FAME Frequently Asked Questions & Answers
Below you will find the frequently asked questions and answers featured in the Q2 2013 edition of FAME’s Inside Report.
Q1: Is there a regulation or a requirement that a school with multiple locations that has FSEOG funds must allot a certain amount of funds to be used at each campus to meet the first selection group requirement? For example, if we have a number of locations but we only allot FSEOG funds to 80% of the campuses to use, are we in compliance with awarding this fund?
A1: As the information from students at all locations was used in the calculation of institutional need (per OPEID), which affects the determination of Campus-Based allocations, Campus-Based funds must be made reasonably available to students at all of those locations.
Q2: As a credit hour school that is required to take attendance, with a program that requires externships, what do we do with a student’s enrollment if externship sites are not immediately available to for the students who have completed all of their classes? Do we have any options other than dropping a student from the program for unavailable externship sites?
A2: If it is a short period of time (a week or two), it could possibly fall under a scheduled break for those students. However, if it ended up being an extended period of time the students would be considered withdrawn and then have to re-enroll once the program resumes.
A potentially bigger issue that ED could have in regard to this is how this program is set up if students have long periods of time within the program with no instruction if that is not how the program was supposed to be designed (based upon accreditation and State approval as well). If this occurs regularly, the school should likely contact their regional ED eligibility team to see if the structure of their program is satisfactory for Title IV purposes, or if it is in jeopardy.
Q3: A student may be eligible for Title IV in 2013-2014 based upon being grandfathered in under the old Ability to Benefit (ATB) provisions (approved ATB test or completing the appropriate hours–6 credit hours or 225 clock hours) of being enrolled in a Title IV eligible program prior to July 1, 2012. When they are selected for verification in 2013-2014, they are not necessarily able to provide any of the documents listed for V4 or V5 tracking groups for high school completion status. Is this when a student would “contact the financial aid office”? If yes, what does the FAA have to collect to document eligibility and complete verification?
A3: The school would have to determine normal student eligibility under the ATB grandfathering process (hours or ATB test). Regardless of verification, if the student is not able to provide the documentation listed in the sample verification text, the school would have to ensure the student was eligible to receive Title IV aid. The school would have to document the ATB eligibility in order to complete verification for high school completion status purposes.
Q4: If a student was enrolled on or before July 1, 2012, could a student use the prior ATB eligibility provisions? If the student had not taken an ATB before, could he or she still take one now, or could they qualify as having ATB based upon one of the other alternatives of 6 credit hours or 225 clock hours?
A4: Yes, that is correct. And, there are no conditions stipulating that a student had to have received Title IV aid prior to July 1, 2012, just that they were enrolled in an eligible program at an eligible institution at some point on or before July 1, 2012.
Q5: We have a student who incorrectly indicated that he had a baccalaureate degree on his 2011-2012 FAFSA. The student did not actually have a baccalaureate degree. This was just recently discovered to be the case by the school. Is there anything that we can do to make the corrections to help the student get the Pell Grant he would have otherwise been eligible for?
A5: Unfortunately, a school may not at this point make any changes to the 2011-2012 FAFSA, and thus may not make a late Pell payment to the student (e.g., via the “administrative relief” process, etc.). Corrections would have had to have been made within the normal end-of-year processing deadlines, which for the 2011-2012 Award Year would have been September 21, 2012 (and a similar date for each Award Year as published annually in the Federal Register, e.g., September 21, 2013 for 2012-2013).