Challenging Cohort Default Rate Data
In case you missed the April edition of the OCAP Outlook, the Department of Education (ED) recently released the FY 2011 2-year Draft Cohort Default Rates (CDR) and the FY 2010 3-year Draft CDRs. Your institution now has an opportunity to challenge the draft CDR data using the electronic Cohort Default Rate Appeals (eCDRA) process.
- Challenges to the FY 2011 2-year draft CDR are due by May 9.
- Challenges to the FY 2010 3-year draft CDR are due by May 16.
If your institution contests the CDR data, you can use the eCDRA process and the Incorrect Data Challenge guide. You'll also be required to provide evidence to the data manager (the guarantor or ED servicer) regarding removal from the cohort. To reduce the CDR, schools generally reduce the number of defaulted borrowers (the numerator in the CDR equation) or raise the total number of borrowers in the cohort (the denominator in the CDR equation).
Once your institution has registered its challenge through the eCDRA process, the challenges will be routed to the appropriate guarantor or ED servicer. That guarantor or servicer has a window of time to respond to your institution's challenge and request additional information. Once the guarantor or servicer responds, your institution can request additional information from the guarantor or servicer. When all of your institution's issues have been addressed, ED will review and close the challenge.
Your school will not have a second opportunity to submit an incorrect data challenge when final rates are issued. Your school will only be able to challenge any new data that appears with the final rate that they believe is incorrect.
Here are a few things to look for when challenging your draft CDR:
- Look at the Lender Record Detail Report (LRDR) coding closely. A "B" at the end of the top line indicates the borrower is in his/her second year of graduate/professional school. A "B" at the end of the bottom line indicates the borrower is included in both the numerator and denominator.
- If the borrower is listed multiple times, only one loan should have a "B" listed in the bottom line. The rest of the loans for the borrower should have an "E" (eligible, not counted) if defaulted or a "D" (denominator only) if not defaulted.
- Did the borrower default and then rehabilitate his/her loan in the cohort period? If so, the borrower should not be included in the numerator. If a borrower consolidates or pays the loan in full, even within the cohort, he/she will still be counted in the numerator.
- Did the borrower pass away before entering default? If so, and there is proof the borrower passed away (e.g., death certificate), the borrower should not be included in the numerator.
If you need assistance with the eCDRA process, please contact ED's Default Prevention and Management hotline at 202.377.4259 or send an email to fsa.schools.default.management@ed.gov.
Mary Heid
Director for Default Prevention, Compliance & Training Services
Oklahoma College Assistance Program (OCAP)
P.O. Box 3000 | Oklahoma City, OK 73101-3000
mheid@ocap.org | www.ReadySetRepay.org