1

MEMORANDUM

Date: February 21, 2019

To: Negotiated Rulemaking Committee 

From: Kyra Taylor

Issue: A Reconsideration Process for Grant-to-Loan Conversions and Rejected Service Year 

Forms, Suspension Requests, and Service Discharge Requests. 

This memo describes two interrelated proposals to create a reconsideration process that 1) 

is fair for both the Department and the TEACH grant recipient and 2) sufficiently protects the 

TEACH grant recipient against harms caused by servicer error. The first proposal explains why a 

reconsideration process should include an assessment of rejected service year certifications, 

requests for service clock suspension, and requests for service year discharges. The second 

proposal explains why heightened protections are warranted while the Secretary considers a grant 

to loan reconsideration request and why heightened remedies—such as credit repair—are 

warranted when the Secretary grants a request to reconvert a loan back to a grant.

Proposal 1: Provide a formal appeal written appeal process to all TEACH grant recipients 

who dispute a) grant-to-loan conversions,1 b) rejected service-year certification, c) denied 

requests for service clock suspension, and d) denied requests for service-year discharge.

Rationale: Given the volume of errors that have plagued the administration of the TEACH 

grant program, TEACH grant recipients should have access to a written appeal process for each 

decision that impacts their ability to complete their service: a) grant-to-loan conversions, b) 

rejected service-year certifications, c) rejected requests for service clock suspension, and d) 

rejected requests for service year discharge. Each significant decision that affects a TEACH 

grant’s recipient ability to complete their service could alter 1) where that teacher decides to 

continue to teach and 2) whether the teacher is able to complete four years of service in a highneed field in a low income school. Because these consequences impact the purpose of the TEACH 

grant program—to place highly-qualified teachers in high-need fields within low-income 

schools—recipients should be permitted to a second level of review to ensure that rejections of 

service certification, request for suspension or request for service discharge are correct. 

The need for a written appeal process to ensure that paperwork rejections are correct is 

evident from current TEACH grant program administration, which has resulted in 63% of grant 

recipients having their grants convert to loans. Incorrectly completed forms have been a significant 

issue, as the current forms are unnecessarily complicated, unclear, and do not always provide 

check-box answers that accurately reflect a teacher’s situation (the current FedLoan certification

form is attached). For example, in the current administration of the TEACH grant program, 

teachers 

 1 Because the Department and the subcommittee agree that a reconversion process is needed for grant to loan 

conversion, it is not discussed at length here. 
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• must state whether they are teaching in a high-need position in a low-income school 

but were not given an option to select if they were teaching but were not teaching 

within a “high-need” position;

• must list what “high-need” position they were teaching, but were not given instruction 

on how to find or appropriately record a state-specific “high-need” teaching position;

• must provide the first and last day that they taught, but were rejected on the basis of an 

incorrect day listing related the first or last day they taught. Teachers did not 

understand what constituted the first or last day of teaching, and questioned whether it 

included professional development, beginning of school preparation,2 or summer 

school.

The problems with the forms are reflected in the exceptionally low number of service forms that 

have been accepted:3 since the program’s inception, only 46,719 recipients have had any service 

certification form accepted.

4 To put that number in perspective, as of 2016, there were 138,000 

TEACH grant recipients,

5 the majority of whom likely attempted to submit a service year form the 

following year. Yet, only 46,719 recipients had any service certification forms accepted, and still 

may have had their grant later during their eight year service period. 

Despite numerous problems with the current forms, recipients have not been permitted to 

request reconsideration. One teacher explained FedLoan’s inflexibility despite her efforts to 

comply with the service certification submission process. 

I worked hard to ensure the best education for my students. Like all teachers, my first year 

of teaching was stressful and overwhelming. On top of the stress of being a new teacher, I 

did not know when I had to certify that I had completed a service year. [...] Yet, I still 

submitted my paperwork on the last possible day. 

August 4, 2014, I was struck with a hard blow. Not only was I an underpaid, overworked, 

new teacher, but I also now had a loan and interest accrued of over 20,000 dollars to pay 

back. I could not believe it. It must have been a mistake. How could the Department of 

Education do this to a new teacher that has consistently struggled to ensure the best 

education for her students? So, I called the Department of Education and FedLoan Servicing 

every day during my prep period. 

It was explained to me that the reasoning for the conversion was a late submission of the 

Certification of Teaching. Even though I fulfilled the requirements to teach in a low-income 

school in a high-need area, my service year certification was denied. When I called 

FedLoan, they said that I had turned in the form one day late. I called one of the numbers 

on the certification forms and spoke with a Department of Education representative 

(although it was not the federal student aid ombudsman) and they explained that while the 

form was in-house on-time, it was processed the following day.

 2 Some schools will require students to attend school before instruction begins to practice school routines, engage in 

team-building, and review school rules. 3 There is no public data regarding how many service certification forms have been rejected by the servicers during 

the same time period. 

4 The Department shared this data with the subcommittee during the last day of our meeting.

5 Study of the Teacher Education Assistance for College and Higher Education (TEACH) Grant Program, at pg. 77, 

Department of Education (March 2018), available at https://www2.ed.gov/rschstat/eval/highered/teach-grant/finalreport.pdf.
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Another teacher explained that her grant was converted even though she told her servicer that she 

was still enrolled in a TEACH-grant qualifying program: 

I am a general education teacher in a low-income elementary school in Prince Georges 

County, Maryland. I took out a TEACH grant in 2012 when I enrolled in a Masters of 

Education in Reading Specialist program. While completing my master’s degree, I 

continued teaching. However, mid-program, I switched to teach in a school district that 

offered tuition assistance for teachers pursuing master’s degrees in education, so I switched 

into the same master’s degree program at a higher-ranked university. However, when I 

switched to the better university, I was informed that my grant converted to a loan. I got 

no warning before the grant converted. When I called my servicer to explain that it should 

not have converted, they told me that because I wasn’t at the school where I received the 

TEACH grant, the grant had converted to a loan. I asked if it could switch back, especially 

because I was still enrolled in a qualifying program and I was still teaching in a low-income 

school. They said no. I didn’t think that I could fight the conversion anymore and I have 

been struggling to pay my loan payments since. It doesn’t feel fair, especially because I am 

still teaching in a low-income school and I had no idea that the grant could convert just 

because I switched universities.

Even with the paperwork simplification in the proposed changes the Department has 

advanced, the complexities inherent in 1) demonstrating which teaching positions satisfy the 

requirements for a service year, 2) what evidence is needed to demonstrate a request for a service 

clock suspension, or 3) what evidence should be submitted to support a service year discharge will

still generate incorrect servicer determinations. Specifically, determining what teaching positions 

will qualify for service year fulfillment will pose a significant issue. Currently, there are material 

discrepancies 1) from state to state regarding how teacher shortage areas are listed and 2) how 

teacher shortage areas are reported for the same state in the PDF report of Teacher Shortage Areas 

Nationwide Listing 1990-91 through 2017-186 and the digital Teacher Shortage Areas report.7 For 

example, look at the differences between the teacher shortages listed for Arizona versus what was 

reported for Florida in the PDF report of the Teacher Shortage Areas Nationwide Listing 1990-91 

through 2017-18:

 6 Available at https://www2.ed.gov/about/offices/list/ope/pol/bteachershortageareasreport201718.pdf 7 Available at https://tsa.ed.gov/#/home/
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In Florida, would an elementary school teacher who teaches all academic subjects count a 

year teaching as a qualifying service year, given that the majority of their day would be spent 

teaching English, Math, Reading, or Science (all fields listed as high need in Florida)? In Arizona, 

would a regular English middle school classroom teacher with 62 students, 41 of whom are ESL 

students, be able to count his or her year teaching as a service year? How should they list their 

teaching position on the form—the position listed in their teaching contract? If the servicer was 

continually making errors when assessing whether the recipient’s teaching position qualified 

towards their service obligation, a teacher would have no recourse to fix a mistaken service year 

certification rejection until grant conversion. Equally as disconcerting, the Department might not 

be aware that definitional issues were arising related to how actual teaching positions corresponded 

to how they are described for each state in the Nationwide List unless recipients are permitted to 

appeal what they believe to be a servicer’s error. 

Moreover, for many teachers, rejection of a service year certification means they will leave 

their current school to chase a qualifying position at another school. As a result, erroneously 

rejected service year certifications creates insecurity for the teacher and instability for the school 

they leave. One special education teacher who used a TEACH grant to enable her to complete a 

master’s degree in special education without debt explained,

I want to continue teaching [as a special education] as a teacher at my school but I will 

have to look for a new job in a qualifying school if teaching at my current school doesn’t 

fulfill my service obligation. When I began in the TEACH grant program, I believed that 

it would help my pay for professional development to continue teaching as Special 

Education teacher at my school [which was on the TCLI list when she began her degree 

program but was no longer designated as a low-income school when she graduated]. [If my 

current position does not count towards my service] I will have to chase a teaching position 

in another school that would qualify for service. Had I known that this would happen, I 

Teacher Shortage Areas for Arizona for 2017-18

Elementary Content Areas

ESL/BLE/SEI Mathematics Interventionist 

Music Reading Specialist/Interventionist 

Special Education Visual Arts (Art)

Middle Grades 

ESL/ BLE/SEI Visual Arts (Art) 

Foreign Language General Science Language

Arts/Reading Mathematics Mathematics Interventionist

Reading Specialist/Interventionist Music

Social Studies Special Education 

Secondary Level 

Biology Chemistry 

CTE–Dual Credit Earth Science Economics

English ESL/BLE/SEI 

Foreign Language General Science 

Geography History 

Mathematics Music 

Physical Science Physics 

Political Science/American Government 

Reading Specialist/Interventionist 

Special Education 

Visual Arts (Art)

Teacher Shortage Areas for Florida for 2017-18

Exceptional Student Education 

English for Speakers of Other Languages 

English 

Math 

Reading 

Science 

 General 

 Earth and Space
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wouldn’t have used a TEACH grant because it wouldn’t be worth it. My grant is still in 

grant status, thank goodness. I would struggle to afford to pay for my grant if it were to 

convert to a loan—my daughter is currently in college and unexpected loan payments on a 

teacher’s salary would just be too much.

The cost of an erroneously rejected service year certification is not just that the teacher 

believes a singular year of service does not count, but that they will leave their current position to 

find another position at another school that is more certain to count. 

Finally, the Department’s proposal to only allow for appeals of grant-to-loan conversions 

but not for these other rejections/denials is not beneficial to either the Department or TEACH 

Grant recipients. For recipients, the lack of a clear and transparent process for challenging a 

mistake by their servicer will leave them in limbo and with only a vague hope that some servicer 

employee will correct the mistake after enough calls and pleading. For the Department, this will 

likely result in more work to correct future erroneous grant-to-loan conversions that grow out of 

wrongly rejected service-year certifications or incorrect denials of clock suspensions; correcting 

these mistakes as they occur would likely require little more than an administrative correction, 

whereas reconverting a loan to a grant—and providing all the necessary corrections that entails—is 

a far more arduous process. Providing an appeals process for each step is not only more efficient 

but also allows the Department to identify recurring servicer errors in real time and develop 

solutions to address them and prevent such mistakes from compounding into a years-long 

detriment to the program.

Proposal 2: Provide heightened protections while the Secretary decides a grant-to-loan

reconsideration request and provide a complete remedy should the Secretary decide that a 

grant has been wrongly converted to a loan.

The attached proposed regulatory language provides heightened protections for the 

recipient during the reconsideration process. It also proposes credit repair for TEACH grant 

recipients whose grants were wrongfully in loan status. 

A. Put the loan in deferment, stop the accrual of interest while the Secretary 

considers a recipient’s request for grant-to-loan reconsideration, and allow the 

grace period for repayment to begin after the request is denied.

Rationale: Putting the loan in deferment status and stopping the accrual of interest during 

the reconsideration process serves two purposes. First, it prevents the recipient from being forced 

to put continued payments towards a potentially wrongfully converted loan. Second, it allows 

recipients to request reconsideration without being penalized by the continued accrual of interest 

while their reconsideration is being decided by the Secretary. The assessment period for the 

Secretary to issue a judgment can take months; months of payments that burden a teacher who 

might never have deserved a grant to loan conversion in the first place. Moreover, some teachers 

may not take the risk of reconsideration out of fear that while their request is being considered 

their debt burden will continue to grow.
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B. If the Secretary approves a request for grant-to-loan reconsideration, provide full 

credit rehabilitation for recipients who had their grants erroneously converted to 

loans in the form of 1) the deletion of all derogatory trade lines and 2) a statement 

of error by the Department for all TEACH grant recipients who have their loan 

reconverted automatically or who have their application to reconvert their loan 

approved. 8

Rationale: Teachers, who already struggle with having the income necessary to purchase a 

house or make significant credit-based purchases, should not suffer negative credit consequences 

due to their improper TEACH grant conversion. The Department should correct their credit report 

and provide them with a letter to present to future creditors to explain any adverse credit reporting 

related to their grant while it was in loan status. 

 8 Given that the Department and the subcommittee has agreed that recipients should receive credit for payments made 

on their grant while it was in loan status, that remedy is not described here. 
EXHIBIT A

FedLoan TEACH 

Certification Form
 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

 

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Records Code: XTAC 

TEACH GRANT CERTIFICATION 

Teacher Education Assistance for College and Higher Education (TEACH) Grant Program 

SECTION 1: TEACH GRANT RECIPIENT IDENTIFICATION Please enter or correct the following information. 

SSN – – Name 

Address City State ZIP 

E-mail: Optional 

Telephone – Primary Telephone - Alternate 

SECTION 2: TEACH GRANT RECIPIENT’S UNDERSTANDINGS AND CERTIFICATIONS 

Before completing this section, carefully read the entire form, including the instructions, definitions, terms and conditions, and important notices 

in Sections 4, 5, and 6. 

 I understand that: 

o	 I must fulfill a teaching service obligation (service obligation) for each academic program for which I received a TEACH Grant, as stated in the 

Agreement to Serve (Agreement) that I signed before receiving each TEACH Grant. If I do not fulfill my service obligation, all TEACH Grant funds that 

I received will be converted to Federal Direct Unsubsidized Stafford/Ford Loans (Direct Unsubsidized Loans) that I must repay to the U.S. Department 

of Education (the Department), with interest charged from the date of each TEACH Grant disbursement. 

o	 To fulfill my service obligation, I must teach full time for a total of at least four academic years within eight years after I complete or otherwise cease to 

be enrolled in the program for which I received TEACH Grant funds. My teaching service must meet the requirements specified in Section 6 and in my 

Agreement. 

o	 After completing each of the four academic years of required teaching service, I must provide my TEACH Grant servicer with documentation of my 

teaching service by providing the information requested in Item A below and obtaining a certification in Section 3 of this form from the Chief 

Administrative Officer for the school or educational service agency where I taught. 

o	 If I am not teaching, I must certify my intent to satisfy my teaching service obligation by checking the box in Item B below and signing the form. (If you 

did not complete your TEACH Grant program of study, see Section 6.) 

 I certify that: 

(A) I taught full time for one complete academic year, as certified in Section 3 (If you check this box for this reason you must complete items 1, 2 and 3 

below, and sign the form. Your Chief Administrative Officer must complete Section 3.) Or 

I am currently performing qualifying teaching service, but have not yet taught for a complete academic year (If you check this box for this reason 

you must complete items 1, 2 and 3 below, and sign the form. If you did not complete the program for which you received your TEACH grants, 

your Chief Administrative Officer must complete Section 3 and indicate that you have not taught a complete academic year using the check box 

provided.) 

(1) I am teaching or have taught full time as a highly-qualified teacher at a/an (check only one box):
 

Low-income elementary or secondary school
 Low-income educational service agency Elementary or secondary school 

operated by the Bureau of Indian Education (BIE) or operated on an Indian reservation by an Indian tribal group under contract with the 

BIE. 

(2) During the year of teaching listed below and as certified in Section 3, more than half of the classes I am teaching or have taught were in 

one or more of the following high-need fields (check all that apply):
 

Mathematics
 Science Foreign Language Bilingual Education English Language Acquisition 

Special Education Reading Specialist 

Other high-need field (see Section 5; list the other high-need field and grade level taught): _________________________ 

(3) I am teaching or have taught at: 

Name of School (Not School District) or Educational Service Agency at which I am teaching School Web Address 

Address of School or Educational Service Agency (Street, City, State, ZIP) 

(B) I am not teaching, but I intend to satisfy my TEACH Grant service obligation. (If you check this box you only need to sign below) 

(C) I did not complete my TEACH Grant-eligible program of study and am not teaching, but I have reenrolled in another eligible program of study, as 

defined in Section 5. (If you check this box, sign the form and have an authorized official complete Section 3 to confirm your enrollment in an 

eligible program. In addition, you may contact us to request a suspension of the eight-year period for completing your service obligation.) 

(D) The information I provided in Sections 1 and 2 is true and correct. 

(E) I have read and understand the definitions in Section 5 and the terms and conditions in Section 6. 

(F) My teaching service met the requirements specified in Section 6. 

TEACH Grant Recipient’s Signature Today’s Date (mm-dd-yyyy) 

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Recipient Name:_______________________________________________________ Recipient SSN:________________________________________ 

SECTION 3: CHIEF ADMINISTRATIVE OFFICER or AUTHORIZED OFFICIAL’S CERTIFICATION 

Before completing this section, carefully read the instructions, definitions, and terms and conditions in Sections 4, 5, and 6. If recipient is 

teaching, complete as Chief Administrative Officer. Return the completed form to the grant recipient identified in Section 1. If the recipient is 

enrolled in a TEACH Grant eligible program of study, complete as Authorized Official.
	

Chief Administrative Officer only: I certify that the grant recipient identified in Section 1 taught during the academic year as a full-time highly-qualified 

teacher (as defined in Section 5) from _______________ (mm-dd-yyyy) to ________________ (mm-dd-yyyy) at the eligible low-income elementary school, 

secondary school or educational service agency identified by the grant recipient in Section 2, and that during this year the grant recipient taught more than 

half of his or her classes in the high-need field(s) identified by the grant recipient in Section 2. 

Check here if certifying teaching service for less than a complete academic year. 

Authorized Official only: I certify that the grant recipient identified in Section 1 is/was enrolled at _____________________________________________ 

(Name of Institution) in an eligible program, as defined in Section 5 during the academic period from _____________ (mm-dd-yyyy) to ______________ 

(mm-dd-yyyy). 

Chief Administrative Officer/Authorized Official’s Name and Title (Printed)	 Telephone 

Chief Administrative Officer/Authorized Official’s Signature		 Today’s Date (mm-dd-yyyy) 

SECTION 4: GENERAL INFORMATION AND INSTRUCTIONS 

 Type or print using dark ink. Enter dates as month-day-year (mm-dd-yyyy). Use only numbers. Example: January 31, 2013 = 01-31-2013. 

 If you are certifying teaching service, the Chief Administrative Officer for the school or educational service agency where you performed your qualifying 

teaching service must complete Section 3. If you taught at more than one school or educational service agency during the same academic year, you may 

complete one certification form for each school or educational service agency at which you taught if one school or educational service agency cannot certify 

your complete academic year of teaching. 

 If you are certifying enrollment in an eligible program of study, an Authorized Official for the school at which you are/were enrolled in the eligible program of 

study must complete Section 3. 

 Return the completed form and any attached pages to the address shown in Section 7. 

SECTION 5: DEFINITIONS 

 An academic year or its equivalent is one complete elementary or secondary school year, or two complete and consecutive half-years from different school 

years (excluding summer sessions) that generally fall within a 12-month period. If a school or educational service agency has a year-round program of 

instruction, a minimum of nine months is considered to be the equivalent of an academic year. 

 An authorized official who may complete Section 3 is an official of the school at which you are/were enrolled in a TEACH Grant-eligible program. 

 The Chief Administrative Officer for a school or educational service agency is the individual who has access to the employment records which establish 

that the grant recipient’s teaching service met the requirements of the TEACH Grant Program, as explained in Section 6, and who is authorized to verify the 

grant recipient’s qualifying teaching service. The Chief Administrative Officer may vary depending on the teacher’s employer, and could include (but is not

limited to) the principal or assistant principal of the school where the grant recipient taught, the superintendent, assistant superintendent, or human 

resources director for a school district or educational service agency, or the chief executive officer of an educational services agency. 

 An eligible program of study is one that is TEACH Grant-eligible and is designed to prepare an individual to teach as a highly-qualified teacher in a highneed field and leads to a baccalaureate or master’s degree, or is a post-baccalaureate program of study. A two-year program of study that is acceptable for 

full credit toward a baccalaureate degree is considered to be a program of study that leads to a baccalaureate degree. An eligible program of study is also a 

program of study that has been determined by a state to satisfy the requirements for certification or licensure to teach in the state’s elementary or secondary

schools. 

 A high-need field includes the following: (1) bilingual education and English language acquisition; (2) foreign language; (3) mathematics; (4) reading 

specialist; (5) science; (6) special education; and (7) any other field listed in the U.S. Department of Education’s (the Department’s) annual Teacher 

Shortage Area Nationwide Listing (Nationwide List). 

o	 Bilingual education is an educational program in which two languages are used to provide content matter instruction. English language acquisition 

is the process of acquiring English as a second language. 

o	 Special education means specially designed instruction, at no cost to parents, to meet the unique needs of a child with a disability, including instruction 

conducted in the classroom, in the home, in hospitals and institutions, and in other settings; and instruction in physical education, i.e., physical therapy. 

A child with a disability is a child who needs special education and related services because the child has mental retardation, a hearing impairment 

(including deafness), a speech or language impairment, a visual impairment (including blindness), a serious emotional disturbance, an orthopedic 

impairment, autism, a traumatic brain injury, another health impairment, or a specific learning disability. For a child age 3 through 9, the term a child 

with a disability may, at the discretion of the state and the local educational agency, include a child who needs special education and related services 

because the child is experiencing developmental delays, as defined by the state and as measured by appropriate diagnostic instruments and 

procedures, in one or more of the following areas: physical development, cognitive development, communication development, social or emotional 

development, or adaptive development. 

 A post-baccalaureate program of study is a program of instruction for individuals who have completed a baccalaureate degree that, (1) does not lead to a 

graduate degree ; (2) consists of courses required by a State in order for a student to receive a professional certification or licensing credential that is 

required for employment as a teacher in an elementary school or secondary school in that State, except that it does not include any program of instruction 

offered by a TEACH Grant-eligible institution that offers a baccalaureate degree in education; and (3) is treated as an undergraduate program of study for 

the purposes of title IV of the Higher Education Act. 

 A school or educational service agency serving low-income students (low-income school or low-income educational service agency) is an 

elementary or secondary school or educational service agency that: (1) is in the school district of a local educational agency that is eligible for assistance 

under title I of the Elementary and Secondary Education Act; (2) has been determined by the Department to be a school in which more than 30 percent of 

the school’s total enrollment is made up of children who qualify for services provided under title I of the Elementary and Secondary Education Act; and (3) is 

listed in the Department’s Annual Directory of Designated Low-Income Schools for Teacher Cancellation Benefits. All elementary and secondary schools 

operated by the U.S. Department of the Interior’s Bureau of Indian Education (BIE) or operated on Indian reservations by Indian tribal groups under contract

or grant with the BIE qualify as low-income schools. If the school or educational service agency where you teach meets the low-income requirements during 

all or a part of a school year of my required four school years of teaching, but does not meet those requirements in subsequent school years, those 

subsequent years of teaching at that school or educational service agency will still qualify for purposes of satisfying my TEACH Grant service obligation. 

o	 An educational service agency is a regional public multiservice agency authorized by State statute to develop, manage, and provide services or 

programs to local educational agencies, as defined in section 9101 of the Elementary and Secondary Education Act of 1965, as amended.
 

o	 An elementary school is a nonprofit institutional day or residential school, including a public elementary charter school, that provides elementary 

education as defined under State law.
 

o	 A secondary school is a nonprofit institutional day or residential school, including a public secondary charter school, that provides secondary 

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education, as determined under State law, except that the term does not include any education beyond grade 12. 

 The Teacher Education Assistance for College and Higher Education (TEACH) Grant Program provides funds to students who are completing or who 

plan to complete coursework that is required to begin a career in teaching. 

 A teacher is a person who provides direct classroom teaching or classroom-type teaching in a non-classroom setting, including special education teachers 

and reading specialists. School librarians, guidance counselors, and other administrative staff are not considered teachers for the purposes of fulfilling the 

TEACH Grant service obligation. 

o	 A full-time teacher is a teacher who meets the standard used by a State in defining full-time employment as a teacher. For an individual teaching at 

more than one school or educational service agency, the determination of full-time is based on the combination of all qualifying employment. 

o	 The highly-qualified teacher requirements are specified in section 9101(23) of the Elementary and Secondary Education Act of 1965, as amended, or, 

for special education teachers, in section 602(10) of the Individuals with Disabilities Act. 

SECTION 6: TEACH GRANT PROGRAM TERMS AND CONDITIONS 

 For each academic program for which you receive TEACH Grant funds, you must complete a service obligation by teaching full time for a total of at least 

four academic years: 

o	 As a highly-qualified teacher (see Section 5); 

o	 At a school or educational service agency serving low-income students (see Section 5); and 

o	 In a high-need field (see Section 5) in more than half of the classes that you teach during each academic year. 

 You must complete the required four years of teaching within eight years after you complete or otherwise cease to be enrolled in the program for which you 

received the TEACH Grant. 

 After completing each year of your required four years of teaching service, you must complete and submit this TEACH Grant Certification to the Department. 

 If you received a TEACH Grant but do not complete the required four years of teaching service within eight years of completing (or otherwise ceasing to be 

enrolled in) the program for which you received a TEACH Grant, all TEACH Grant funds you received will be converted to Federal Direct Unsubsidized 

Stafford/Ford Loans (Direct Unsubsidized Loans) that you must repay in full to the Department, with interest charged from the date of each TEACH Grant 

disbursement you received. 

 If you received a TEACH Grant but did not complete your program of study, within 120 days of ceasing enrollment you must certify that you are employed as 

a full-time teacher in accordance with the terms and conditions listed in your Agreement to Serve, or that you are not yet employed as a full-time teacher, 

but you intend to meet the terms and conditions of your service obligation. If you do not meet one of these requirements, your TEACH Grant will be 

converted to a Direct Unsubsidized Loan. 

 If you received a TEACH Grant but did not complete your program of study, within one year of ceasing enrollment you must re-enroll in a TEACH Grant 

eligible program, begin creditable teaching service or be determined eligible for a suspension of your eight-year obligation period. If you do not meet one of 

these requirements, your TEACH Grant will be converted to a Direct Unsubsidized Loan. 

 If you complete the academic program for which you received a TEACH Grant, you must actively confirm at least once each year that you intend to satisfy 

your service obligation. If you do not actively confirm your intention, your TEACH Grant will be converted to a Direct Unsubsidized Loan. 

 You must maintain qualifying employment within a timeframe that allows you to complete your service obligation within the allotted eight-year period. 

 For complete terms and conditions of the TEACH Grant Program, see the TEACH Grant Agreement to Serve (Agreement) that you were required to sign 

before you received a TEACH Grant. 

SECTION 7: WHERE TO SEND THE COMPLETED CERTIFICATION FORM 

Return the completed form and any attachments to: 

U.S. Department of Education 

FedLoanServicing 

P.O. Box 69184 

Harrisburg, PA 17106-9184 

or Fax to: 717-720-1628 

If you need help completing this form, call: 

1-800-699-2908 

International: 717-720-1985 

TDD: 1-800-722-8189 

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Exhibit B

Proposed Reconsideration 

Regulatory Language
686.44 Reconsideration Process

a) A TEACH grant recipient may request that the Secretary reconsider a decision to:

1) Convert a TEACH grant to a direct loan before the expiration of the eight calendar years

the TEACH grant recipient had to complete service obligation as explained in section

686.43;

2) Reject a service obligation documentation as defined in section 686.40;

3) Reject a request for suspension of the eight-year period as defined in section 686.41;

4) Reject a request for a discharge of an agreement to serve as defined in section

686.42.

b) The Secretary will provide notice to the public of the evidence a TEACH grant recipient must

submit to support their appeal and prove that they satisfied sections 686.40, 686.41, 686.42, or

686.43.

c) The Secretary may reverse its decision relating to a grant to loan conversion, rejection of

service year documentation, rejection of a request for a suspension of the eight-year period, or

rejection of a request for service discharge at any time.

d) While an appeal related to a grant-to-loan conversion is pending, the TEACH recipient’s eightyear service period will be automatically suspended and a grant which has been converted to a loan

will be put in deferment.

e) Should the Secretary grant a TEACH grant recipient’s appeal relating to a wrongful grant to

loan conversion,

1) The TEACH grant that has been converted to a loan will be reconverted to a

grant; 

2) The recipient will receive credit for payments made on the loan;

3) The Department will request deletion of all derogatory trade lines reported to the credit

bureaus related to the grant while in it was in loan status; and

4) The Department will furnish a statement of error, where applicable, that the recipient

may provide to consumers of the recipient’s credit reports.

f) Should the Secretary deny a TEACH grant recipient’s appeal relating to a wrongful grant to

loan conversion, no interest will accrue during the pendency of the appeal and:

1) If the appeal was filed within one month of the conversion from a grant to a loan, the

recipient’s six-month grace period shall begin upon the Secretary’s denial; 
2) If the appeal was filed after one month but less than six months following the

conversion from a grant to a loan, the recipient’s six-month grace period shall be tolled

during the pendency of the appeal and shall resume upon the Secretary’s denial; or

3) If the appeal was filed more than six months following the conversion from a grant to a

loan, the recipient’s first payment shall not be made due until at least 30 days after the

Secretary’s denial.