Eight Steps to Appeal

If you believe that your cohort default rate is incorrect, first review information about cohort default rate calculations in the U.S. Department of Education Cohort Default Rate Guide.

Then take these eight steps to review your cohort default rate data from the Department and, if appropriate, issue an incorrect-data challenge:

  1. Download the Department’s Electronic Loan Record Detail Report. The Department offers information about downloading the report.
  2. Collect and review any relevant internal enrollment and repayment data. Such data could 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 (link to: https://www.nslds.ed.gov/nslds_FAP/secure/logon.jsp) borrower enrollment history or borrower aid history.
      • Lender or servicer records.
  3. Create a spreadsheet with data about borrowers in the cohort and when they entered repayment, based on your school’s data.
  4. Compare the internal data you gathered 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.
  5. Access the Department of Education’s eCDR Appeals Web-based application. View eCDR resource from the Department.
  6. Determine what kind of error you believe has been made. Allegations usually fall into one of following categories:
      • Data incorrectly reported
      • Data incorrectly excluded.
      • Data incorrectly included.
  7. Review and confirm your data. You must provide documentation to prove each allegation.
  8. Gather supporting documentation. Submit your incorrect-data challenge through eCDR. You should maintain the documentation that verifies the receipt of the incorrect-data challenge as well as all electronic and hard-copy documentation submitted as a part of the incorrect-data challenge process. You should note that guidance published in the Department’s Cohort Default Rate Guide directs guarantors to decline to review a school’s challenge that is not submitted within the 45-calendar-day time frame.