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Since You Asked: Questions & Answers

Q1:  If our Program Participation Agreement (PPA) is set to expire, what happens if we have not received our new PPA from ED before the expiration date?

A1:  When a school submits a materially complete Recertification application on time, the school’s PPA and Eligibility and Certification Approval Report (ECAR) continues on a month-to-month basis until the review of the new application is completed.

Q2:   For a clock-hour GE program, is the school’s satisfactory academic progress (SAP) policy limited to 150% of the minimum number of clock hours required for training in the recognized occupation for which the program prepares the student?

A2:  No.  The 150% maximum time frame for SAP purposes is totally different than the requirement that a school’s academic program length not exceed by more than 50% the minimum number of clock hours required for training in the recognized occupation for which the program prepares the student, as established by the State in which the school is located, if the State has established such a requirement, or as established by any Federal agency.  And, to clarify, for a clock-hour program, a SAP maximum time frame of 150% of the program does not increase the length of the program.  It only determines the maximum amount of time in which the student has to complete the program hours in the program.  For example, a student in a 900 clock-hour program will not be able to exceed 900 hours in the program.  For SAP purposes, the maximum time frame for a clock-hour program must be stated in calendar time, e.g., weeks or months.

Q3:  At what point does ED consider that an institution has ceased offering a program?

A3:  ED considers a program to have been discontinued by an institution when the school no longer offers the program to any students (including continuing students) and when the institution has reported to ED via its E-App that it no longer wants the program to be Title IV-eligible.

Q4:  The scenario is one where the student has an outstanding balance at a prior institution for which she is trying to demonstrate she received academic credit (credit or clock hours).  Because she still has an outstanding balance, the school will not release an academic transcript.  We are wondering if the bill from the school’s accounting department that shows what she still owes for the courses she took would suffice.   The only thing we have read is that an academic transcript or grade report would suffice for documenting attainment of academic credit at a prior institution.  Are there any other forms of acceptable documentation to demonstrate academic credit was earned at a prior institution for unusual enrollment history (UEH) purposes?  Would a bill from the prior school indicating what she still owes suffice?

A4:  No, a bill from the prior school would not suffice because it is possible that she incurred the charges but never actually received credit.  An official letter from the school indicating the student earned credit would be sufficient.  Otherwise, not having one of the types of documentation mentioned (a transcript, record of academic credit, a grade report showing credit earned, or a letter from the school), there is no proof of having received academic credit.  Without proof, as the current school, you would have to assume she did not earn credit and follow ED’s guidance and obtain additional documentation for students that did not earn credit.  See Dear Colleague Letter GEN-13-09 for more information.

Q5:  What is ED’s current guidance in regard to performing clock-to-credit hour (C2CH) conversions as it relates to rounding during the calculations?

A5:  The most recent guidance we have received from ED in regard to rounding in C2CH calculations is that a school may use the actual calculated hours (for example, even if it was calculated to be 3.45 credit hours).  Few institutions would ever actually 3.45 credit hours on a transcript (as given in our hypothetical example).  Accordingly, that would effectively negate being able to use actual hours (and, actual hours may benefit the students and school).  As long as a school awards on the actual number of hours, they are fine.  However, a school would not want to ignore its accrediting agency rules regarding rounding or program length.  As was stated, C2CH conversion for the purpose of awarding Title IV funds is accomplished according to ED rules and conventions.  Yet, the length of a recognized program (outside of statutory minimums) is certainly an accreditor-determined factor.  If, for example, an accrediting agency-imposed rounding convention resulted in that accrediting agency recognizing fewer credit hours in the program length than what would result from an ED-prescribed C2CH conversion, the program length would be capped at the number of hours permitted by that accreditor.

Q6:   What is ED’s latest guidance regarding verification and applicants who have amended tax returns?

A6:  When an institution is aware that an amended tax return was filed, the institution will need to use information from the documents below to complete and satisfy the verification requirements:

  • an IRS Tax Return Transcript (that will only include information from the original tax return and does not have to be signed), or any other IRS tax transcript(s) that includes all of the income and tax information required to be verified; and
  • a signed copy of the IRS Form 1040X that was filed with the IRS.

(ED no longer requires the original signed copy of the tax return to be submitted in the cases where an amended tax return has been filed.)

Individuals who originally utilized the IRS DRT to complete their FAFSA may not rely on that tax information to complete and satisfy the verification requirements if an amended tax return was filed.  In such a case, the documentation listed earlier must also be obtained in order to complete and satisfy the verification requirements.  This guidance is effective as of August 13, 2015, for the 2015-2016 award year and beyond.

Q7:  Can we have a SAP policy just for veterans that allow us to only factor in the credit that counts towards their degree program on their transcripts, while for everyone else we will count all credit on their transcript?

A7:  No, there are no separate standards for subsets of students.  Although you can have different SAP policies for different categories/groups of students (i.e. by program, enrollment status, grade level, etc.) you must apply the same standards to all students within those categories.  You cannot have separate standards for subsets of students.  You, of course, may adjust your overall policy on how you handle transfer credits, but then that policy must be applied consistently to all students.

Q8:  A student has an old defaulted loan (from early 1990s) that is in “DW” status.  Can the student reaffirm the debt?  Years ago students could “reaffirm” the debt and make satisfactory repayment arrangements to eventually get back to Title IV eligibility.  I do not see that mentioned in the Federal Student Aid Handbook anymore.  Is that no longer an option?

A8:  Yes, it is possible to reaffirm the debt and pay back the outstanding balance to get in good standing.  The student or school may want to reach out to ED’s Borrower Services Office so they can help walk the borrower through the process.  Contact your regional ED School Participation Team for the contact for your region.

Q9:  A student, who is trying to apply for aid is having a default C code issue.  It is due to the student’s parent who defaulted on a PLUS Loan back decades ago and has a loan status code of “DW.”   Is there a reason why the DW would still show up on the student’s record as being a default status when it is not the student in default and causing us to intervene and make a determination on a PLUS from decades ago when the student certainly will not have any control over the parent’s financial matters these decades later?  Why does the student get flagged if it is a PLUS loan?

A9:  The student would still be eligible for Title IV aid.  The Parent PLUS default should not show up on the student’s ISIR unless the student took out a PLUS Loan themselves.  You will want to check with CPS to determine the financial aid history process and what should actually be placed on the ISIR.  It may be that there was an input error in NSLDS, in which case you would need to contact NSLDS.

Q10:  We have several questions in regard to students enrolled in crossover periods.

  • In a crossover period, is it correct that a student can be paid a Pell Grant from either award year as long as the payment period crosses July 1st and the student was enrolled in that payment period with a valid ISIR?
  • Also, if the school teaches a semester-based program in 4 week modules, is it true that it does not matter if the student drops or graduates before the payment period ends (e.g., module 3 ends on June 10 and module 4 in mid-July) for the student to be paid Pell grant out of either award year?
  • And, finally, consider this scenario:  the student starts a May semester (consisting of 4 modules of 4 weeks each) that ends in August and the student does not have a 2014-2015 or 2015-2016 ISIR submitted yet.  The student graduates from the certificate program after completing 8 weeks and 6 semester credits in June.  The student then re-enrolls in another program in January of 2016, and now has a valid 2015-2016 ISIR.  Can the student be paid for the enrollment in the May crossover semester from 2015-2016 Pell based on the enrollment status he had then?

A10:  The answer is yes to all of the scenarios listed.  But, remember, if you are paying retroactively for a completed term, the enrollment status is based on completed hours (which can include an earned F as well).


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