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Since You Asked: Questions & Answers

Q1:  If we have a student who had a G-845 received in the 2013-2014 award year and their citizenship paperwork does not expire until 2015, and we received a 2014-2015 ISIR with a C code, can we use the previously completed G-845 to confirm eligibility for the 2014-2015 award year? Or, must we complete a new G-845 for each award year?

A1:  If you have confirmed the student’s eligible noncitizen status in a previous award year, and you have no conflicting information or reason to doubt the student’s claim of having an eligible noncitizen status, you are not required to perform secondary confirmation in the subsequent award year if the documents used for that prior year’s secondary confirmation have not expired.

Q2:  Is there anything that would prohibit a clock hour for-profit school from having a “summer break”?

A2:  There is not a Title IV regulatory prohibition to having summer breaks for any school type.  The important thing is that the school follows its approved academic year definition.  Having a summer break may provide a student retention challenge in programs that are typically offered in clock hours, but a “summer” break would not be any different, from a regulatory perspective, than a break of five days or more between starts around holidays, season of the year (e.g., in August before a new start in September), etc.

Q3:  Does our school have to get ED’s permission before we change the address or physical location of our main location?  For example, if we were to move to a different location with better accessibility to students, would that require ED’s permission?

A3:  No, such a change does not require ED’s permission.  But, ED must be appropriately notified within 10 days of such change.  Additionally, the school must ensure it has any necessary approvals from the state and accrediting agency before making such a move.  However, if the school is making a move of a great distance, it is possible that it could be viewed as the closing of one location and the opening of another location.  This would require ED approval, as it is dependent upon several variables, to include the size of the city, if the change in distance could be considered a reasonable commute for students, availability of public transportation, etc.  Schools may find it wise to contact their ED Regional Office in advance of making the move if the new location is a number of miles from the current location.

Q4:  Can a school have Title IV students attend 40 hours a week and non-Title IV students attend 50 hours per week in same program?

A4:  Schools are allowed to offer different schedules to students.

Q5:  On page 3-31 in 2014-2015 Federal Student Aid Handbook (Volume 3, Chapter 1), under “Re-entry after 180 days and transfer students,” in the paragraph under the first two bullets, the last sentence of that paragraph reads:  “In this circumstance, the student may be paid for repeating coursework if the student is receiving credit for repeating the course.”

The scenario is where a school had a 1500 hour program and a student is returning to the same program (after 180 days) where he previously took 1100 hours.  But, the school is only allowing credit for 1000 hours upon the student’s return.  Does this mean that the student is then going to get paid for repeating 100 hours?

A5:  Our guidance from ED indicates that this is correct.  In this scenario, the student would get paid for repeating 100 hours.

Q6:  Our clock hour school has a situation where a student has to repeat hours previously attempted.  So, no new hours are being taken.  Do we have to report to NSLDS that the student is below half time or withdrawn?

A6:  No.  As long as they are still attending at least 12 hours per week they would be half-time.  They are still enrolled and working towards their program completion in their payment period.  Now, however, SAP may become an issue down the road.

Q7:  Our school has a consortium agreement with another school.  As the home school, we have a term that starts on 8/25/2014 and ends 12/12/2014.  The student is taking 6 credits at our school.  She is also taking 3 credits at a host school for a term that starts 12/8/2014 and ends 2/6/2015.  The next term at the home school starts on 1/20/2015 and ends 5/15/2015.  As the home school, may we use the 3 credits being taken at the host school in the term that starts on 12/8/2014 towards the credits in the term that started 8/25/2014?

A7:  Per ED’s latest policy guidance, you can add the credits to either payment period.  ED states that they are more flexible with consortium agreements in regard to overlapping terms and allowing the home school to remain a standard term program.  If you add the credits to the earlier term, you must remember that, depending on the school’s Pell Grant recalculation policy, you may or may not be able to add the class into the student’s enrollment status since the home school’s Pell Grant recalculation policy does not change as a result of having a consortium agreement.

Q8:  School “A” wants to add a location to their school.  However, the location they want to add happens to be School “B” that previously was Title IV-eligible, but has since closed.  If School “A” wants to purchase the closed School “B” location, would that location have to exist for 2 years without Title IV aid eligibility unless School “A” agrees to be liable for improperly spent funds, etc., or does a teach-out?  This is all based on the FSA Handbook Volume 2, Chapter 5, pages 2-91 and 2-92.

A8:  Generally speaking, an additional location isn’t required to meet the two-year rule, unless the new location (e.g., School “B” in your question) was:

  • previously another Title IV-eligible institution that closed,
  • the applicant school (School “A” in this example) acquires the assets of the closed school (School “B”), and
  • the closed school (School “B”) has a repayment arrangement with ED, but isn’t complying with it.

The current understanding from ED is that all three points must be true in order for School “A’s” new location (School “B”) to be required to be in existence for two years without Title IV eligibility under the new ownership.

Q9: I am just confirming my understanding of the scenario of students who were at some point wards of the court.  The 2014-2015 Federal Student Aid Handbook (AVG-25) states that “a student who was at any time since the age of 13 a foster child or a ward of the court is independent even if her status changed later.”

So, am I correct in reading that statement to say that a student who was the ward of the court at some point after the age of 13, but for whom subsequently had the custody of the state terminated and the parents again had “joint legal and physical custody to determine her best care,” etc., is to be considered independent no matter what?  For example, the student is again in the parents’ legal and physical custody before turning 18.  But, the student is still to be considered independent?  The parents could still claim them on their tax return, etc., but the student is independent?

A9:  You are correct.  ED’s most recent guidance to us has affirmed this to be the case.




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