California Student Aid Commission Item 15 (Action) Consideration of an appeal by San Diego Christian College SUMMARY: Agenda item will be sent under separate cover. RESPONSIBLE PERSON(S): Catalina Mistler, Deputy Director Program Administration and Services Division ATTACHMENTS: Description Attachment 15.1 Appeal Attachment 15.2 Letter of appeal Attachment 15.3 Additional Materials Distributed on June 1, 2017 California Student Aid Commission Page 1 of 19 June 1-2, 2017 Attachment 15.1 APPEAL BY SAN DIEGO CHRISTIAN COLLEGE SUMMARY San Diego Christian College (SDCC) filed an appeal asking that the Commission determine that SDCC is eligible to participate in the Cal Grant Program for academic year 2017-18 even though SDCC does not comply with statutory Cal Grant standard for cohort default rate (CDR) (see Attachment 15.2). Later, SDCC’s graduation rate was included in the appeal. In 2015-16, 134 Cal Grant students attended SDCC. To date in the 2016-17 academic year, 114 Cal Grant students received payment at SDCC. The United States Department of Education (USED) reported SDCC’s CDR to be 15.7%, which exceeds the 15.5% Cal Grant limit. USED also reported SDCC’s graduation rate to be 30%, which fails to meet the Cal Grant requirement that the graduation rate be higher than 30%. SDCC argues that USED did not correctly calculate the cohort of students by which the CDR was determined. However, SDCC appears to have failed, inadvertently, to use the USED appeal process by which it could have made its arguments directly to USED. SDCC also represents that its CDR, if correctly calculated, would have been 15.4%, and would have satisfied the Cal Grant requirements. Further, SDCC indicates that this situation is an anomaly and has plans to institute debt management education for current students and early outreach for those in repayment. SDCC, however, has not made a comparable representation about the graduation rate to staff. The Commission has previously granted several appeals by institutions whose CDRs and/or graduation rates failed to meet statutory Cal Grant standards due to incorrect calculations. However, in each of these instances, the evidence provided in the appeals included verification from USED of the CDR and/or graduation rate that would have resulted if the institution had appropriately followed the USED appeal process. Staff was then able to determine that the rate or rates re-calculated by USED staff would have satisfied the statutory Cal Grant requirements. In this case, SDCC has tried, unsuccessfully over several months, to obtain such verification from USED. Due to staff’s concern about the effects on Cal Grant students attending or considering attending SDCC, staff independently attempted to obtain verification from USED, again, unsuccessfully. Absent verification from USED of the CDR that would have been established if SDCC had appropriately followed the USED appeal process, staff cannot determine whether that rate would satisfy the statutory Cal Grant requirements. The Commission has also previously considered an appeal by an institution that did not contest that its non-compliant CDR failed to satisfy the Cal Grant standards, but asked the Commission to establish an exception from those standards because the size of institution’s cohort that was used to calculate the CDR was extremely small. The institution proposed that it and the Commission would work together to seek legislation that would establish an exception for institutions with extremely small cohorts. The Commission granted the appeal but made it subject to the enactment of the legislation. The Commission also agreed to cooperate with the institution California Student Aid Commission California Student Aid Commission Page 1 of 5 Page 2 of 19 June 1-2, 2017 June 1-2, 2017 Attachment 15.1 in seeking the legislation. Although the appeal was granted, the institution continued to remain ineligible until the legislation was enacted and became effective nearly two years later. With respect to graduation rates, the Commission previously denied an appeal by an institution with a graduation rate that did not comply with Cal Grant requirements, rejecting arguments that a graduation rate applicable to a later academic year should be used in place of the appropriately applicable rate. In this case, staff can determine no basis for granting an appeal of SDCC’s graduation rate. To staff’s knowledge, SDCC did not assert that the graduation rate was incorrectly calculated. Even if SDCC were to make that assertion, staff could not recommend granting the appeal in the absence of USED verification similar to that required for the CDR. Thus, staff cannot recommend granting the appeal. RECOMMENDATION: The appeal by San Diego Christian College should be denied. BRIEF HISTORY OF KEY ISSUE(S): San Diego Christian College SDCC is an independent institution with undergraduate, graduate and online programs. SDCC is currently a participating Cal Grant institution. In 2015-16, 134 Cal Grant students attended SDCC. To date in the 2016-17 academic year, 114 Cal Grant students have received payment at SDCC. SDCC’s historical CDR and graduation rates have been: Academic Year CDR Graduation Rate 2012-13 2013-14 2014-15 2015-16 2016-17 5.8% 9.0% 6.8% 8.4% 8.4% 59.2% 59.2% 30.8% 42.9% 44.0% For 2017-18, USED reported SDCC’s CDR to be 15.7%, and its graduation rate to be 30%. SDCC indicates that this situation is an anomaly and has plans to institute debt management education for current students and early outreach for those in repayment. CDR and Graduation Rates Education Code section 69432.7(l)(3) provides in relevant part: California Student Aid Commission California Student Aid Commission Page 2 of 5 Page 3 of 19 June 1-2, 2017 June 1-2, 2017 Attachment 15.1 (3) (A) The commission shall certify by November 1 of each year the institution’s latest official three-year cohort default rate and graduation rate as most recently reported by the United States Department of Education. For purposes of this section, the graduation rate is the percentage of full-time, first-time degree or certificate-seeking undergraduate students who graduate in 150 percent or less of the expected time to complete degree requirements as most recently reported publicly in any format, including preliminary data records, by the United States Department of Education. * * * (C) For purposes of the 2012–13 academic year, and every academic year thereafter, an otherwise qualifying institution with a three-year cohort default rate that is equal to or greater than 15.5 percent, as certified by the commission on October 1, 2011, and every year thereafter, shall be ineligible for initial and renewal Cal Grant awards at the institution. * * * (F) For purposes of the 2012–13 academic year, and every academic year thereafter, an otherwise qualifying institution with a graduation rate of 30 percent or less, as certified by the commission pursuant to subparagraph (A), shall be ineligible for initial and renewal Cal Grant awards at the institution, except as provided for in subparagraph (H). [Emphasis added.] SDCC’s 15.7% CDR for 2017-18 is greater than the statutory limit of 15.5%, and thus renders SDCC ineligible to participate in the Cal Grant Program for 2017-18. SDCC’s USED-reported graduation rate of 30% also renders it ineligible for 2017-18. USED, for purposes of establishing CDR and graduation rates for institutions, receives data from institutions, and calculates draft CDRs and graduation rates. USED then notifies each institution of its draft rates, and provides an appeal period in which the institution may seek changes in the calculations based on corrected data. If USED agrees with the institution, it will recalculate the relevant CDR or graduation rate and report the corrected rate. Cal Grant law expressly mandates that if USED corrects an institution’s CDR and/or graduation rate, and that correction would bring those rates within the statutory Cal Grant standards, the institution would immediately regain its eligibility to participate in the Cal Grant Program (see Educ. Code, §69432.7(l)(3)(D)(ii)). Some institutions, however, inadvertently fail to follow the USED appeal process to get their rates changed even after being notified by USED of draft CDRs or graduation rates that would render them ineligible for Cal Grants. In the past, some of these institutions have asked the Commission to find them eligible for Cal Grants based on CDRs or graduation rates calculated with corrected data, rather than the official USED-reported rates. The Commission has determined that, under special circumstances, institutions can be eligible for Cal Grants even though their CDRs and/or graduation rates officially reported by USED did not meet statutory Cal Grant standards. In the initial appeal, Menlo College argued its ineligibility for the 2013-14 academic year was due to an error in the data it had reported to USED, and claimed that had the correct data been used, its CDR, in fact, would have met the requisite statutory Cal Grant standard. The Commission found: 1. Menlo College has been determined to be ineligible for Cal Grant awards for 2013-14 because the United States Department of Education (USED) has reported the Menlo California Student Aid Commission California Student Aid Commission Page 3 of 5 Page 4 of 19 June 1-2, 2017 June 1-2, 2017 Attachment 15.1 College 2009 3-year cohort default rate (CDR) to be higher than the maximum CDR of 15.5% authorized by Education Code section 69432.7(/)(3)(C). 2. Due to a mistake by a loan servicer involving data for just one student, Menlo College’s CDR was incorrectly calculated to be 15.6%. 3. Using factually correct data, Menlo College’s CDR is 15.15%. 4. Menlo College failed to timely avail itself of USED challenge and appeal processes to correct the mistake. 5. USED has verified that had Menlo College timely challenged and appealed the mistakenly calculated CDR, USED’s reported 2009 3-year CDR for Menlo College would have been below 15.5%, and that the Menlo College would have been eligible for Cal Grant awards in 2013-14. From these findings, the Commission concluded: The Commission concludes that despite the technical lack of compliance with the method by which Education Code section 69432.7(/)(3)(C) requires the Commission to identify a CDR to use to establish institutional eligibility for a Cal Grant, Menlo College complies with the substantive standard established by section 69432.7(/)(3)(C) by having a factually correct CDR below 15.5%. This satisfies the primary purpose of section 69432.7(/)(3)(C) and constitutes substantial compliance for purposes of determining Menlo College for Cal Grants. Based on the findings and conclusion, the Commission granted the appeal by Menlo College, which became eligible to participate in the Cal Grant Program in 2013-14. The Commission considered several later appeals from institutions using the analysis from the Menlo College appeal. In each appeal, USED provided verification of the CDR and/or graduation rate that would have been established if the institution had appropriately followed the USED appeal process. The Commission also considered an appeal in 2014 by Charles R. Drew University of Medicine and Science (Charles Drew). Charles Drew did not contest that its non-compliant CDR failed to satisfy the Cal Grant standards, but asked the Commission to establish an exception from those standards because the size of the institution’s cohort that was used to calculate the CDR was extremely small and, thus, disproportionately affected by small numbers of students. Staff essentially agreed with the disproportionate effect to extremely small cohorts, but could not recommend granting the appeal because the Cal Grant statute did not allow such an exception to be created administratively. Charles Drew’s President proposed that the institution and the Commission work together to seek legislation that would establish an exception for institutions with extremely small cohorts. The Commission agreed and granted the appeal, but made it subject to the enactment of the legislation. Although the appeal was granted, the institution continued to remain ineligible until the legislation was enacted and became effective nearly two years later. With respect to graduation rates, the Commission previously denied an appeal by National Hispanic University of its ineligibility for 2014-15. National Hispanic University argued that although the graduation rate applicable to the 2014-15 academic year did not comply with Cal California Student Aid Commission California Student Aid Commission Page 4 of 5 Page 5 of 19 June 1-2, 2017 June 1-2, 2017 Attachment 15.1 Grant requirements, the Commission should use its draft graduation rate applicable to the 201516 academic year, which did comply, and was the latest reported graduation rate by USED. The institution asserted that the 2015-16 draft rate was the result of the institution’s committing significant resources into financial counseling and student support. The Commission rejected those arguments and denied the appeal. ANALYSIS: Education Code section 69432.7(l)(3) requires the Commission to certify CDR and graduation rates calculated and reported by USED, and establishes that the USED-reported rates must be applied to determine whether institutions satisfy statutory Cal Grant standards to participate in the Cal Grant Program. Thus, when an institution has failed to follow the USED appeal process, verification by USED of the rates that would have resulted if the institution had appropriately followed that process, provides a supportable basis for the Commission to grant an appeal allowing a deviation from the express statutory Cal Grant requirement that the USED-reported rates are to be used to determine eligibility in the Cal Grant Program. The Commission’s Menlo College decision was supportable because USED verified the rate that would have resulted if Menlo College had appropriately followed the USED appeal process. SDCC and Commission staff have been unsuccessful in obtaining USED verification of SDCC’s re-calculated CDR. In the absence of that verification, staff cannot recommend granting the appeal. With respect to the graduation rate, staff can determine no basis for granting the appeal. Education Code section 69432.7(l)(3)(F) expressly states that “an otherwise qualifying institution with a graduation rate of 30 percent or less, as certified by the commission . . . shall be ineligible for initial and renewal Cal Grant awards at the institution….” [Emphasis added.] To staff’s knowledge, SDCC did not assert that the graduation rate was incorrectly calculated. Even if SDCC were to make that assertion, staff could not recommend granting the appeal in the absence of USED verification similar to that required for the CDR. RESPONSIBLE PERSON(S): Catalina Mistler, Deputy Director Program Administration and Services Division California Student Aid Commission California Student Aid Commission Page 5 of 5 Page 6 of 19 June 1-2, 2017 June 1-2, 2017 Attachment 15.2 7 IEGO II I A November 18, 2016 California Student Aid Commission PO. Box 41907 Rancho Cordova, CA 95741 9027 To Whom it May Concern: I am writing to appeal the'disqualification of San Diego Christian College (SDC) as an eligible institution to receive Cal Grant funds. This longstanding program has benefited Cal Grant eligible students for the history of the college, and we plead for consideration to maintain this student resource. As noted in the Department of Education?s announcements, Cohort Default Rate returned as 15.7% for FY2013. This was a dramatic and unprecedented increase from the 8.4% CDR in FY2012 and strikingly similar 8.4% CDR in FY2011. While appeals through the Appeal process were submitted to the Department of Education, the data challenges were inconclusive. We are currently working with the Department to mitigate any confusion on these appeals. SDC has plans to institute Debt Management education for current students and early outreach for those in repayment, and are confident that these efforts will impact future cohort default rates. We are convinced that this spike in the CDR is an anomaly, and a reflection of unique staffing challenges at the time these students exited the school. Thank you for your discernment and consideration as we appeal for grace in this matter. Please feel free to reach out to SDC with any questions, clarifications or concerns as you deliberate on this decision. Respectfully, Director of Financial Aid San Diego Christian College 200 Riverview Parkway Santee, CA 92071 P: 619.201.8727 F: 619?201?8749 E: daniel.reed@sdcc.edu SDCC.EDU 619-201-8700 200 Riverview Parkway, Santee, CA 92071 California Student Aid Commission Page 7 of 19 June 1-2, 2017 Attachment 15.3 AN IIEGQ A {eifege Feunded en flufll Mav 26, 201? Dear Interim Chair ejese and members, I am appealing te CSAC en behalf ef San [liege Christian Cellege with eur request te recensider eur Cal Grant eligibilitv. The attached decuments detail the raticinale and administrative errers that advecate fer a faverahle decisien. Due te the petential damaging impact the current deeisien will have en eur SDC students and pelential students, we respectfullv aslt that the Curnmissien review ciur appeal with discernment, empathy, and cempassien. A significant percentage ef eur SDC students receive I[lal Grant. We are grateful ferlhe supper-t Califernia prevides students with need te cheese the cellege that meets their needs and supperts their learning styles and geals. While there are celleges that have extensive endewments, and mav replace the less efthis reseurce threugh institutienal funds, this is net the case with San Diege Christian. If we replace these funds, it will have a significant impact en the services we effer as theyr will need te he reduced er discentinued. This is net DLJF desire. I am happy.r te previde any infermatien er ceetest needed te reviewthe data previded and am available fer anv questiens. The entire SDC cemmunitv is grateful Fer each l[Semrnissiener?s censideratien in this decisien. ectfuilv, lh?ll?5?tt'l' California StudentAdebtf?W?rE's?iB??mm? 5mm?- ?1533353 m? ?'3?de June1-2, 2017 Attachment 15.3 AN IEGO Appeoi Summary LHRES Due to unfortunate events, SDC's Cohort Default Hate returned as 153% for Films. This was a dramatic and unprecedented increase from the 3.4% GDP. in and $5513 P'f Hill {see Appendix While 15 data challenges were submitted to the Department of Education through the Appeal process this past Summer, these were filed for the incorrect year. By the time this mistake was identified, it was past the deadline to continue appeals on the correct year. Had SDC submitted the correct year appeals, as indicated by our Servicer?s data {see Appendix there was one student who resolved her default within the required timeframe. An approved appeal for this single student would have returned a 15.3% CDR, which is below the published maximum for participation in Caiifornia?s state grant program. This would have validated our continued participation in awarding Gal Grant funds. It can also be noted that there is subsequent data that indicates others could have been included in the appeals process [see Appendix We are convinced that this spike in the is an anomaly, and a reflection of unique staf?ng challenges at the time these students exited the school an issue that has since been resolved. SDC plans to pair with Great Lakes Higher Education Guarantee Grganization for delinquency outreach, default management, and financial literacy for current students, and we are confident that these efforts will impact future cohort default rates. Already, 1D of the 46 students listed as defaulted within F?r?2013 have resolved their accounts {See Appendix Also, our Graduation Rate was reported as the exact published maximum for Cal Grant eligibility. SDC can show that part?time students were inadvertently included in this cohort. If the original cohort is adjusted to include only the full?time, first?year freshmen, the number completing a degree within the 150% time frame yields a graduation rate of 35% {see Appendix We understand that AD 25 authorizes CSAC to review appeals, and thus we submit our case for your consideration. This longstanding program has benefited l[Sal Grant eligible students for the history of the college. Today, San Diego Christian serves over 1DD Cal Grant recipients, near Ellis of our Traditional population. Dur students are not only economically diverse, but also ethnically diverse. student population is 46% white, Edit? Hispanichatino, 14% Black or African American, 4% two or more races, 2% Asian, and the remainder are unreported. Many of these are first generation college students. We are proud of admitting students of all backgrounds, and are able to provide them with the support needed to graduate successfully. The ioss of Cal Grant eligibility creates a significant hardship on students seeking to continue their education at their school of choice. it also creates an astounding economic burden on SEC to suppIEment this lost resource through institutional aid. As noted in reports, SDC doEs not have the endowment reserves to support such a loss without reducing or discontinuing services. Please consider our appeal to regain Cal Grant funding for the Emit?21318 year. We realize that support from the Department of Education would ease this decision, and we have done everything in our power to obtain this, reaching out to Region lit offices, the Default Resolution Center, ED Trainers, the Ombudsman, the Under Secretary of Education, and our local legislators. Likely due to the Government transitions during this time frame none have been able to review our data or provide the letter of support requested by GSAC. Dur data shows that the metrics initially submitted were incorrect, and that even a single student variance makes the difference in meeting the stated benchmarks. We want to make this right and can provide any information regarding action steps to be taken or any further context that would be useful in making your determination. Thank you for granting EDIE the opportunity to appeal Gal Grant eligibility for our students. California Student Aid Commission Page 9 of 19 June 1-2, 2017 ?"Atta?chment 15.3 Appendix 1: Appear! and Eligibility Timeline 3f1f2015 - Draft 2013 CDR Released SDC notified of 153% Rate 4f15f201l5 SDC Began Appeals process through ED System 55;;2015 - ED accepted one appeal accepted, requested ciarification from ED 3f1f2016 1- Appeals case closed by ED. all now denled [Incorrect year appealed] Rfl?i?ifz?l? - First connected with Default Resolution Center 111'31?2016 - Concern with Cal Grant eligibility identified - Initial Appeal submitted to encouraged to gain ED support to recognize student information that could have been appealed 11f13!2016 I Default Resolution Center responds with stated timelines for appeals - Left first message for Region Di ED Rep 11f23f2016 - Connect with Region IX ED Rep, redirected to Default 12f12f2016 Resolution Center - ineligible School list posted by CSAC - Met with Default Resolution Center Manager and Director, request emphatically dismissed 1f12i?201? - Requested support from Government Representatives . Rep. Hunter sends request of support letter to Acting ED USHER Secretary on behalf of SDC 2f16f201? 0 CSAC reiterates that ED Support is essential 3f?f201? - Draft 2014 CDR Released SDC Notified of 10.3% Rate 123'143'2015 noting they will not review any information AXE-ARMS - Response recewed from then ED FSA cot} James Runcie California Student Aid Commission Page 10 of 19 June 1-2, 2017 Attachment 153 Appendix 2: Cohort Defouit Rote History SDC CUHDRT DEFAULT HATE DVEH TIME 5.50% 5.10% "h were 4.611% Pill]?! I F?il?l? marks an unprecedented spike I is the current draft rate, well within eligili'iilitt.r I To further decrease the future CUR measurements. BBC is beginning to partner with Great Lakes Higher Education Guarantee Organization on: Portfolio Navigator outreach and Default management} tiraoFieaoyr [Financial Literacy} SDC DEFAULT HATE OVER TIME iconeecrep) 3.60% 31003 H110 Hill 201?! 213113 I the corrected, had the single appeal been approved {see appendix 3] California Student Aid Commission Page 11 of 19 June 1-2, 2017 Attachment 15.3 Appendix 3: San Diego Christian College CDR Analysis 33H Dammit-main nun-n: Linn 1.11m monu- AmouanDIIa 1311mm 1111-1103 . 1.1.11 3111:1111-me ?lplr?nllin??'nm?r 51111111111 0 Pritit?hid wt: 1111111011111 111 311111-31r c0111. 1111111151511 1111 mart 0110; 1:501?: 00-111 Hat-noun 15.11111110me minimumsmi'm 111151141! {daurhllitot 1011:1111} [mania-Iliu- 1511 1:011: 712111513 Wm 15115-53 313312012 313612012 ?Wj_ot_la_e?qgluded__ ?Should not 55- included '12-'116'233'1111'71'26'12 91'93211??! 242:]. 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ECWE 925.15% -1533: 11113013301311.1013 I 5511131113? 1015333013 1.311131111' 511115-51 11113113014 10115111111 3.10.1; 11111-111011 1.51.3; 41135131113 11113313013 413513013I1013313013 correct 51115:: 1 1111111111.: 5111113513 35011! 1151111131 55511.! 1111113013 5115131113 1111313013! 511513013 correct correct I 515131.115: '1'1'1511512 35131115 311311533 3333'!" 3111113013 111013013 111513013; 111013013 15111.43 1.1.1.511 i 31291291}; .32151'2il-13 la?itleareddefault 1111222012 511622013 511512013 correct i 5215121312 Hum-1:1 151114191311; 31.102311}: 35535 11111013112 correct correct I 11115111111 111511011 35011. 1113113011 3501: 514113013 1013113013 511113011:101311301:r correct 11:11::1 31151311111 111151311113 13511! 9135111111 1351:1311-5153:115151111 31313?015 101.15.130.13 1111313013 10113130135 411.13.130.13 1.1.1511 11111511 111111111111 1133131113 11511; __3'1'313'015 51513011 3131311135 51513013 51115:: . correct 5111111111 111131113 3:75?01 1130131113 3350' 1111131113; 111013013 1:511:41: Inn-:11 1 0130130141 1111013011 1511111 ?111311011 1.1313011131313013 513131113: 111513013 51115:: 5 15115:: 51.113013 111111113013 151300; 3133131113 3551- 51151201? 11114131011? 511513013'1111411'3trl? tone-:1 . i? 3511115313. 1.151191% 35.31.31: 511411511 1534 313313013 113313013- 3.1111135 1011-11-11 31151-111131 51:11111111 11503 15135111111 '1'1151 1111313013 5115131113 1111313013; 511513013 51115:: I correct 21'21'2Ellj" ?imdi'j: 215d? 51251121312: 22222291} i This redacted listing of the 1?15 students included as defaulted in the 3013 CDFI reveals several things: The first six lines show last dates of attendance inaccurately reported, re3u ting in wrongful inclusion for the 2013 EUR The seventh line shows a student who resolved her default on '1'1'ltl1?2?15, which is within the time frame measured by the This is con?rmed below by the loan sewicer Cal?amggagmpn? since [after the measured timejl?mei 2017 uILl-ullul II Attachment 15.3 USA I-?nnda A 1 If: LED Na RU. Heat ?34513, ELLE MC E2142 ?dikes-Earle} Vii-tit eur wee nite at tt raffle anne lutienneaa ?lndner hill)! 25.. i Dr . hiaitdd?annaax Eta-34nd Nainherit?mlim Dear Simeenhid?aabrn NaeierrtReintiere-i1 Hit: [a a newieel: at student [tan-u; natienal and atute guarantee ageneiea. Fen eentaeted Navient {Pei-ll Claim Maintanee} regarding yeur edeea'iien leam?a}- We appreeiate yenr eeneent~ and en hehalt'e?i' year guarantee we had; thrward tn helping yet: with yeur? lean :reapennihilitien. As at Wild-2015, year denialtiai student [ean{a} liated heiew was eenaelidatini and the innate} in new eenaidered natiaFied, The heider etiyeur eenaelidatien lean will need yen repayment teen-e. Nat-tent, en helralf at United Student Aid i-?enda, [tale in allewed ie repert eredit infermalien at a lean level. Guarantee are required under the Fair Credit [needing are: in reperi aeeurare infermatien regarding atederrt lean in additien, the federal generating the Federal Family Edeeatien Lean Pregrarn requirea en te repert updatea tn the natienai want-turner reperrieg ageneiea err herrewern' The reperting atteetnre in and appreved by all narienal: eerutuine: repeating ageneiea te whieh we reperi: en United Student Aid Fund-a, Theda behalf the aeVen yearn item the date at Thin update will net an}r etedit entries; appearing an Havient er a previeua lender repel-ting year lean The lnanta} yea ehtained was. guaranteed tinder the Federal Family.-r Fdneatien Pregrarn. in with the Higher Edeeatinn diet, guarantee-z ei? defaulted learn: are required tn repnrt te ntd?ienal eredi't hnreaua seven years frinnihe ?en date at" delinqueneg,r the feliewing infenwitien: The date et' ?nd delinqueney 13 infernlatien. eeneerning the ef the Eeae; auei: as? date at" last payment and halanee The iietertte'aeati?ii?ancrl During the seven year periedi, in?i'ermatien will he updated hut it ranniet he deleted. Pleaae alne ireew that due te identitieatien heing een?eerted than Eneial Seeurity Heathers te Cuntemer Identi?eatiee Newman in April an update an generated with the natienal eredit bureaus te refleet thi a ehange. update wiil net a?het an}r eredit entries appearing an "Navient" er a lender repel-ting yen: lean . Yen ean pret'ide thin lettet te yeiu'finaneialaid ei?iiee an pree?i?thatyeu 111a}.r he eligihle fer additienal Title hid. if yer: have ether ieana in defaeit, yen will net be eligible fer Titie TV untii the de?rult atatua en all at year learn: in reaelaed. Please retain the; letter t'er year an it year that the innate} listed helew la paid in Full, . I literal]? Itineranter I Distinr?ement'?ntei Dlehr'itemeni?meanti at USA. 'thds Hanan-ale? handled -IH 11" yea have addilienal queatiena, pleaae eeniael eur e?iee tell the at ii?ld?llh?ildl er via email at .1- California Student Aid Commission Page 13 of 19 June 1-2, 2017' Attachment 15.3 Appendix 4: Graduation Rate Summary PUBLISHED SDC GRADUATION RATE EVER TIME 51% 4'1 sass I EDIE The reyiew ofthe EDGE Freshmen Cohort data reveals several issues that impacted the graduation rates as reported. 1. The initial freshmen cohort of 63 as reported for IPEDS included 5 students who were not full-time freshman in the fall of EDDIE. They were part?time students and should not base been included in the Full-time, Freshmen Cohort. E. The graduation dates are recorded by date earned and date awarded. In dong the reporting, dates awarded were used rather than dates earned and thus resulted in errors in identifying time to degree. If the original cohort is adjusted to include only the full?time first~year freshmen, the cohort would be 5? students. {if those 57" students, the number completing a degree within l??tla time would be 2t) students which yields a graduation rate of 35% {see below}. Two additional students completed within zoos-s time, for an oyerall graduation rate of 33.5%. Additional data can be proyided to support these numbers. SDC GRADUATION RATE EVER TIME 44% 35% California Student Aid Commission Page 14 of 19 June 1-2, 2017 Attachment 15.3 GIN SERVICES Was Ir. DI: Gr- =Ics: TFF GN I 2129 BUILDINL: Was-'- -. . Etc-oats EDUCATIUW AND 1 ill: CI: T: I I magnify-11H 21;??me IGM THAN AND INFRASTRUCTURE EN T-E an: Lumpy-5 'I'nnHGI'rr-Irnrlure Ila-Joh- MEG-5201 a. 1l~ Fritteur: I351 I taunt-an mourn the. ihuust sf tutti ihisttitt, distifomis January 31,201? Philip Rosenfelt Acting Secretary of Education US. Department of Education 4th] Maryland Avenue, SW Washington, DC. 2?2?2 Dear Acting Secretary Rosenfelt: I am writing today to ask for your assistance in a matter involving San Diego Christian College which is located in my Congressional District, and their appeal to the California Student Aid Commission to maintain eligibility in the state Cal Grant Program. In short, SDCC mistakenly submitted inaccurate data to CSAC for the institution?s Cohort Default Rate (CDR) for Fiscal Year (FY) 21313. mistake resulted in their CDR for to total which exceeds requirement that institutions maintain a CDR under 15.5% in order to maintain Cal Grant eligibility. This came as a surprise to SDCC, as historically their GDP. has been well below the 15.5% mark required to maintain Cal Grant eligibility. In fact, just two years prior to FYEIJI I?their CDR was reported as It?s clear that a mistake was made. SDCC has taken measures to ensure such a mistake is not repeated, and has compiled and submitted corrected data. In order for this mistake to be remedied, however, a letter from your of?ce to CSAC is necessary to ensure SDCC students maintain Cal Grant eligibility. Such a tetter would 1terrify that SDCC has appealed their of?cial CDR and, if corrected, would lower their of?cial for FY2013 to below 15.5%, thus making SDCC eligible for the Cal Grant Program for the fall semester of QUIT. In 45-year history participating in the Cal Grant Program, this is the first year the institution has been at risk of losing program eligibility. According to Dr. Paul argue, the President of SDCC, the institution has taken the necessary actions to ensure students are equipped with the ?nancial information required once they leaye the institution. Further, when reviewing case, it?s important to note efforts to reach minority student populations. Ten years ago, student population was represented as 8TH: Caucasian. Since then, SDCC has diversi?ed their student population and is now California Student Aid Commission Page 15 of 19 June 1-2, 2017 l'nnrr' house 95-.- Attachment 15.3 represented as the fellevving: 311% HispaniefLatine, 14% Filael: er A?'iean Ameriean, 4% ?ve er Inere raees and 2% Asian {14% is unreperted). SDCC is preud te serve students ef all haehgreunds and is able te previde eaeh ef them with the suppert needed te get te graduatien l-levvever, with ever Etl?t?ri: ef their student pepulatien partieipating in the Cal Grant Pregrare= the less ei?l?unding threugh the pregram 1areuld he detrimental te the students impaeted, as it 1.venld disrupt the students? eempletien ef their desired higher edueatien esperienee. Yeur immediate assistanee in this matter will help ensure that students are able te eentinue te their edueatien at the institutien at their eheiee. My etTiee can he reaehed with any euestiens veu may have by eentaeting Tire lEarlten en my staffer er at With regards tn the requested letter te CSAC, the letter ean he addressed te Keith Yamanaha, Bea: 4191326 Ranehe Cerdeva, CA 95T4l-9?26 er emailed te KYamap??esae-eahev. Thank ven far veer assistanee with this impertarit matter. I leek fenvard te hearing ??em veu shertlv. California Student Aid Commission Page 16 of 19 June 1-2, 2017 Attachment 15.3 Egem-site {Halfforttfa i?egtelatnre JDEL ANDERSON SENATOR THIRTY-EIGHTH SENATF oiaTnIoT Mr. Hal Geiogue, Chair California Student aid Commission 1104i] White flock Fiancho Cordoya, Cit DEE-TD Chairman Gelouga, Thank you and the members of the California Student Aid Commission for your efforts to ensure that California students haye the resources they need to pursue their educational dreams. We write today to request your assistance in keeping that access open to many desewing students attending college in my district. San Diego Christian College located in our legislatiye districts, is set to lose Cal Grant eligibility in the fall of 201? due to institutional eligibility metrics that were based on data errors for which the school has taken responsibility. Subsequently, SDC corrected the erroneous data and resubmitted it but apparently were too late. SDC has informed us that the corrected data would meet the program's eligibility standards. Nearly Edit: ofSDC?s student population are Cal Grant recipients. Should appeal be denied, the administration will not be able to supplement the lost resources for those students. That means students may face the decision to drop out if the school's Cal Grant eligibility is not restored. In order to ensure these students who, through no fault oftheir own, haye seen their educational paths potentially jeopardized, we ask that you giye appeal your careful consideration. (or Thanlt you, I II i- .lthl hnderson Handy Voepei .I I I . I fenetor, District 38 District it only uanc oe o-emict o: F-cc cam or rice ?Jun, ma, amt, t.iuic. Di?nol?L Iii-ii:- cam-.QL my? Em only ca oeces Tu, on eats-.1 clues: 93112.5. EEI I'd-533 7&2?ng 551-1193L'l E's'tJti California Student Aid Commission ?mm" g? June 1-2, 2017 SET: I: I Ir I STATE EHFITCII HUHM dial-FIE lT-n's EDEN-1 Ins (Halifnrnia ?tate ?enate SENATOR BEN HUESD FUHTIETH SENATE DISTRICT Attachment 15.3 5. :Il'l'tr El ll I-I AND BANKING d: EH HEN Tr'tL .siaTLI HAL January 30, Bill? Iylr. Hal Ucoiguc. Chair llilttlifiarnia Student Aid Commission White Rock Road itanoho CA 9567!} Dear lChairman fjeiogue. As the chair of the Senate?s Latino Caucus. one of my priorities is to increase access to higher education for minority students. Thanks to the Calilbrnia Student Aid lCommission our state is able to ensure that more and more students have the resources they need to pursue higher education goals. I write today because I am concerned this acecss may be decreased for students in parts of my senate district in San Diego. I represent one of the most diverse areas of San Diego County. I have been impressed with San Diego Christian College and their almost minority student enrollment. At this time. however, the college may not be able to keep those numbers because of the potential loss of Cal Grant eligibility due to institutional eligibility metrics that were based on Faulty data. I understand the college takes full responsibility for these errors and would lilte the CSAC to take into consideration the corrected numbers. Nearly of student populations are Cal Grant recipients. A loss of Cal Grant eligibility would be a detriment to the college?s ability to provide resources for students who cannot afford to continue their studies. I fully support SDCC's appeal to the Calit'omia Student Aid Commission in hopes that students can continue their educational path toward attaining a degree. i ask that you please give this careful consideration. If you any questions, please do not hesitate to contact me or a member of my staff at my San Diego District office {ti stilts?715913. I California State Senator. 4?th District LII-II II A routine. I It' I rle 303 STREET. E-IJITE Ci!- California Studentl'?tqugb??gr??on Page180f19 STWET SUITE CA TE. Iron-ass sat-is l-?LnITEozann-aeaa June 1 2, 2017 Attachment 15.3 '13" GF.- 111' LEIJC-FITIEJ 11111-111. 1111-11 1.1.5. 2112.11 1111513111111 1131-3 .'1'115113 111111111111: 1111' I131IEI I11. 111E E11 111E311 11131111311151111 11111111111111 1311111111113113111111 G1En111311l 111111 11-11 11111-1111 Eu1 1E1115r E1111. E11g1b111t5 13111 ?11 E111 11111911111. 1E 111E ICIEI 111113111111 13:11 11-. 11111111111111.- 3111.111 1311111111 1131111. 1511-111111- 1111'111111113111111111. 1111-. 1111.11.11111111111111- 115111.111 C1311 E1111. 1'1-111'. 1111.1 311 EII 111111111 13111131111315r 1E1: 111E E111 1E 1111 311111] 1313111. 13551111111131111 131E EIEEL 11.11.1111 111111 1.11: 31111.] 1111111. 11111 51111111111113 1111 11115111111 (111 11.1111 341.1135. 1311512111). 11111] 11111111111 11E 17'1". 211131 1111111111] 1:112:31. E. 1.1111111 F111 I213 13 133111111111 13.13111 IE. 551311. 111' 111E311 111111 E111 111111311 11111 1.111133153311111111315'. 111E 1.1111111111111111 ED121111 111E111 1111111111 11111111 111-11111. 11111 111111 13-111 1.111111111111111 E13111 111111111. 131E111 111111 1111 5E'11r EE 11151111 3.1" 51:11.1 .11151 1.1111111' I-. I I - 3.1111EE 11111 1:11.: ILEI111I1I 11111111111 1311111111 F1311: ._3311 Fig.1 L11: 3211:1112 California Student Aid Commission Page 19 of 19 June 1-2, 2017