February 10, 2011

Cohort Rates Released and New Challenge Process Explained

Cohort Default Draft Rate Timeline

The Department of Education (ED) outlined several important dates related to cohort default rate calculations in the Oct. 20 NSLDS Technical Update (PDF). Don’t forget to mark the dates on your calendar.

FY09 Draft Cohort Default Rate:

• Calculation: Jan. 15, 2011
• Release: Feb. 14, 2011

FY09 Official Cohort Default Rate:

• Calculation: July 30, 2011
• Release: Sept. 12, 2011

The 2009 Cohort Default Draft Rate challenge period opens on the sixth business day after the rates are released and closes 45 days later. This year, the challenge period will open Feb. 23 and close April 8.

The Challenge Process

During the challenge period, schools may submit incorrect data challenges (IDC), and request both verification of date and correction of errors from guarantors and ED’s servicers.

New this year: Note that schools must now use the Electronic Cohort Default Rate (eCDR) appeals system to file all challenges. Paper challenges will not be reviewed. ED outlined several benefits associated with the eCDR system:

• Reduced risk of sending Privacy Act data to the wrong entity.
• Ease of use in submitting a challenge/adjustment. For example, because the system will automatically bundle the school’s adjustments to the data manager listed in the LRDR (guaranty agencies/DL Servicer), schools do not need to prepare separate challenges or adjustment transmittals for each data manager when submitting electronically.
• Faster review time by ED and the data managers.
• Increased likelihood that submissions will be routed properly. For example, either the school or a data manager can use the system to change a loan’s holder if it is incorrect in the LRDR, which prompts the system to automatically reroute the adjustment request.

Instructions for filing IDCs are outlined in ED’s e-CDR Appeals IDC User Guide (PDF). IDCs are filed after the draft rates are released in February. Uncorrected Data Adjustments and New Data Adjustments filed after the final rates are released in September must also use the eCDR appeals system.

If you have questions about the eCDR Appeals system, consult the ED’s Frequently Asked Questions webpage. For more information about cohort default draft rate challenges, contact Matt McCreary at 405.234.4296 or mmccreary@ogslp.org.

2004-2008 Cohort Default Rates

ED’s Dec. 20 announcement provided an explanation and summary of the three types of default rates – Cohort, Budget Lifetime and Cumulative Lifetime – for the cohort years 2004-2008.

Release of 2008 Cohort 3-Year Trial Rate

ED released the 2008 Cohort Trial rate on Feb. 4. This is the first cohort to have a 3-year trial rate. These rates are informational only and include no benefits or sanctions. Benefits and sanctions begin with the 2011 Cohort 3-Year Rate issued in 2014.