” to view a report with only R2T4 calculations where the R2T4 Coronavirus Indicator was

flagged. Users select “No” to view a report with only R2T4 calculations where the R2T4 Coronavirus

Indicator was not flagged.

The R2T4 Report will be expanded to include the following columns: Calendar Period Start Date,

Calendar Period End Date, and R2T4 Coronavirus Indicator.

In addition, the Department is in the process of developing training material specifically about the changes to

the R2T4 calculator. Once it is ready, it will be made available on the FSA Training website.

Contact Information If you have questions about this announcement, contact the COD School Relations Center at 1-800-848-0978.

You may also email CODSupport@ed.gov.

REMINDER: FISAP DUE NOVEMBER 2, 2020

The upcoming deadline for submitting the Fiscal Operations Report for 2019–20 and the Application to

Participate for 2021–22 (FISAP) for the Campus-Based Programs has been extended to Monday, Nov. 2, 2020.

All schools requesting Federal Supplemental Educational Opportunity Grant (FSEOG) and Federal Work-Study

(FWS) program funds for the 2021–22 Award Year and/or that had either FSEOG and FWS expenditures or

Federal Perkins Loan (Perkins Loan) activity for the 2019–20 Award Year are required to electronically submit

a FISAP via the Common Origination and Disbursement (COD) website. Schools that closed during the 2019–

20 Award Year are required to complete and submit a final FISAP to report 2019–20 Campus-Based

expenditures.

The COD website allows a school to complete and submit its FISAP online, receive real-time validation edits,

and access prior-year data to assist in completing the FISAP. Schools should review all validation edits and

ensure accuracy of the information reported. For information about accessing the FISAP on the COD

October 2020 11

website and to review important reporting reminders, refer to the August 3, 2020 Electronic Announcement

announcing that the 2021–22 FISAP is available.

The deadline for electronic submission of the FISAP is 11:59 p.m. Eastern Time (ET) on Nov. 2, 2020.

Transmissions must be completed prior to midnight. Additionally, the signature page must be printed, signed,

and mailed by the Nov. 2, 2020 deadline. Signature requirements and instructions can be found in the 2021–22

FISAP Instructions, page 14.

FISAP Reminders

Click “Submit” – Remember that saving data into the FISAP online is not the same as submitting the

FISAP. Data can be entered and saved as a school user works through the form, but it is not actually

submitted until the school user clicks on “Submit.”

Consequences for Not Filing the FISAP – 2019–20 Campus-Based funding levels will be reduced to

zero ($0) for a school that received 2019–20 Campus-Based funds but fails to file the FISAP by the

deadline. This includes schools that closed during the 2019–20 year and drew Campus-Based funds for

that year from G5. Any 2019–20 program funds that have been drawn down in G5 will be required to be

returned to the Department of Education (the Department). Campus-Based funds for the 2021–22 Award

Year will not be awarded to schools that fail to file the FISAP.

Schools must provide true and accurate data and must not roll forward data previously reported on last year’s

FISAP just to meet the deadline.

Note: Failing to accurately and timely file the FISAP may result in referral to FSA’s Program Compliance

office for further review and action. These actions may include fines, and a limitation, suspension, or

termination of your institution’s eligibility to participate in the Campus-Based Programs. In addition, through

the signature process, the President/CEO has certified that information in the FISAP is true and accurate and in

compliance with legislation and regulations. Providing false and misleading information can result in fines,

prison, or both.

Updated Financial Aid Administrator (FAA) Contact Information Required – All Campus-Based

notifications are sent via email to the FAA. For timely receipt of these notifications, it is important that a

school ensures the accuracy of its FAA contact information, including the FAA email address. A school

can update its contact information when submitting the FISAP or by selecting “School Information”

then “Demographics” on the Campus-Based section of the COD website. All changes or corrections to

contact information must also be updated in the Program Participation Agreement using the E-App

website.

Automatic Underuse Penalty Waiver– As announced in the August 3, 2020 Electronic

Announcement, schools that return more than 10 percent of their 2019–20 FSEOG or FWS allocation do

not need to request a waiver for the underuse of funds penalty in Part II, Section C, Line 6 of the

FISAP. Underuse penalties will not be applied on any 2021–22 FWS or FSEOG awards for all schools

due to the impact of the COVID-19 emergency.

Accuracy Helps Avoid Negative Balances – Make sure the information reported for expenditures of

2019–20 award amounts are accurate and consistent with the amounts drawn in G5. For example, if a

October 2020 12

school's FWS authorized amount was $50,000 and the school reported an expended amount of $40,000

on the FISAP (Part V, Section E, Field 18), the school's award will be closed out at the expended

amount of $40,000 (i.e. the $10,000 difference will be deobligated from G5). If the amount the school

has drawn from G5 is different from the expended amount reported on the FISAP, we will assume that

the correct expenditures are the amounts reported on the FISAP and certified by the Chief Executive

Officer in Part I, Section B. In some cases this results in a negative balance which is required to be

returned by the school to the Department. Using the above example, if the school drew down its entire

$50,000 FWS authorization from G5, it would need to return $10,000.

Edit Corrections through Dec. 15, 2020 – Once a FISAP is submitted, the school can submit

corrections until 11:59 p.m. ET on Dec. 15, 2020. Data can be entered and saved as a school makes

corrections. If corrections are made, remember to submit them. Transmissions must be completed prior

to midnight. Note: After the Dec. 15, 2020 deadline for submitting corrections, approval of FISAP

change requests is reserved for exceptional issues only.

Perkins Loan Reporting Reminders

Report the correct data for all cumulative and annual reporting for Perkins Loans.

Schools that had cash in their Perkins Loan Revolving Fund (Perkins Fund) were notified of the required

distribution of assets process and the required amount of the federal share to remove and return to the

Department; the required amount of the institutional share to remove and return to the school; and if

eligible the amount to remove and reimburse the school for service cancellations.

o If your school returned the federal share, report the cumulative federal share repaid to the federal

government from the Perkins Fund in Part III, Section A, line 28.1 “Repayments of fund capital

to federal government.” (Line 28.1 should be the sum of the cumulative amount reported in line

28 on last year’s FISAP plus the amount the school repaid in 2019–20.)

o If your school returned the institutional share to the school, report the cumulative institution

share repaid from the Perkins Fund in Part III, Section A, line 30.2 “Repayments of

excess/liquidated fund capital to Institution.”

o If your school was eligible for reimbursement of Perkins loan service cancellations and was

notified of the amount to reimburse the school from the Perkins Fund, report the amount that the

school was reimbursed from the Fund for cancellations in Part III, Section A, line 28.2 “Service

cancelation reimbursement received on or after 07/01/2019.”

Online Help is Available 24/7 – If additional help is needed, the COD website has several documents that can

be accessed online as well as a series of frequently asked questions and answers (Q&As).

DJA Clients: If you are a DJA Client and contract with DJA for your SEOG Processing, then we are already

working diligently on your FISAP and will have it submitted ahead of the required deadline. Are you

overwhelmed with the annual FISAP and Financial Aid Processing in general? DJA would love the opportunity

to chat with you about our services. Contact Kristi Cole, Director of Sales at DJA, at 1-800-242-0977 or via

email at kcole@gotodja.com for more information on how we can assist.

https://ifap.ed.gov/electronic-announcements/092420ReminderFISAPdueNov22020

October 2020 13

COMPLIANCE CORNER

USING A JOINT RETURN TO FIGURE INDIVIDUAL AGI AND TAXES PAID

Excerpt from the 20/21 Application and Verification Guide, page 93:

If the filer of a joint return has become widowed, divorced, or separated since filing the return, it may be

necessary to determine the individual’s income and taxes paid using the joint return and W-2 forms. If a W-2 is

not available (the filer is self-employed for example) or if a duplicate copy from the employer who issued the

original W-2 is not available in a timely manner, the school may permit the filer to provide a signed statement

that certifies the base year AGI and U.S. taxes paid. If he has divorced and married someone new (see “Parent

remarriage after applying” on page 104 if this occurred after completion of the application), then the new

spouse’s income and assets would also need to be included.

Add the income amounts from the individual’s W-2 forms to any other income that can be extracted from the

joint return. Any interest or business income earned on joint accounts or investments should be assessed at 50%.

The same procedure should be used to divide business or farm losses. Also, if the AGI listed on the joint return

was adjusted, you should reduce the individual’s AGI by the portion of the adjustment that applies solely to him

or her. An AGI figure can be calculated for the individual filer. A signed statement from the filer certifying that

the data from the joint return were accurately assessed is sufficient documentation for this method.

Use one of the following methods to figure the individual’s taxes paid:

• Tax table (preferred method). Using the IRS Tax Table or Tax Rate Schedule for the appropriate year,

calculate the amount of tax that would have been paid if a separate return had been filed. Use the deductions the

individual could have claimed if he or she had filed a separate return. (If itemized deductions were taken, count

only the portion of those deductions that could have been claimed on a separate tax return.)

• Proportional distribution. Determine what percentage of the joint AGI was attributable to the individual, and

then assess the joint taxes paid by that same percentage.

Example

Calculating the individual AGI from a joint return

Eddy’s application is selected for verification. He and his wife filed a joint return for 2018 and have since

divorced. The AGI on Eddy’s FAFSA matches the AGI of $56,500 on the 2018 tax return, which means it’s

wrong because it includes his wife’s income.

Eddy’s W-2 shows that his income for 2018 was $25,900, and the tax return shows $400 in interest. Because it

was interest on a joint savings account, the aid administrator adds $200 of it to Eddy’s income and submits

$26,100 as the corrected income via FAA Access.

October 2020 14

Calculating the individual tax from a joint return

The aid administrator determines that Eddy’s part of the $56,500 AGI he and his wife reported is $26,100. If he

had filed his tax return as single, his standard deduction would have been $12,000 (instead of $24,000 for

married filers). Eddy’s income of $26,100 minus $12,000 for the standard deduction results in $14,100 in

taxable income.

The aid administrator uses the tax table to determine how much tax Eddy would have paid on this amount,

taking into account any applicable credits reported on the original return. With a taxable income of $14,100, the

tax amount from the tax schedule is $1,505.

To use the proportional distribution method instead, the aid administrator figures out what percentage of the

joint AGI Eddy’s income represents. The percentage is 46% (26,100 ÷ 56,500 is .4619). The aid administrator

then multiplies the income tax paid as reported on the tax return ($3,522 for this example) by this percentage.

Eddy’s income tax by using this method is $1,620 (.46 X $3,522).

https://ifap.ed.gov/sites/default/files/attachments/2020-05/2021FSAHbkAVG.pdf

DJA CALENDAR 2020 DJA MONTHLY WEBINAR SCHEDULE

Monthly DJA Webinar: Enrollment Reporting - Wednesday, October 7 - 11 a.m. CDT

NOTE: There may be a difference between DJA local time and your time zone. To determine your time zone

equivalent, click on this link to view a time zone map: http://www.worldtimezone.com/time-usa12.php

Webinars are free to clients. There is a $45 fee for all others who may be interested in joining us for these

presentations. Invitations are automatically sent to all clients, however if you do not receive an invitation, email

Renee Ford at rford@gotodja.com. After registering, you will receive the log-in information. Questions can be

directed to Renee by email or by calling toll free at 1-800-242-0977.

2020 DJA MONTHLY WEBINAR SCHEDULE

OCT 7 Enrollment Reporting Using NSLDS

NOV 4 Program Integrity (Audits, Program Review)

DEC 2 1098-T Reporting

October 2020 15

2020 ANNUAL AMERICAN ACADEMY OF COSMETOLOGY SCHOOLS CONFERENCE- VIRTUAL EDITION

COVID and social distancing can’t stop members of AACS from coming together as an industry and knowledge

sharing for their annual conference. While the meeting has gone virtual this year, attendees will still have the

opportunity to learn from the best in the sector and attend informative training sessions. The 2020 AACS

Convention and Expo will be held virtually October 27-29th. For more information on registration, visit

https://www.beautyschools.org/events/2020-aacs-convention-expo/.

To learn more on Cybersecurity Compliance and how to prepare the most effective Information Security

Program, our very own Renee Ford, Vice President of DJA, will be hosting a webinar on the topic during this

virtual convention.

2020 FEDERAL STUDENT AID (FSA) TRAINING CONFERENCE GOING VIRTUAL Don’t miss the first-ever virtual Federal Student Aid training conference!

Federal Student Aid is committed to providing a meaningful training experience for you amid the uncertainty

caused by the COVID-19 emergency. The 2020 FSA Training Conference for Financial Aid Professionals will

be delivered virtually Dec. 1-4, 2020, and will feature dynamic keynote addresses, engaging general forums,

and informative breakout sessions.

Later this summer, additional information will be released on the IFAP website about the virtual conference and

how you can participate.

Disclaimer: The information presented in this Newsletter is provided as a service and represents our best efforts to assist institutions with federal student aid

regulations. We have collected information we believe to be important in finding and obtaining the resources for administering federal student aid; however, we assume

no liability for the use of this information. The information in this newsletter does not constitute, and should not be construed as, legal advice.