Adjustment, Chapter
Page 4.11 - 1
Chapter 4.11 Challenge, Adjustment, and Appeal Tools
What types of loan record detail report allegations may a school submit
as a part of an incorrect data challenge, new data adjustment, or
erroneous data appeal?
The school alleges that the loan record detail report incorrectly
reports a data element and the data element should be
changed (incorrectly reported).
The school alleges that the loan record detail report incorrectly
includes a borrower whose repayment date does not fall within
the cohort fiscal year and the borrower should be removed
from the cohort default rate calculation (incorrectly included).
The school alleges that the loan record detail report incorrectly
excludes a borrower who entered repayment within the cohort
fiscal year and the borrower should be added to the cohort
default rate calculation (incorrectly excluded).
Page 4.11 - 2
Challenge, Adjustment, and Appeal Tools Chapter 4.11
Does a school need to submit loan record detail report pages with its
allegations?
incorrectly reported,
incorrectly included, or
incorrectly excluded.
Adjustment, and Appeal Tools
In certain circumstances the school must submit multiple loan record CHAPTER 4.11 - Challenge,
detail report pages from the same cohort fiscal year. If the borrower
has multiple loans that appear on more than one page, the school
should include each page where the borrower appears. If the borrow-
er is missing from the cohort default rate calculation, and the missing
borrower would have appeared at the bottom of one page or the top
of the next page, the school should include both pages.
Page 4.11 - 3
Chapter 4.11 Challenge, Adjustment, and Appeal Tools
Page 4.11 - 4
Challenge, Adjustment, and Appeal Tools Chapter 4.11
What supporting
What is the school
Allegation What does the school allege? documentation should
requesting?
the school enclose?
Incorrect last date That the correct change in That the date entered Documentation of the
of attendance or enrollment status was timely repayment be changed enrollment status change
less-than-half-time submitted to the data manager
enrollment date or NSLDS
Unexpired grace That the borrower re-enrolled That the date entered Documentation of the
period at least half-time at their school repayment be changed enrollment status change
or another school before the
grace period ended
Death, disability, That the loan was discharged That the date entered Documentation that the
bankruptcy, or other before the borrower entered repayment be changed loan was discharged
type of discharge repayment to the date the loan was before the scheduled
before expiration discharged date entered repayment
of grace period
Loan paid in full That the loan was paid in full That the date entered Documentation that the
prior to expiration before the borrower entered repayment be changed loan was paid in full
of grace period repayment to the date the loan was before the scheduled
paid in full date entered repayment
Repayment began That the borrower began That the date entered Documentation showing
before expiration making scheduled loan repayment be changed that the borrower made
of grace period payments before the expiration to the date the borrower a full scheduled payment Adjustment, and Appeal Tools
of the grace period started repayment before the scheduled CHAPTER 4.11 - Challenge,
date entered repayment
Federal SLS loan That the borrower's Federal That the date entered Documentation showing
and Federal Stafford SLS loan and Federal Stafford repayment be changed that the loans were
Loan not linked Loan should be linked because so that the Federal SLS obtained in the same
the loans were obtained during loan and Federal Stafford period of continuous
the same period of continuous Loan are linked in the enrollment
enrollment same cohort default rate
calculation
Page 4.11 - 5
Chapter 4.11 Challenge, Adjustment, and Appeal Tools
Page 4.11 - 6
Challenge, Adjustment, and Appeal Tools Chapter 4.11
Page 4.11 - 7
Chapter 4.11 Challenge, Adjustment, and Appeal Tools
If the Direct Loan servicer concludes that the loan’s status has been
determined accurately, and the loan meets the criteria to be counted
as a defaulted loan, the Direct Loan servicer will send the school the
repayment record for the loan. The school then reviews that record
and, if it disagrees or questions the determination, the school may
request clarification from the Direct Loan servicer within 15 calendar
days. The Direct Loan Servicer then has 20 calendar days to respond
to the school. If the Direct Loan servicer believes the loan’s status has
been determined incorrectly and agrees to remove the borrower
from the numerator of the cohort default rate calculation, the Direct
Loan servicer will not send repayment information to the school.
Page 4.11 - 8
Challenge, Adjustment, and Appeal Tools Chapter 4.11
Spreadsheet Tools
using the loan type codes from Figure 2.3.6 in Chapter 2.3,
“Loan Record Detail Report;”
Page 4.11 - 9
Chapter 4.11 Challenge, Adjustment, and Appeal Tools
There are also several optional things that can be done when creat-
ing and completing the spreadsheet to make the spreadsheet easier
to read. They include
making sure the columns are wide enough to fit all text,
Page 4.11 - 10
Challenge, Adjustment, and Appeal Tools Chapter 4.11
You should note that some spreadsheet programs limit the amount
of information that can be placed in a header. If you get an error
message that states the header has exceeded the maximum space
limit, try abbreviating some of the titles in the header. As an alterna-
tive, you can list some of the titles in the first few lines of the
spreadsheets instead of in the header. However, if you list titles in the
first few lines of the spreadsheet, make sure you set the spreadsheet
program to repeat those lines on all of the pages of the spreadsheet.
There are also full-sized blank spreadsheets at the end of this chapter.
A school or data manager may photocopy and use the full-sized
blank spreadsheets instead of creating their own spreadsheets. If a
school or data manager photocopies and uses the full-sized blank
spreadsheet, they should remember to return the full-sized blank
spreadsheet to this chapter of the Guide. They should also remember
to circle the appropriate titles on the spreadsheet, since many of the
spreadsheets are designed to be multi-purpose, covering several
different challenge, adjustment, or appeal types.
Although a school is required to submit a hardcopy of a spreadsheet Adjustment, and Appeal Tools
to a data manager, some data managers may be willing to accept an CHAPTER 4.11 - Challenge,
electronic copy of a spreadsheet in addition to the hardcopy of a
spreadsheet. Submitting an electronic copy in addition to the hard-
copy may speed processing. A school should contact the relevant
data manager to see if the data manager will accept an electronic
copy in addition to the hardcopy.
Page 4.11 - 11
Chapter 4.11 Challenge, Adjustment, and Appeal Tools
Left-side Header Titles: Left-side Header: Enter the titles shown in Figure 4.11.6. After
Type: each title, enter the information appropriate to that title.
Cohort FY:
From: Right-side Header: Enter the titles shown in Figure 4.11.6.
Code:
To:
After each title, enter the information appropriate to that title.
Code: The information cannot be entered until the remainder of the
spreadsheet is created and completed. After “Number of
Right-side Header Titles: Borrowers:” enter the borrowers from Column A. Do not count
Number of Borrowers: a borrower more than once. After “Number of Loans:” enter the
Number of Loans: total loans from Column D.
New Data Adjustment Column A, Borrower’s SSN: Enter the SSNs of all the borrowers.
• School to Data Manager
• Data Manager to School
Column B, Borrower’s Name: Enter the names of the individuals
Erroneous Data Appeal whose SSNs are listed in Column A.
• School to Data Manager
• Data Manager to School
Column C, Type of Loan: Enter the code for the loan.
• School to Default Management
Page 4.11 - 12
Challenge, Adjustment, and Appeal Tools Chapter 4.11
Column H, CPD, DD, ICRD, or N/A: Enter the CPD (claim paid date),
DD (default date), or ICRD (Income Contingent Repayment
date), or enter “N/A” if the loan has not defaulted, based on the
school’s records or the data manager’s records for each borrow-
er listed in Column A.
Column M, Data Manager Code: Enter the code for the data
manager that sent the letters listed in Column D. Include this
column when creating an erroneous data spreadsheet to
Default Management.
Page 4.11 - 13
Chapter 4.11 Challenge, Adjustment, and Appeal Tools
A B C D E
Student's Student's Loan Type
Student's Enrollment Dates Loan Period
1 SSN Name (if any)
2
3
4
5
6
Date ___/___/_____ Page __ of ___
Left-side Header Titles: Left-side Header: Enter the titles shown in Figure 4.11.7.
Type: After each title, enter the information appropriate to that title.
Cohort FY:
From:
Code:
Right-side Header: Enter the titles shown in Figure 4.11.7.
To: After each title, enter the information appropriate to that title.
Code: After “Cohort Default Rate” enter the cohort default rate used
in the participation rate index challenge or the participation
rate index appeal. After “12-Month Period” enter the selected
Right-side Header Titles: 12-month period. The information in the next three lines cannot
Cohort Default Rate: be entered until the remainder of the spreadsheet is created
12-Month Period: and completed. After “Total Borrowers:” enter the borrowers
Total Borrowers:
from Column D. After “Total Regular Students:” enter the total
Total Regular Students:
PRI: students from Column A. After “PRI:” enter the participation rate
Adjustment, and Appeal Tools
CHAPTER 4.11 - Challenge,
Participation Rate Index Challenge Footer: Include a footer showing the date the spreadsheet was
• School to Default Management prepared and the page number.
Participation Rate Index Appeal
• School to Default Management
Page 4.11 - 14
Challenge, Adjustment, and Appeal Tools Chapter 4.11
Column D, Loan Type (if any): Enter the type of loan (FFEL or DL)
for those students in Column A who received loans with a loan
period that overlaps the selected 12-month period. Enter “No” if
the student did not receive a loan or the loan period does not
overlap the 12-month period. These are the borrowers who will
be included in the numerator of the participation rate index.
Page 4.11 - 15
Chapter 4.11 Challenge, Adjustment, and Appeal Tools
A B C D E F
Borrower's Borrower's Type of Number Date Data Manager Data Manager
1 SSN Name Loans of Loans Agreed Code
2
3
4
5
6
Date ___/___/_____ Page __ of ___
Left-side Header Titles: Left-side Header: Enter the titles shown in Figure 4.11.8.
Type: After each title, enter the information appropriate to that title.
Cohort FY:
From: Right-side Header: Enter the titles shown in Figure 4.11.8.
Code:
After each title, enter the information appropriate to that title.
To:
Code: The information cannot be entered until the remainder of
the spreadsheet is created and completed. After “Number of
Right-side Header Titles: Borrowers:” enter the borrowers from Column A. Do not count
Number of Borrowers: a borrower more than once. After “Number of Loans:” enter the
Number of Loans: total loans from Column D.
Page 4.11 - 16
Challenge, Adjustment, and Appeal Tools Chapter 4.11
Column F, Data Manager Code: Enter the code for the data
manager that sent the response letters listed in Column E.
Page 4.11 - 17
Chapter 4.11 Challenge, Adjustment, and Appeal Tools
Left-side Header Titles: Left-side Header: Enter the titles shown in Figure 4.11.9.
Type: After each title, enter the information appropriate to that title.
Cohort FY:
From:
Code: Right-side Header: Enter the titles shown in Figure 4.11.9.
To: After each title, enter the information appropriate to that title.
Code: The information cannot be entered until the remainder of the
spreadsheet is created and completed. After “Number of
Right-side Header Titles: Borrowers:” enter the borrowers from Column A. Do not count
Number of Borrowers: a borrower more than once. After “Number of Loans:” enter the
Number of Loans: total loans from Column D.
the sample.
Column C, Type of Defaulted Loans: Enter the code for the loan.
Page 4.11 - 18
Challenge, Adjustment, and Appeal Tools Chapter 4.11
Column F, Date Letter Sent: Enter the date a letter other than the
final demand letter was sent. If no letter other than the final
demand letter was sent, enter “No.”
Column I, Date Final Demand Letter Sent: Enter the date the final
demand letter was sent. If no final demand letter was sent, enter
“No.”
Column K, Date of Skip Tracing Activity: Enter the date the skip
tracing took place if the borrower’s address was unknown. If
skip tracing did not take place or skip tracing was not required,
enter “No.” If the borrower’s address was known, enter “N/A.”
Column O, Data Manager Code: Enter the code for the data
manager that sent the letters listed in Column F. This column
should only be included when completing a school loan
servicing appeal spreadsheet to Default Management.
Page 4.11 - 19
Chapter 4.11 Challenge, Adjustment, and Appeal Tools
A B C D E F
Page 4.11 - 20
Challenge, Adjustment, and Appeal Tools Chapter 4.11
Column E, EFC and Award Year: Enter the student’s EFC and the
applicable award year if the student is considered low income
because of his or her EFC. Enter the information in the following
format: EFC/Award Year. If Column D is marked “No,” enter “N/A.”
If the student is considered low income because of his or her
AGI, enter “N/A.”
Column F, AGI, Family Size, and Calendar Year: Enter the student’s
AGI, family size, and the applicable calendar year if the student
is considered low income because of his or her AGI. Enter the
information in the following format: AGI/Family Size/Calendar
Year. If Column D is marked “No,” enter “N/A.” If the student is
considered low income because of his or her EFC, enter “N/A.” Adjustment, and Appeal Tools
CHAPTER 4.11 - Challenge,
Page 4.11 - 21
Chapter 4.11 Challenge, Adjustment, and Appeal Tools
Left-side Header Titles: Left-side Header: Enter the titles shown in Figure 4.11.11.
Type: After each title, enter the information appropriate to that title.
Cohort FY:
From: Right-side Header: Enter the titles shown in Figure 4.11.11.
Code:
After each title, enter the information appropriate to that title.
To:
Code: After “12-Month Period” enter the selected 12-month period.
The information in the next three lines cannot be entered until
Right-side Header Titles: the remainder of the spreadsheet is created and completed.
12-Month Period: After “Placed Students” enter the students from Column F.
Placed Students: After “Total Students” enter the students from Column A. After
Total Students: “Placement Rate:” enter the placement rate. Calculate the place-
Placement Rate:
ment rate by dividing the placed students by the total students.
Adjustment, and Appeal Tools
CHAPTER 4.11 - Challenge,
Use for: Footer: Include a footer showing the date the spreadsheet was
prepared and the page number.
Economically Disadvantaged Appeal
• School to Independent Auditor
• School to Default Management
Page 4.11 - 22
Challenge, Adjustment, and Appeal Tools Chapter 4.11
Page 4.11 - 23
Chapter 4.11 Challenge, Adjustment, and Appeal Tools
A B C D E F G H I J
Student
Transfers to Date
Student's
Student's Completed Student's Higher Program: Student
Student's Student's Scheduled Student Student's
Enrollment Program Program Date, School Entered
SSN Name Completion Completed GPA
Dates Date of Study Name, School Armed
Date
Address, Services
1 Program
2
3
4
5
6
Left-side Header Titles: Left-side Header: Enter the titles shown in Figure 4.11.12.
Type: After each title, enter the information appropriate to that title.
Cohort FY:
From: Right-side Header: Enter the titles shown in Figure 4.11.12.
Code:
After each title, enter the information appropriate to that title.
To:
Code: After “12-Month Period” enter the selected 12-month period.
The information in the next three lines cannot be entered until
Right-side Header Titles: the remainder of the spreadsheet is created and completed.
12-Month Period: After “Completed Students” enter the students from Column E.
Completed Students: After “Total Students” enter the students from Column A. After
Total Students:
“Completion Rate:” enter the completion rate. Calculate the
Adjustment, and Appeal Tools
Completion Rate:
CHAPTER 4.11 - Challenge,
Page 4.11 - 24
Challenge, Adjustment, and Appeal Tools Chapter 4.11
Column A, Student’s SSN: Enter the SSNs for the former regular
students initially enrolled on a full-time basis in a Title IV eligible
program who were originally scheduled to complete their
programs during the selected 12-month period. These are the
students who will be counted in the denominator of the com-
pletion rate calculation.
Page 4.11 - 25
Chapter 4.11 Challenge, Adjustment, and Appeal Tools
Page 4.11 - 26
Type: Incorrect Data Challenge / New Data Adjustment / Erroneous Data Appeal Number of Borrowers:
Cohort FY: Number of Loans:
From:
Code:
To:
Code:
A B C D E F G H I J K L M
CPD,
Type Number Basis of Date Data
Borrower's Borrower's Earlier of DD, Cohort Effect on Agree/
of of Alleged Entered Comments Manager
SSN Name LDA or LTH ICRD, FY(s) Calculation Disagree
Loans Loans Error Repayment Code
1 or N/A
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
Date ___/___/______ Page __ of ___
Type: Participation Rate Index Cohort Default Rate:
Cohort FY: 12-Month Period:
From: Total Borrowers:
Code: Total Regular Students:
To: PRI:
Code:
A B C D E
1 Student's SSN Student's Name Student's Enrollment Dates Loan Type (if any) Loan Period
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25