Decoding CDR Reports and
Correcting Data
Why Review Your CDR Data
Administrative capability
– High CDR could result in
•
•
•
•
Adverse publicity
Loss of Title IV eligibility
Loss of access to private loan funds
Extra work
Why Review Your CDR Data
Administrative capability
Better-quality decision-making
– Correct data
– Accurate data
– Timely data
Why Review Your CDR Data
Administrative capability
Better-quality decision-making
Better service to students
– When borrowers default
• Pay more in interest and collections fees
• Government can seize wages, tax refunds, Social
Security, and disability benefits
Objectives
• Understand Cohort Default
Rate (CDR) cycle
• Decode Loan Record Detail Report
• Learn how to collect, compare, and
correct data
• Know common appeal errors to avoid
Understanding the Cohort
Default Rate Cycle
What Is a Cohort Default Rate?
The Numerator is the
number of Stafford loan
borrowers from the
denominator who default
within a cohort period
The Denominator is the
number of Stafford loan
borrowers who enter
repayment within a
cohort period
All borrowers entered
repayment in 2011
= Did not default
in 2011-2013
= Defaulted
in 2011
= Defaulted
in 2012
= Defaulted
in 2013
What Is a Cohort Default Period?
2-year CDR
Example FY2011
3-year CDR
Example FY2011
Borrowers who entered
repayment between
10/01/2010 and 9/30/2011
and who defaulted between
10/01/2010 and 9/30/2012
Borrowers who entered
repayment between
10/01/2010 and 9/30/2011
and who defaulted between
10/01/2010 and 9/30/2013
Borrowers who entered
repayment between
10/01/2010 and
9/30/2011
Borrowers who entered
repayment between
10/01/2010 and
9/30/2011
What Is a Cohort Default Rate
Cycle?
Official Rate Cycle
Draft Rate Cycle
February
Draft default rates released
to schools only
August
September
January
Official rates released to
schools and the general public
• Department sends draft and official cohort
default rates to schools
– Eligible to participate in any of the Title IV programs
– Borrower in repayment in the current or any of the
past cohort default rate periods
Source: CDR Quick Reference Guide
What Is a Cohort Default Rate
Cycle?
Official Rate Cycle
Draft Rate Cycle
February
Draft default rates released
to schools only
August
September
Official rates released to
schools and the general public
• Official cohort default rates are available at:
– ed.gov/FSA/defaultmanagement/cdr.html
Source: CDR Quick Reference Guide
January
No Sanctions or Benefits
Associated with Draft CDR
• Keep in mind
– Schools that fail to challenge accuracy of
draft rate data through incorrect data
challenge can’t contest accuracy of official
rate data
Publication of CDRs
Fiscal
Year
(FY)
Denominator
# in
Repayment
Numerator
# in Default
Draft CDR
Publication
Date
Official CDR
Publication
Date
Rate Used for
Sanctions
2010
10/01/09 – 09/30/10
3-yr: 10/01/09 – 09/30/12
3-yr: Feb 2013
3-yr: Sept 2013
N/A
2011
10/01/10 – 09/30/11
2-yr: 10/01/10 – 09/30/12
3-yr: 10/01/10 – 09/30/13
2-yr: Feb 2013
3-yr: Feb 2014
2-yr: Sept 2013
3-yr: Sept 2014
2-yr rate (25%)
3-yr rate (30%)
2012
10/01/11 – 09/30/12
3-yr: 10/01/11 – 09/30/14
3-yr: Feb 2015
3-yr: Sept 2015
3-yr rate (30%)
How Are Schools Notified?
• CDR notification packages
– Sent electronically to all domestic schools
(eCDR)
• Student Aid Internet Gateway (SAIG)
• 5 business days to report problems
• Challenges, adjustments, and appeals begin 6th
day following announced transmission date
– Posted on IFAP (ifap.ed.gov)
What is Included in the eCDR?
• CDR package includes
• CDR package includes
SHDRLROP
– Cover
letter
– Cover letter
– Loan
Record Detail
SHCDRROP
– Two Loan Record Detail Reports (LRDR)
(LRDR)
– Reports
SHCDREOP
• Reader-friendly
• Reader-friendly
• Extract-type
• Extract-type
Decoding the Loan Record
Detail Report
Loan Record Detail Report (LRDR)
• Contains borrower information for Stafford
loans used to calculate draft or official
cohort default rate
– Includes borrower’s
•
•
•
•
Name, Social Security number
Date borrower entered repayment
Date of default (if applicable)
Loan type
– Borrowers with multiple loans counted only
once
Review LRDR
• Check for accuracy
• Compare to school records
– Repayment Date
– Default Status
– Cancellations/Refunds
What is Included in the eCDR?
• Beginning with the
FY 2009 cohort
– MUST use eCDR
appeals to prepare
and submit
challenges or
adjustments
Reader-Friendly LRDR
Loan Record Detail Report –
Data Manager
• Three-digit code used to identify entity
reporting the information
Guaranty Agency
Department of Education
Loan Record Detail Report –
Repayment Date
• Indicates when borrower began repayment
• Determines if loan is included in denominator
Loan Record Detail Report –
Default Date
• Indicates the date
– Direct Loan considered in default based on past due status
OR
– Guarantee agency paid default claim to lender for FFELP Loan
Loan Record Detail Report –
CDR Usage
• Indicates how loan is included in calculation
–
–
–
–
“D” Denominator only
“B” Both Numerator and Denominator
“N” Not Used
“E” Eligible, but not counted
Important Codes to Know
Source: CDR Guide, page 2.3-7
Important Codes to Know
Source: CDR Guide, page 2.3-8
Collecting and Comparing
Data
Collecting the Data
• Determine data that needs to be captured
– Last date of attendance (LDA)
– Less than half-time date (LTH)
– Withdrawal date (WD)
– Date entered repayment (DER)
– Claim paid date/default date (CPD/DD)
• Spreadsheet or database to collect data
– Implement this process early
Collecting the Data
Determine where
to find data
– Internal resources
available on-campus
– External resources
• NSLDS
• Servicer reports
• Guaranty agencies
Possible Errors on LRDR
• LRDR incorrectly:
– Reports data element and data element
should be changed
– Includes borrower whose repayment date
does not fall within cohort fiscal year;
borrower removed from calculation
– Excludes borrower who entered repayment
within cohort; borrower added to calculation
Should the Loan be Included in
FY09 3-year CDR?
Darin
• Graduated from school 11/4/2008
• NSLDS reveals transferred to another school
2/4/2009
LDA
11/4/2008
Date
entered
repay
Estimated
5/5/2009
Transferred
to other
school
2/4/2009
Date entered
repayment
Actual
5/13/2010
Default
date
5/8/2011
Should the Loan be Included in
FY09 3-year CDR? No
Darin
If date of repayment is delayed by re-enrolling in
school prior to the end of grace, inclusion in a
CDR calculation is also delayed
Y
Defaulted between 10/1/2008 – 9/31/2011
• Defaulted 5/8/2011
N
FY2009 (10/1/2008 – 09/31/2009)
• Date Darin entered repayment 5/13/2010
Should the Loan be Included in
FY09 3-year CDR?
Kara
• Left school 11/4/2008
• Transferred to another school 1/12/2010
• Loans deferred 1/12/2010
LDA
11/4/2008
Date entered
repayment
5/5/2009
Transferred
to other
school
Loan deferred
1/12/2010
Should the Loan be Included in
FY09 3-year CDR? Yes
Kara
Deferments or forbearances do not alter the date
the borrower entered repayment
N
Defaulted between 10/1/2008 - 9/31/2011
Y
FY2009 (10/1/2008 – 09/31/2009)
•
No default
• Date Kara entered repayment 05/05/2009
Should the Loan be Included in
FY09 3-year CDR?
Kyle
• Withdrew from school 6/1/2008
• Defaulted on loans 5/27/2010
• Consolidated three loans 12/4/2010 in order to
regain Title IV eligibility
LDA
6/1/2008
Date entered
repayment
Default
date
Consol
date
Consol
enters
repay
12/2/2008
5/27/2010
12/4/2010
2010
Should the Loan be Included in
FY09 3-year CDR? Yes
Kyle
The date underlying loans entered repayment is
the date used in the cohort default rate
calculation
Y
Defaulted between 10/1/2008 – 9/31/2011
• Kyle defaulted 5/27/2010
Y
FY2009 (10/1/2008 – 09/31/2009)
• Date Kyle entered repayment 12/02/2008
Should the Loan be Included in
FY09 3-year CDR?
Bethany
• Graduated from school 6/1/2008
• Paid loan in full on 7/1/2008
LDA
Date entered
repayment
Harrah’s
6/1/2008
12/2/2008
Loan paid in
full 7/1/2008
Should the Loan be Included in
FY09 3-year CDR? No
Bethany
The paid-in-full date becomes the new repayment date.
Same is true for loans discharged due to death,
bankruptcy, disability
N
Defaulted between 10/1/2008 – 9/31/2011
• No default
N
FY2009 (10/1/2008 – 09/31/2009)
• Date Bethany paid in full 07/01/2008
Correcting Data
Challenges of Draft CDR
Incorrect Data Challenge (IDC)
– Used to correct errors on draft CDR
– Submitted to guarantors (FFEL) and/or DL
servicers via eCDR appeals within 45 days of
timeframe begin date
• Relevant information for each borrower challenged
• Supporting documentation for each borrower
challenged
• CEO Certification Letter
Challenges of Draft CDR
Participation Rate Index Challenge (PRI)
– Only available if school potentially subject to
loss of eligibility (or provisional certification)
based on draft rates
– Must send completed PRI Challenge to U.S.
Department of Education within 45 days of
timeframe begin date
• PRI Challenge Spreadsheet (CDR Guide page
4.2 – 8)
• Letter
Adjustments of Official CDR
Uncorrected Data Adjustment (UDA)
– Ensures school’s official cohort default rate
calculation reflects changes correctly agreed
to as result of incorrect data challenge
– Must submit UDA to Department within 30
calendar days of timeframe begin date via
eCDR appeals
Adjustments of Official CDR
New Data Adjustment (NDA)
– Allows school to challenge accuracy of “new data”
included in most recent official CDR
• Compare LRDR of draft CDR to LRDR of official CDR to
determine if new data reported correctly
– Must submit NDA to Data Manager via eCDR appeals
within 15 days of timeframe begin date
• Relevant information for each borrower challenged
• Supporting documentation for each borrower challenged
• CEO Certification Letter
Appeals of Official CDR
Loan Servicing Appeal (LS)
– Alleges school’s official cohort default
rate includes defaulted loans considered
improperly serviced for cohort default rate
purposes
– Example
• Borrower never made loan payment and school
can document that lender/servicer failed to
complete due diligence
Appeals of Official CDR
Loan Servicing Appeal (LS)
– Must send request for loan servicing records
to Data Manager and Department within 15
days of timeframe begin date
Appeals of Official CDR
Loan Servicing Appeal (LS)
– Data Manager notifies school and Department
within 20 days of receipt
• Fees for providing records
• List of representative sample
• Description of how sample was chosen
– School must pay fee, if charged, within 15
days of data manager notification
Appeals of Official CDR
Erroneous Data Appeal (ER)
– Available if school is subject to loss of
eligibility (or provisional certification) based on
official rates
– School previously challenged accuracy of
data as part of Incorrect Data Challenge
– Review of loan record detail reports for draft
and official rates show new data
Appeals of Official CDR
Erroneous Data Appeal (ER)
– School must send Erroneous Data Appeal
allegations to Data Manager within 15 days of
timeframe begin date
•
•
•
•
Erroneous Data Appeal spreadsheet
Relevant pages of Loan Record Detail Report
Supporting documentation
Letter
Appeals of Official CDR
Economically Disadvantaged Appeal (EDA)
– Available based on loss of eligibility or notice of
second successive official rate potentially subjecting
school to provisional certification
– School must submit independent auditor’s written
opinion to Department within 30 days of timeframe
begin date
• Spreadsheet of students that qualify to be included
– School’s low-income rate and placement rate
(non-degree-granting school)
– School’s low-income rate and completion rate
(degree-granting school)
Appeals of Official CDR
Participation Rate Index Appeal (PRI)
– Only available if school is subject to loss of
eligibility or provisional certification based on
official rates
– Must send completed Participation Rate Index
Appeal to Department within 30 days of
timeframe begin date
• Participation Rate Index Appeal spreadsheet
• Letter
Appeals of Official CDR
Average Rates Appeal
– Subject to sanctions based on three consecutive
CDRs that meet or exceed relevant threshold if
• At least two official cohort default rates are average rates
• CDRs would have been less than relevant threshold if calculated as
non-average rates
– School must send completed Average Rates Appeal
to Department within 30 days of timeframe begin date
• Supporting documentation
• Certification
Appeals of Official CDR
Thirty or Fewer Borrowers Appeal
– Department automatically determines if school
meets criteria for thirty or fewer borrowers appeal
– School disagrees with Department’s
determination
• Must send completed Thirty or Fewer Borrowers Appeal to
Department within 30 days of timeframe begin date
– Supporting documentation
– Certification
Common Appeal Errors to
Avoid
Avoid Two Common Errors
1) Check NSLDS for student's
enrollment status
– Students who have withdrawn or dropped to
less than half-time status may be taking
classes that maintain their eligibility elsewhere
Two Common Errors
2) If two entities are listed for loan, make
sure to send challenges to correct entity
– Indicated with usage code of “B” rather than
“E”
– Sending challenge to wrong servicer or
guarantor can result in missed deadline
Conclusion and Resources
Take Action
• Review LRDR
• Compare defaulted borrowers to your
own system to ensure borrowers are
listed correctly
• Submit timely appeals
• Analyze defaulted borrowers to see
if changes are needed in default
management plan
Resources
Default Prevention and Management
– ifap.ed.gov/DefaultManagement/Default
Management.html
eCDR Appeals System
– ecdrappeals.ed.gov
Thank You!