AUTHORIZED EVENTS 2017-18 STUDENT ELIGIBILITY Slide Handout CREDENTIALED TRAINING
2010 2017 by National Association of Student Financial Aid Administrators (NASFAA). All rights reserved. NASFAA has prepared this document for use only by personnel, licensees, and members. The information contained herein is protected by copyright. No part of this document may be reproduced, translated, or transmitted in any form or by any means, electronically or mechanically, without prior written permission from NASFAA. NASFAA SHALL NOT BE LIABLE FOR TECHNICAL OR EDITORIAL ERRORS OR OMISSIONS CONTAINED HEREIN; NOR FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES RESULTING FROM THE FURNISHING, PERFORMANCE, OR USE OF THIS MATERIAL. This publication contains material related to the federal student aid programs under Title IV of the Higher Education Act and/or Title VII or Title VIII of the Public Health Service Act. While we believe that the information contained herein is accurate and factual, this publication has not been reviewed or approved by the U.S. Department of Education, the Department of Health and Human Services, or the Department of the Interior. The Free Application for Federal Student Aid (FAFSA ) is a registered trademark of the U.S. Department of Education. NASFAA reserves the right to revise this document and/or change product features or specifications without advance notice. April 2017
National Association of Student Financial Aid Administrators A NASFAA Authorized Event 2017 18 Slide 1 2017 NASFAA Lesson 1: Introduction to Slide 2 2017 NASFAA How Does a Student Become Eligible? Meet general and program-specific criteria: Before aid is awarded or disbursed Schools cannot impose additional eligibility requirements Slide 3 2017 NASFAA 2017 NASFAA 1
General Eligibility Criteria Slide 4 2017 NASFAA Other Factors Affecting Eligibility Educational coursework and programs Prior degrees Enrollment status Remedial coursework Correspondence study Distance education Slide 5 2017 NASFAA Slide 6 2017 NASFAA 2017 NASFAA 2
Quick Quiz 1: 1. What are the three broad categories of student eligibility requirements? 2. Provide an example of how a prior degree may affect a student s eligibility for Title IV aid. 3. A student who does not have her high school diploma or its equivalent, has not completed a state approved home school program, or has not demonstrated the ability to benefit from the training or education offered by the institution, can be admitted as a regular student. True False Page 4 Slide 7 2017 NASFAA 1. Do you believe any of the general student eligibility criteria are fair or unfair? Why? Page 5 Slide 8 2017 NASFAA Lesson 2: Criteria Checked Via the Application Process Slide 9 2017 NASFAA 2017 NASFAA 3
Application Process Source: studentaid.ed.gov/sa/resources Slide 10 2017 NASFAA Federal Agencies and Systems Slide 11 2017 NASFAA Database Matches SSA DoJ DHS VA SSS DoD NSLDS Slide 12 2017 NASFAA 2017 NASFAA 4
Reject Codes and C-Codes Reject Code FAA Information section EFC not calculated Instructions for resolution C-Code Record is flagged with C Ineligible until resolved Collect documentation and submit any corrections EFC calculated, but cannot be used Slide 13 2017 NASFAA Citizenship Status FAFSA SSA citizenship match Confirmed C-Code View original documents May accept images, if ensure true and exact copies Maintain copies Document eligible status (allow at least 30 days) Eligible noncitizen Slide 14 2017 NASFAA Citizenship Status Applies as eligible noncitizen Alien Registration Number required DHS primary match DHS secondary match Paper third-step confirmation Slide 15 2017 NASFAA 2017 NASFAA 5
Citizenship Status Status documented within 30 days School may accept images Paper third-step confirmation for eligible noncitizens Submit Form G-485 within 10 business days Verification of valid documentation only If no response within 15 business days, school makes determination Required in subsequent years only if document expires or status is conditional Slide 16 2017 NASFAA Citizenship Status Eligible noncitizen Paper third-step confirmation is not used for: Victims of human trafficking and qualifying relatives Battered immigrants and designated children Native Americans lawfully admitted under Jay Treaty of 1794 School is not liable if correct procedures are followed Slide 17 2017 NASFAA Slide 18 2017 NASFAA 2017 NASFAA 6
Quick Quiz 1: 1. What is the name of the system ED uses to process FAFSA data? 2. What two items may appear on a student s ISIR and SAR if there is a problem with her application? 3. With what federal agency does ED perform a database match to confirm a student s claim to be a U.S. citizen? 4. In what situation does DHS perform a secondary match? Page 15 Slide 19 2017 NASFAA Quick Quiz 1: 5. How much time must a school give a student who claims to be a U.S. citizen, but who fails the database match, to document his or her status? At least 7 business days At least 15 business days At least 15 calendar days At least 30 calendar days Page 16 Slide 20 2017 NASFAA Quick Quiz 1: 6. A school must submit a copy of the student s documentation of his or her status as an eligible noncitizen along with a copy of a completed G-845, Verification Request to the USCIS within how many days of receiving the student s documentation? 7 business days 10 business days 15 business days 30 business days 7. Once a student s status has been confirmed, the school must confirm it again in subsequent award years under what conditions? Page 16 Slide 21 2017 NASFAA 2017 NASFAA 7
Quick Quiz 1: 8. How often must the eligibility of a victim of human trafficking be confirmed? 9. U.S. noncitizens who are eligible for Title IV aid include which of the following? Citizens of the Federated States of Micronesia, Marshall Islands, and Palau Persons born in Puerto Rico Persons born in Guam, the U.S. Virgin Islands, and Northern Mariana Islands Foreign exchange students Page 16 Slide 22 2017 NASFAA Social Security Number CPS conducts three types of database matches: Student SSN Parent SSN Date of Death Slide 23 2017 NASFAA Social Security Number Match FAFSA Name, SSN, and DOB match Confirmed C-Code View documentation of correct SSN Award and disburse Title IV aid Maintain copies Document eligible status (allow at least 30 days) Correct SSN with SSA, or file new FAFSA Slide 24 2017 NASFAA 2017 NASFAA 8
Selective Service Registration Mandatory for males between 18-26 years of age Certain exemptions allowed No database match No Title IV aid until resolved Documentation of eligible status is required School determines whether knowingly and willfully failed to register Slide 25 2017 NASFAA Defaults, Overpayments and Fraud No aid awarded or disbursed until resolved NSLDS: Pre- and postscreening Transfer Student Monitoring Parent PLUS borrowers Slide 26 2017 NASFAA Resolving Defaults, Overpayments and Exceeded Loan Limits Satisfactory repayment arrangement (six on-time consecutive payments) Rehabilitate the defaulted loan (nine payments within 10 months) Compromise agreement with loan holder to settle the debt Direct Consolidation Loan after three on-time consecutive payments Direct Consolidation Loan under an income-driven plan Discharged through bankruptcy (or dischargeable in active bankruptcy) Overpayment repaid or arrangements for repayment made Documented resolution of issues identified in NSLDS Slide 27 2017 NASFAA 2017 NASFAA 9
Unusual Enrollment History NSLDS reveals unusual enrollment patterns Recipients of Pell Grants and certain Direct Loans within previous four years Flag Indication Action Needed Resolution N No UEH None None needed 2 Possible (code enrollment 359) pattern problem 3 (code 360) Questionable enrollment pattern Review enrollment and financial aid records for past four years If received Pell Grant or Direct Loan funds at current school at least once in the four years, no further action required* Review NSLDS If academic credit earned at each prior and transcripts for school while receiving Pell Grant or past four years Direct Loans, no further action required* *Any current concerns must be resolved. Slide 28 2017 NASFAA Unusual Enrollment History Resolution Undergraduate and graduate enrollment reviewed independently School may need to review enrollment, financial aid, and academic records If no academic credit earned, student must explain Student must have opportunity to appeal School s decision is final Slide 29 2017 NASFAA Drug Convictions Department of Justice Hold File Self-reported via FAFSA Question 23 Worksheet helps student determine status Loss of eligibility may be regained Slide 30 2017 NASFAA 2017 NASFAA 10
Department of Defense Increased eligibility for certain students: Death of parent or guardian; Result of military service in Iraq or Afghanistan after September 11, 2001; and Student was under 24 or enrolled in college Qualify for maximum Pell or equivalent IASG award Apply sequestration reduction to IASG Slide 31 2017 NASFAA Statement of Educational Purpose Comply by signing the FAFSA Not necessary to document unless selected for verification for this purpose Slide 32 2017 NASFAA Slide 33 2017 NASFAA 2017 NASFAA 11
Learning Activity: Determining Whether a Student Knowingly and Willfully Did not Register with Selective Service Page 31 Slide 34 2017 NASFAA Learning Activity: Selective Service You have an appointment with a student who failed the database match with the Selective Service System because he did not register when he was eligible to do so. He wants to discuss what he needs to do to be eligible to receive Title IV aid. In reviewing his file before his appointment, it is unclear if he qualifies for an exemption. Page 31 Slide 35 2017 NASFAA Learning Activity: Selective Service 1. Should you ask the student to request a Status Information Letter from Selective Service? Why or why not? 2. What additional documentation could you request from the student? Page 31 Slide 36 2017 NASFAA 2017 NASFAA 12
Learning Activity: Selective Service 3. What factors could you consider when you review the student s documentation? Page 31 Slide 37 2017 NASFAA Learning Activity: Selective Service 4. If you determine that the student is not eligible for Title IV aid because he knowingly and willfully failed to register with Selective Service, what options does he have to pay his school-related expenses? Page 31 Slide 38 2017 NASFAA Why are database matches an effective way to check various student eligibility criteria? Why is it appropriate for a financial aid administrator to make the final determination of a student s eligibility for a criterion such as registration with Selective Service? What do you think is the rationale for the Iraq and Afghanistan Service Grant Program? Page 32 Slide 39 2017 NASFAA 2017 NASFAA 13
Lesson 3: Criteria Checked and Monitored by the School Slide 40 2017 NASFAA Academic Credentials Regular student with one of the following: High school diploma or recognized equivalent Home schooling at secondary level Ability to benefit Available if first enrolled prior to July 1, 2012 Different rules if first enrolled on or after July 1, 2014 and enrolled in an eligible career pathway program Slide 41 2017 NASFAA Ability-to-Benefit Alternatives Slide 42 2017 NASFAA 2017 NASFAA 14
Satisfactory Academic Progress Policy requirements Qualitative and quantitative standards Frequency of evaluation Appeals Financial aid warning Financial aid probation Academic plans Slide 43 2017 NASFAA Satisfactory Academic Progress Qualitative Standard Grade point average (GPA) or comparable qualitative measure Equivalent of a C or better Quantitative (Pace) Standard Cumulative Hours Completed Cumulative Hours Attempted Slide 44 2017 NASFAA Satisfactory Academic Progress General for All Students Same as or stricter than Evaluation Components Quantitative Qualitative Maximum timeframe Frequency of evaluation Appeals Assessment Slide 45 2017 NASFAA 2017 NASFAA 15
Financial Need Federal Pell Grant, IASG, campus-based, and Direct Subsidized Loan (i.e., need-based) programs TEACH Grant, Direct Unsubsidized Loan, and Direct PLUS programs Slide 46 2017 NASFAA Program Eligibility Requirements Slide 47 2017 NASFAA Slide 48 2017 NASFAA 2017 NASFAA 16
Learning Activity: Satisfactory Academic Progress Page 53 Slide 49 2017 NASFAA Learning Activity: Satisfactory Academic Progress For the case study of Joel on page 53, use the sample policy for calculating pace described at the top of page 60 to answer the questions regarding Joel s academic progress. Be sure to take into consideration the loan fees for both types of loans. Page 53 Slide 50 2017 NASFAA Learning Activity: Satisfactory Academic Progress 1. Joel has completed 55 credits, but he has attempted 85 credits. What is his calculated pace? 2. Based upon the institution s SAP policy, is Joel making SAP? Why or why not? Page 53 Slide 51 2017 NASFAA 2017 NASFAA 17
Learning Activity: Satisfactory Academic Progress 3. If SSU adopted the staggered approach to pace instead, would Joel be making SAP? Why or why not? Page 53 Slide 52 2017 NASFAA Learning Activity: Satisfactory Academic Progress 4. If Joel is not maintaining satisfactory academic progress, what could he do? 5. What would Joel s status be if you approve an appeal? Page 53 Slide 53 2017 NASFAA Criteria Not Specifically Checked Simultaneous enrollment Judgment lien Incarceration Fraud Slide 54 2017 NASFAA 2017 NASFAA 18
Slide 55 2017 NASFAA Quick Quiz 2: 1. Criteria not specifically checked during the processing of the FAFSA, which must be resolved if conflicting information exists, include which of the following? The student's citizenship status, fraud, and a judgment lien on property for a debt owed to the U.S. Incarceration, fraud, and simultaneous enrollment in an elementary or secondary school Fraud, Social Security Number of a parent, and incarceration Bankruptcy, judgment lien on property for debts owed to the U.S., and simultaneous enrollment in elementary or secondary school Page 56 Slide 56 2017 NASFAA Quick Quiz 2: 2. Define conflicting information. 3. What types of Title IV aid are incarcerated students eligible to receive? 4. When a student attempts to secure funding under false pretenses, it is considered. A judgment lien Fraud Unusual Enrollment History Professional judgment Page 56 Slide 57 2017 NASFAA 2017 NASFAA 19
Quick Quiz 2: 5. If a school suspects a student may have engaged in criminal misconduct in the Title IV application process, the school must refer the information to whom? Page 56 Slide 58 2017 NASFAA Learning Activity: Interview Page 57 Slide 59 2017 NASFAA Learning Activity: Interview 1. Does your office have a procedure to follow if a financial aid administrator suspects a student may be committing Title IV aid fraud? If so, what is it? 2. How does your financial aid office work with other offices on campus, such as the Office of Admissions, the Office of the Registrar, or the Bursar s Office, to resolve conflicting information? Page 57 Slide 60 2017 NASFAA 2017 NASFAA 20
Have you ever caught a student or suspected one of committing fraud? If so, how did you handle the situation? Did you involve other campus offices or your school s legal counsel? Is there anything you would have done differently? Page 58 Slide 61 2017 NASFAA Lesson 4: Educational Coursework and Programs Affecting Slide 62 2017 NASFAA Educational Coursework Correspondence Distance Education Remedial ESL Programs Eligible only if part of eligible degree program No limitation; any type of credential Eligible only for courses within the eligible program One year limitation If solely ESL, only eligible for Pell or IASG Remedial, if within a program Slide 63 2017 NASFAA 2017 NASFAA 21
Slide 64 2017 NASFAA Quick Quiz 1: 1. How is correspondence coursework defined? 2. How is distance education coursework different from correspondence coursework? 3. What are the accepted modes of delivery for distance education coursework? 4. For how long may a student receive Title IV aid to pay for remedial coursework? 5. What Title IV aid is a student enrolled in a program consisting solely of ESL coursework eligible to receive? Page 76 Slide 65 2017 NASFAA Programs Affecting Direct assessment programs Comprehensive transition and postsecondary programs Short-term programs Eligible career pathway programs Slide 66 2017 NASFAA 2017 NASFAA 22
Slide 67 2017 NASFAA Quick Quiz 2: 1. Define direct assessment program. 2. What is the definition of a student with an intellectual disability for the purpose of enrolling in a comprehensive transition and postsecondary program? 3. What types of Title IV aid may a student enrolled in a comprehensive transition and postsecondary program receive? 4. Define short-term program. 5. What types of Title IV aid may a student enrolled in a short-term program receive? Page 80 Slide 68 2017 NASFAA Learning Activity: Interview Page 81 Slide 69 2017 NASFAA 2017 NASFAA 23
Learning Activity: Interview 1. Does the institution offer any correspondence or distance education courses? If yes, how many students enroll in such classes each academic year? 2. Does the school offer remedial courses? If yes, what is the average number of remedial credits taken by the typical student? 3. Does the school offer or plan to offer a direct assessment program? Why or why not? Page 81 Slide 70 2017 NASFAA Clock/Credit-Hour Conversion Purpose Exempt programs Definition of clockhour programs Impact on: Program eligibility Student eligibility Slide 71 2017 NASFAA Learning Activity: Clock/Credit-Hour Conversion Page 84 Slide 72 2017 NASFAA 2017 NASFAA 24
Learning Activity: Clock/Credit-Hour Conversion For the case study described on page 84, use the worksheet provided to perform a clock-credit-hour conversion. Program: Legal Eagles Institute has a one-year, credit-hour certificate court reporting program, which it offers in semesters. Students enrolled in the program complete 24 semester hours over 33 weeks. Because the program does not lead to an associate degree or higher, and is not fully transferable, the clock/credit-hour conversion requirement applies. Legal Eagles Institute has determined the total number of clock hours of instruction is 600. Page 84 Slide 73 2017 NASFAA Learning Activity: Clock/Credit-Hour Conversion Page 84 Slide 74 2017 NASFAA Changes in Student s Eligibility Status Gaining eligibility SAP Resolution of issues with SSN, citizenship and Selective Service registration Resolution of any other issues Losing eligibility Slide 75 2017 NASFAA 2017 NASFAA 25
Learning Activity: Changes in Student Status and Eligibility for Title IV Aid Page 86 Slide 76 2017 NASFAA Learning Activity: Changes in Student Status and Eligibility for Title IV Aid For the scenarios described on page 86, determine whether or not the student appears to be eligible to receive Title IV aid. If so, what Title IV aid may he or she receive, and for what time period? Page 86 Slide 77 2017 NASFAA Learning Activity: Changes in Student Status and Eligibility for Title IV Aid 1. Yasmine begins attendance in Fall 2017 for the 2017 18 award year. She transposes the last two digits of her Social Security Number on her FAFSA, and it takes her until the middle of February 2018 to correct the problem. Her financial aid counselor tells her that, once she resolves the issue, she would be eligible for both a Federal Pell Grant and a Direct Subsidized Loan. Eligible? Types Page 86 Slide 78 2017 NASFAA 2017 NASFAA 26
Learning Activity: Changes in Student Status and Eligibility for Title IV Aid 2. Ivan is a sophomore. For the 2017 18 award year, he is awarded a Federal Perkins Loan, a Direct Subsidized Loan, and FWS. He receives his Federal Perkins Loan and FWS funds during the fall term. He completes the MPN for his Direct Loan on January 10. SAP is evaluated at the end of every payment period. After evaluating Ivan s progress on January 5, his school determines that Ivan is not maintaining SAP. Eligible? Types Page 86 Slide 79 2017 NASFAA Learning Activity: Changes in Student Status and Eligibility for Title IV Aid 3. Tatiana is a third-year student for the 2017 18 award year who previously attended a community college. She waited three years, during which time she did not make any loan payments. When her ISIR arrives, it indicates she is in default on that loan. Tatiana resolves the default on February 1, two weeks after the term starts. Tatiana is awarded a Federal Pell Grant, FSEOG, and a Direct Subsidized Loan. Eligible? Types Page 86 Slide 80 2017 NASFAA What are the benefits of allowing students to receive Title IV aid while taking coursework in different formats, such as correspondence coursework and direct assessment programs? Why do you think certain student eligibility criteria are waived for students enrolled in a comprehensive transition and postsecondary program? What could be the rationale for allowing students who lose eligibility during the award year due to a change in eligibility status to receive Title IV aid for the remainder of the year? Page 87 Slide 81 2017 NASFAA 2017 NASFAA 27
Question and Answer Segment Slide 82 2017 NASFAA Thank you for attending! Slide 83 2017 NASFAA Slide 84 2017 NASFAA Slide 84 2016 NASFAA 2017 NASFAA 28
NOTES:
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