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Since You Asked: Questions & Answers

Q1:  A student submitted a 2014-2015 FAFSA and a 2015-2016 FAFSA at the same time and the ISIRs for both came back the same day.  The strange thing is that her 2014-2015 FAFSA came back with no C-Code issues but her 2015-2016 FAFSA has one.  On her 2014-2015 FAFSA the first page says “your citizenship status has been confirmed by DHS and you meet requirements for federal student aid.”  However her 2015-2016 FAFSA says that “USCIS of DHS did not confirm that you are an eligible noncitizen” and she must submit proof to her school.  I understand that this means we need to submit a G-845 with a copy of her Green Card, but my question to you is do we really have to?  Since her 2014-2015 FAFSA says that DHS confirmed her citizenship why would her 2015-2016 FAFSA not say the same, especially because they were submitted and processed at the same time?

A1:  The bottom line is that you are correct.  You will need to submit the G-845 for secondary confirmation.  As it currently stands, you are not able to pay based upon the 2014-2015 ISIR because you now have conflicting information since the second ISIR for 2015-2016 did not confirm her eligible status.  There are a couple of possible things that “may” have generated these results.  First, it is a possibility that the database match was down when the second one ran (this is not likely, or the DHS2 flag would likely have shown as a P).  Or, second, the student’s record in UCIS is showing her documentation (Visa, etc.) expires before 2015-2016.  So, the G-845 needs to be utilized.  But, you may also want to take a look at the expiration date on her documentation.

Q2:   If a school submits the G-845 and it comes back as an approved status (if done before the actual expiration date), is the student able to get aid for the entire award year based upon that approval?  Or, does the student lose eligibility immediately upon the expiration date of the document used to approve her status?

A2:  Based upon our most recent guidance from ED, if the school checks the student for the award year and the status is approved via the G-845 secondary confirmation process, you won’t need to check again after the date her documentation is currently due to expire.  (This, of course, assumes you do get a response back prior to document expiration.)  You do have to document the eligible noncitizen status each award year for a conditional permanent resident, in part because students in any of these categories may have been re-designated to permanent resident status or may have had their statuses revoked.  Therefore, the school will have to send the documents for secondary confirmation if the student’s status was not confirmed through the USCIS match.  Also, schools only need to check citizenship status once during the award year.  Per the 2015-2016 Federal Student Aid Handbook, page 1-21:  “A student’s citizenship status only needs to be checked once during the award year; if the status is eligible at that time, it remains so for the rest of the award year.”  If the school knows that a document will expire later in the year, it does not need to recheck the student’s citizenship status after that expiration date if she was confirmed to be in an eligible citizenship status earlier in the award year.

Q3:  Our school has a short full-time day program and uses 900 clock hours and 26 weeks to define our academic year (AY).  For purposes of the 150% limit on Subsidized Direct Loans, we will be reporting the academic year of 900 hours as it is the longer of clock hours or weeks of instruction.  We will use an average for the hours per week because the student takes different hours in different weeks throughout the program.  If we also have a weekend program that takes longer, would we use the same AY definition as the full-time day program, or would we calculate the end of the AY based on only the weekend hours per week?

A3:  Based on the Q&As, AYLP-Q2 and AYLP-Q7, from ED’s “150% Direct Subsidized Loan Limit Info”    Web site, the day program’s AY would be based on when the student in question is estimated to complete an AY (i.e., after 900 hours, as it is presumed that 26 weeks will be reached well before they would complete 900 clock hours).  The weekend program’s AY would be determined in conjunction with the number of hours per week the program meets.  Remember that the loan period should be the actual time it will take the student to complete the loan period and a loan period cannot be longer than the AY.  So in these type of programs (especially non-term programs), the AY and loan periods may change depending on how long it actually takes the student to complete the periods in question.

Q4:  We know that there is an expiration date on old ATB tests taken prior to November 1, 2002.   But, although the old ATB tests (taken prior to 11/1/2002) had 12-month expiration dates, does the fact that the student was enrolled in an eligible program and received Title IV aid allow the student to be considered for eligibility now under the grandfathering provisions (allowed in the Consolidated Appropriations Act of 2012)?  That is, if a student took an approved test back in 2000 and began enrollment in an eligible program and received aid, and actually completed that program, would such student still be eligible for Title IV aid if enrolling in another eligible program now?  Does the fact that the student took a test prior to 11/1/2002 preclude him from getting aid now?  Or, does the fact that he was in an eligible program and received aid trump that date, thereby extending his eligibility through the grandfathering provision?

A4:  Our most recent guidance from ED stipulates that if a student took and passed an old ATB test (prior to 11/1/2002) and started in a Title IV-eligible program and received Title IV aid, then the ATB test would be valid forever.  The issue with the 12-month expiration is if the student withdrew from school before receiving Federal Student Aid funds and then re-enrolled more than 12 months after taking the test, he or she would have to be re-tested.  However, to qualify for the grandfathering provision, the student must have attended a Title IV-eligible program prior to 7/1/2012.  (They do not have to have received Title IV aid to meet the grandfathering provision.)

Q5:  We have questions as to how to handle a student’s loan disbursements in the case of a withdrawal and return within 180 days.  The first question scenario is that the student started in a clock-hour program on August 22, 2014, and withdrew in December 2014.  The student received $1750 as the first disbursement of a Subsidized Direct Loan and $3000 as the first disbursement of an Unsubsidized Direct Loan.  The parents of the student received a PLUS loan denial.  The student returned to school in April 2015, which is within 180 days.  Do we reinstate the second loan disbursements from before, or do we first need to have the student’s parents submitted for another credit check?

The second question scenario is in a similar withdrawal situation, but in this case, a credit check was performed on the parents and now a parent is approved for a PLUS Loan.  Do we ignore the credit check and reinstate the second loan disbursements as scheduled before the withdrawal, or do we reinstate the second disbursement for the Subsidized DL, but now apply for a PLUS Loan to replace the second disbursement of the Unsubsidized DL?

A5:  In response to the first question scenario, you could simply reinstate the loan and the loan period since the student returned within 180 days and thus, it is as if the student never left.  You would need to extend out the academic year (AY) and loan period dates when reinstating the loan in COD.

In the second question scenario, it is important to keep in mind that once a PLUS Loan is approved, any additional Unsubsidized DL funds waiting to be disbursed (above the dependent student levels) must be cancelled.  Any prior additional Unsubsidized DL funds disbursed prior to the PLUS Loan approval can be retained, but those funds must be factored into the estimated financial assistance (EFA) when awarding the PLUS Loan amounts.

Q6:   In regard to Gainful Employment reporting, is institutional debt to be counted if a student did not complete the program but withdrew?  My understanding is, yes, it is to be reported for completers and those who withdrew.  But, the wording of the regulations generated a question.  Specifically, there seems to be disparity in wording between 668.411(2)(iii) and 668.404(d)(1)(iii).  It sounds like 668.404 is saying you only include institutional debt of “completers,” i.e., do not include the debt for those who withdrew.  But, 668.411 says to report for both completers and those who withdrew.  Why would there be this conflicting wording?   The NSLDS GE User’s Guide, page 169, states in the comments related to Field Code 020 (Institutional Debt):  “•  Required if Program Attendance Status During Award Year equals ‘G’ or ‘W’.”

A6:  As stated in the guidance we received from ED, the Department is collecting the amount of debt of all students in a program (hence 668.411).  However, the Debt-to-Earnings (D/E) rates are only calculated for completers (668.404).  So, the bottom line is that you are reporting debts on all students—graduates and withdrawals—but, it is the completers’ information that will determine the rates.

Q7:  Can we require all of our students to complete entrance counseling each year or before each loan disbursement?

A7:  While requiring students to complete entrance counseling each year (and/or before each loan disbursement) may have been viewed as a good tool to make the students aware of their borrowing rights and responsibilities, schools may not require students to complete entrance counseling again after they have initially completed the requirement prior to their first FFELP or Direct Loan disbursement.  This also applies in the case when a student has previously borrowed at another school and completed entrance counseling prior to the first disbursement of the loan there, but now the student is subsequently enrolling at your institution and will be a first time borrower at your school.  Your school may not require a student who has previously completed entrance counseling to complete it again, even if it was completed at another institution.  A school may provide additional counseling, or add content to the required elements stated by ED, and use various methods of conducting loan and financial counseling.  But, a school may not require a student to again complete loan entrance counseling.   If a student chooses to participate in extra loan counseling, it must be clear that it is voluntary, and such additional counseling may not be used to delay disbursement of Direct Loans in any way.  For more detailed discussion on this topic see DCL GEN-15-06, and the feature article, “Loan Counseling Conundrum,” earlier in this edition of the Inside Report.

Q8:  Does our school have to have a Title IX Coordinator when we only participate in Title IV Federal Student Aid funding?

A8:  Yes, all schools that participate in Title IV Federal Student Aid programs must have a Title IX Coordinator.  While this is a requirement of Title IX, your school agreed to comply with Title IX when it signed the Program Participation Agreement (PPA) for the Title IV programs.  The Office of Civil Rights of the US Department of Education sent out an e-mail on April 24, 2015, that contained information related to this requirement.  The press release that contains the same information as the e-mail they sent to schools may be viewed at

Q9:  A PLUS credit check comes back approved.  (It is a single parent, so there is no other parent to borrow.)  In the interim, the student tells us that the parent is in default on a student loan.  When we looked it up in NSLDS, it did indeed show that the parent is in default on a loan, and has been, since 1995.  The code in NSLDS is code “DU – Default, unresolved.”  So, the parent is not eligible for FSA funds.  It is a mystery as to why the credit report shows approved.  But, can we document the file with NSLDS screen printouts to show that the parent is in default?  And, if it is not able to be resolved, may we then process the student for the additional Unsubsidized Direct Loan?

A9:  Yes, that is correct.  The parent is not eligible to borrow until he or she resolves the default situation.  The student’s file must be documented appropriately before awarding additional Unsubsidized DL.

Q10:  We have a student’s ISIR with a UEH code of 3.  What is ED’s guidance regarding documentation of academic credits earned if one of the prior schools has closed?

A10:  Our latest guidance from ED indicates that you will still need to try to get documentation to support the assertion of earned academic credit at the prior institution.  If you cannot obtain any documentation from the school, alternatively you should get a signed statement from the family and something from the state or the former school stating that the records are gone.  If you truly can document that you cannot get any information authenticating that the records are unavailable, you should treat the student as if they did not earn academic credit and follow ED’s guidance for additional information in DCL GEN-13-09.

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