To: Lenders, Holders, and
Servicers Participating in the Health Education Assistance Loan (HEAL)
Program
Subject: Borrower Loan Status
(BLS) Rules and Reporting Requirements Lender Policy Memorandum L-1997-7
This policy memorandum explains
the revised HEAL Borrower Loan Status Business Rules and Reporting Requirements.
These revised rules and reporting requirements will allow the HEAL program
to obtain the most current information on borrowers which will be used to administer
the HEAL Program in an accurate and effective manner.
The HEAL Program,
with the assistance of the Student Loan Marketing Association and the Pennsylvania
Higher Education Assistance Agency, developed the following: (1) BLS Business
Rules; (2) Status Update Data Dictionary; (3) BLS Error/Warning Messages; (4)
Customer Tape Specifications for Reporting BLS Updates, Lender-to-HEAL;
and (5) Sample pages for the Transaction Processing Reports for Errors, Acceptances,
and Summary. In addition to loan status changes, updates to social security
number, borrower name, address, telephone number, holder, servicer, graduation/separation
date, and initial repayment date will be made through this process. All changes
must be reported to the HEAL Program on a monthly basis. Corrections
of any errors must be resubmitted on a separate tape or disk within 55 days
from the date the change first occurred or the date the lender/holder/servicer
was notified of the change.
By informing lenders/holders/servicers
of our new rules and requirements, we hope to make the HEAL loan status
process more accurate, complete, and uniform. Correct statuses and borrower
information is imperative because it affects the accuracy of many reports produced
by the HEAL Program such as school default rates, litigation activity,
and refinancing which are provided to schools and lenders on a regular basis.
This revised process will be implemented for the reporting period endingDecember 30, 1997, with the first monthly report to be submitted to the HEAL
Program on or before January 10. 1998.
We appreciate the effort
involved in complying with these new procedures for updating loan status and
other borrower information. We are committed to making this new system work
smoothly with your help and cooperation. If you have any questions, please contact
Ms. Terri Ehrenfeld or Ms. Denise Hugueley of the HEAL Program at (301)
443-1540.
Stephen J. Boehlert
Associate Division Director, HEAL
Division of Student Assistance
HEAL Borrower Loan Status
Business Rules
Basic Requirements/Reporting
Borrower Loan Status
(BLS) data must be submitted to HHS by the 10th of each month.
BLS data must reflect
status changes or other relevant information that occurred the prior month.
HHS expects data reported
by servicers/holders will be accurate and complete.
Loan ID must be unique
on the tape submission, not submitted more than once.
BLS data must be submitted
to HHS in ascending order by loan id.
HHS will produce an
acceptance and error/warning report for each BLS data submission.
Servicers/holders must
correct error/warning reports and resubmit errors on a separate electronic
submission to HHS within 55 days from the date the action occurs or the date
the servicer/holder is notified of the action.
In the case of status
changes, HHS retains only the last action for the loan.
HHS assumes the last
status action reflects the accurate status of the loan at the time it is reported.
All most recent SSN,
name, address and phone number changes will be reported for all loans on the
BLS submission within 45 days from the date the action occurs or the date
the servicer/holder is notified of the action.
SSN, name, address,
phone number, servicer, holder and current anticipated graduation/separation
date changes are independent of loan status change actions.
Each borrower status
record includes all applicable data elements as defined by the attached HEAL
customer tape specifications (Lender to HEAL).
Events that Trigger a
BLS Transaction
Borrower's most recent
name changes.
Borrower's most recent
address changes.
Borrower's most recent
loan changes status.
Borrower's most recent
SSN changes.
Borrower's most recent
phone number changes.
Servicer of loan changes.
Holder purchases borrower's
loan.
Borrower's most recent
current anticipated graduation/separation date changes.
Definitions/Inferences
D- In School
- "In school"
means the borrower is currently attending a full-time eligible HEAL
school.
- "In school"
borrowers have never been in repayment.
- If a borrower's loan
is in "In school" status, the borrower's loan is not in a school
deferment.
- "In school” indicates
that a borrower has not graduated or withdrawn from school.
G- In Grace
Period
- "In Grace Period"
means that the borrower is in the nine month grace period.
- In "I" type
deferments (internship or residency) the "Grace Period" follows
the deferment.
If not an "I"
type deferment, the "Grace Period" begins immediately following
separation from school or attendance less than full time.
- Nine months of grace
must be completed prior to entering repayment.
I - Deferred
(Repayment period postponed)
- Payments are deferred
j to the expiration of "In Grace Period".
- Internship/residency
programs that begin prior to the expiration of the grace period.
- Fellowships and educational
programs that begin within twelve months of the end of internship/residency
are eligible for "I" type deferments and the grace period will start
upon completion of this deferment.
Graduates of chiropractic
school are eligible for "Deferred" status immediately upon graduation
- for 1 year and prior to the grace period.
R –
Repayment
"Repayment"
means that a borrower is in the repayment period either on the 1st day of
the 10th month following graduation after the 9 month grace period or the
1st day of the 10thmonth after an "I" typedeferment
plus grace. Repayment date has been called conversion date.
Q - In repayment,
but deferred
Payments are deferred
after the expiration of the "In Grace Period". Borrower has
used the nine month grace period. Borrower has enrolled, full time, in a HEAL
school or at an institution of higher education, is participating in the Federal
Family Education Loan Program (FFELP) or the Direct Loan Program, is
a member of the Armed Forces, Peace Corps, VISTA or National Health
Service Corps, or has completed an internship or residency training program
in osteopathic general practice, family medicine, general internal medicine,
preventive medicine, or general pediatrics and is practicing primary care..
F - Forbearance
Borrower is currently
in a period of forbearance granted by the loan holder. Immediately preceding
forbearance status could not have been a "D". Status preceding forbearance
could have been "G", "R" or "Q”. Borrower
must be in repayment status to receive a forbearance.
PB - Paid
loan in full by borrower
Borrower has paid the
HEAL loan in full to the holder. "Borrower paid loan in full"
does not mean a claim has been paid on the loan by HHS. "Borrower paid
loan in full" does not mean the loan has been consolidated. "Borrower
paid loan in full" does not mean the loan has been sold to another HEAL
holder.
PO - Paid
loan in full by another party other than the borrower.
Another party other than
the borrower has paid the HEAL loan in full to the holder. Examples
of another party other than the borrower are financial or educational institution,
mortgage company, friend, family member, attorney, etc. "Other than borrower
paid loan in full" does not mean a claim has been paid on the loan by
HHS. "Other than borrower paid loan in full" does not mean the loan
has been sold to another HEAL holder.
EP - Loan
paid in full by Dept. of ED
Borrower has consolidated
this HEAL loan with the Department of Education and the loan holder
no longer holds this HEAL loan for this borrower.
Loan Status
BLS actions are reported
on a loan level.
BLS actions are not reported
on a disbursement or borrower level.
Voided or canceled loan
transactions are not valid BLS actions and therefore should not be reported.
All BLS actions are reported
to HHS within 45 days of the date the action occurs or the date the servicer/holder
is notified of the action.
Loan status must be one
of the following values:
D - In school
G - Grace
I - Deferred (Repayment period postponed)
R - Repayment
Q - In repayment, but deferred
F - Forbearance
PB - Paid loan in full by borrower
PO - Paid loan in full by another party other than the borrower
EP - Loan paid in full by Dept. of ED
For multiple changes in
one report period, only submit the most recent loan status.
The loan status for all
loans purchased in a given month is reported by the new purchaser (holder) to
HHS within 45 days after the purchase transaction.
The "effective date
of loan status" refers to the date the action actually occurred on the
loan.
The "effective date
of loan status" is independent of the holder's system posting date.
Future, estimated, or
projected status change dates will not be reported to HHS.
If a loan is sold in
a given month, the holder purchasing the loan reports the current loan status
to HHS within 45 days of the purchase transaction.
If a loan is sold in
a given month, the lender selling the loan does not report the loan to HHS.
All loan statuses must
have an effective date of loan status.
Loans with statuses
"G"," W, or “I” can not have a conversion to repayment date.
Valid repayment statuses
are "R”, “Q”, or “F".
Loans with statuses
“R”, “Q”, or “F" must have a conversion to repayment date.
Loan statuses “PB”,
"PO", and “EP”, are considered closed statuses.
Loan statuses "PB",
"PO", and "EP" are reported to HHS only once.
Loan statuses “PB”,
"PO", and “EP”, must have a conversion to repayment date, if the
loan was in a repayment status before the loan was closed.
Once in the repayment
status of “Q”, or “F" a loan cannot go into a “D" status unless
separation/graduation date changes. If a loan goes into a “Q”, or “F"
status the repayment date on the record does not change.
Once in a repayment status
of "R' a loan cannot go into a “D" status unless the borrower's separation/graduation
date changes.
Repayment Date
Repayment date is defined
as the date the borrower actually begins repayment.
Repayment date typically
begins either the first day of the 10th month after the borrower graduates
or the first day of the 10th month after an “I” type deferment.
Repayment date will
not be reported to HES until the borrower actually goes into repayment.
If reported correctly,
the repayment date value never changes, unless a status change causes a change
in separation/graduation date.
The repayment date value
will not be changed if the borrower status changes to a “Q” only the effective
date of loan status will change.
Future, estimated, calculated
or projected repayment dates will not be submitted to HHS.
A repayment date should
only be submitted once (at the time the loan goes into repayment), unless
status change causes a change in separation/graduation date.
Anticipated Graduation/Separation
Date
Anticipated Graduation/Separation
Date should be submitted as an expected date until the borrower actually graduates
or separates from school. Servicer should then report an actual date of graduation
or separation if it is different than what was previously submitted to the HEAL
Program.
Status Update Data Dictionary
Field Name
Field Definition
and Constraints
Warning
A message that informs
the servicer that problems may exist. The BLS record is accepted and the
HEAL database is changed.
Error
A message that informs
the servicer that problems do exist. The BLS record is not accepted and
the HEAL database is not changed. Servicers
are responsible to fix the record and resubmit.
Loan ID
Number assigned
or approved by HHS for all insured loans.
YYYY indicates the
government fiscal year in which the loan was disbursed, BB is the HHS
assigned block number, followed by a 6 position sequentially generated
number.
SSN
Social security number
for borrower currently on the HEAL database. If there is a SSN change,
report old SSN in this field and new SSN in "New SSN" field.
Name of Borrower
Includes Last, First
MI in that order. Must include comma. If there is a name change, report
old name in this field and new name in "Borrower's New Name" field.
File Type “S”
will always be reported
in this field to indicate a Status Update file type.
Holder ID Number
HHS assigned number
for the holder of the loan.
Servicer ID Number
HHS assigned number
for the servicer of the loan.
New SSN
Report the new SSN,
if applicable. If new SSN, then old SSN is reported in "SSN" field.
If no change, leave blank.
Date of First Disbursement
Date of the first disbursement
of the loan. May leave blank if loan ID is submitted.
Current Loan Status
Loan status of borrower's
loan in the month the data were reported.
Effective Date of
Date loan status change
actually begins. Data in this field is
Loan Status
submitted to HHS no
earlier than the date of occurrence andno later than 45 days
after the date of occurrence.
Repayment Date
Actual date the borrower's
loan went into repayment
Repayment Date Change
A "Y"
or blank indicator representing a repayment date
Delete Indicator
change or deletion
due to a status change from an “R” to a "D", “I”,
or "G".
Current Anticipated Grad./Sep.
Date
Date the borrower is
expected to graduate or withdraw from school.
Borrower's Street
Address (first line)
Current street address
of the borrower.
Borrower's Street
Address(second line)
Addition to borrower's
street address shown on first line.
Borrower's City
Current city in which
borrower resides.
Borrower's State
Current state in which
borrower resides. Must be a valid US state code, "FC" for
foreign country, "AA" for Military Americas, "AE"
for Military Europe/Mid East/Africa/Canada or "AP" for
Military Pacific.
Borrower's Zip Code
Borrower's current
zip code.
Borrower's Phone
Number
Current phone number
for the borrower. Include area code.
Borrower's New Name
Report any name change,
if applicable. If new name, then old name is reported in "Name of Borrower"
field. If no change, leave blank.
BORROWER LOAN STATUS
Error/Warning Messages
Error Reasons:
Required value is missing.
Supplied value is invalid.
Cannot find SSN in HEAL
file.
Loan ID supplied is
invalid since the HEAL system contains no record of the supplied Loan
ID ever being issued.
Loan ID supplied is
associated with another borrower's SSN.
New SSN already exists
in HEAL file for another borrower.
Loan ID is submitted
more than once on the electronic submission.
Anticipated Grad/Sep
Date is before borrower's Last Disbursement Date for this loan being submitted.
Repayment Date is before
Last Disbursement Date of the loan being submitted.
Effective Date of Loan
Status is before First Disbursement Date of the loan being submitted.
Effective Date of Loan
Status is greater than HEAL received date.
Cannot submit a "D"
(in school) status since a repayment date already exists in the HEAL
file for this loan and a "Y" was not in the "repayment date
change/delete indicator" field.
Cannot submit a "D”
(in school) status since the effective date of the loan status is after the
anticipated Grad/Sep Date for this loan.
Cannot submit a "G"
(Grace Period) status since the effective date of the loan status is prior
to the Anticipated Grad/Sep Date for this loan.
Cannot submit a "G"
(Grace Period) status since a repayment date was submitted for this loan.
Cannot submit an "I"
(Deferred) status since the effective date of the loan status is before the
Anticipated Grad/Sep Date for this loan.
Cannot submit an "I"
(Deferred) status since a repayment date was submitted for this loan.
Cannot submit a "D"
(in school) status since the previous status was a Q, F, R, PB, PO,
or EP for this loan.
Cannot submit a "D"
(in school) status since the previous status was a G, I, or R and a
"Y" was not in the "repayment date change/delete indicator"
field.
Cannot submit a "G"
(Grace Period) status since the previous status was Q, PB, PO, or
EP for this loan.
Cannot submit a "G"
(Grace Period) status since the previous status was an "R” and
a "Y" was not in the "repayment date change/delete indicator"
field.
Repayment date is not
9 months later than the Anticipated Grad/Sep Date for this loan.
Cannot submit an "I"
(Deferred) status since the previous status was Q, F, PB, PO, or EP
for this loan.
Cannot submit an "I"
(Deferred) status since the previous status was an "R" and
a "Y" was not in the "repayment date change/delete indicator"
field.
Cannot submit a "R”
(Repayment) status since the previous status was PB, PO, or EP for
this loan.
Cannot submit a "Q"
(In repayment, but deferred) status since a repayment date does not already
exist in the HEAL file for this loan.
Cannot submit a "Q"
(In repayment, but deferred) status since the effective date of the loan status
is before the Anticipated Grad/Sep Date for this loan.
Cannot submit a "Q"
(In repayment, but deferred) status since the previous status was EP,
PB, PO, or D for this loan.
Cannot submit a 'F'
(Forbearance) status since the previous status was EP, PB, PO, or
D for this loan.
Cannot submit a “F”
(Forbearance) status since a repayment date field was not submitted for this
loan.
Cannot submit a 'F'
(Forbearance) status since the effective date of the loan status is before
the Anticipated Grad/Sep Date and/or the repayment date for this loan.
Cannot submit a "PB"
status since the previous status was an EP or PO for this loan.
Cannot submit a status
change since this loan is part of a HEAL consolidation or is part of
a paid claim.
Cannot submit a "EP”
(Dept. of Education Consolidation) status since the previous status was a
PB or PO for this loan.
Warning Reason:
Borrower's new name already
exists in the HEAL file for another borrower with a different SSN and
the same date of birth.