Ten Steps to Review Cohort Default Rate Information

By Anne Fischer, USA Funds Consultant

With today’s release of draft 2011 three-year cohort default rates, you’ll want to compare your school’s own records against the information from the U.S. Department of Education. Examine the data and, if appropriate, submit an incorrect data challenge.

Let’s review 10 key steps that USA Funds® recommends you follow in evaluating your cohort default rate data from the Department and potentially issuing a challenge:

1. If you believe that your cohort default rate is incorrect, review information about cohort default rate calculations in the Department’s Cohort Default Rate Guide.

2. Download the Department’s Electronic Loan Record Detail Report (DRCO35, School Cohort Default Rate History Report — extract version, message class SHCDREOP). The Department offers information about downloading the report.

3. Collect and review any relevant enrollment and repayment data. This data should include the following:

  • Records from the financial aid office or the registrar’s office.
  • Student Status Confirmation Reports or other electronic enrollment reports.
  • Transfer requests for new students and former students.
  • National Student Loan Data System borrower enrollment history or borrower aid history.
  • Lender or servicer records.

4. Create a spreadsheet with data about borrowers in the cohort and when they entered repayment, based on your school’s data.

5. Compare the internal data against the data on the LRDR. If there is data on the LRDR that you believe is incorrect, based on your internal data, you should contest the LRDR data.

6. Access the Department’s eCDR appeals Web-based application. The Department is the data manager for all Direct Loans and offers information about filing appeals through eCDR.

7. Determine what kind of error you believe has been made. Allegations usually fall into one of these categories:

  • Data incorrectly reported.
  • Data incorrectly excluded.
  • Data incorrectly included.

8. Review and confirm your data.

9. Gather supporting documentation. You must provide documentation to prove each allegation.

10. Submit the incorrect data challenge. The Department’s guidelines set a 45-calendar-day time frame for submitting incorrect data challenges — which means you have until April 11, 2014, to challenge your draft 2011 three-year cohort default rate. Make sure you maintain documentation that verifies the receipt of the incorrect data challenge, and all electronic documentation that you submitted as part of the incorrect data challenge.

If you need additional help as you review cohort default rate information, contact USA Funds.

A Wednesday, Feb. 19, webcast can help you as you examine your draft cohort default rates and look to improve future rates. Learn more and register. USA Funds also offers a variety of default prevention tools and solutions.

And for more information about USA Funds’ response to any of your cohort default rate challenges, contact Scott Lauth, USA Funds compliance specialist, by email or by calling (317) 806-1259.