Draft CDR: Reviewing and Resolving Errors


In What’s the Big Deal with Draft CDR? we discussed the benefits of having a low CDR (and the ramifications of having a high one!), as well as how participating in this annual review can help your alumni. Remember, the Federal Fiscal Year 2019 (FFY19) cohort is made up of students who borrowed loans at your school for which they entered repayment between October 1, 2018, and September 30, 2019. The rate is calculated by dividing the number of cohort members that defaulted during the 3-year monitoring period (October 1, 2018 – September 30, 2021) by the total number of borrowers in the cohort.

On February 28, 2022, Federal Student Aid (FSA) announced the distribution of schools’ eCDR packages and provided the schedule for challenging incorrect data. Schools have 45 days from March 8, 2022, to file, and loan servicers, known as data managers in this process, have 30 days to respond.

If you have not already, here are some initial steps to take before beginning your review:

  • If you’ve never used the eCDR Appeals application, your destination point administrator will need to register (if they have not already) and then grant access to you.
  • Also, new users should take advantage of the training resources provided including recorded demonstrations that show how to navigate the system.
  • Everyone needs to request the required certification letter on school letterhead from your president/CEO. See the Cohort Default Rate Guide, Chapter 4, page 4.1-9 for a sample.
  • As you’ll see, most errors involve incorrect enrollment or separation dates, so request a list of the students who would have entered repayment during the FFY19 from your registrar’s office. This would most likely be students separating from your college between April 1, 2018, and March 31, 2019.
  • Finally, download the Loan Record Detail Report (LRDR) Import Tool. This will allow you to import the text file that was delivered in the eCDR package into Excel so you can sort and filter the data to make your review much easier.

The LRDR contains the following information from NSLDS: the borrower’s name and social security number and for each loan, the amount, the loan period, the grade level, the enrollment status at the time the draft rate was calculated, the repay date and, if applicable, the date of default. In addition, each record in the LRDR contains Usage Codes which makes it easier to quickly identify the loans impacting your CDR. If you have a limited amount of time to spend on this process, prioritize the loans being counted in both the numerator and denominator of the CDR calculation. See the Cohort Default Rate Guide, Chapter 2.3 for more information about the LRDR. At the end of the day, there are really only two things you can validate from your office — whether the student received the loan listed and whether the student’s repay date is valid. The most critical piece of information you have is the student’s separation date since it drives the entire schedule from the beginning of the grace period to defaulting on the loan.

When you find errors, the information you’ll be entering in the eCDR Appeals system is whether that borrower should be removed from the denominator or removed from both the denominator and the numerator based on your records. You’ll also upload documentation such as an official transcript or record of loan cancellation. Once all of the errors you find have been logged, you’ll submit them with your certification letter and then await responses from the data managers.

Finally, we wanted to point out some situations that are commonly reported as errors, but really aren’t.

  • The borrower’s defaulted loan was ultimately cancelled. This borrower will still be counted in the numerator if they defaulted during the monitoring before cancellation was processed.
  • The borrower brought the defaulted loan into good standing by paying it off or consolidating it. As in the above example, the resolution of the default doesn’t make it ‘not count.’ There’s one exception and that is when a borrower defaults and then rehabilitates the defaulted loan before the end of the monitoring period because by definition rehabilitation erases the default from the borrower’s record.
  • The borrower returned to school. As in the first two bullets, if the student entered repayment and defaulted during the monitoring period — even if that was after they enrolled — the default is still counted in your numerator.
  • The borrower has loans at multiple servicers and one or more servicers are reporting loans in good standing while others are reporting defaulted loans. The default will still count in your CDR because the borrower is responsible for all of the loans even when they wind up at different servicers.

The IDC process is time-consuming and often confusing, so if you feel like you could use some help, email us at info@heag.us!