FAME Frequently Asked Questions & Answers
Below you will find the frequently asked questions and answers featured in the Q1 2014 edition of FAME’s Inside Report.
Q1: If our State requires 85% attendance but we have a 10% excused absence policy for disbursing aid and we make everyone comply with 90% attendance for graduation, does this mean that we have to change our satisfactory academic progress (SAP) policy which says students need to complete 66.67% of the hours to be able to complete within 150% of the maximum time frame?
A1: No, a school can have a separate attendance policy that is different from their SAP policy. It is important to remember that pace of progression is about successful completion of hours and not just seat time (although they can be similar at times). Successfully passing courses with the appropriate grades in a timely manner (SAP) is separate and distinct from how many hours a student may sit in class (attendance).
Q2: We are a school that has a master’s program. We charge by the credit hour. If we do a standard cost of attendance (COA) based on 18 credits per trimester, but the student takes 20 credits in the 2nd trimester, can we at that point increase the COA to allow the student to borrow more Graduate PLUS Loan? I read in the Federal Student Aid Handbook that a school can do a COA based on the student’s academic workload.
Also can the school add in the bar exam fee? Would that be similar to the one-time licensing fee or certificate if incurred during enrollment?
A2: If the student’s tuition goes up you could choose to increase his COA. (This is assuming that all students who take 20 hours are charged the same.) And, yes, the bar exam fee can be added if it meets the criteria of the one-time license fee outlined in the Federal Student Aid Handbook, Volume 3, Chapter 2.
Q3: I am trying to clarify on a 90/10 question. Does a school count Direct Loan money used to pay for books/supplies as revenue in the 90/10 calculation? The Federal Student Aid Handbook states (page 2-63) that “Funds excluded from revenue” (i.e., don’t count as revenue) include “the amount the student is charged for books, supplies, and equipment unless the institution includes that amount as tuition, fees, or other institutional charges.”
A3: If the student takes out the money to pay for books/supplies that are purchased through the school (i.e., the charge for the books show up on his/her account), then the amount should be counted as revenue. If the student takes out the loan to buy books/supplies through an outside entity or bookstore, then it would not be counted as revenue.
Q4: We are a school that has a nursing program. Some students may not pass a required exam at the end of the program. We want to give them 4 attempts to pass the test within the next 6 months. We consider the student to still be enrolled. Some would continue to study on their own or have discussions with instructors, etc., in order to be more prepared for their next attempt at the exam. Are we able to consider them enrolled during this period in which they will re-take the exam?
A4: Our latest guidance from ED on this matter is that the best approach is seen to be to list the person as being enrolled, but as enrolled below half-time. Since the student has completed all of the academic requirements, the student can no longer be enrolled with any credits to establish an eligible enrollment status, yet the school wants to technically say the student is still enrolled because he/she has not completed a required program exam. By listing the student as below half-time, the grace period will start and it will not appear that the school is trying to get around or delay the repayment process. Listing the student as a withdrawal could achieve the same outcome as well (i.e., the R2T4 calculation will show the student earned 100% of aid). We are not aware of any other specific guidance on this scenario. Either approach will satisfy the Title IV issue of having the student start their grace period because there are no more academic requirements for this program. They have essentially completed the program.
Q5: A question has come up regarding the situation where a dependent student is getting married between terms. The student was not Pell eligible as a dependent. However, if we determine to allow the student to update his application once married such that he is then independent and includes the spouse in the household and includes her AGI, etc., and his EFC then falls in a Pell eligible range, will he be eligible only for the Spring term, or retroactive to include the Fall as well?
A5: The new EFC is good for the entire award year and, if otherwise eligible, the student could be paid Pell for hours completed (including “earned” Fs) in the Fall term.
Q6: If we have students enrolled in non-Title IV-eligible programs, but the students have previously received aid (either here or at another institution), do we report their current enrollment status in the non-Title IV program for NSLDS Enrollment Reporting purposes?
A6: Yes, you should report their enrollment status in NSLDS Enrollment Reporting since for a FFEL or Federal Direct Loan in-school deferment a student must be at least half-time in a Title IV-eligible school. However, the student does not specifically have to be enrolled in a Title IV-eligible program of study to obtain the in-school deferment. But, if the student is not in a Title IV-eligible eligible program of study, the student would not be eligible for Title IV aid.
Q7: We are a semester-based school with an academic year that is 30 weeks and 24 semester credits. We teach our programs in 4-week modules. We have several schedule options for students. Some full-time students attend all week beginning on Monday through Thursday (or the class could end on a Friday or Saturday, depending upon the course schedule). And, if the student is enrolled in an online class, the end of the class is on a Sunday. The published module dates always show the classes as starting on a Monday and always ending on a Sunday. Can we use the start of the semester through the end date (a Sunday) for the enrollment period (number of days) in the R2T4 calculation even if the student is actually attending a Monday through Thursday schedule?
A7: Our latest guidance from ED is that, yes, that is ED’s general rule. Now, if the student is only attending a module or two and not the entire semester, then of course their days would be adjusted accordingly.
Q8: If a student has to pay sales tax for books or a kit (e.g., for cosmetology programs), is that considered part of the cost of the book or kit, and thus allowable to have Title IV funds cover it? Or, is it not considered part of the cost of the book or kit/supplies, and therefore not able to have Title IV aid cover it?
A8: ED’s latest guidance states that they would consider the sales tax to be part of the cost associated with books and kits. ED has not specified that taxes have to be broken out separately from the cost of the books.
Q9: What is acceptable when a parent claims they cannot read or write? Can they go to a notary and make a mark and have that mark with the notary stamp be acceptable for processing aid? If so, does this still allow them to borrow a PLUS loan, or are they precluded from PLUS borrowing?
A9: The current guidance we have received from ED on this topic indicates that ED allows the special process outlined in the Federal Student Aid Handbook for completing the paper FAFSA where a high school counselor or college financial aid administrator may sign on behalf of the parent when a parent is unable to sign the FAFSA because this is simply providing data to assist the student. In no way is the parent becoming obligated to take on debt. However, signing a promissory note and becoming responsible to pay back a loan is different. No one can sign the promissory note in place of the parent. They have to be able to read and understand what they are signing. If the parent is unable to complete the promissory note they would not be able to borrow without an accepted MPN. This may be grounds to award additional unsubsidized Direct Loan for the student.
Q10: A student went on a leave of absence (LOA) and returned within 180 days of the start of the LOA. The textbooks for the program changed during the time the student was on LOA for all newly enrolled students. The textbooks are completely new and different than the ones this particular student received prior to his LOA. Can we charge this particular student for the new textbooks, and would that charge be able to be covered by Title IV aid?
A10: If you want the student to be considered to be in an approved LOA the school cannot list the new book charges as institutional charges and have Title IV aid cover them. There does not appear to be any exceptions listed in the LOA rules around additional charges. If you do include new institutional charges, then the LOA is not valid (due to the additional charges) and you would have to follow the rules for an unapproved LOA for Title IV purposes.