Prompted by the 1992 Reauthorization of the Higher Education Act that required the standardization of forms and procedures, the Common Claim Initiative (CCI) provides the means to realize operational efficiencies while maintaining the integrity of both default aversion activities and claim filing through standardized forms and their electronic equivalent. For claim filing purposes, CCI promotes operational efficiencies and common standards for the FFEL community to utilize in the submission, acceptance, review and payment of claims for Federal insurance. CCI also provides consistency in the data collected necessary for Post Default Collections. The development and maintenance of CCI is provided by NCHER’s Standards and Operations Committee.
Procedures & Guidelines
The Industry Manuals and Guides file library on the Manuals, Guides & Newsletters page in the NCHER e-Library contains the Common Claims Review Procedures outlining the process a guarantor is encouraged to use as a guide to review a claim filed on the common Claim Form as well as the FFEL CCI Post Claim Sampling Review Guidelines that are the operational guidelines and process expectations to implement the Post-Claim Data Integrity Sampling (PCS) plan, used to standardize processes for FFEL participants and provide assurances through data integrity verification that the data reported on the Claim Form (for the purpose of the PCS plan, the term "Claim Form” refers to both paper and electronic formats) correctly reflects all necessary activities.
Post-Claim Sampling Contact List
The formal approval by the Department of Education of CCI for claim filing is provided in the following series of letters:
December 19, 2005 : Provides ED approval for lenders to submit claims utilizing the CCI format and guarantors may review the submissions for completeness and for making a determination as to whether the lender has complied with all of the origination, servicing, and due diligence for claim approval, with certain stipulations that includes the implementation of an ED approved process that guaranty agencies will use to conduct a Post-Claim Review in order to ensure CCI claim submissions are accurate.
July 15, 2008 : Provides ED approval and outlines the Post Claim Data Integrity Review Sampling (PCS) process and remains in effect until ED notifies the guaranty agencies otherwise. This approval provides further stipulation that requires guaranty agencies to report information on the PCS process on a Federal Fiscal Year basis. The PCS process provides a methodology that will enable guarantors to make a valid statistical inference as to the accuracy of the claim submissions received from each lender/servicer.
December 11, 2008 : Provides ED approval of the Post Claim Data Integrity Review Sampling report, as required by the July 15, 2008 approval. The approval remains in effect until ED notifies the guaranty agencies otherwise.
Documents, Tools and Reports supporting the initiative are maintained with the NCHER e-Library, within the
Other FFELP Forms section, include the following:
- CCI Default Aversion Assistance Request(DAAR) Form
A standardized form developed under the Common Claim Initiative to support the lenders’ requirement to submit a complete and accurate request for default aversion assistance no earlier than the 60th day and no later than the 120th day of the borrower’s delinquency.
- CCI FFELP Claim Form
A standardized form developed under the Common Claim Initiative designed to be used by a lender to request claim reimbursement with the guarantor of the loan. Includes IBR provisions.
- CCI Ineligible Borrower and Identity Theft Supplemental Form
A standardized form designed to accompany the FFELP Claim form to support and provide additional information necessary to request claim reimbursement for an Ineligible Borrower or Identity Theft claim.
- CCI Partial Discharge Request Form
A standardized form developed under the Common Claim Initiative designed to be used by lenders to request reimbursement for the partial discharge of a Federal Consolidation loan due to the death of a dependent student for whom a PLUS loan was received and later consolidated, the death or total and permanent disability of one of two borrowers on a spousal Federal Consolidation loan, or the discharge of an underlying loan(s) due to a closed school or false certification situation.
- CCI Post Claim Sampling Report
A standardized report developed under the Common Claim Initiative and approved by the Department of Education to be used by guarantors to report the results of their Post Claim Data Integrity Sampling reviews on a Federal fiscal year basis.
- CCI Supplemental Claim Form
A standardized form developed under the Common Claim Initiative designed to be used by lenders to submit a request for increase in the amount of claim payment to the guarantor.
- CCI Teacher Loan Forgiveness Request Form
A standardized form developed under the Common Claim Initiative designed to be used by lenders to accompany the Teacher Loan Forgiveness Application provided by the borrower to request reimbursement under the Teacher Loan Forgiveness program.