Presenter: Mary Lyn Hammer Proprietary A PLAN of ACTION Cohort Default Rates & Gainful Employment.

HIGH RISK at Institutional Level for Cohort Default Rates

TARGETED RISK at Program Level for Gainful Employment Accountability

Presenter: Mary Lyn HammerProprietary

A PLAN of ACTIONCohort Default Rates& Gainful Employment

Higher loan balances

Transition from FFELP to Direct Loans

• Multiple loan programs, lenders, and servicers

• Multiple payments that are hard to manage

• Multiple forms needed to cure delinquencies

• Decline in the quality of loan servicing

Skip borrowers not located through traditional methods of skip tracing

Gainful Employment rules are contradictory to CDR’s servicing

Loss of interest subsidies will complicate both CDR’s and GE

Bad economic times and the unstable environment intensify the headwinds of the storm.Proprietary

The Perfect StormRISK

Borrowers Who

Historically Became

Delinquent

Borrowers Who Historically Paid

BUT Are Currently Becoming

Delinquent

Borrowers Who

Historically Are Never Delinquent

ADVERSE conditions are IMPACTING YOUR student loans

Proprietary

RISK Challenges

Proprietary

RISK Challenges

FY 2008 Trial 3-year Cohort Default Rates

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ate

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Than

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CD

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Prop

rieta

ry 2

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ear

CDR

UP

96.8

%

National Average CDR UP 83.6%

Proprietary

RISK Challenges

FY 2009 2-yearCohort Default Rates

Priv

ate

Scho

ols

CDR

UP

15.0

%

Publ

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CDR

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Nati

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Prop

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%

Ther

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You can turn your rates

around with the right

intensity and processes.

Proprietary

RISK Challenges

CDR Definition Loss of EligibilityDisbursement

Benefits

2-Year CDR3 Consecutive

Years Over 25%1 Year

Over 40%3 Consecutive

Years Under 10%

3-Year CDR3 Consecutive

Years Over 30%1 Year

Over 40%3 Consecutive

Years Under 15%

The thresholds for eligibility and participation changes are not consistent with real increases.

Accrediting agencies have been asked by the U.S. Department of Education to place additional restrictions and oversight on those

institutions they identify for at-risk of high CDR’s.

Institutional Eligibility

Proprietary

ComplexitiesPREPARE

Cohort Default Rate DefinitionsEffective with the Higher Education Opportunity Act (H.R. 4137 for the HEA of 2008)

Cohort Year LDA Range EnteringRepayment Dates

2-year CDRDefault Dates

3-year CDR Default Dates

CDR Draft & Official Release Dates

FY 2009 CDR 3/30/2008-3/29/2009 10/1/2008-9/30/2009 Through 9/30/2010 Draft: February 2011Official: September 2011

Through 9/30/2011 Draft: February 2012Official: September 2012


Through 9/30/2012 Draft: February 2013Official: September 2013



Proprietary

ComplexitiesPREPARE

Eligibility for Title IV funding, including federal loan and grant programs, is dependent upon the institution’s cohort default rate (CDR).

Based on the HEOA (Higher Education Opportunity Act) passed on August 14, 2008, the current 2-year definition will be used until there are 3 consecutive CDR rates under the new 3-year definition.

FY 2009 CDR through 9/30/2011 will be the first cohort default rate period measured under the new 3-year definition.

TRANSITION ofCohort Default Rate Definitions

Proprietary

RISK ChallengesProgrammatic Eligibility

All Proprietary Institution Programs except those with a Baccalaureate Degree in Liberal Arts that have been regionally accredited since October 1, 2007; or preparatory courses of study that provide course work necessary for enrollment in an eligible program.

Non-Profit, Public, and Private Institution Programs except programs that lead to a degree; Programs that are at least 2 years in length and fully-transferable to a bachelor’s degree program; or preparatory courses of study that provide course work necessary for enrollment in an eligible program.

Teacher Certification Program Exclusion applies if the program does not lead to a certificate awarded by the institution.

Eligible Program for Gainful Employment34 C.F.R. 668.7(a)(3)(i) A program refers to any educational program offered by the institution under 668.8(c)(3) or (d).

Proprietary

RISK Challenges

A program must pass at least one of the three metrics to remain eligible for federal student aid funding.

Programmatic Eligibility

Gainful Employment Metrics:

Repayment Rate: At least 35% of the former students are repaying their loan, as demonstrated by a balance that declines over the course of the year (prorated if multiple programs or institutions are included in the consolidation calculation.)

Debt-to-Discretionary Income Ratio: The annual loan payment does not exceed 30% of the typical graduates’ discretionary income.

Debt-to-Total Earnings Ratio: The annual loan payment does not exceed 12% of the typical graduates’ total earnings.

Proprietary

RISK Challenges

If a program fails all three of the metrics

Programmatic Eligibility

• After 1 failure: The institution must disclose the amount by which the program missed minimal acceptable performance , the program’s plans for improvement , and establish a 3-day waiting period before students can enroll.

• After 2 failures within 3 years: The institution must tell students in the failing program that their debts may be unaffordable, the program may lose eligibility, and what transfer options exist.

• After 3 failures within 4 years: The program loses eligibility for federal student aid. Institutions cannot reestablish the program’s eligibility for at least 3 years; however, they can continue to operate without federal student aid.

Proprietary

ComplexitiesPREPARE

Eligibility MEASUREMENT ofGainful Employment Programs

• By the 6-digit OPE ID Code (School level, not campus level)

• By the CIP Code established by the National Center for Education (NCES) and assigned to the program and approved by the Secretary of Education

• Credential Level (i.e. undergraduate certificate, associate’s degree, bachelor’s degree, post-baccalaureate certificate, master’s degree, doctoral degree, and first-professional degree)

Proprietary

ComplexitiesPREPARE

EXCLUSIONS for AllGainful Employment Measures

• PLUS Loans made to parent borrowers

• TEACH Grant-related Unsubsidized Loans

• Loans included in an In-school Deferment at any time during the most recent FY

• Loans included in an Military-related Deferment at any time during the most recent FY

• Loans discharged due to the death of the borrower.

• Loans assigned or transferred to the Secretary for discharge as a result of a total and permanent disability of the borrower.

Proprietary

ComplexitiesPREPARE

EXCEPTIONS for Programs with Small Numbers

• 2-year Measures are used if there are 30 or more students in the program at the relevant credential level after exclusions

• 4-year Measures are used if there are fewer than 30 students in the program at the relevant credential level after exclusions

• Programs are exempt if there are fewer than 30 borrowers in the 4-year measures for the program at the relevant credential level after exclusions

Proprietary

ComplexitiesPREPARE

INCLUSIONS for Repayment Rates• FFEL Loans

• Direct Loans• Consolidation Loans that refinanced eligible FFEL or Direct Loans• Loans Paid-in-Full by the Borrower (LPF) if:

• They have never been in default• In the case of a Consolidation Loan when it or any underlying FFEL or Direct Loan

have never been in default • Loans with Payments Made (PML) if:

• They have never been in default• In the case of a Consolidation Loan when it or any underlying FFEL or Direct Loan

have never been in default• Payments made by the borrower during the most recent FY reduce the

outstanding balance of a loan plus any accrued and unpaid interest to an amount that is less than the outstanding balance of the loan at the beginning of the year.

• A borrower is in the process of qualifying for Public Service Loan Forgiveness and submits an employment certification to the Secretary that demonstrates the borrower is engaged in qualifying employment and the borrower made qualifying payments on the loan during the most recently completed FY

• A borrower is making scheduled payments under income-based (IBR) or income-contingent (ICR) or any other repayment plan with a maximum limit of 3% of the total dollar amount for interest-only or negative amortization loans.

Repayment Rate Calculations

OOPB of LPF plus OOPB of PMLOOPB

Proprietary

Determination for inclusion or exclusion is made on a borrower-by-borrower basis for all federal loan borrowers.

Calculation of the REPAYMENT RATE is based on the dollar amounts associated with each borrower within CIP code at the highest relevant credential level.

REPAYMENT RATE =

PREPARE Complexities

The OOPB is the Outstanding Original Principal Balance including outstanding interest on the date the borrower entered repayment.

The determination of principal reduction is based on the outstanding balance at the beginning and end of the fiscal year of the calculation; however those dollar amounts are not used in the calculation.



Calculation Options for CIP's with MORE THAN 30 BORROWERS (Cumulative after exclusions)Sanction

YearPrincipal Reduction

Year Calculation OptionRepayment

YearsDate Entered

Repayment DatesLast Date of Attendance

Standard CDR Servicing

2013FY 2012

OOPB on 10/1/2011OOPB on 9/30/2012

2YP-A(2012, 2013, 2014) FY 2010-2011 10/1/2009-9/30/2011 3/30/2009-3/29/2011 FY 2010 servicing ends 9/30/2012

Servicing is simultaneous

2YP FY 2008-2009 10/1/2007-9/30/2009 3/30/2007-3/29/2009 FY 2008 servicing ended 9/30/2009FY 2009 servicing ends 9/30/2011

2YP-R * FY 2005-2006 10/1/2004-9/30/2006 3/30/2004-3/29/2006 FY 2005 servicing ended 9/30/2006

2014FY 2013

OOPB on 10/1/2012OOPB on 9/30/2013



2YP FY 2009-2010 10-1-2008-9/30/2010 3/30/2008-3/29/2010 FY 2009 servicing ends 9/30/2011


2015FY 2014

OOPB on 10/1/2013OOPB on 9/30/2014





2016FY 2015

OOPB on 10/1/2014OOPB on 9/30/2015



2017FY 2016

OOPB on 10/1/2015OOPB on 9/30/2016


2YP-R * FY 2009-2010 10/1/2008-9/30/2010 3/30/2008-3/29/2010 FY 2009 servicing ends 9/30/2010



Calculation Options for CIP's with LESS THAN 30 BORROWERS (Cumulative after exclusions)Sanction

YearPrincipal Reduction

YearCalculation

OptionRepayment

YearsDate Entered

Repayment DatesLast Date of Attendance

Standard CDR Servicing

2013FY 2012

OOPB on 10/1/2011OOPB on 9/30/2012

4YP FY 2006-2009 10/1/2005-9/30/2009 3/30/2005-3/29/2009 FY 2006 servicing ended 9/30/2007

4YP-R ** FY 2003-2006 10/1/2002-9/30/2006 3/30/2002-3/29/2006 FY 2003 servicing ended 9/30/2004

2014FY 2013

OOPB on 10/1/2012OOPB on 9/30/2013



2015FY 2014

OOPB on 10/1/2013OOPB on 9/30/2014



2016FY 2015

OOPB on 10/1/2014OOPB on 9/30/2015



2017FY 2016

OOPB on 10/1/2015OOPB on 9/30/2016




Proprietary

Required Medical or Dental Internship or Residency


The *2YP-R and *4YP-R calculations are used when a medical or dental internship or residency as identified by the institution is required. For this purpose, a required medical or dental internship or residency is a supervise training program that:

(1) Requires that student to hold a degree as a doctor of medicine or osteopathy, or a doctor of dental science;

(2) Leads to a degree or certificate awarded by an institution of higher education, a hospital, or a health care facility that offers post-graduate training; and

(3) Must be completed before the borrower may be licensed by the State and board certified for professional practice or service.

Calculated for ALL education debts for federal and non-federal loans, including FFEL, Direct, Consolidation, Private, and Institutional Loans.

Proprietary

EARNINGS RATE =

DISCRETIONARY INCOME RATE =

Annual Loan Payment

Mean or Median Annual Earnings – (150% *Poverty Guideline)

Annual Loan Payment

Mean or Median Annual Earnings

Threshold of 12%

PREPARE ComplexitiesDebt-to-Earnings Ratios

Threshold of 30%


Proprietary

Mean or Median Debt


Annual Earnings As a cohort, the HIGHER of…

The Mean or Median Annual EarningsObtained from the Social Security Administration (SSA)

By Student, the LESSER of…

The Total Amount of Debt the Student IncurredOR

The Total Amount of Tuition and Fees

The mean and median debt payment calculations are based on the current student loan interest rate and the credential level of the program:

• 10 year standard repayment calculation for undergraduate, post-baccalaureate certificate or associate’s degree programs

• 15 year standard repayment calculation for bachelor’s and master’s degree programs• 20 year standard repayment calculation for doctoral or first-professional degree programs

Proprietary



Calculation Options for CIP's with MORE THAN 30 BORROWERS (Cumulative after exclusions)

Sanction Year Reporting Year

+ Assumed Earnings Year Calculation Option

Program Completion

YearsProgram Completion Date (Last Date of Attendance)

2013 FY 2012 20112YP FY 2008-2009 10/1/2007-9/30/2009

2YP-R * FY 2005-2006 10/1/2004-9/30/2006

2014 FY 2013 20122YP FY 2009-2010 10-1-2008-9/30/2010

2YP-R * FY 2006-2007 10/1/2005-9/30/2007

2015 FY 2014 20132YP FY 2010-2011 10-1-2009-9/30/2011

2YP-R * FY 2007-2008 10/1/2006-9/30/2008

2016 FY2015 20142YP FY 2011-2012 10-1-2010-9/30/2012

2YP-R * FY 2008-2009 10/1/2007-9/30/2009

2017 FY2016 20152YP FY 2012-2013 10-1-2011-9/30/2013

2YP-R * FY 2009-2010 10/1/2008-9/30/2010

+ Outstanding Question:

Is the earnings based on

information from the prior year or the current year

(reporting year)?

Proprietary



+ Outstanding Question:

Is the earnings based on

information from the prior year or the current year

(reporting year)?

Calculation Options for CIP's with LESS THAN 30 BORROWERS (Cumulative after exclusions)

Sanction Year Reporting Year

Assumed Earnings Year Calculation Option

Program Completion

YearsProgram Completion Date (Last Date of Attendance)

2013 FY 2012 20114YP FY 2006-2009 10/1/2005-9/30/2009

4YP-R ** FY 2003-2006 10/1/2002-9/30/2006

2014 FY 2013 20124YP FY 2007-2010 10/1/2006-9/30/2010

4YP-R ** FY 2004-2007 10/1/2003-9/30/2007

2015 FY 2014 20134YP FY 2008-2011 10/1/2007-9/30/2011

4YP-R ** FY 2005-2008 10/1/2004-9/30/2008

2016 FY2015 20144YP FY 2009-2012 10/1/2008-9/30/2012

4YP-R ** FY 2006-2009 10/1/2005-9/30/2009

2017 FY2016 20154YP FY 2010-2013 10/1/2009-9/30/2013

4YP-R ** FY 2007-2010 10/1/2006-9/30/2010


Proprietary


Draft Debt Measures and Data Corrections:

• Pre-draft Corrections within 30 days: • Accuracy of the data used in the list of students at least 30 days prior to the

release of the draft calculations• Post-draft Corrections within 45 days:

• Accuracy of data used in the list of students• Accuracy of the loan data used to calculate the mean or median debt

Additional Information:

• Institutions may not challenge the accuracy of the income data provided by the SSA

• If the SSA cannot provide income data for any students, the highest income data used for the equivalent number of students will be removed from the calculation

• Alternate income data may be used including:• State data• Survey data supported by an attestation audit• BLS data

Proprietary

RISK Challenges

FY 2009 2-yearCohort Default Rates

Priv

ate

Scho

ols

CDR

UP

15.0

%

Publ

ic S

choo

ls

CDR

UP

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Cham

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You can turn your rates

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Cham

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Ten

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Reputation

Enrollments

Employer Confidence

Student Satisfaction

Loss ofEligibility

$0.00

School Value

30-50% Variation

$$$$$

EVERYTHING What do you have to GAIN or LOSE?

ChallengesRISK

Dropped Students

Graduated Students

Employers

• Reason for Dropping• Potential for Re-enrollment• Potential Problems within the

School Can Be Identified & Corrected

• Student Satisfaction Evaluated• Appropriate Job Placement Services

Improves Placement Rates• Verified Employment Information

for Annual Reporting of Placement Rates and Debt-to-income Ratios

• Employer Satisfaction Evaluated• Potential Issues with Training Can

Be Identified & Adjusted to Fit Employer’s Needs

• Potential for Future Employment Opportunities Improves Placement Rates

Institutional Effectiveness

Improved Satisfaction

Positive Relationships

Who Why What

ACTION What Your School Can Do

PROACTIVE debt management is an INVESTMENT

REACTIVE debt management is a CONSEQUENCE

There is no one MIRACLE for SUCCESSFUL debt MANAGEMENT


Make StudentsRESPONSIBLEFor Their Own

REALITIES



Master promissory notes and electronic processes have had unintended consequences by taking the responsibilities out of the borrowers’ hands.

Get the students involved in the responsibilities:

•Individual Entrance Interviews•Check Disbursement Acknowledgements•Individual Exit Interviews•Address and enrollment updates

Use every opportunity you can during and after enrollment to encourage interest payments during deferments and forbearances.

Encourage payments first. If the borrower can’t make full payments, encourage them to pay the accruing interest at a minimum. You can not require them to do so, but you can encourage the payments.

Repeat the basics MANY times.

Put complicated details in writing.

Make Students Responsible for Their Own Realities



Have every borrower with prior loans bring the loans current before starting school.

If the borrower is in default, have them fully rehabilitate the loan before starting school.

• 9 on-time payments within10 months• Paid-in-Full• Rehabilitated through Consolidation• Getting a new loan after 6 on-time payments does not rehabilitate the loans

for the student or for the school!

Have every borrower sign an In-school Deferment when starting school and when there is a change in their anticipated graduation date.

Have students sign Change of Address Forms for the lenders, servicers, and guarantors.



Skip tracing has become a manual process.

Collect at least 6 different references

Verify the references before disbursing funds

Mail grades and other pertinent information

Send out graduation announcements to “references” collected before graduation

Collect the graduation announcement information through your teachers or student services, not through financial aid

You Can’t Help Borrowers Who You Can’t Find



Borrower Educationand

AccountabilityImproving Borrower Responsibility

BaCfreedom.com

Be A Champion…

Choose Financial FREEDOM

Champion STUDENTS

enjoy the benefits of

having their own website

to develop life skills and

financial literacy that will

enhance their abilities to

succeed in attaining their

financial freedom and in

becoming a CHAMPION for

LIFE!

Introducing…

Highly Effective Proven Successful FINANCIAL LITERACY Curriculum for Students Powered by

BaCfreedom.com

ADVERSE conditionsAre IMPACTING

your student loans

MULTIPLE loan programs servicers loan payments delinquent loans forms to cure loans

If any ONE thing goes WRONG… Everyone LOSES…

StudentsSchools

Taxpayers

http://www.everfi.com/index.php

Teaching ACCOUNTABILITYStudentBenefits

Borrower Education PPT in a colorful 14-slide

presentation that motivates students to make good

decisions for their financial freedom by focusing on

making interest payments, choosing a repayment

schedule that drives long-term success, and advising

them of their rights and responsibilities.

Both poverty and RICHES begin with a THOUGHT

You have a CHOICE to DETERMINE your DESTINY

EDUCATION is a meansfor making DREAMS come TRUE

PAYING student loans is a MEANSfor making FINANCIAL FREEDOM come TRUE

Dream BIG

Live WELL

Be EXTRAVAGANTwith your DETERMINATION

Be CONSERVATIVEwith your FINANCES

CREDIT is an ILLUSIONof having MONEY that you DON’T really have

Reality

Fantasy

Teaching ACCOUNTABILITY

Borrower Education Sheets that include pertinent information

from the Borrower Education PowerPoint in a colorful and

comprehensive 2-sided sheet to give to borrowers during

Entrance and exit Counseling or any other relevant borrower

education sessions.

StudentBenefits


Business Cards in a colorful format for

students to carry with them so they can quickly and easily contact Champion College Services if they

need any type of assistance. Space is

provided so they can fill in servicer information or

school information.

StudentBenefits


Set of 3 Awareness Postersare colorful in their 16 x 20 size and help students consider the impact that paying their student

loans has on their lives.

StudentBenefits

Thank You!For the PRIVILEDGE of

Helping Your Students Become CHAMPIONS!

PROACTIVE debt management is an INVESTMENT

REACTIVE debt management is a CONSEQUENCE

There is no one MIRACLE for SUCCESSFUL debt MANAGEMENT

800.761.7376 ChampionCollegeServices.com

Ms. Mary Lyn Hammer’s belief that education is the vehicle for making dreams come true has led her in a passionate fight, that began in 1987, rectifying problems in the higher education industry to insure future participation for all students. Her innovative “Hands On” Default Management Program is recognized by the Department of Education for its remarkable results. Ms. Hammer is the Owner, Founder, President and CEO of Champion College Services, an international company offering default prevention for Federal and private student loans, job placement verification, skip tracing, consulting services, and custom surveys for students, alumni, and employers. She specializes in staff training, program development, and default prevention operations. She has participated in training sessions and workshops for numerous state, provincial, regional, national, and private associations in both the U.S. and Canada in a continued effort to share experiences and knowledge. Ms. Hammer was active in aiding the Department of Education in drafting language for default management that was in effect from 1989 until 1996 (now known as “Subpart M”); she has served three times on negotiated rulemaking committees and was instrumental in working with the Department on regulatory language for cohort default rate appeals, school-based loan issues, and the Cohort Default Rate Guide; and she has worked closely with Congressional Representatives and key staff at the U.S. Department of Education on many issues over her 20 year career in the higher education industry to insure program integrity and access to low income students. Her accomplishments include the 1989 nomination for the Member of the Year for the National Association of Trade and Technical Schools, the 1998 Outstanding Associate Member for the Arizona Private School Association, the 2000 Best Associate Member Participation for the Arizona Private School Association, the Millennium (2000) and 2006 editions of Who’s Who in Executives and Professionals for both the U.S. and Canada, the 2000 Wall Street Journal’s Businessman of the Year Award for Arizona, the 2005 CCA National Achievement Award for the Allied Member of the Year, and the 2007-2008 Best Associate Member Participation for the Arizona Private School Association. She has been elected four times to the Board of Directors for the Career College Association (CCA). Additionally, she serves on the Board of Directors for the Northwest Career College Federation (NWCCF) and is the Charter Member and former Chairwoman for the Higher Education Allied Health Leaders (HEAL) Coalition.

(800) 761-7376 4600 S. Mill Avenue, Suite 180, Tempe, Arizona 85282 [email protected]

Biography of President and CEO

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Presenter: Mary Lyn Hammer Proprietary A PLAN of ACTION Cohort Default Rates & Gainful Employment.

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