TEACH Grants Subcommittee – January 18, 2019, Afternoon session

welcome back everybody I just wanted to
make sure that that we were back on our audio so to to this I think for the
afternoon and I wanted to toss this out to the table see how you feel we have a
very big section 0.4 t3 is a big section and I think realistically it will take a
lot of time potentially so I was wondering if people wanted once we were
done with this section whether that would be sufficient for the for our to
conclude our meeting for this time with the exception of next steps obviously
and then we would be convening again February and 13th does that sound like a
plan or is that there a counterproposal plan what do you think I see no dissent somehow I was just not really expecting
it but you know I I don’t I think the plan then for the next block
what do you all have in mind sort of for how those two days will go just revisit
some of the things we’ve already discussed some of the things that we put
aside as things we want to revisit I know like greatly qualified or something
right so we can talk about next steps after we do that I think that’d be more
we might have some of the things that come out of this that may impact that so
so I don’t want to pre you know schedule is or something that we may or may not
need but I’m happy that’s part of the next steps conversation how how how this
will move forward for the next round so that shouldn’t that gives us three and a
half hours before we jump into the either where we left off for the next
time yes I have some statistical information on topics we’ve already
talked about okay great yeah so when we’re talking about suspensions the
question came up you know about how how many do are they receiving or how common
is this so last year fedloan received aprox
six-hundred suspension forms and how that compares is annually they get
approximately 52,000 certification forms so that just kind of gives you an idea
of the volume comparatively where is that data where did you find that
information they sent it to me the Fed loan people said did you yes oh great
could you share it do we circulate that email I will
and also they just the email one clarifying point that they have been
applying suspensions administrative suspensions as a result of disasters
without the recipient requesting the suspense
there’s no regulatory authority but there is an administrative authority to
do so and they’ve been monitoring FEMA updates to apply suspension benefits
under the department’s direction so I just want to let everybody know so
that’s kind of a good thing for yeah made me feel good to hear that so it did
it have in there how many of those those are the suspension applications right
the 600 correct they talk about how many of those were approved no but I’ll ask because I believe that was your question
right from our earlier yes conversation since you’re asking um
maybe how long it took them what’s the average time for examining and sending
out notification on on the suspension thank you yeah it’s no harm in asking
whether they answer or not that’s the whole other thing oh also I just would
like to strike the approve by the Office of Management and Budget under control
number eighteen forty five zero zero eight three four periods of suspension documenting this I think it may show up
in documenting the service obligations where it’s showing up in these forms
that haven’t actually gone through the OMB process I’m sure it will have a
control number as it will go through now but currently it has not been approved yes so it should be that’s the 80s so I’m looking at page 23
where it says at the very bottom of 41 approved by the Office of Management and
Budget under control number eighteen forty five zero zero eight three zero
zero eight three is referring to the agreement to serve it does not govern
this process I am not sure why in the regulations it
says that because the regulations also have to be cleared through a 1b and I
frankly I’m not sure why that is showing the approval member for the agreement to
serve that seemed odd doesn’t it well we wouldn’t include it and uh we wouldn’t
include that informations in proposed tools to go to a negotiating committee
anyway and that’s all done after the fact and the fatigue requirement in
certain instances so it wouldn’t we wouldn’t normally include that anyway
okay you steep in it doesn’t seem to be that
odd to me because these are suspensions of the agreement to serve so maybe
that’s why it’s reflecting back on the agreement to serve sorry my rationale
was that it’s not so odd to have it there because these are suspensions of
the agreement to serve now necessarily in terms of the structure since this all
hasn’t gone through and be it also is a question in the overall offering of
regulatory language but maybe that’s my thought is why might it be there is
because we’re talking about the agreement to serve these suspension
they’re out before we move on to the obligation to
repay that grant is there any other discussion on previous the previous
issue just to close it out and going back to the exception I think we ended
up agreeing that that was too broad but we did want to tie it in with I think
local not disasters but local circumstances that may impede someone
from fulfilling their employment obligations go back go up just there
were we have D under exceptional circumstances I think we agreed that
that was too broad from the OU’s perspective but we were
looking for language that dealt with the local impact that might occur that would
impact someone’s employment and so we were looking at actually tying I guess
closer to said a I think what we were doing was giving ourselves some time to
think about it maybe coming back to this later because we were talking about do
we need a list and what’s in that list so maybe we need to highlight it so that
yeah do something to it so that we can come back to you to reflect that it’s
that’s going to be revised in some way to reflect local concerns rather than
all the other stuff that’s there which the comments yeah what I was saying is that the
comments in the comment bubbles I should have clarified maybe made me make it
clear that that this is going to be reviewed in the context of local
circumstances the other additions comments and I’m
never sure it still would be included in the military spouses I thought we had
remedied that I think the military spouses is gonna be additional language
because it’s specific to that subset of people but that we would draft for the
next session and then bring it to the table right I was just saying it cuz
it’s right now it’s in the comment section for there under that one we just
wanted to leave that right that make sense and I think David correct me wrong
if I’m wrong but your your comment on that I actually made some shorthand it’s
not what you said but it’s what I interpreted incapacitating circumstances
stances preventing service for a specific period of time like not the two
weeks it’s bright you know you may have had better words than that but it’s a
little bit more than just incapacitating circumstances preventing service for a
specific time is that cover okay we turn with fresh eyes so our last and
final section which is 0.4 t3 obligation to repay the grant so obviously I’m just
going to do the line by line we have struck federal under a1 then we move to
the grant recipient regardless of enrollment status requested each grants
be converted began we’ve struck Federal Direct unsubsidized loan because he or
she is decided not to teach in a qualified school or educational service
agency or not to teach in the high need feel or for any other reason or and we
have gone and struck a whole bunch of information there we have struck within
120 days of seeking enrollment we have struck within one year we have struct
have been determined for a suspension for an eight-year period we have struck
be enrolled in teach grant an eligible program begun credible teaching the only
things we have left here the grant recipient excuse me does not begin or
maintain qualified employment within the timeframe that without an interval
individual to complete the service obligation within the number of years
required under six twelve point two what we’re trying to do here the big picture
is this we are trying to simplify the conditions under which a student must
repay the grant to two conditions to conditions only first of all that the
student would request the grant be converted to a loan voluntarily or the
recipient does not begin or maintain a qualified employment within the
timeframe that would allow that recipient to actually complete the
service obligation within the eight year requirement and that is it so the earliest that a grant would
convert would be at the four year mark following cease the enrollment at their
institution assuming they didn’t really enroll the earliest it would convert
mm-hmm actually I mean assuming I think I understand what you’re asking assuming
they didn’t ask us to convert you know a little more than four years have passed
and you haven’t done any teaching at all and you haven’t received a suspension
then you no longer have time to do your four years when the eight year period
and remember that is an existing trigger we’re not changing it it’s just it’s
there now and I don’t know how many grants have been converted for that
reason we could we could find out but yes that’s basically if we could get
that day that I am curious about how often that has happened so that would be
that would be great and I can submit that in writing later as well this is
that trigger at year four or year five I guess that’s how you define here yeah
find out exactly how they’ve operationalized I mean obviously it
precisely for years you still looking started teaching you could but at some
point after that right then you’ve run out of time or if you’ve done one year
and then you waited too many years before you did any more teaching you
could run out of time it’s gonna vary from individual to individual okay so I
just wanted to make sure I was thinking girls like thank you and I just wanted
to confirm just because I’ve heard from folks that a number of teachers who have
had their grants convert when they have had a form for qualifying service
rejected that has triggered the conversion that that would no longer
occur well I don’t think people have had their grants converted simply because
the form was missing some information it would be because they didn’t correct it
and get it in by the deadline that’s the issue is missing the deadline under this
even if they miss it for that year as long as they’re still
able to fulfill their service requirements within the eight even if
they have a a qualifying service year form that gets rejected that should not
well with what we’re proposing there is no specific deadline for some you’re
still required after each year this is statutory after each year of
teaching you’re required to send us something certifying your teaching but
there’s no longer going to be a specific annual deadline for you to do that
you’re gonna be reminded regularly of this and expected to do it but there’s
no longer going to be this annual deadline and that’s why it way back when
when I said it bring through they’re going to come back and request our
recommendation need to strike the sangwich yeah because so many of these
issues have involved missing this deadline were our thought is that these
changes would really simplify the process by largely eliminating that
issue so I it’s a it’s at 6:12 that’s why this is why we don’t want its page
11 of the original redline so your so if I understand you correctly you’re saying
that for the teachers that I have heard from who have their service year form
rejected you’re saying that that rejection should not have been the basis
for their grant conversion it should have been missing the annual intent to
serve right no I’m saying that if they had it rejected because something was
missing and they were they were told you need to resubmit it with the corrected
information you’ve got until this date to do it the reason for the conversion
should be because they missed that deadline not simply because if they said
they I submitted it with something this now
you could have a case I suppose where someone did not respond to the first two
notes because remember people effectively get up to 90 days to do this
if you if you only responded to the third and final notice and then you
didn’t submit it until right towards the end of the deadline and there was
something wrong with it then you can’t do it because you you’re right up at the
end so but you know what my point was you don’t you don’t get converted simply
because you sent something in in a timely manner
and it wasn’t complete but what I hear you say is that if you miss the deadline
on qualifying your service year even if you still could have fulfilled that
service requirement if you miss up on that timeline well that that’s the issue
we’re trying to address here and what we’re doing with this reconsideration
process because we recognize that there were people who were fulfilling the
service obligation but had their grants converted to loans simply because they
missed this final deadline that’s what we’re trying to address but with the
changes that we’re proposing here we’re hoping to basically eliminate that issue however what I’m saying is that
regardless of whether or not a qualifying service year form is accepted
or rejected if they miss if they meet that timeline or not that alone if they
can still fulfill the service requirement should not have converted
their loan at all or their grant at all in the past and I
want to preserve that that will not happen under the way that this is
written because it also wasn’t written into the regulations before but it
sounds like that is the way it has been interpreted I’m not sure that I’m
understanding what you’re suggesting talk let’s talk about going forward
rather than right so are you suggesting for example that someone six years out
who has not turned in anything at all could have their grants converted
because more than four years have gone by but then they turn in
things saying oh wait I taught for four years I just never said anything in that
will are use if you could give me an example of what so my example is he
teach grant recipient graduates from their program they go in to teach they
get a qualifying service here their first year teaching the next year they
submit a form for a qualifying service year and that form gets rejected for
whatever reason that second form has converted people’s grants and so I want
to confirm that that would not happen under these regulations no it would not
be but again if in your the current scenario if they submitted it and it was
rejected because it was missing the signature of the school principal or
something they get an opportunity to correct it they don’t just say sorry you
didn’t this was missing we’re converting your grants loans it’s it’s not simply
it’s missing the deadline that has caused problems I think but that has not
been the experience of I thought I have a question about that because if you’re
only in year two and whether it was qualifying or not that shouldn’t
automatically convert you because you have the eight year window so it sounds
like these are things that should be taken up with FSA because these are
opportunities for accountability for the servicer yeah I mean we really need to
look at these individual circumstances because as I said you wouldn’t be that
there’s an annual deadline but we’re not going to kick they don’t convert someone
simply because they sent in a form and something was missing if they otherwise
send it in a timely manner it goes back and you’re given an opportunity to
correct it so we we need to know more about these particular situations but to
your question no that would not happen here because we’re doing a way we’re
proposing to do away with this annual certification deadline okay I still have
to certify after each year of teaching but there’s no specific date each year
by which you have to submit that okay so I have I have a concern with each day
racing the deadlines not saying it’s not a great idea cuz I actually love this
but um if we say there’s no deadline right
because it’s the way I’m reading this we moved kind of like from a active
certification to kind of a passive type thing you’re going to just assume
they’re doing what you’re doing until it’s too late and they can’t do it but
if there’s no deadline and so at year two because they missed the first one
they just missed it but they talk but they just didn’t tell you and they
missed the first one and so they’re into the middle of year two and they’re like
oh I probably need to do that now it’s been like two years and so they submit
this and they have two years worth of service you count the two years yes and
in fact that’s happening now I mean although even now people are supposed to
certify every year if someone doesn’t one year but they
maybe certify intent so they avoid conversion and then the next year they
submit a certification that has two years they’re giving credit for that
house so yes they did not see a problem because if that’s the case what I’m
reading and I could be wrong so please tell me but what I’m reading is saying
that like at some point it like maybe four and a half years or five years it’s
going to automatically convert because now they have no but what in regulation
what is to prevent them from saying well I only started my qualified service on
year three and I’m two years in there was no annual deadline I haven’t told
you and then you can burn my loans at your five and I have two years do you
soon so it makes sense like I’m starting late but without some type of
accountability from the grant recipient I feel like we could get caught into
they’re using they’re like the last four years of their eight years they used to
fulfill their service and so we could have already converted so I have another
question cuz um for me on page 11 it’s a submitting upon
completion of each year of service by the annual certification due date which
yesterday you said was consolidated down to October 31st and then they have the
or October 1 and then you have the 30 the 30 and the 30 so isn’t that actually
the certification due date no well that that’s now but remember that we were
thinking that those words should not be there because there’s no other reference
in these right to an annual okay cuz it’s in red page 11 that just added in
did I just miss that you’re trying to remove it we’re gonna remove that yes
what we talked about in regard to the October 1 date was our interim stat
we’re standardizing the interim definitely notes in December to just
have a standardized date and there won’t be a formal date if these regs as we’ve
proposed here were to be approved and get published beginning July 1 2020
there would not be a formal drop-dead date but that that informal suggested
deadline or however you want to call it what you’re gonna you’re going to
continue on with other October dates yes or no those would disappear so this is
just in the interim no I mean once these new regulations go into effect no they
would no longer be they this this would go away but so that when no one would be
provided any singular date no they’re going to be getting the intent is that
they would be regularly reminded of their service obligation and reminded
that if you’re teaching you need to let us know after every year but the the
grant recipient also has some responsibility to understand the service
obligation and to do what they agreed to do when they sign the agreement to serve
which was to teach and to let us know when they did it I I do understand your
point I think the dilemma is if you set a deadline what is the consequence for
missing the deadline and if you say the consequences we convert your grants to
loans then we’re right back where we are now
their nature is there an interim consequence like a penalty fee or
something like that does it have to be converted loan I I don’t know that we
could do anything like that and I think there have been suggestions to maybe
only convert some of your Long’s loans but I don’t think the way the statute is
written well – suggests just thinking off the top of
my head I strongly feel like there needs to be a deadline because otherwise
you’re gonna get to your 8 and they’re gonna come at you and say well I did it
at year 2 and they did it took another year off and I did in year three and
then took two years off and I did six and you know I think so so you suggest
maybe put a deadline in there but maybe without a well put a deadline in
consequence know something with it you know all of this with the caveat that if
we don’t receive all of your related service of certifications by X date
which would be the date by which well I would suggest something I’m saying yes
we have like a passive thing saying that maintain qualified employment within the
timeframe that would allow you to complete your service obligation of the
years knowing maintained but notify like you have to notify me the in the first
four years that you’ve done something so it’s not like an annual deadline but in
the first four years I should have heard from you or I’m gonna assume you cannot
complete right does that make sense yeah yeah I tend to agree that the that
there has to be a clear deadline by which teachers have to submit their
paperwork I say that’s because I have a teacher
that I spoke with Victoria lip sac who says explicitly after graduation I
filled the teach grant requirement and got a job as an ela teacher to teach
English language learners and a title one school in south Phoenix I worked
hard to ensure the best education for my students like all teachers my first year
of teaching with stress one over and then she still submitted work
submitted her paperwork for that qualifying year on the last day that it
was due okay she did it and then on August 4th 2014 she was struck with a
hard blow in her first year of teaching not only was i underpaid overworked new
teacher but now I had a loan and an interest accrued and I had over twenty
thousand dollars to pay back and I couldn’t believe it it must have been a
mistake how could the Department of Education do
this to me as a teacher so I called the Department of Education and fedloan
servicing every day during her prep period and she was told that her grant
was converted because of the late submission of the certification of
teaching and so I think we want to make it very clear exactly when the people
that the certification is due to count the year but I also think we want it in
regulatory language to say if there is a error on the form you have 60 days to
fix it and make it very clear here because I’m not sure where the
miscommunication was but obviously this poor Miss Lipp sac suffered a conversion
fact when you have 60 days to correct it if she sends in her idea of a correction
on day 60 and on day 60 one is determined it’s not sufficient where do
we draw that line that’s kind of the verification thing like where do we draw
the line to say we’ve given you all these cushions so like even if we say
enter for thing at your for you have to tell us something we’ve had for years if
you tell me at your four and day one how much leniency do i as Edie how much
leniency do idea do I give you another 60 days and then you tell me on day 61
you know it’s not like yeah at some point it’s got to be it’s gotta be
generous it’s gotta be acceptable maybe it shouldn’t be like we I think you the
one telling us that random times of the year random people are certain think
maybe that was all just a little chaotic but that was in the past but going
forward I think we need a deadline I think it needs to be firm I think it
needs to be generous there needs to be much like what we
talked about the 30 30 30 you have 90 days but again I’m getting back to my
passion my passion is the counseling right we’ve been through mine yesterday
we got today we’re curious but at that counselling they have they have to
understand we have to find a better way than web-based click click click to make
them understand your first year’s gonna be crazy you’re gonna forget everything
I said but what you cannot forget $20,000 mistake is you’ve got to do it
before year 4 you’ve got to tell them before year four not oh you have four
years you know I’m talking about like no I think I think we we have what you’re
talking about you can’t wait until four years have passed and then send us
something so maybe required that you know we’re doing away with the whole
certification of intent but we’re gonna say if you’re doing what you agreed to
do and you’re teaching you’ve got to give us some documentation of that at
some point you’re supposed to do it every year but at a minimum you’ve got
to do it before you get to a certain point and is that what you’re suggesting
the other sir I think so I think the word is recommendation we recommend you
do it annually you know kind of like an update with your servicer so I think are
we really saying that the critical year is the fourth year I mean that’s the
year that if you don’t have all of your stuff in by then that’s the that’s the
year so would it make sense to do something on the net and this is just to
your point like how do you make that a little bit less less burdensome in terms
of the the crazy over the first year for instance but at the same time provide
the student with some heart from deadlines and I’m just trying to cook
the alternative ways of looking at it so what if it was something like you know
up until the first or what years one through three whatever those happen to
be because they could be coming in year five and six wrong we know right those
you can submit pretty much at any time but if you’re on that fourth year that’s
the critical year that’s the it’s gonna be the the trigger point that
ears shifts for students who have so I focusing too much on year four could
then confuse the student who’d you see what I mean yes I’ll do it that’s why I
said that’s why I’m trying to come up with yeah like so how would you do that
I don’t know and I think using the word recommend is very bad with students they
don’t hear anything after you say the word recommend and I would really
suggest maybe this whole section is a really great opportunity to to perhaps
allow all of us to step back and sort of imagine how we would we would envision
this whole process and you know from from our perspective I think we’re
interested in thinking about a grace period where the department or the
servicer would let the individual know that their loan is about to be converted
within a certain amount of time and then that individual would then have the
opportunity in that time period to then provide some sort of documentation to
counter that out that maybe thinking about some of these things a little more
conceptually may allow space to think about some of these very nitty-gritty
minor issues that I think we run into as we go word for word on some of this but
so are you suggesting maybe that because everybody’s service obligation period is
going to be different depending on when it when it started and whether they had
suspensions so are you suggesting that for an individual grant recipient when
you’re approaching the time when they’re getting close to running out of time to
do the four years that they be sent something saying basically in other
words you’re you’re running out of time and you’ve got until this date to give
us some documentation showing that you’ve been satisfying the service
obligation is that kind of what you’re suggesting yes and I think across the
board for a variety of different scenarios and that sort of model may fit
a number of different cases because it provides notice and time and hopefully
also instructions on how to remedy the situation and then from there you can
think about we can think about what happens then if it’s converting things
like that but but how does something from the grace period your
screaming so you’re thinking something along that lines in my head I’m hearing
some hearing is and I’m pretty literal in with this one like but like at
anniversary year one I know it’s different for difference but I’ve
graduated I went into basically repayment right so I’m gonna pay with
service I’m going to pay with cash for the time going into repayment
anniversary year one I haven’t heard from you and saying I haven’t heard from
you if you’re providing if you know if you’re performing service for repayment
you know for long teach grant then please let us hear from you so we can
adequately credit your account for your service years if not please let us know
what your intent is or update your address or anything like that just to
suggest you know unless same you penalize them but if they don’t that’s
that’s that’s that but just let us know something year to notify them again
you’re in the second year you know just annually it doesn’t have to be like all
at the very last ninety days but annual notification I haven’t heard from you if
you’re performing the service it’s a great idea to tell us if not give us an
update and I think this would be a good place also to incorporate the
information about voluntary conversion if you know you’re not going to any
complete and suspension and anything where I gather benefits that they may
take advantage of a little bit distinct from the 30 day grace period which i
think is a great idea because before anyone’s can convert it they would have
the opportunity to submit documentation this is more here’s where you are in the
program here’s what information we have that you’ve submitted and what counts
and what doesn’t and you have an X amount of time left and that would be an
algorithm algorithm that would be automated so it would also accommodate
students who may have had their there clock changed overtime or students that
reenter it would be able to account for those changes I don’t think there have
to exist separately right this is more of an a notice every year but then also
I think regardless of any scenario under the Sun if your if your grant is about
to be converted to a loan I think we should to think strongly and I would
strongly encourage support of a grace period where it would just be standard
across the board and I think that would also hopefully alleviate some
frustration if you know in some of these circumstances you’re talking about it it
really would allow for this advance notice in times in preparation I then
think there should be and we’ve suggested this to a 60-day window then
to correct any errors submit documentation obviously these things
take time but if you do not answer within that 30-day window then it’s
converted or if you acknowledged or whatever so wait is it a is it a thirty
day or 60-day grace um so thirty so what we’re seeing this is something that that
we’re suggesting is a 30 day grace period and then you would have 60 days
from such notification to correct any errors so you’re notified 30 days prior
to it going into a loan right I would almost say they should be 60 days okay
yeah that was just because that would be very scary I like if I get a letter
saying I’ve got a month I’m gonna probably freak out a little well and I’m
thinking to depending on the time of year that could be very stressed yeah
and then if they don’t need to get forms and signatures and their superintendent
maybe isn’t around or whatever yeah we’re just think about that in concept
so I but um but another thing I want to add to that is I would even suggest that
it’s straw is longer because if I’m gonna be notifying them you told me to
dream so this is my this is my what send box right here if I’m gonna
say I’m going to notify them annually then that last year your for basically I
haven’t heard from them at all and in your for I’m gonna amp it up I’m gonna
notify them at six months I’m gonna notify them at three months then I’m
getting into my 30 days and saying it’s gonna happen
and then have some type of I would love for this to be so dreaming now I would
love for this to be somewhere on a database pet counselors can see so that
the service or everybody can see like has this communication goes we have a
software system that does this for us and it is priceless it is the benefit is
just undescribable because I can go back to a students say we sent this letter to
this email to this address one year ago two years ago three years ago six months
ago 30 days again and for us with face-to-face contact with these students
if we could help I’d say this is where they sent it this is where you told them
your address was this was your email address they’ve sent it to you seven
times so then when they do come to Hiro with a letter she has access to say they
did come here can’t wait you know it’s a bad address that’s we got to have the
student be responsible for that a couple of things there is an annual
notification requirement built into the regulations which we haven’t talked
about yet it doesn’t include it’s more general it doesn’t include what I can
tell the these regs don’t contemplate specific information about where this
individual borrower teacher is at this point and it’s possible you know that
could be built in there would be some concerns from FSA on how much it would
cost us in terms of contracting but you know that’s if the decision is made to
do that it’s also important to keep in mind that you know we have a lot of
experience on this on income based repayment where borrowers have to
provide us income annually we start sending them notices 90 days before that
deadline we send them 90 days we send them 60 days we send them 30 days we
send them when the deadline is over we send it after our response rate on those
is horrendous we don’t get the information so you know
we’ve gotten to the point where we’re trying to work it out with IRS that we
had the information directly so no matter how my really appreciate that
effort by the way no matter how much we can’t as you’ve been saying it you you
could you know if you could go down you know people will not respond it may be
better on this because it’s one thing with income information versus well on
teaching that’s pretty much public anyway in Simla certainly would be
income driven repayment plans you’re right they don’t respond until they
don’t reckon us the information and then their payment is recalculated and it
goes up that’s what gets their attention just it’s not as drastic consequences
having years is this thing that just federal student aid administrators I
mean the missing done thing it’s not until we till they can’t register the
next semester and they don’t haven’t they didn’t pay last semester you know
that’s one a that’s one a it hits them but I’m thinking more along the
communication to them I’m thinking of that is it just a better service just
because it’s Friday afternoon no very couple but just to keep it Kyra happy
you’re talking about if she would have the documentation so that when this
person does complain even if they’re doing it through IB art you know it’s
like we did our part mm-hmm you know right now that’s not necessarily easy to
defend so but if we had the communication out there we can say we
did exactly what we said and we did our defect you know good thing to do that
not say you’re not doing a good thing but it’s just a lot easier to track and
it’s a whole lot easier for all of us to get behind you when we can see it
happening you know and and help out and but it also gives someone like mislead
sack who had her grant converted purely due to a service year form right that
should not have converted the opportunity to go back before it
converts and say no I still have seven years left in my service obligation like
this should not convert you know you are making an error
and hopefully if there’s better information available on that si website
and on the edge website about the dispute process then she would be able
to raise it so that now you know she’s been in the position where she’s been
paying this off for four years even though she’s she had every intention of
complying with the with the service requirement yeah I mean some of that
what you’re describing there really clearly is either ed needs to go back
and look at how they’ve told fedloan to do this because I I’ve been stuck even
though listening to this conversation and around the fact that that’s your one
you have eight years total and so what’s happening there so I think again we have
opportunities whether it’s through this regulation or just because you guys get
to take this back and say oh my god we heard about this all day long is like
holding the servicer accountable because that to me is not that unique of a story
of all the stories that are out there about the teach grants and I’m not sure
how the community what the communication is or how these things are laid out what
script is written or what but it’s happening and it seems like you guys get
that to some degree because you’re doing this reconciliation process but
certainly as we move forward while it may not be in the purview for us to say
this is what you say to whomever you contract this with that the oversight of
the servicers in fact not just for this but for all servicing of federal student
financial aid needs to be more deeply incorporated to the practice of the
department because it’s been going on it happens with other servicers as well in
different ways and it’s just very clear that it’s not
Ed’s intention to have this unfold this way it’s not the students intention to
have these things unfold and it’s at the servicers point because to some degree
it it is and if it is in the financial benefit of the service order to convert
because they make more money when they’re servicing a loan in particular
in this case for sure they get make more money when they’re servicing them when
they’re holding the teach grant in dealing with it
some would argue some would say even that possibly the servicer sees
themselves as losing money because nothing’s coming in except paperwork and
work for them unless you start to service alone instead of the grant it’s
been on my mind can you tell even on a Friday afternoon so so you know I very
much appreciate I’ve been a teacher to know that it’s challenging first year or
any year really of teaching I’m I’m hesitant to put out there that we would
do any of what we’re talking about because it’s so overwhelming to be a
teacher that to me is not compelling reason for doing any of what we’re
talking about I think it actually potentially infantilizes teachers and
says you’re so overwhelmed you you can’t possibly do X Y or Z and they do X Y
they pay their rent they pay their car insurance and such and it goes back to
those are triggered by a bill and so I go back to something I think I heard you
say W before could it be that there’s there’s a bill and their way is to pay
so how are you paying you’re paying through service and tent to service like
like to me that’s how everything else operates is you get a bill you pay and
it’s regular there’s a date there also with that too and if you miss it by this
window there’s this fee there’s this window there’s that fee I mean to me
that’s just how everything else operates why we why would we do this differently
than other than maybe there’s a reason why but I think when I mean I can say I
was surprised by the annual certification of an intent to do
something I already intended to do if I knew that my year wasn’t gonna qualify
it’s not intuitive to do that at all and in that way it is the same for paying
the rent because it is intuitive to pay the rent every month you sign the lease
you know exactly when you’re gonna have to pay I think here on one hand I I
think I agree with you that you know teachers have to be notified but I think
that is that a sort of the idea of giving them notice in advance of the
conversion and sending them an annual reminder is also at times depending on
the delay of some of this stuff maybe letting them know how would they’ve
submitted has been counted or not as well and so it’s not so much
infantilization of the teacher although you know I hear your concerns on that
it’s more making sure that that they have the opportunity to check how
everything is being counted or not well that’s what a bill would use it would
say so we got this payment from you again payment in terms of service or
whatever yeah from you last year this is what’s due now this is what’s doing the
fuel kind of like a house liner you have every the whole history in the future is
like right there every month there’s no confusion because it’s just right there
I actually oh go ahead I really like that idea and I’m I’m even thinking like
the communication annual communication I don’t necessarily think it needs to be
just a form letter because they’re gonna trash it
they’re not gonna read it we’ve already talked about that they’re not gonna read
it but if it does resemble type of like
this is your commitment you have four years of service you’ve used your one
would you like to use service for that submit these documents would you like to
use that as one of your and we can name it better but term it as an off-year
then we’re going to assume this is an off-year unless we hear from you dear to
comes around same thing you know you used to would you like to use this as
your off year or would you like to use a service year to meet this and even have
on there the monetary amount yes because that’s what drives them as we’ve
all discussed money drives them so I owe $16,000 at the end of my time and is
undergrad then here’s your sixteen thousand dollar bill would you like to
use one year maybe it has to be that simple
do you don’t really say that – they’re actually they date they do get something
like that now if they’re actually they get letter saying you’ve satisfied X
number of years you have X number of years to go so they’re already getting
that but it’s tied to this annual certification to date so that’s already
that’s already kind of happening but and as you see is Brian mentioned earlier
when we get a little further on would you talk about how the secretary will at
least annually notify the grant recipient of various things including
how much time you have to do this and so really ER with we
already as I said we’re already doing something like this so it really
wouldn’t be a big change to say here’s what you’ve done so far here’s how much
you have to do and here’s how long you you have to do it I think that’s the
question I think we’re still debating is whether there needs to be some kind of
deadline for doing it and what the consequence we met to that end I guess
back to my whole struggle with the at the end of year one you don’t file your
paperwork and so you’re converted why do we have to assume that there that there
needs to be some sort of consequence um and maybe that’s I’m just asking that
because if we’re if really kind of what’s happening like I do I was gonna
agree just like Debbie here to say that’s a really nice idea to lay it out
I was gonna recommend even this may be a stretch I don’t know it shouldn’t be too
hard – this is how much interest has accrued should your granite convert
later that gets added on so it’s now sixteen five you know sixteen eight
whatever um and even include if at this point in time you know you’re not going
to complete your teaching commitment the service component the voluntary
conversion and statewide because if you convert now your principal is lower and
therefore you know you you will be paying back less depending on other
things of course all math aside and having that be the communication and
giving them a deadline if you don’t hear from from them by then then you see it
in the next year this like just like Debbie was saying this is your – we
haven’t heard from you so we assume you’re not teaching here’s your interest
your blah blah blah and so that there’s no sort of stick if that makes sense I
don’t know I totally agree I have no problem with a sort of enhanced
notification right I do have a problem if we’re tying that
notification – some sort of penalty especially when they still have the
eight years to fulfill their obligations like that to me is just not fair
and I also think you know I understand I I would like to also discuss some of the
nitty-gritty because I think the more clear we can make our regulations on
what the timeline is on these on what has to be submitted after that first
year of service may help clear up some of these things and I understand the
idea that the notification should be formatted like a bill and so I really
like the idea of having the interest and having information about a voluntary
conversion but again I would just strongly caution us not to penalize
folks teach recipients who have every ambition to fulfill their service
obligation and cut them off at the knees before they’ve had the opportunity to
demonstrate that they’re going to do that they’re going to face other
obligations and I would just add that I I really like the idea of the bill – and
then voice in it I mean we don’t trigger anything in our head without in their
voice right but I think also the listing of what the anticipation is anticipated
remedy is is important you talked about having first service being the first
listing the second listing being that we’re taking that time off right and
then going down the list with the penalty being the very least the very
last on the list which i think is important because otherwise we know that
you’ve already mentioned how important how how inundated teachers are with
other things a lot of them are only gonna read those things that are listed
first they’re only going to take from that form what the intent is based on
what how those that information is listed and so I would only add that we
need to be very intentional and how that form is put
together and have the listing with the least amount of penalty at the beginning
so I’m just wondering since we’re talking about putting all this stuff
into a notification of some sort whether we want to look at what we’ve got here
for the notifications and then see what we want to do with that
does that make sense the only thing I wanted to add to that is if we are going
to somehow regulate the bill be sent I would want to add it into entrance
counseling that it be told to students upfront that you will receive a bill
regarding your up your service obligation or your or your payment or
work obligation or something like that so that they begin to conceptualize that
this grant comes with a bill because I think that’ll be very confusing if it’s
not explained right up it’s not a deal yeah it’s no literal bill that they have
to respond to like it’s not formatted in such a way that it triggers in their
brain the same type of reaction that we would have that oh this is something
that requires my attention and my focus and bills are usually the thing that do
that for us the most is that sort of David what you were working on hinting
at and it would be amazing if as counselors we had a copy of the format
so that we could actually put in it with exit counseling to say this is what it’s
this is serious you know this is not just another hey consolidate all your
loans and win a breadbox this is serious and I can’t remem n shinned it first but
somebody said that it was really notification and as I would like us to
use that terminology as it relates to it but I totally agree I think looking like
a bill and indicating that there is some obligation that you’ve agreed to and
this is the offset of that is a great notification of exactly where
they are in the process each year I just wonder if sending something that looks
like a bill to a student they’re gonna be more inclined to ignore that anyway I
was thinking maybe the other way too maybe another way to look at it would be
like an account update like you get from your bank now granted not everybody
looks at that with a deep focus either I agree but maybe it’s your obligation
update or your your obligatory account update or something that ties it back to
the obligation that you agreed to gives you the full understanding of what’s
happening but again I don’t think this should be ten pages long either as we
draft this there should be something that is maybe ideally in the world it
would be one page but maybe two pages that has all of this information so that
it’s a with appropriate links and such as needed for them to reference to
because any longer than that and they’re gone because we would be gone I understand some of the sentiment around
the bill idea and I think that’s great and all well and good I I don’t know
exactly what wording will end up actually putting in the regulation I
think some of this is will have to be up to FSA and a sort of implementation of
some of these of some of this regulatory language perhaps it’s better as we think
about what might be best to think about consumer testing and ensuring that some
of these forms go out for comment or something along those lines
is something that I think may be a better path to go down than saying in
the regulations somehow like expect something that kind of looks like a bill
or or I don’t know what it whatever we end up thinking but just something even
like we currently have it as notifications that’s why I was
suggesting we can get it and see what how close is interesting that expand a
bit and what I said before they are I’m pretty sure that the they already get
the notices that they get as they do include the amount of interest they
could potentially have to pay so we’re already doing something like that
arguably I think these communications could be a little more clearly written
and we’re gonna be working on that so they’re already doing something like
this I think that it would be a matter of changing the timing of when these
things are so now so something like this is actually already in place so let’s
review what we’ve got here as potential notifications that and see what what
else we want to do here if anything so again we’re here we specify at least
annually during the service obligation period we will notify the grant
recipient of the terms and conditions that the grant recipient must meet to
satisfy the service obligation the requirement for the grant recipient to
provide to the secretary upon completion of each of the four required elementary
or secondary academic years of teaching service documentation of that teaching
service-learning form approved by the secretary and certified by the chief
administrative officer of the school or educational service agency in which the
grant recipient taught can we stop there before further so I would like to define
completion of each academic year of service because I will tell you I have
heard of forms that have gotten rejected and folks have not had the opportunity
to complete them because it fell after that very firm they’re very firm
deadlines their correction was received afterwards was accepted but then was
rejected because it was received after their certification deadline and what
that means so for some schools they have professional development after the last
day students are present for other schools they might think of the end of
the school year as the last day that they receive their employment check that
covers the previous year’s contract so how do we define that time isn’t every definition of it in the way
Cartman you know we have a definition of academic year or
its equivalent for elementary and secondary schools in the actual CFR I’ll
read you what it is but in sight I see that on page two when one complete
schoolyard shoot some people however that doesn’t clarify what counts as the
last day of school for a teacher who’s trying to submit at the forum so good
but again if I could ask what are we talking about the current situation or
people nursing deadlines are we talking about going forward yeah we erased the
deadline so no I’m not talking about that I’m talking about for a teacher
filling out just filling out the form which says what was the last day of
school that even that has been a point of contention that no one really knows
what the last day of school is under these the way that these regulations
have been written which may then impact their timeline on on one whether or not
the form is accepted and to when they would even submit the plan but the
school years always have a an official starting date in an ending date so I’m
not sure that I understand where that is but not always for teachers but but even
but and maybe this isn’t specific enough but this is actually fairly flexible it
says one complete school year or to complete a consecutive half years from
different school years excluding summer sessions which
generally fall within a 12-month period so it’s it is more to it I’m just so
then maybe this is just a point for how the forum yeah I was gonna say maybe
this maybe this goes back to the reform and there’s actually more – it’s as if a
school has a year-round program of instruction of secondary considers a
minimal of nine consecutive months to be the equivalent of an academic year it’s
doesn’t it’s it’s pretty flexible actually it sounds like this goes back
to the servicer and how the servicer has interpreted the school year and and
therefore it goes back to the forum so it sounds like the forms require my
attention it was a issue you’re describing – to add under that
I think the current form is set up so that the chief administrative officer
actually I believe was specific dates of employment as a teacher and that his
sometimes caused some problems so we were actually in the process of
developing new forms to go through um be clearance when it was determined that we
were going to potentially revise the regulations so we pulled back on that
because it made no sense to proceed with that because whatever we do here could
make those forms obsolete to address that issue what we are
proposing to do was to instead of having the chief administrative officer
certified specific dates of employment it would simply be certifying that you
had completed the 2018-2019 school year to get away from those dates
so that was the direction we were going next and then with the chief
administrative officer how is that defined because I’ve also heard from
teachers I mean oftentimes in these schools there can be a lot of turnover
in the administrative staff if you don’t have a principal present if you don’t
have the vice-principal to present who would certify the point well well it’s a
term that we also use for other programs that teacher loan forgiveness in we
define it on the forms it does not have a regulatory definition anywhere I don’t
think it’s basically and it’s gonna vary from school to school in some places and
maybe the principal in some places it may be at the district level it could be
someone in the HR office it’s basically I don’t have the verbiage here from the
form but it’s whoever is authorized to verify your employment and has access to
the records that show that you met all of the qualifications but that could be
different depending on the school so three Romina three the time frame
would in which the teacher barret recipient must complete the service
obligation I think we all just discussed that the conditions under which the
grant recipient may request a temporary suspension of the period for completing
the service obligation the conditions under and just stopped me if there’s any
point we want to discuss my the conditions under which each grant
amounts dispersed to the recipient will be converted to a direct unsubsidized
loan with interest accruing from the date that each grant disbursement was
made can we actually stop there this assumes the conditions under which will
be converted can we just say what the condition would be if you reach a point
where you can no longer complete your service fulfill your service obligation
within eight years unless you have a I think just I think leaving it this way
would allow for an explanation of voluntary conversion I would in in the
interest of clarity to just make it as clear as possible so that we prevent
some of these miss interpretations on this servicer side who are also relying
on the regulation so I would want to clarify that it’s either to voluntary
conversion or through through if you do not fulfill if you reach a point where
it becomes a possibly for you to fulfill your four-year service obligation I’m
just wondering whatever happen but what if suddenly
other conditions material is due wouldn’t we want to keep this language
more flexible I’m just wondering yeah I don’t think that those conditions this
just saying the notice will explain the conditions and those conditions will be
whatever conditions are in effect under the regulations at that time so the
actual notice that goes out will say if you voluntarily request it if you run
out of time or if we establish some other condition it would list that so I
don’t think that needs to be here I disagree because if you are going to
rework the obligations to repay the grant you’d have to have this this whole
section go through Network anyway if this notification provision is within
the obligations to repay the grant if you’re going to change when the
obligations would arise you’d have to renegotiate the whole section anyway can
you explain a why D why you think that in this section where we’re describing
the contents of the notice we need to say would it help just add a
cross-reference here to say the conditions under which the grants will
be converted loans as described in with that I mean yours you’re referencing the
same your reference you’re referencing a one and A yeah a one I mean if we may need to break this
piece and obligation to repay very grant and the notification into two separate
sections yeah this this has been going on throughout yeah I mean even though
it’s titled an obligation to repay the grant what too is specifically
addressing is exactly what’s in the notice right there no and it’s browsing
so it’s it’s it’s this is all considered part of the obligation Mike wasn’t now
I’ve forgotten what now um that as so sorry for not turning on my mic but
number two is just about the the process of making sure that the individual is
aware at all points along the way well in this case not all put but annually
they’re aware of where they stand yes in the obligation to repay yes but if we’re
talking about the obligation would change over time what I’m saying is this
whole section would be would be considered in its in a subsequent
negotiated rulemaking to redefine what the obligations are tree Pam all I’m
saying is in instead of leaving it unclear to say explicitly your loan your
grant will only convert through voluntary conversion or if you do not
fulfill if you reach the point of impossibility for you to fulfill your
Forest Service series within your service block I think that’s not
necessarily true because somebody could fulfill it but just never communicate so
if we if we leave it that specific then they could communicate 20 years later
and say oh but I did it okay subject to I think it’s right but you
still good I’m saying right like adding the paperwork all I’m saying is to make
it as clear as possible in these regulations so that it is clear exactly
when your grant will convert across the board I know though I do agree with you
that it needs to be clear I mean I’m the one at the table that it always says we
just got to be detail in there but again when we’re
talking as my peers you all trained me yesterday when we’re talking regulation
versus the form maybe that is addressed at the Forum level and at the regulation
level I mean I just really don’t see the biggest the difference between
addressing the details here versus when we were talking about exit counseling
and the entrance counseling like yes I want every bit of it in there but if we
put it in there then it’s just tying us down to where we can adjust the forms
and if we get to the form level we get to look at that and yes we get every
detail on there I guess I’m still not clear on why we would need to add those
conditions those specific conditions here because this is just saying the
notice that we send will include this information with one of them and one of
those pieces of information is the conditions for loan conversion those are
specified up here so the actual notice will say your grants will be converted
if you ask us to or if you run at a time but we don’t really need to quit that
information we’re not losing anything if we don’t repeat that information here
because it’s already in the earlier paragraph into this section let me think on it a little bit further
I mean it is really an excess of caution to make sure it is as clear as possible
at every point to make sure that none of these inadvertent conversions happen I
hear what you’re saying that it is duplicative of what is stated earlier
but at the same time if we can condense it down and make it really clear again
then that would be the language that would compete copy pasted by other
institutions and used by other folks so I’ll think on it okay three the teach
grant amounts this first to a recipient are converted to a direct unsubsidized
loan alex is me if that each grant amounts disbursed to a recipient are
converted to a direct unsubsidized loan the secretary notifies the recipient of
the conversion and explains that the recipient will receive a six month grace
period before he or she enters repayment on the direct unsubsidized loan but the
recipient has the option of paying the interest that has accrued since the date
of each teach grant disbursement and that any unpaid interest will be
capitalized at the end of the six-month grace period and this should be dropped
but it’s not that once a teach grant has been converted to a direct unsubsidized
loan it cannot be converted to a grant unless the grant was converted to a loan
and error and before we move just because it’s a quick fix and when I keep
harping on get the error verbage yes thank you yes do does the interest capitalize
currently within six months yeah it’s not paid which is basically the same
thing that happens with a regular and you always have the option to their
principal is increasing exponentially I mean yep so if that is if that has to
remain because that is just how direct unsubsidized loans functioned I I do
believe that informing students that their interest will be capitalized is
critical at each point that could be how would you like a job so spend lots of
our time doing that but I think in terms of the written documentation when we’ve
been talking about entrance and exit counseling we’ve been talking about
retroactive interest we have not included that it will be capitalized in
in this row if it’s not in here it’s definitely in the actual counseling
tools including examples of what that looks like
yeah one thing I’d like to put on the table sort of while we’re on this topic
is one thing that we’ve discussed in our offices considering some sort of
additional counseling for a student who has their loan converted some sort of
know exactly what it would look like but it would be an opportunity to discuss
and remind the borrower the now borrower of some of the standard items that that
we think about as we think about unsubsidized loans one in particular
being the availability of public service loan forgiveness and
options I don’t know exactly how we might get about doing that but an a
touch point to provide that counseling for what they now have it’s a kind of
like entrance counseling right it’s like you’re about to be a borrower well in I
mean that’s like I said again my soapbox is the counseling um I would just really
loved to hear what everyone has to say when we come back in February about how
we can do counseling better because I don’t have any ideas you know you can
talk to them when they’re 18 years old at entrance counseling you get to talk
to them again as they’re trying to get graduation parties scheduled and their
break visiting trip what are they gonna do with your spring break and their
senior year you talk to them then and then you don’t talk to them again and
it’s really really neither one of those times do you have their attention just
to be honest with you you don’t have their attention and it’s even worse when
it’s web-based because all they’re doing is just meeting whatever you put in
front of them and just to get out of the way and so if anybody has any ideas on
how we can do a good job of counseling them I don’t know how you would get a
attention of somebody who’s waited five years and just done nothing on their
teach grant how would you get their attention to counsel them you couldn’t
get their attention the first five years I don’t know how you do that but I would
just love to hear what the committee has to say because to me that’s the
turnaround in every bit of this because if they knew that the interest was
retroactive and capitalized and they knew what that looked like and they knew
what that monthly payments going to increase and they knew what their rent
was in their car note is and how that’s going to impact them I don’t think they
would make the same decisions but then it’s too late by the time I think bronze
one that said and they get the bill in you know it’s too late it’s sad it’s
really counseling to me is the catalyst here that kind of leads into to my
concern as I’m reading this section this is the annual notification part
and it then for three and the four subsets of that three that’s if it so
it’s it’s kind of interesting to me because this I feel like should be a
separate it should be pulled out of the annual notification because it’s a lot
of detail and it’s important but this is around very specifically if the loan
converts and so I feel like three should be its own sort of notification all of
that information and what goes out annually are things like it is its own
notification it’s it may be that the the distinction in the regs isn’t is clear
but yeah it’s not and then three is the whole news event okay and three is if
they if it’s converted so it may not be as distinct so then can we add yes
things before the teach grant amounts to sisters fare recipient are converted to
a direct opposite unsubsidized loan the secretary will notify or I would say you
can’t greater than thirty especially if we’re going to allow for these call them
late certification of service years sure so at the beginning of three here so at
least I would be comfortable with ninety and I think that that would give if this
is the event that triggers some action I think ninety days it should be
sufficient to to get everything submitted um and number two we began
with at least annually so for consistency on number three can we maybe
say something like at least 60 days prior to conversion
I like 90 days 90 days at least 90 days prior to conversion and so that kind of
gives us a little window if they want to do 120 days well here’s the thing with
that by saying at least 90 again thinking from the students
perspective if I send them something that says a year from now we’re gonna
convert your loan they’re going to ignore that too because a year in the
mind of a freshly graduated student seems like an eternity even though as
older folks know that it’s really not I would also add that you if it’s a self
conversion you couldn’t do it you couldn’t do it at all
so what I would recommend is saying is you don’t say exactly 90 days so
something like between 120 and 90 days prior to a non self conversion or
something like that to non-voluntary I’m thinking about this even if we go with
what we’re discussing earlier if we were to do something like you’re getting
close to the point where you running out of time and we tell you you’re running
out of time you’ve got to do something we still don’t know for a fact that
you’re gonna be converted until you reach that point so it might be a little
difficult to put a time on this because we may not know for sure 90 days out
that you’re going to be converted because you could turn into you see what
I’m saying I mean if nothing changes you can also assume that they’re not
submitting anything yeah make you keep this because this would be the fright
factor that would get them to communicate with you because if you
don’t even if you haven’t heard from them and they have been doing their
service for three or four years when you send down you may have a little bit more
impact on 90 day they’re like oh wait wait wait here’s all four years right
here but if we don’t if we just wait right up until the end yeah they may
have already done their service but they may not have and now we’re stuck with
again two weeks from now we’re turning this around yeah and I think if they’re
sent this an error it store it’s gonna cause panic but it will also still cause
that communication which is what we’re trying
to jog anyway although on the flip side of this you know we’re all thinking that
they’re going to get a document at you you know the end of year four which is
get into your high-needs school and get this teaching done or it’s gonna convert
when really if we’re giving you know they get that alert this notice comes
out you know between 120 and 90 days of that last of the eight years is that how
you assuming that everything trucks long as it is is that what we want because
then yeah if they have it done great but if not like I think there should be it
and I’m just based on previous conversation is this really when we want
this I don’t know thinking through it if I haven’t heard from them in four and a
half years they would get this notice because I would assume I have not heard
one word right because like if I haven’t heard anything because we’ve said yes
that it’s the first time a student would receive it yeah the first time they’ll
get this is like four and a half years and so then like I said the fear factor
would jump in and maybe they do submit two more two years of service and then
I’m starting my clocks on the clock over them counting and it may be at your six
at that point they get another but this says yeah cuz right now this reads are
converted or at least in three it says blah blah blah what we’re putting in
there amounts disbursed to a recipient are converted so that’s my concern then
we need to change that verbage to address this because right now this is
like hey this is it so I know we’re trying to change things so we just need
to I see what you’re saying it’s in conflict with itself yes yes thank you basically what’s happened here is we’ve
changed what is a conversion subsection in three twe notice subsets yes and we
haven’t changed the rest of the line yeah basically a three
we’d replace three make sure this out I would also like to maintain some sort of
and we can talk about it as a group I guess but some sort of concept of once
it is converted if there is additional communication maybe what we do instead
is instead of redrafting three is create a new three that is the notice has in it
what we would like to be there and then keep three as it is with whatever
changes we make moving through okay so can we have a new three please thank you
I defer to my colleagues on what should be there we can copy that language
between and/or language just the beginning between 90 and 120 days prior
to involuntary conversion mm-hmm I move that up to three before the teach grants amounts to a
recipient will be covered in just comment here we don’t use the term
involuntary conversion anymore maybe we were going to cross-reference the
conversion due to running out of County honors we got so between 90 and 120 days
prior to a conversion due to the reason in know this isn’t prior to conversion
this is 90 to 100 days prior to the last point that you have to complete your
service obligation is that what you guys are talking about yes this which is
synonymous with when it would be cleared no but it wouldn’t necessarily be
converted right then and there I mean because we soaked it wait and I am I
think I would like to keep it this way because I want to threaten them with
convenience I just had it thought I think for public service loan
forgiveness we put in the regulations you know or at maybe it’s for the income
driven repayment plan when they get to the point nearing the point we need to
get land forgiveness we’ve got some language in there that says X amount of
time in advance when we expect the borrower going to meet the requirements
make it sound like that could be used as a model yes good idea prior to that version of putting it here
we can just put fire to a point and the secretary would expect the grant
recipient recipients to no longer be able to complete their service
obligation you know you know the divine we go service obligation period so what would you want to tell them then
I mean would it stay the same well I would say that first okay so we would
then this is the the secretary will notify the grant recipient is there
gonna be more than one thing included in this because if so I would you like rate
them yeah so grant recipient maybe yeah yeah no I think the way they have it it
goes to a little I I don’t it doesn’t seem as consistent I would expect it’s
not a legislative assertion the necessity to submit paperwork or the
appropriate paperwork reflecting any service obligation completion or
teaching I’ve forgotten what help me out what were the terms we were using
throughout the Reg in other words get your paperwork in if you’ve actually
done this completely Frank I mean I will I was a
sting looking back at the service obligations there is not a cleared
deadline by which they have this event the service obligation this yeah
service obligation documentation right this is why yeah this is why we’re
saying you gotta get this and say you just haven’t talked to them and for a
half years I don’t but I don’t think we need the
word prior yeah but also I would like to add the consequences oh yeah this is
just a list of things yeah this is the first one I just don’t want this one to
be the warm fluffy no this is gonna lay out like I think your paper get your
paperwork in if you’ve done it is the first I I think does not submit the
paperwork there’s grant will convert you alone with well this is the notice so
inside this notice I would like for it to say this is your interest accrued
unto this up to this point right so is what I’m saying we’re gonna get there in
the here’s what you need to do to fulfill the service requirement if you
do not submit the documentation your grant will convert to a loan if your
grant converts to a law and it has already accrued X amount of interest it
does that address that yeah I just I’m not in love with the verbage um yeah no
I think this River sounds like the notice rather than you regulation
governing that notice this I’m sorry I’m sorry I missed I missed what she said
it’s okay I think we’ll have time to change the verbage anyway I just don’t
know you said this sounds like a notice and I thought rather than the regulation
that would drive a notice okay but some of this other stuff is rather
scripted too so I think you know guess language massage but it might be okay to
have it there see I just I don’t like the witness
starts with if and this is a regulation and I’m reading if what it how do I
think I like consequences of like we’re notifying them why this is the notice
they’re trying to question the paperwork not be submitted or should the service
obligation something out about is it should the paperwork not be submitted
something about the service obligation so that the if is not there that it’s so
we’re the Secretary will notify the grant recipient the necessity to submit
the paperwork the consequences if the recipient does not submit the paperwork
and that mean the consequences if the grant converts to a loan that’s better
I’m still not but it’s better we’re treating so I guess and I’m
probably just being picky but it’s not the consequences if they don’t submit
the paperwork it’s the consequences if they can’t submit the paperwork because
just submitting the paperwork still doesn’t guarantee that see I see yeah
because they could submit paperwork in desperation that means nothing they have
not they will not be they have not because it it’s they still have a chance
if they possibly if they’ve done some obligations so it’s not an absolute that
it converts so you know I think this is something we that we probably need to
take home with us and work on some language definitely because I’m also I
don’t see in here where there’s any deadline for requesting a suspension
either and so that’s the thing I was gonna add it’s the soy one I would like
this notice to even include the option to request the suspension the secretary
will notify the grant recipient of the option to the option to request
obligation specification of whatever that I don’t know how the conditions
under which one can request a suspension because if if we don’t say that then it
sounds like hey I need a suspension we have it earlier the conditions under
which the grant recipient may request a temporary suspension of the period for
completing the service obligation yeah is it up right above it
or go up a little bit it’s actually more where it’s yep lettuce the term consequences to me is one I
would like to see change because that could be it’s quite broad
look we lots of consequences and we don’t expect that this is so is it’s the
action taken regarding the loan or something are we regarding the ground or
something like the action the secretary will take regarding alone loan grant some booklet yeah right I think I think the appeal
information should go with the because this is not actual conversion paperwork
just yet and it’s not being counted and now none of my four years of counted
because of one disagreement that so if you put the appeals process here that
gets confusing because the first month this is a notification to just say this
is like the hey just in case you didn’t get us the paperwork get us the
paperwork and there’s an int but if you don’t then these others we and and PS we
just want you to be aware of these other things but then the department’s drafted
language about when it’s converted they even have some language on an appeals
process in the offering that they have on the paper so I think if you put in it
if you mention it too soon it just gives them another – I can just let this
convert and I can appeal later right not not only that but I think part of the
battle we’re fighting is information overload that’s part of the problem with
why this is so very confusing for students in the first place and so with
the intent to be as effective as possible I think keeping it shorter
rather than longer and extraordinarily relevant to what we’re trying to jog
which is communicate with us and get us or service it to me would make more
sense why don’t we see what else we have here
and see how these other things may fit in and then we can I mean I I also
wonder whether or not in the same way that we provide a notice here that we
also provide a notice when service years have been accepted or rejected and when
there’s a final decision there I mean what think we do wasn’t the annual
notice in the prior so that would so I remembered to get my mic that time so in
the annual notice it does your your being updated like so say I submit after
service year and I think I’ve got it and then I look back and the department
doesn’t have that then I know I immediately have to ping them and say
now time out here you rejected this so but I completed my service because I
think we talked about it that we did not alright so right at least annually
during the service obligation period the secretary notifies the grant recipient
of terms and conditions than adopt requirement for the grant recipient to
provide the secretary upon completion the timeframe within which the grant
recipient must complete and the conditions under so this is again just a
very general information so it doesn’t speak to the things that we were but I
think about it’s already happening correct that the you you you were
stating that they do get it told in there no you were sidetracked because
even if it’s already happening as far as regulation goes I would like to have
that annual notification to to include service years or obligation already met see that it
just says the obligation but not what was met
I wonder if under his eye I sort of here we are going with this but also the
terms and conditions of the grant recipient must meet to satisfy the
service obligation if that’s an annual thing does that change therefore with
that would you perceive that a to I like each year who changes the terms and
conditions that the grant recipient must meet this has to be the service
obligation changes based on whether or not they’ve submitted well their
paperwork actually I think what we intended there was simply a reminder
that basically you got to teach and I Neifi low-income you know so maybe right
there we could I would just suggest as a um well I’m wondering is like romanette
three the timeframe our intent there was to say you’ve got to do it by this point
and are you suggesting we expand that to be little more okay kind of deal I like
something that’s comfortable what they already here you know you’ve already
done X number of years you got X number of years well when you have this much
time to do okay so we need to be well is it there we already have you I checking with Lucas
everybody’s thumbs up all right Oh Aaron is not Aaron I’m sure he’ll be back yeah
find him good cause we really do need Aaron particularly since for about two I
hope at least move on to the next piece after wrapping up a little bit even if I
wanted to get on everything is lost ago it’s like there’s nothing I can do sorry
we can still talk about right though Jake you got your own interchange because the scammers can go in and you
found words that weren’t even words just don’t worry we can’t start without you
oh we’re running over you’re running are running are myth okay so before we move on to number four
are there any when I say four I’m talking about grooming up for guess we
haven’t talked about because there’s also for way below that so I just what I
want to forget that one that we have that one are there any other pieces that
we want to discuss before we go into romanette four can we just go on to
remand it for at this point and assume that people will be worth smithing over
the break we’re still talking about or we’re talking about the new inserted and
that we haven’t even gotten to what was previously listed as three so did you
mean romanette four of this this one being we haven’t gotten yeah we’re not
at three yet so now we’re onto the new four or the four that was previously
three correct you got it so now we’re gonna go to three as we
have it on the paper which is now four on the screen yes which is the
notification when a grant is converted yes that’s where we are
yes yeah the teacher amount is first recipient reverted to a direct
unsubsidized to teach the secretary notifies the
recipient of the conversion and explains hi that the recipient will receive a
six-month grace period before he or she enters repayment in a direct
unsubsidized loan WI that the recipient has the option of paying the interest
that has accrued since the day of each teach grants disbursement and that any
unpaid interest will be capitalized at the end of the six-month grace period
and in that three run three should be dropped but right in here that once a
teach print has been converted to a direct menses unsubsidized loan it
cannot be converted to a grant unless the grant was converted to a loan in
error when that was where the error Burbidge was at it and then finally for
running it for the process by which the recipient may contact the secretary to
request sorry if the recipient believes that the teach grant was converted to
alone and error the deadline by which the grant recipient must submit the
request for reconsideration and a list of the specific documentation required
by the secretary to reconsider the conversion has Department started
defining what that process will because it’s referred to and then not described
in these regulations yeah at this point I don’t we haven’t
really talked about what this going forward process would be is there
something you were thinking well so I have heard from folks who have tried to
appeal their wrongful grant olan conversions with fedloan and they’re
never told that they could appeal the decision with the FSA Ombudsman I’ve
heard from folks who talked to the FSA um or who talked to a Department of
Education representative and are never directed to the FSA Ombudsman I’ve heard
of folks who heard from the FSA Ombudsman that their grants that their
grants converted to loans could not be reconverted so I just want to I I would
hope that during this process we would have a more clear process to find what
we we recognize that we haven’t currently had a clear process to find
and they probably haven’t publicized it as much as we could so that that’s the
intent here is they going forward to spell that out be a more transparent
deposit so during the next session should we come with proposed language
around the process okay so I did also want to flag I did also want to flag
what I mentioned earlier and wanted to get the the sort of opinion of the folks
around the table regarding counseling and that sort of idea I don’t I think
this is sort of the right space for that and and what additional information
should be provided to some of whom now has alone are you thinking like a third
so you have the in addition to the guidance that institutions are given
when they’re doing entrance and exits lying
you have the PDS that are the initial and exit counseling as well that it
would be like a third document like conversion counseling yes some sort of you have someone who
has had a grant and now has a loan and so as we’ve when someone receives a loan
they they’re the fictions and exit counseling as part of their program I’m
not necessarily suggesting the full gamut of counselling but that’s I don’t
I figure I think that’s be a good idea because there could be some teach grant
recipients that don’t have loans and so and they didn’t go through entrance or
exit counseling so we need to know about options like consolidation like the
different raymond option or ways where would you add that right and I also want
other one other point that I think I mentioned earlier too was that I do want
to make sure that there is information provided about public service loan
forgiveness as well I definitely agree with adding information about the other
programs um one teacher brought up to me that the
teacher loan forgiveness program is almost identical qualification so if
they may have been eligible for Heath grant they likely would also be eligible
for the teacher loan forgiveness program and it would just be more if they were
teaching in any position as opposed to a regular position but I am wondering with
the counseling would that put an obligation back on the institution to
follow good alumni I don’t think it would be the institution I think would
be the servicer so it’d be like another web-based program most likely right I
mean that’s what we have an hour all web-based we would have eight Wow
depending on how we would incorporate it I would suggest kind of mirroring but
we’ve got currently frig’s at an entrance this is something we can think
about too until the next again what we have now I do am not a fan of but it’s
better than nothing I think my question is is it the servicer that should do it
or is it something that we should look I don’t know forgive me
FSA should do or as we think through this we
I think we all agree especially because there could be students who do not have
loans that this is a necessary thing but we should also make sure that we are
considering the right provider I don’t know what that necessarily means I defer
to my maybe adding help currently not all but most institutions rely on the
the web-based tools which are provided by FSA at studentloans.gov there are
still some smaller schools that do the face-to-face counseling and we do
face-to-face counseling whatever we can but it doesn’t touch everybody we rely
on the web-based so when you say whose responsibility would it be I would
envision something at studentloans.gov but maybe called conversion counseling
so the tricky part is that you know the onus really is on the institution for
entrance counseling and we cannot disperse the loan funds to the student
until it at least appears as though they did it when maybe their parent actually
did it but until it appears of the student completed entrance counseling we
can’t disperse so the onus and becomes what reliable mechanism can we ensure
that they get the information other than just mailing it to them telling them
they have a requirement so I think that’s going to be the most difficult
piece I think it’s basically the same with regular loan exit counseling you is
the school you have to tell the students that they’re required to complete it and
if they don’t complete it you have to mail them or notify second notification
right bottom line is there’s nothing we can do
unlike entrance counseling there’s no hook if you’re a first-time borrower you
don’t get your loan until you do it but if you don’t do the exit counseling it’s
not like you don’t get along Yeah right so we’re not gonna say well otherwise I
wouldn’t do that I would say that for some folks even having initial
counseling exit counseling conversion counseling on the FSA website they do
refer to those documents I’ve heard them talk about referring to those documents
especially you know we hope that that 1b form process fixes the form but when
those forms are confusing folks do go back to the
counseling and so I still I still think it’s worth while even if we don’t know
if it’s gonna reach students because just because it’s not yeah if it’s not
touching them at the intended place yeah I do want to say it’s a few minutes with
the feds in here and I’m sure this is completely out of the scope of what
we’re doing but that exit counseling that we’re talking about you don’t have
a hook what you do because you have an interest rate and when I mean felt yeah
probably say but when felt lenders we’re doing their their thing I’m aging myself
right now but that’s how they entice their borrowers to do things after
exiting the institution is they would reduce their interest rate by five
percent or something so just something for you guys to think about just saying
because you do have that and if they do their exit counseling we actually can’t
do that there’s statutory limitation we can only give a lower interest rate in
order to encourage timely repayment we used to have a little more flexibility
but no longer but maybe we can change that in the new higher end authorization
that’s coming just in a year now that has that all right we have that in our
HEA recommendations so that’s one of ours just out of curiosity is there a
place in these regulations where you think that actually could live that’s my
other question I do and I think it does belong in the right here because we’re
talking about at the time of conversion so I would and I could take a look at
existing entrance and exit requirements and kind of mirror some of that and
bring it next time can you read that can I actually just as we’re thinking
about how to define the process going forward for the next session what so I
know that there’s not a process nano would the Department to be able to
process disputes assuming that all the disputes that have been coming up like
there will always be some service or errors right like that’s just sort of
inevitable and there will always be some issues with form submission inadvertent
administrative Earth’s would the department need to specify that at least
one full-time employee deals with teach grant disputes in that set of
regulations I just need a little bit more how does that work within the
organization of FSI as ever would you require within the regulations that
there’s a person okay have a comment on the reconsideration paragraph and
specifically the word believes it says if the recipient believes that the grant
was converted in error can we change believes to is able to
provide evidence sorry it’s in for is able to provide evidence wait a second though I mean I wouldn’t I
would want them to look through the entire process I think if they believe
that their grant was converted in there it should direct them to where the full
process is defined elsewhere and then that process would be defined as needing
to provide evidence can we in in this case of error
can we put service or error there just simply because we’re talking about the
student perspective your mic your mics not on but wouldn’t that limit if for
any reason it wasn’t a service or error and it was something because we’re
asking remember the servicer is acting on behalf of the secretary but if there
were some other error that unforeseen unthought-of here at the department if
you just say servicer then it can only be a service or error I would rather
leave it more general error other than the students error in which case this is
sort of an endless loop of paper submission because for a student it
could just be I forgot my deadline in error I understand that um but I’m
thinking that because this is a regulatory language to leave some room
not necessarily with anything specific in mind well I’m not sure that the
verbage we’ve been relying on to parse that out has been determined to be can
at this point the sense of clunky the process by which the recipient may
contact the secretary to request reconsideration of conversion if the
recipient that that if the recipient is able to provide a bit of evidence that
the teach grant has been determined to be cut what that doesn’t work what about
if we use just an administrative error administration error that way it could
be surf servicer I think it admit a student can also make an administrative
error whoops I forgot to sign it that that could be interpreted as an
administrative error I’m not saying it is I’m saying the student could perceive
that as I’m not saying that it would be that’s not this is not what the
student’s going to be reading so um I think it is again correct it’s
not what the students going to be reading but it’s what’s going to govern
the practice by which all of these are reviewed correct but I think you keep
saying that the student would read as these things so I guess trying to
process everything you’re trying to share well I’m trying to grasp why that
would be because there’s been concerns have been raised with that particular
yeah I mean I can just context as we think about it right so if this is just
the information provided to someone who is yeah
about to go about to undertake this process and they’re being notified then
you’re just simply providing them the process by which they can appeal I don’t
I don’t necessarily know we need to spell out specifically what era
I would I would hope that as a student or a borrower or her previous teacher
grant recipient would understand that and I would want them to think that they
could file an appeal in a variety of settings I would I don’t need them to
necessarily parse out exactly if my case fits here exactly right I think it would
be nice if they felt like it was converted in there to get rid of the
change then so what you’re saying I think in areas is sufficient it’s really
what I don’t know if we need to go through well also I think then if we
leave in if we take out believes and is able to provide evidence then we need to
sort of tie up the end because the end of this is the evidence that the
secretary would be asking for and so I still think if we if we do go with
changes from believes but to that end of what you just shared Steven if we’re not
going to sort of parse things out then it should be left open that
student believes there was an error so they enter into this process and the
results are not necessarily that the Department agrees that there was an
error but comes back and says thank you for submitting all of your documentation
yada yada sorry or thank you for submitting your documentation and then
we shift into the hey you just got converted back to a teach grant I agree
with that and that’s why kind of and that’s why able to provide evidence I’m
not sure we want that I think the believes state might or something and
then I think we’ll get into a broader conversation of what now constitutes
evidence too because here’s what concerns me about leaving believes in
there is it establishes this process as a belief space process not an
evidence-based process and so I think we’ll be able is is indicating that they
don’t act at the point at this point need to but they will need to submit
evidence that that’s why but at the end of that statement there it does say that
the grant recipient must submit the request for reconsideration and a list
of specific documentation required by the secretary to be rican to reconsider
the conversion so in the as you finish off that section it already lays out you
have to prove it with this documentation so that’s why I think believes is okay
because they may enter into this and then start reading through all the
documentation and go whoa I don’t have any of this so I must really well or
they enter into it anyway and then really quickly somebody goes ynx you’re
out I mean this is also one of those cases where as we define what the
process looks like we can define what the initial form looks like and that I
mean we’ll know if they can’t complete the form they will most likely select
out or they’ll get a very quick response from the
saying no this this this one was not completed and it doesn’t pass muster and
their four-year loans were not converted to her I just go back to you know things
I’ve said before I believe to me is not regulatory language that I’m used to
that were comfortable with it’s one of those I don’t know I’m much more but I’m
not gonna argue the point because it doesn’t seem to be winning at the moment
and I get that the second part is there but it’s just not me regulatory language
we can rather have it say feels feels there’s but but to me it actually reads
the same feels or believes and that’s that’s my concern but I mean assumes
maybe that this was done in error I mean all of this I I hear you in terms of the
word believes in the challenge of it being in regulatory language but I think
as we stay student student centric throughout this whole conversation maybe
we just highlight believes and say we want to come back to that word later or
that you know that verbage later to figure out what might be the right thing
because you could believe that you did everything right and still and and
discover a you don’t have all the document documentation to submit or go
through the entire process and have the secretary still say no or whoever
whoever what if we just said the process by which the recipient may contact the
secretary to request reconsideration of the conversion period the deadline or
comma the deadline by which the grant recipient must submit the request well
you actually you can just you can you can get rid of that and just strike the
stuff in the middle yeah you can take all of it out yes if we just talk about it enough somebody
in the room gets the answer right it takes out error it takes out evident Aaron yeah that paragraph just right
above it where it says converted to long in error is that where you want your it’s to romanette for five
so if a grant recipient who requests reconsideration demonstrates to the
satisfaction of the secretary that at each grant was converted to a loan an
error the secretary converts the loan to at each grant and notifies the recipient
of the conversion to a grant and explains that the recipient is once
again responsible for meeting all requirements of the service obligation
under six eight six point one two which is the agreement to serve my I think my
my only addition here is that they notified the recipient of the
reconversion and explains the recipient is once again responsible meeting all
the requirements but somehow I would like to see in the regulation whether
the Klotz going to give us a suspension for the time that it was that’s in the
limbo stage because and I don’t and I don’t I know we kind of went through
this earlier whether during the suspension time the student or the
recipient loses their service time or maybe even the recipient has the option
to choose I’ll take the suspension years or I will keep the years and use my
service time I just think somewhere right here if the secretary is going to
notify them of the reconversion that whole thing needs to be addressed I
agree and that’s what my comment was going to be I think this is a great
place to put in an automatic suspension for that matches the time frame for
which the and even for awhile it was converted I think it should encompass
the whole timeframe from conversion to determination but the students but the
student should have the option to keep the start date back where it was and not
use a suspension well this is where we come back into our discussion is it okay
to have concurrent suspension and service completion I would say yes
I don’t read the statute either/or right I think you can have
both simultaneously and I would say though in the department clarify why not
it would be if the if this teacher was doing qualifying service during that
period they get the credit if they were not doing qualifying service they get a
suspension that yeah cuz they get them whatever works out exactly what I was
trying to say whatever so now we need burbage for that actually no I think it would be whatever
indents after yeah this is the notification so if this can be pretty
great grant recipient this is gonna be real sketchy guys if the grant recipient
completed qualifying service during the time of
the conversion they will be counted if not it could be suspension this is
automatic suspension this there are other there are other periods in which
while we’re considering a person’s request I’m thinking total and permanent
disability we don’t capitalized interest or we
don’t charge interest during the period in which the bar was in the what used to
be called the conditional discharge period so this would be somewhat similar
if the teacher was doing qualifying service we would retroactively lis give
them credit for that service assuming the a documented that they were doing
the service if they were not doing qualifying service we would not penalize
them for basically raising the issue of the you should’ve you know my decision
was wrong and we would give them a suspension for that for that appeal
period or reconsideration period yeah so while we’re looking at it we’re
not going to penalize them for that period this is the notification part
yeah I know work is a little off yes I also want to flag I know we’re still in
the notification piece but because it’s under double I yeah as we further define the reconsideration
process this what I would see this as being like part of the result of that
process so we’re gonna have to add another paragraph to address that and
then we’d want to add refunds loan payments if the grants converted back
mm-hmm and they paid made payments on this lawn I wasn’t ever supposed to be
at the money one question I have to the department I don’t know if this has been
considered at this point but if a loan is converted back to a grant would that
be considered forgiveness and then how would that effective tax life it’s it’s
not considered loan forgiveness isn’t it great thank you well one thing I just
been and I’m still trying to sort it out is remember that going forward into what
we’re proposing the only things that would convert would be if you ask us to
or you run out of time so I’m thinking there should be far fewer disputes about
conversions in air and I’m even wondering what those errors could be but
if say you were converted because you ran out of time and you hadn’t provided
any documentation of teaching service yet what I’m trying to envision what
sort of air could have resulted in an improper conversion so this talk about
draining a suspension I’m just do you see what I’m saying I’m trying to it’s
not clear to me under what circumstances this would apply I think in everything
functions perfectly you may be right but in an excess of caution given house
certainly you might have a case where maybe the grant recipient I guess could
say well I actually have more time left because the graduation date reported
from biomech school was incorrect I actually didn’t graduate until you know
you’re later so that’s one possibility but we’re lost
lost documentation something like that yeah I’ll also say on the suspension
provision and given our notification there could also be the circumstance
where someone becomes very ill doesn’t file for the suspension at the beginning
of their illness gets the notification that their grant is about to convert and
then would submit or had it convert wrongly and then is able to submit
retroactive suspension paperwork we did not say that the suspension could not be
retroactive and I think it was presumed that it would be during the pendency of
the department determining whether or not the suspension would apply so there
would be circumstances where maybe this could still arise just to administrative
issues again I just want to ask again if the
grant recipient did not complete qualifying service during this time it
would be automatically suspended is it is it going to be automatically
suspended are you just gonna not penalize them because that’s kind of
different right because for the period of suspension that that time would be
added on on the back end of their eighth year what I’m hearing bronze ladies do
they wouldn’t be penalized with interest and such but the under the pin of the
definition of penalizing you would not count that as part of their eight years
okay next bye if a grant recipient her
requests reconsideration does not demonstrate to the satisfaction of the
secretary that at each grant was converted to it on an error the
secretary notifies the recipient that the grant that alone cannot be converted
to a teach grant explains the reason or reasons why the loan cannot be converted
to a teach grant and explains how the recipient may contact the federal
student aid Ombudsman if he or she good thing is to believe that the teacher ant
was converted to a loan in error so in here I would also like to add just in
case the student because remember they got converted and the turret not the
tradition but we’re inserting conversion counseling but if they felt that they
were converted in error they might not go do that counseling so I would like to
include some language that now sort of reiterates again because they’ve been
declined and now they’re now for sure they’ve got this loan that they need
that count conversion counseling again I don’t know like a double hit so this
would be spot to where they may receive information on conversion Council yes I have no lightning
I don’t did we have specific language any verbage yet but I’m envisioning
whatever comes under number 3 yeah just that this would be for maybe or I’m not
sure I think it would be I think making it a four because it’s one more thing
it’s not necessarily tied to any of these others directly but make it a
Roman numeral four so that and then Emily if we do find that it should shift
but just looking at the back with whatever the verbage is that we end up
agreeing on after I bring it to the day yeah yeah cuz it would be the same same
thing again yeah and then I just want to flag that
additional appeal to the Ombudsman may be subject to change based on how we
talk about process and whether or not the I misled men would be the one the
one conducting that I feel of that decision question for the department I
know you haven’t considered this process yet but would you
is it a potential that the Ombudsman would be the individual or the office by
which this appeal would be run the initial yes the initial probably okay so
yeah I think we just leave it there because the Ombudsman is like them but
the last jelastic the Ombudsman’s role is not to be a decision-maker
they kind of coordinate getting people together to actually go yeah that
they’re not under the statute they’re not created to to make administrative
decisions gotcha but we need to identify somebody
appropriate within the department to do that so forget it’s a little bubble that
says we need it that that is not the party to so I have a mental note that
it’s the FSA Ombudsman is not the appealing agency but we’ll have to
identify an appealing or not the I don’t know have someone specific who they
train up and it’s not for us the same regulation this is kind of like the
appeal to the appeal yeah this is the last this is the last oh this is like
the last resort so the first appeal we do need to know who who’s gonna be
dealing with that but if you don’t like what the secretary says the only place
you have to go or bring an APA anything else before we move on which is six eight each grant recipient
remains obligated to meet all the requirements of the service obligation
under the agreement to serve even if the recipient does not receive the notices
from the secretary as described in paragraph a two of your section so
that’s just there so a student couldn’t say but I moved so I never got them it’s
if the secretary never sends them that’s a different scenario right okay you have
to know where they are wait but if the secretary does never
send some they also would not have this that also wouldn’t be a defense
it’s about conversion so that that actually is not a different scenario at
all they just said it was that’s right it’s like we don’t even if we don’t send
any bills on a student loan doesn’t matter the bar we’re still required to
repay that’s just a matter of you can’t use somebody else as excuse to get out
of your obligation I mean somebody else’s failure to get out of your
obligation so then this is saying I don’t think that they would do it but
accidentally they may miss a chunk of students for any of these touch points
or notifications and the student could still have their loan convert would it
be an argument for erroneous conversion okay again struck the usual I have a question
why doesn’t the teach grant count towards the aggregate limit of stafford
loans well because it that without actually just said advantageous to the
student because it could limit your future loan borrowing he wanted to go
back because if we didn’t increase your outstanding balance and count towards
the aggregate along with it so we purposely did not want to count that so
that this is a good thing for the student and it would be really difficult
to count a grant in a loan aggregate while the student is in school yeah so
so for example if you if you had potentially sixteen thousand dollars in
grants converted to loans and they stayed converted and that counted
against your aggregate loan limit well I have one thing it could cause you to
exceed the loan limit or yeah or it could take you so close to the limit
that if you decided to go back to the school you had nowhere mean no limited
or no eligibility for more direct loans right but the whole reason that the loan
limit is there is to prevent people from taking on debt that they cannot that is
that is excessive right I mean we we are putting teachers in a position that if
it does convert that there’s debt but then eventually be well over the limit
and be excessive I think one alternative you have to consider that in that case
is is most likely the student will pursue their additional program and then
they may be then forced into non favorable private lending options which
a number of consumer advocates may find troubling as well yeah
I guess my question was about the the six-month if that mean are you think
talking about the we had earlier conversations about giving people a
grace period right this is a totally different grace period this is really
like the grace period you get on our regular Direct Loan when you graduate
day it’s the six month grace bear this is this is where you we use that term
grace period loosely in the other discussion but that’s something totally
different from this um I don’t see any language in here and I don’t think this
is happening now but I just don’t know if we want it regular put it in the
regulations regular regulated that although the teach grant does not teach
grant compared to a loan does not count against this recipients annual aggregate
limits but they do get the benefits of in-school deferment and such and they
can consolidate these with their regular loans and so that’s been a question I
know just among my students in my area not me personally but in my area when
would they know that they’re going to not fulfill their commitment like when
they change they’re just wanting to know if they once they turn this into a loan
what if I’ve already consolidated my loans and then eight years later this
converts into a loan and under the current regulations if you get a new
loan you can go back and consolidate but I’m talking about yeah it’s basically it
essentially has all the same terms and conditions as a what I call a regular
direct unsubsidized loan so if you had previously consolidated all of your
outstanding loans and then you had your teach grants converted you could then
consolidate those with the existing consolidation learning to a new
consolidation okay and that’s what I’m suspecting
that’s what that’s actually what fed long time is but shouldn’t we put in
here where it says is elder for all the benefits of the Direct Loan Program
including we put in here including in-school deferment but also
consolidation something right there to refer to the consolidation so that it’s
not just like it makes it look like it could be separate because this is what
the students are saying my interest is retroactive i consolidate on my lungs
from those times that time period and so even though it only turned to a
unsubsidized loan in 2016 it was really because it was in 2008 and i consolidate
all my loans from 2004 to 2010 is this a 2008 loan that I can’t consolidate
because it’s not new or is it brand-new because it didn’t turn into a loan until
2016 like I said fedloan servicing clarified that yes you can go any merge
it back and consolidate it with the rest of your loans and yeah you got to got it
but that’s not spelled out here so I just don’t know because we’ve already
talked about how some servicers will tell you this and somebody else will
tell you that I just want I think we might have an option here to put it well
then I think if you’re gonna call out specific benefits I’m not sure how you
decide what to call out I mean because they essentially have all the same terms
Canisius any direct unsubsidized loan and as far as calling out consolidation
I think that if you’re you know nowadays most going forward more and more
Barbara’s gonna have only direct loans so if you had regular Direct Loans if
all you have are Direct Loans there is rarely any reason for you to want to
consolidate but so if you had regular Direct Loans I mean at each grants
converted to your direct unsubsidized alone I don’t know that there’s any
particular reason we’d want to call out consolidation because there isn’t any
real benefit to it in fact in some cases maybe your disadvantage to
consolidate your direct loans because you may lose credit for payments you’ve
made like towards bsl-4 income driven repayment but so but the short answer
though is that if you did have a prior consolidation loan that repaid all of
your outstanding loans move your Direct Loans maybe add some fel loans and then
this happens you could then if you wanted to you could reconsolidate this
loan with the existing consolidation loan into one new consolidation and I do
understand I said that was what we were advised I just and I understand what
you’re saying as far as calling out all the benefits we’re gonna air quite a bit
advance because that could be what I was doing was okay if they say it has all
the benefits including consolidation I’m just not sure why we would call out
condition every single apartment that’s that’s not point I think in school
deferment is maybe always a benefit whereas consolidation maybe isn’t but
you wouldn’t have to consolidate to get any in school deferment well then you go
back to school if that’s the case then it would be even I’m even I’m even more
adamant about putting here because is the element for all the benefits of the
direct loan program so if in-school deferment is always a benefit that’s
already in plot all the benefits and if we say include including an in-school
deferment then it almost limits the language so either we strike that yeah I
see everything you sometimes write about like I’m there because I like the is
eligible for all benefits of the student loan program period here you drop the
mic everything that you everything that Bo does actually ask
practice questions when these loans convert what does the interest rate
freeze from the point where you take out the grant so it would be the
unsubsidized interest rate or is it the unsubsidized interest rate when the
grant converts to a it is the uncited spelled out in the agreement survey is
the unsubsidized it is the interest rate for unsubsidized loans that were
dispersed at the same time as your teach grant and so that means that because
direct unsubsidized loans have a different interest rate depend on
whether you’re an undergraduate or graduate that carries over here so if
you get at each grant for a master’s degree program the interest rate is
going for each teach grant disbursement is going to be the interest rate that
was in effect for direct loans that were dispersed at the same time oh yeah that
was my only I just seem to muddy the water every time we are through pass one it took us two
days we worked really really hard and we got it done so we should all just give
ourselves a hand because we did a great job thank you everybody so next steps
let’s talk about this a little bit so that we have some sense of where we are
going to be going forward we will have worked on we have a red line here that’s
the new updated red line yes I think we should email so that everybody has a
copy now remember this is still a proposal we have not nobody has really
signed off on anything here right very rough proposal yes because we are going
to make multiple passes yes and add and so my what I’m feeling will probably
happen is that between now and the next time we meet everybody will be looking
at it and thinking through you know is what should we do at this language do we
really want these changes whatever is appropriate and trying to get that
feedback so that when we meet the next time we can move much more quickly
through the document and start start solidifying things that should be
solidified and then making sure everything kind of works together so I
have no idea how long that process would take but it should work faster than
going through this the first time around I believe that we were asked for some
some data I don’t know when we will receive that data but if it is possible
for us to get it to you by the next time we absolutely will
were there any forms that that we were supposed to get that we know
can’t remember certification form and wind I sent that to you okay so we have
that okay so that’s this service we also get this
service well actually it’s all in one has all of
the ones they use now has area it’s the certification of in tad Hamlin in the
station they teach me service yes how long have you been using that form
they’ve been using it for several years now do you know that those started using
it when they became the swords so we need to get that everybody as well oh you emailed it already okay I said
well we can I guess at this point what you mail it out I just want to be sure
that we have the salient to ask yes I appreciate all this work but can we get
these forms in electronic format yes oh you mean the other forms that were
provided today for to talk about the PDF what are you gonna do nothing you guys
can have it there’s two of them I just wanted I just wanted you to
understand that you know Shelly tells me you can export if you do all the states
you can do all the years and then you can export all the data into XML and
then you can sort and filter it there is there is a link there is a link to Sofia’s to their plaintive
phase-out yeah yes that’s what I was gonna say the link the link there is a
link to the let’s sort of step back a second that’s a PDF version compiling
what everybody in the nation has done there is a new link that I’m not sure
how well it’s working so you may if you don’t get on it from Internet Explorer
you might want to try Google Chrome that is the new collection site I guess I
want to play it for States to submit this information and then the guests can
go in and export this information out it’s it’s still a work in progress so I
don’t want to like you know tell you this we had some email exchanges about
that is there I just be aware I think they’re still working out so I I’m happy
to send you the link as long as with the caveat that it’s still a work in
progress and and just as an example I was actually working on it was a teach
grant in case where someone was teaching in a tiny field listed in their list it
was it was shown in that document but I couldn’t pull it up in this new new one
but it was there in that nothing so there that’s a big issue I think that’s
a huge issue yeah I don’t know how and I think you may pick some similar I would
describe this as this the this this is a better thing to look at for the purposes
of thinking about the regulations while we’re working on this electronic well I
think we need to somehow that to students how can we be making
regulations that rely on something that doesn’t work well we have brought these
issues to focus attention but I think we also brought it up as a one of the
issues that students have had in the past in deciding if they were gone going
forward or if they were in compliance with the teach grant because of both
state the national list and the other links and making sure that whatever we
end up saying or stating in the in the policy that or in the rig’s that it’s
consistent with the most up-to-date information and that it takes everybody
in consideration all of those my major concern is that maybe I’m a teacher and
I go online to look to see if my service counts and it appears that it does not
what are they supposed to do or can’t even fathom and what is fedloan using to
determine what is the high mean teaching position versus what is not in rejecting
these forms to find out if that is still available yes now you can still get this
is teach recipients pain have been penalized based on this confusing
information I don’t need to I’m not saying that these are widespread but it
Sofia said there may be previs with what browser because I also had some problems
doing a search with one browser but it worked okay with another browser it
could that could have been part of the issue that I experienced but we do you
have this and that is reliable I I don’t I can’t estimate what they’re using but
I’m not aware of any issues that have come up and obviously if somebody was
denied because they said well we don’t see that
you’re teaching a hiney deal and they could show that it was then that
standard my concern is more that as a person I’m going to validate that before
I send in my paperwork and if I can’t validate it myself by seeing it in a
database I’m not gonna send it in I don’t think anybody would the bother the
link that we provide in the 80s currently is to that we purposely did
not update it yet to this other ones so people who click on a link are gonna be
taken to that but why is the other one even live if it’s not accurate well we
don’t really necessarily know that it is no we just I said there’s one situation
I saw that did concern me and I brought it to the attention of the people that
are working on this but there are some other more technical issues too that
I’ve experienced by other websites that they work fine with one browser they
don’t work with another browser that was a problem like with the new one if it
with anything like this it takes a while to work the bugs out and they are
working on it and the problems I had we’re trying to do searches it was easy
with one browser not with another browser that yeah I think for our next
conversation though our next meeting we need to take that in consideration as
well as I think we brought up that there’s states that have a have a list
out there and how we can make sure that we are drawing everybody to the same
list or to the National list that we do on the agreement to serve in all of our
our materials we direct people to this list that that’s what we do and again
what they’re directed to is this one not the right anyway so there’s so for our
next meeting rule you will have some further information on this where does
the forum just I’m never going to assume anything the forum that sent out for the
annual certification does it reference that or does it just say it because it
references the nationwide list every every Center annual certification you’re
more likely going to end up at this
electronic – you are now and I’m not just to put it in perspective just keep
in mind – that the overwhelming majority of teach grant recipients are not
they’re teaching in one of what I call the core and I need field so it’s not
excuse me that’s not to suggest that you know that that couldn’t be an issue but
for the great majority people they’re teaching math science you know I’m just
saying you just put it in give a little perspective right now right now they’re
linked to this that’s where they go yes which they may have filled out four
years prior to now filling out their service obligation perhaps this is
something that as you’re working on this reconsideration that you’re about to
launch that there’s that this is also just flagged as one of those potential
reasons for conversion even if you may not find that that’s the case at all but
if it’s at least liked but I would I would like to bring that suggestion to
the main committee in the event that just because all of these I mean these
are these would be so confusing for teach grant recipients trying to figure
out how to comply with it which means they should not have they should not
suffer bright tender I did a reconsideration process that we’re
undertaking if the reason you were converted was you submitted a
certification of teaching and you got it in past the deadline or you you got it
in and you said you were teaching in high-need field X and the fedloan for
some reason looked at the other database and it just so happened that the Heine
field was not in there but it wasn’t here and by the time you got back to us
it was past the deadline and you could show that in fact it was I need field
you would qualify for reconversion I hear what you’re saying and I know we’re
trying to be done here but I think that when you send out this notice it’s
probably already drafted but this notice that’s going to all students who had
their grant converted I think you need to point out that there are
inconsistencies in the data basing but we’re not pointing out in the notice
that’s going out we’re not talking about the reason for the conversion doesn’t
matter it’s just going to people if you believe again the service obligation
requirements were not specially I don’t believe I am because when I looked it
wasn’t in there right that is the scenario tried why were you teaching in
that field he didn’t believe it was I need field you wouldn’t have been
presumably you would have thought it was a high need field and that’s why you
were presumably and then I would probably be a little confused as to why
it wasn’t there when I went well if you were if you were if I remember that can
be back and we’re told how long has I think the other question is because I
know we’re starting to look back in time and freak out about all these students
but I think it would be helpful in the email that you’re putting out to us with
all this information is to say this website went live on this day and you
know how we can be of assistance to you to push it your tech people to fix it
and that sounds like it hasn’t been up for very long and I say that loosely but
I think knowing exactly how long would just be helpful I will also I just it is
interesting to me that the department is suggesting that that students would know
that now this is suddenly legitimate whereas they’ve been told over and over
and over again that their grant cannot convert and so if I was receiving an
email from the department saying now I’m Africa free consideration I would assume
it is fraud and wouldn’t complete it so I I just think that that weighs in favor
of automatic discharge to the extent that the department is willing to
reconsider that well I think one of the other things that was brought up by and
I don’t remember the name which by the way as a side request could we get the
names and the emails of the people who were in the room from the department you
have you know how to reach us it’s not fair it’s not fair but there
have been some other people popping in and out I don’t remember I think her
name was Anna Marie but she basically pleaded with us to help the department
know how to get this information out and I think that that is something that we
really need to take to heart because as you say when this notice goes out you
might consider it fraud if you’re just you know that it and of course many
people will have that mindset and I think that’s something that isn’t in
this regulation but you know I heard myself going like okay why you know do
you have interviews already set up with papers of record you know across in each
state and I you know Twitter yes and who’s doing Instagram here at the
department or what can we do in our respective associations and institutions
so that this drumbeat continues so that they do know because I hear you that
we’ve got to make sure that I would rather sorry have the Department flooded
with people saying go back and look at this for me then for them to just have
that little trickle anything else I know she has to go get her luggage thank you
everybody safe travels and we will see you next

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