NMU's Compliance Database - Northern Michigan University
DOE Composite Score Triggers - Borrower Defense to Repayment
Reviewed By | Internal Auditor Owner |
Regulation Reference Cite | 34 CFR 668.171 and 2019 DOE Guidance |
Report Due Date (Actual) | 10 days after trigger occurrence |
Level | Compliance Report |
Oversight Unit | FINANCE & ADMIN, VICE PRES |
Person Responsible | Robert Leach |
Secondary Person Responsible | Debra DeMattia |
President / VP Level | Finance |
Description |
After discussion with counsel, NMU interprets this regulation to mean that NMU loses the exemption and would have to report on triggering information if any of the following applied: 1) (Federal) Program Audit with compliance findings - track for five years; In general, the requirement is for all institutions to ensure that protocols are in place to report new triggering events (effective October 17, 2018) to the Department of Education in a timely manner, generally within 10 days. Independent nonprofit colleges and universities are subject to ED’s financial responsibility standards, while public institutions are exempt from the financial responsibility standards, unless subject to a condition of past performance under 34 CFR 668.174 (these are the four conditions listed above). The department may require a recalculation of an institution’s most recent composite score if certain triggering events occur: In March 2019, the US Department of Education, subdivision Office of Post-Secondary Education, issued a guidance about the November 1, 2016 regulation regarding recalculation of the composite score. Specifically, there are five triggers that must be reported. NACUBO summarizes these triggers as: Automatic triggers. The final rules define five types of events or actions that would cause ED to recalculate an institution’s composite score, without waiting for the institution’s audited financial statements: One additional automatic trigger—a cohort default rate (CDR) of 30 percent or higher for two consecutive years—would not involve any recalculation. Finally, there are several discretionary triggers:
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Contacts and Data Sources |
file:///C:/Users/jicompto/Downloads/9%20May%202019%20update%20to%202018%20Fin%20Responsibility%20Advisory%20Report%20(1).pdf https://ifap.ed.gov/eannouncements/030719GuidConcernProv2016BorrowerDefensetoRypmtRegs.html |
Internal Notes |
This compliance item has notes that are available internally to the oversight unit. Please contact the Risk Management Department for more information |