150% Direct Loan Legislation Update

In 2013, the U.S. Department of Education announced changes to the enrollment reporting process used to complete National Student Loan Data System (NSLDS) compliance reporting.

On February 27 of this year, the department released the final requirements for these 150% enrollment reporting changes in an electronic announcement, with some of the requirements subject to compliance as early as April 14, and the remainder by July 1.

Since the announcement, institutions have expressed concerns regarding the unrealistic six-week turnaround to make the necessary changes to comply with the new reporting requirements. Especially considering these process updates are commonly conducted through the National Student Clearinghouse and facilitated by data extraction specifications that must be created by institutions' student information system (SIS) providers or institutions’ homegrown system developers.

Additionally, practitioners tasked with implementing the process changes have raised questions about the definitions of new data elements such as "Program Enrollment Effective Date" and "Program Published Length."

In response to growing concerns, AACRAO sent a letter to the Education Department, with the support of the National Association of Financial Aid Administrators (NASFAA) and the American Council of Education (ACE), requesting additional clarification of these new definitions as well as an extension for the compliance deadline in order for schools to build, test, and correct their processes.

The department has signaled its willingness to extend or make soft the current deadlines for compliance. We also anticipate that the department will issue additional guidance on the definitions of the new data elements in the next few weeks.

AACRAO will alert the membership as soon as an official announcement has been made.