## Why should a data manager review this chapter?

Data managers should review this Guide for information regarding cohort
default rates. This chapter contains basic strategies to prepare a data
manager for the release of the cohort default rates as well as
strategies to help a data manager process challenges, adjustments, and
appeals.

## What strategies can a data manager employ before the release of the draft and official cohort default rates?

There are a number of strategies a data manager can employ before the
release of the draft and official cohort default rates:

-   determine data manager staff responsible for processing all cohort
    default rate challenges, adjustments, and appeals;

-   establish school and Department cohort default rate contacts within
    the data manager organization and provide updates to schools and
    Default Prevention and Management (DPM) when those contacts change;

-   notify DPM if data manager address or corporate structure changes;

-   identify staff responsible for enrollment changes;

-   keep copies of all relevant correspondence between the data manager
    and schools, lenders, and the Department;

-   timely submit, in accordance with Department regulations, changes in
    a borrower's loan information to the National Student Loan Data
    System (NSLDS) and print NSLDS screen to show acceptance of data
    manager changes;

-   develop a plan to assist schools that enhances understanding of what
    reports and information a school can obtain from the data manager
    and describes how a school can correct the information; and

-   use this Guide as a reference when discussing cohort default rate
    matters with schools.

A data manager may wish to develop a checklist, specific to the

data manager's needs, of the activities the data manager needs to do
before, during, and after the release of the draft and official cohort
default rates.

A data manager should also begin preparations for the release of the
cohort default rates. A data manager should prepare and send monthly
status reports to DPM. Further, there are a number of spreadsheets and
letters used in each challenge, adjustment, and appeal. See the
individual challenge, adjustment, and appeal chapters in Part IV for
information on these spreadsheets and letters and how a data manager
uses them. If a data manager has not previously created electronic
copies of the various spreadsheets and letters it should do so before
the release of the cohort default rates. If a data manager has already
created electronic copies of the various spreadsheets and letters, it
should locate those electronic copies and verify that they are ready for
use.

## What strategies can a data manager employ to help process challenges, adjustments, and appeals?

There are a number of things a data manager should do as part of the
challenge, adjustment, and appeal process.

-   A data manager should date stamp school challenge, adjustment, or
    appeal submissions when the submissions are received. The data
    manager response time frames begin when the package is first
    received by the data manager. Therefore, a data manager may wish to
    keep the package for proof of the receipt date until the challenge,
    adjustment, or appeal process is finished.

-   A data manager should check the date a school received its cohort
    default rate notification package on the electronic file sent by DPM
    to determine if the school is timely in its submission. If the date
    is not listed on the report, or if the file cannot be opened, the
    data manager should contact DPM for the date.

-   A data manager should contact DPM to discuss eligibility issues if
    the data manager receives any adjustments or appeals from a school
    on the Department's sanction list. When the official cohort default
    rates are released, the sanction list is made available online under
    "Default Management" on the IFAP Web site (ifap.ed.gov).

-   A data manager should review prior challenge, adjustment, and/or
    appeal responses if the data manager believes the school is
    attempting to submit a challenge, adjustment, or appeal for a
    borrower who was addressed in a previous challenge, adjustment, or
    appeal.

-   A data manager should contact a school as soon as possible if the
    school does not include all the appropriate challenge, adjustment,
    or appeal materials.

-   A data manager should make sure comments are entered in the comment
    column of the spreadsheets, particularly if the data manager
    disagrees with the school. The data manager should make sure the
    comment is clear and that supporting documentation is attached to
    the spreadsheet. The data manager may use abbreviations as long as
    the data manager provides a list of those abbreviations.

-   A data manager should contact DPM if assistance is needed to make a
    determination on a school's data, supporting documentation, or other
    information submitted as part of the challenge, adjustment, or
    appeal process.

-   A data manager should send copies of its challenge, adjustment, or
    appeal responses to DPM as the responses are processed. The data
    manager should not wait to send all the copies as one batch.

-   A data manager should send all cohort default rate correspondence to
    all entities via certified mail or commercial delivery and maintain
    the documentation that shows the correspondence was timely sent.
    This information will be sent to DPM as part of the monthly status
    report.

-   A data manager should inform schools and DPM if the data manager is
    unable to comply with time frames due to the data manager's
    workload.

## What should a data manager do if it receives an incorrect submission from a school? 

A data manager should contact a school as soon as possible if a school
incorrectly asks for guidance about or submits an uncorrected data
adjustment, participation rate index challenge, economically
disadvantaged appeal, participation rate index appeal, average rates
appeal, or thirty-or-fewer borrowers appeal to the data manager. The
data manager should inform the school that the materials or question
must be submitted to DPM within the appropriate time frame. The data
manager must also inform DPM of the incorrect submission.

If the data manager receives a challenge, adjustment, or appeal but

the data manager does not hold the loans, the data manager should

notify the school and DPM that the challenge, adjustment, or appeal must
be submitted to the appropriate data manager and remind the school that
the challenge, adjustment, or appeal must be submitted to the
appropriate data manager within the appropriate time frame.

There will be some instances where the data manager was the former
holder of the loans but those loans have been assigned to the Department
and the loan record detail report does not yet reflect the assignment.
In that event, the data manager should send the school and DPM a notice
stating that the loans have been assigned to the Department. The data
manager should instruct schools to send the request to DPM within 15
calendar days of receipt of the data manager's letter.

## What should a data manager do if the school's challenge, adjustment, or appeal is successful?

After a school's successful incorrect data challenge, the data manager
must update NSLDS and the data manager's internal records with the new
information prior to the calculation of the next official cohort default
rates. The data manager must also submit to NSLDS any subsequent
incorrect data challenge changes submitted to the data manager by DPM.

After a data manager is informed by DPM that a school's new data
adjustment, uncorrected data adjustment, or erroneous data appeal was
successful, the data manager must update NSLDS and the data manager's
internal records with the new information prior to the calculation of
the next draft cohort default rates.

A data manager must ensure that the data is successfully entered into
NSLDS. A data manager should review the NSLDS error report. Contact
NSLDS Customer Service at 1-800-999-8219 for submission assistance.

## How does a data manager keep the Department informed about its cohort default rate actions?

Data managers send monthly reports (see the following example) to DPM
listing the status of all cohort default rate related requests the data
manager has received. The monthly status report is a cumulative list of
requests that data managers receive from schools after the release of
the draft cohort default rates or the official cohort default rates.
This process minimizes the need for DPM to contact a data manager. These
status reports will assist DPM in monitoring the time frames associated
with the cohort default rate process. The monthly status reports should
be sent to DPM within seven calendar days after the end of each month.

If the data manager does not receive any requests from schools, it
should submit a blank monthly status report to DPM indicating that it
has not received any requests. If the data manager does not review a
response because of an untimely submission, the data manager should note
this on the monthly status report.

A data manager should not submit copies of its responses to schools to
DPM with its monthly report. Copies of these responses should be sent to
DPM at the same time the data manager sends the response to the school.
Once the data manager has responded to all of the requests received, and
the data manager has not received any subsequent requests, the data
manager should send DPM an updated status report marked "FINAL." After
the data manager sends DPM the final report, the data manager does not
send any more monthly status reports until the next cohort default rates
are released.