Cohort Default Rate Season: Nine Challenge Types, Hard Deadlines, and How Not to Miss One

ApolloSRM computes your cohort default rate the way the Department does, truncated to one decimal and never rounded up. It flags the sanction triggers for you (over 40 percent in a single year; 30 percent or more across two years, which goes provisional; 30 percent or more across three years, which is a loss of eligibility), and it runs the full challenge, adjustment, and appeal workflow for all nine types with the federal deadline computed on each one. The borrower counts come from your LRDR. We do the math, the deadlines, and the paper trail; you file through eCDR Appeals.

Why the CDR trips up even a healthy school

Two things make this number dangerous out of proportion to how your borrowers actually behave. The data is frequently wrong: borrowers misattributed to your cohort, servicer errors, students counted who never entered repayment. And the windows to challenge that data are brutally short. An Incorrect Data Challenge on the draft rate gives you 45 days, and the official-rate windows are tighter still. Miss one and a rate you could have beaten becomes a sanction you live with for years.

What we compute

The rate truncates to one decimal because that is the federal convention. A 66.66 reads as 66.6, not rounded up to 66.7, and getting that wrong moves your exposure in the wrong direction. The sanction logic knows the difference between consecutive and scattered years, so three non-consecutive years over 30 percent is not a loss, and the most recent year drives the single-year trigger. On top of the rate we run the Participation Rate Index test against the 0.0625 and 0.0832 thresholds, and the Economically Disadvantaged math (low-income at two-thirds or more, placement at 44 percent or better, completion at 70 percent or better) from the numbers you enter.

Nine windows, every one on a clock

Incorrect Data, Uncorrected Data, New Data, Participation Rate Index, Economically Disadvantaged, Loan Servicing, Average Rates, and the thirty-or-under cases each carry their own federal window of 45, 30, or 15 days, depending on the type and whether you are in the draft or official phase. ApolloSRM computes the closing date from the day the clock starts, so you can see exactly when each one shuts. Every filing moves through draft, submitted, under review, and decided, so nothing sits forgotten until it is too late.

Where we stop

We do not transmit to the Department. The borrower counts are yours from the LRDR, and the filing itself happens in eCDR Appeals, where it belongs. What we take off your plate is the part that actually costs schools their eligibility: the arithmetic slip, the sanction trigger nobody flagged, and above all the deadline nobody was watching. A bad CDR is often a beatable one if you catch it early, build the right appeal, and file before the window closes. Treat the season like a launch window. Miss it and you wait a very long time for the next one.