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Alerts and Updates

Institutions of Higher Education Must Act Prior to U.S. Department of Education System Upgrade

October 25, 2023

Institutions of Higher Education Must Act Prior to U.S. Department of Education System Upgrade

October 25, 2023

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We recommend that institutions of higher education carefully review this announcement and take any required action by December 7 to avoid interruption in Title IV aid processing.

On October 16 and 20, 2023, the Department of Education published two technical but very important updates for institutions of higher education.

First, on October 16, 2023, the Department published Electronic Announcement GEN-23-85, “Active Confirmation of TG Numbers (SAIG Mailboxes) and Electronic Services User Accounts Required by Dec. 7, 2023 to Maintain Access to Federal Student Aid Systems.” This announcement is part of the Department’s ongoing effort to ensure the security of Federal Student Aid data systems. Every organization enrolled for a Student Aid Internet Gateway (SAIG) account is required to review and validate its assigned TG numbers and Electronic Services user accounts by December 7, 2023. This includes TG numbers (SAIG mailboxes) with access to the National Student Loan Data System (NSLDS) Professional Access website, the Common Origination and Disbursement (COD) website and all FAA Access to CPS Online and EDconnect user accounts. It also includes TG numbers enrolled for SAIG batch services for the NSLDS, the Central Processing System (CPS), the COD System and the Financial Management System.

We recommend that institutions of higher education carefully review this announcement and take any required action by December 7 to avoid interruption in Title IV aid processing. Failure to accurately complete this process by December 7, 2023, will result in loss of access to Federal Student Aid data systems, including services such as Institutional Student Information Record deliveries and requests, Free Application for Federal Student Aid corrections and NSLDS enrollment reporting and updates.

Second, on October 20, 2023, the Department provided an update on the timeline for long-awaited system upgrades to the Electronic Application (E-App) via Electronic Announcement GEN-23-86, “FSA Partner Connect – Implementation Planned for December 2023; E-App and Other Actions Required by Nov. 24, 2023.” The E-App is a critical feature of the FSA Partner Connect platform, which serves as the portal for information from and reporting to the Department.

On December 17, 2023, the Department plans to launch a redesigned E-App as well as some enhanced reporting features. We recommend reviewing the Electronic Announcement for the new features and ability to report into the system, removing reliance on email communication with Department staff.

This notice is to provide you with the key dates that lead up to the launch, including system closures and impacts to processing timelines. Institutions need to take some action prior to the system shutdown to preserve their existing data. Further, institutions need to anticipate their reporting needs for the remainder of the calendar year in order to avoid missed deadlines or late filings.

System Closure

The system will need to shut down for a period of three weeks in order to make these revisions. The Department issued the following dates for closure:

Starting November 25, 2023, users will no longer be able to sign in to the eligcert.ed.gov online system. Accordingly, users should review the following information to ensure all necessary actions are completed by November 24, 2023.

In addition, no later than November 24, 2023, we strongly encourage schools to download or print the following items to save for their records and to have available to reenter data in the new online system, if needed:

  • Current ECAR
  • Any acknowledgement and approval notices and letters that the school does not have saved
  • The school’s application data (for cases in which a school recently applied, but that application has not been processed)

It is imperative for any participating institution to have a complete and accurate record of the information currently in the E-App as this will be the sole record of that data with which to audit the data ported over during the relaunch.

Processing Time 

The closure of the system and the relaunch of the portal will impact the Department’s processing times for new and pending applications. The Department will not be accepting submissions, except on a very limited basis, as such, institutions need to review items that are due in the next eight weeks and consult the Department’s guidance on the impact.

The processing of E-Apps during the transition period will be impacted as follows:

  • If a school is part of the December 31 recertification cohort (i.e., schools that have program participation agreements expiring on March 31, 2024), we strongly encourage the school to submit its E-App via eligcert.ed.gov no later than November 24, 2023, as communicated in email notices sent by FSA. If a school did not receive an email notice, it is not part of the December 31 recertification cohort.
  • An E-App submitted by a school via eligcert.ed.gov by November 24, 2023, will be reviewed and processed by FSA via FSA Partner Connect after implementation.
  • An E-App started but not submitted by a school via eligcert.ed.gov by November 24, 2023, will not be saved or carried over to the new system and will need to be re-started by the school and submitted via FSA Partner Connect after implementation.
  • If a school encounters a major event impacting its eligibility, such as a change in accrediting agency or an addition of new location after November 24, 2023, the school will need to notify its School Participation Division via email of the event. The school must submit the E-App for this reported event via FSA Partner Connect after implementation.
  • If a school anticipates it will close after November 24, 2023, and before the new system is available, the school should contact its School Participation Division for further guidance.

Change in Ownership

Under the recently released Electronic Announcement regarding notification for a change in ownership (CIO), General-23-77, institutions must submit notice to the Department no less than 90 days prior to the anticipated date of the change.

The Department provided the following guidance for submissions that will fall in the closure window:

For reporting that must occur after November 24, 2023, and on or before December 18, 2023, schools must provide the information as follows:

  • 90-day reporting must be made via email to the school’s School Participation Division with "90-Day CIO Notice for <OPEID>" in the subject line. Follow GEN-23-77 guidance for required documents.
  • 10-day required notification must be made via email to the school’s School Participation Division no later than 10 days after the CIO transaction occurred to maintain Title IV eligibility. The school must submit the E-App for this reported event via FSA Partner Connect after implementation.

We recommend institutions planning a change of ownership before the end of the calendar year consult with counsel to determine the optimal date for submission in light of this system closure.

Government Shutdown

The above information and advice from the Department does not take into consideration the looming government shutdown date of November 17, 2023, related to the potential lapse in government funding. It is possible that the federal government may experience a slowdown or shutdown during the negotiations over continued government funding. In that instance, the Department will be impacted and we would anticipate delays in the system upgrade. It is noteworthy that Secretary of Education Cardona has indicated in prior statements that, in a shutdown situation, he may designate a larger pool of Department employees as essential, which could mitigate impact of a shutdown on Department services including the system upgrade launch.

Duane Morris will continue to monitor the Department’s announcements on the anticipated system updates.

For More Information

If you have any questions about this Alert, please contact Katherine D. Brodie, Anthony J. Guida Jr., Jennifer D. DeMay, any of the attorneys in our Higher Education Group or the attorney in the firm with whom you are regularly in contact.

Disclaimer: This Alert has been prepared and published for informational purposes only and is not offered, nor should be construed, as legal advice. For more information, please see the firm's full disclaimer.