Policies and Procedures For Clock-Hour Programs Disclaimer This is general information only. Important This is no substitute for the Federal Student Aid Handbook, the related regulations or the statute. You must stay tuned in to IFAP for any future guidance. 2 1
What does this mean to me? Which academic programs will this affect at my school? Will I have to learn to administer Title IV aid under the clock hour regulations? Will I have to update my P & P manual? Will I have to update my ECAR? Will I be able to retire before July 1, 2011? 3 UPDATING THE ECAR 4 2
Applying for Participation Initial Application http://www.eligcert.ed.gov Click on Use the E-App to recertify or update information Go to Section A, Question 1 and list why you re submitting the E-App Go to Section E, Questions 26, 27 Section K question 69 is optional Go to Section L for appropriate signatures 5 Apply to Participate Applying for Participation Initial Application http://www.eligcert.ed.gov 6 Apply to Participate 3
Applying for Participation Initial Application Click on Use the E-App to recertify or update information 7 Apply to Participate Then you ll see the Index. Click on Section A, Question 1 8 4
Log in as instructed ED + 8-digit OPE ID ED + 9-digit EIN Go to Section E, Questions 26, 27 Section K question 69 is optional Go to Section L for appropriate signatures Submit E-app and mail signature page 10 Apply to Participate 5
Program Participation Agreement (PPA) and Eligibility and Certification Approval Report (ECAR) PPA = School s contract with ED ECAR = Programs, school approved for Title IV aid When application is approved President and financial aid administrator will receive an e-mail directing them to the PPA/ECAR page on http://www.eligcert.ed.gov School prints ECAR, reviews for accuracy and retains in their records 11 Apply to Participate Reporting Changes Report and Go All schools must report the following information within 10 calendar days of the change Change in measurement of program (e.g., from credit hours to clock hours) 12 Apply to Participate 6
WILL THE PROGRAM STILL BE ELIGIBLE FOR TITLE IV? 13 Institution of Higher Education Eligible Institution Types of Institutional Control Proprietary Institution of Higher Education Postsecondary Vocational Institution A public or private nonprofit educational institution located in a state A private, forprofit educational institution located in a state A public or private nonprofit educational institution located in a state 14 Apply to Participate 7
Eligible Programs Institution of Higher Education Associate, bachelor s, graduate or professional degree, or At least a 2-year program acceptable for full credit toward a bachelor s degree, or At least a 1-year training program that leads to a degree or certificate (or other educational credential) and prepares students for gainful employment in a recognized occupation 15 Apply to Participate Eligible Programs Proprietary Institution of Higher Education and Postsecondary Vocational Institution Programs must provide training that prepares student for gainful employment in a recognized occupation and contain a minimum of: 15 weeks instruction; 600 clock hours, 10 weeks of instruction; 300 clock hours, Graduate or professional program or admit only students with equivalent of an associate degree 10 weeks instruction; ti 300-599 clock hours, 70% completion rate and 70% placement rate in related job fields; in existence for one year (eligible for Direct Loans only) 16 8
What Hours Count? A clock hour is based on an actual hour of attendance Each hour may include a 10-minute break Outside work does not count in the number of clock hours 17 Title IV Eligibility May Be Impacted EXAMPLE Prior to July 1, 2011, school has a 48 semester credit hour program granting a certificate School offers the program over four 15 week terms during which the student attends and earns 12 semester credits for each 15 week term School defines its AY as 24 semester credits and 30 weeks of instruction 18 9
Title IV Eligibility May Be Impacted In our example, the program is exempt from the clock to credit conversion formula 1 credit hour = 1 hour of instruction in the class room and at least 2 hours of outside work per week Remember, clock hour programs do not count outside work For the entire program 12 hours of instruction ti per week x 15 weeks = 180 hours 4 (terms) x 180 hours = 720 clock hours of instruction 19 Title IV Eligibility May Be Impacted Program is 720 clock hours and 60 weeks of instruction AY is defined, for clock hours, as 900 clock hours and 26 weeks of instruction Since the program is < 900, the program is < AY Weeks are greater than 26 but both measures are looked at for this determination Program was a 2 AY program using credit hours and is now a < 1 AY program using clock hours 20 10
Eligible Programs Proprietary Institution of Higher Education and Postsecondary Vocational Institution Programs must provide training that prepares student for gainful employment in a recognized occupation and contain a minimum of: 15 weeks instruction; 600 clock hours, 10 weeks of instruction; 300 clock hours, Graduate or professional program or admit only students with equivalent of an associate degree 10 weeks instruction; ti 300-599 clock hours, 70% completion rate and 70% placement rate in related job fields; in existence for one year (eligible for Direct Loans only) 21 ACADEMIC YEAR DEFINED FOR TITLE IV (AY) 22 11
Academic Year Minimums Statutory Definition of an Academic Year Academic Progress Measured By: Minimum Completion Requirement* Minimum Instructional Time Requirement ** Semester hours Trimester hours Quarter hours Clock hours 24 semester hours 24 trimester hours 36 quarter hours 900 clock hours 30 weeks 30 weeks 30 weeks 26 weeks *Number of hours that a student enrolled full time is expected to complete in a full academic year. **A week is a seven day period in which there is at least one day of instruction or exams. Minimum measure! Can be more! Academic Year Must be defined for each eligible program May be the same for all programs May be different for some or all programs Must contain at least 900 clock hours and 26 weeks of instructional time A week of instructional time is any 7 consecutive days in which at least one day of instruction occurs. Day 1 of the 7 day period must be the first day of class Need not correspond to a calendar week 24 12
Academic Year Minimum full-time standard for undergraduate programs is 24 clock hours per week A student attending 24 hours per week will complete 900 hours in 37.5 weeks A student attending 30 hours per week will complete 900 hours in 30 weeks A student attending 35 hours per week will complete 900 hours in 26 weeks School defines full-time (at least minimum standard) Half-time is half full-time (minimum 12 hours) 25 Academic Year Programs may be longer than, shorter than, or equal to the definition iti of the AY The AY is period of time for which Title IV aid is calculated and disbursed Does not always correspond to a school s scheduled d academic calendar 26 13
Academic Year Your school s scheduled academic calendar is typically in your publications to let your students know when each enrollment period starts, stops, scheduled breaks, important dates, etc. This has nothing to do with your school s s definition of your Title IV Academic year. Two separate concepts 27 Academic Year Example Program is 1000 clock hours and 30 weeks 1. If we assume the academic year definition of 900 hours/26 weeks First AY is 900 hours and 26 weeks Second AY contains 100 hours and 4 weeks (AY definition is still 900 hours and 26 weeks) 2. If we assume the academic year definition is 1000 hours/30 weeks 28 Program is only one AY in length 14
Your School s Academic Year Is the Academic Year defined in your P&P manual? You ll need to revisit the definition so your credit hour programs and your clock hour programs have the required components. 29 Award Year The award year is July 1 of one year to June 30 of the following year Example: July 1, 2011 to June 30, 2012 Defines the timeframe in which students may receive the maximum amount of Pell funds for a given period Pell Grant amounts are established each award year by Congress Maximum amounts may change each award 30 15
Annual/Scheduled Pell Award The maximum amount a student would receive during a full academic year for a given enrollment status, EFC, and COA. 31 Annual/Scheduled Pell Award The annual award for a student in a clock- hour program is taken from the full-time payment schedule, even if the student is attending less than full-time. Therefore, the annual award will always equal the scheduled award In other words, there are no ¾ or ½ time students in a clock hour program. 32 16
Payment Periods 33 Payment Periods In a term based program, terms usually are the payment period for Title IV programs Always for Pell and CB Usually for DL Summer can be an exception Summer I and II being considered one payment period 34 17
Payment Periods Two important points: In a clock hour program, THERE ARE NO TERMS for Title IV In a clock hour program, THERE ARE NO TERMS for Title IV 35 Payment Periods There can be terms for other purposes Grading Charging Requires educating Title IV students on the difference 36 18
Payment Periods Why is this important? In the clock hour world, you disburse aid by payment period, and there are no terms The payment period depends on when the student begins and ends the payment period 37 Payment Periods The next payment period can t start until the previous one is completed Sometimes different students complete the payment period before others If the program allows this Work could be prescribed and not self-paced 38 19
Payment Periods But, if work is not prescribed, Students will have a different start date for their next payment period Payment periods are student-driven, not term driven 39 Payment Periods Payment period - is a period (measurement of time) used to determine award amounts and timing of disbursements during an academic year 2 areas impact payment periods Academic year definition Length of program (clock hours) Please note: Calendar time, award year or number of hours a student earns or is expected to earn in a period of time will NOT shorten payment periods 20
Payment Periods For clock-hour programs, the payment period is defined d not only in clock hours but also in weeks of instructional time Why? Because AY definition has these same two components 41 Payment Periods A student must successfully complete the clock hours AND weeks of instructional time in a payment period to progress to the next payment period 42 21
Payment Periods Program of one AY or less 43 The program is divided into two payment periods CANNOT have more than 2 PP in an academic year First payment period is the period of time in which a student successfully completes half the clock hours in the program AND half the weeks of instructional time in the program Second payment period is the period of time in which a student successfully completes the remainder of the program Examples: Payment Period 840 clock hour program with 28 weeks of instructional time (AY definition is 900/30) First payment period = 420 clock hrs & 14 wks Second payment period = 420 clock hrs & 14 wks 900 clock hour program with 26 weeks of instructional time (AY definition is 900/26) First payment period = 450 clock hrs & 13 wks Second payment period = 450 clock hrs & 13 wks 44 22
Payment Periods in a Program = to AY or Less AY = 900 clock hours and 30 weeks of instruction Program is 840 clock hours and 28 weeks PP 1 420 CH & 14 wks PP 2 420 CH & 14 wks 45 Payment Period Program greater than one AY For first AY, and any full AY after that First payment period is point at which a student completes half the clock hours and half the weeks of instructional time in the AY Second payment period is point at which a student completes the remainder of the AY 46 23
Payment Period Example (AY = 900 hrs/26 wks) Program 1800 hrs and 52 wks First AY First payment period is 450 hrs and 13 wks Second payment period is 450 hrs and 13 wks Second AY Third payment period is 450 hrs and 13 wks Fourth payment period is 450 hrs and 13 wks 47 Payment Periods in a Program > an AY AY 1 = 900 clock hours and 26 weeks AY 2 = 900 clock hours and 26 weeks Program is 1800 clock hours and 52 weeks PP 1 450 CH & 13 wks PP 2 450 CH & 13 wks PP 1 450 CH & 13 wks PP 2 450 CH & 13 wks Award Year 1 July 1 >> June 30 Award Year 1 July 1 >> June 30 Award Yr 48 Award Year 1 July 1 >> June 30 Award Year 2 24
Payment Period Program greater than one AY For the remainder of a program that is more than ½ of an AY Third payment period of the program is ½ of the clock hours and ½ of the weeks of instructional time in that remaining period Fourth payment period is the final half, i.e., the time necessary to complete the remainder of the program. 49 Payment Period Example (AY = 900 hrs/26 wks) Program is 1390 hrs and 40 weeks First AY First payment period is 450 hrs and 13 wks Second payment period is 450 hrs and 13 wks Second AY First payment period is 245 hrs and 7 wks Second payment period is 245 hrs and 7 wks 50 25
Payment Periods in a Program > an AY AY 1 = 900 clock hours and 26 weeks AY 2 = 900 clock hours and 26 weeks Program is 1390 clock hours and 40 weeks PP 1 450 CH & 13 wks PP 2 450 CH & 13 wks PP 1 245 CH & 7 wks PP 2 245 CH & 7 wks Award Year 1 July 1 >> June 30 51 Award Year 1 July 1 >> June 30 Award Year 1 July 1 >> June 30 Award Year 2 Award Year 2 Payment Period Program greater than one AY For the remainder of a program that is equal to or less than ½ of the AY The payment period is the remainder of the program 52 26
Payment Period Example (AY = 900 hrs/26 weeks) Program is 1200 hrs and 34 weeks First AY First payment period is 450 hrs and 13 wks Second payment period is 450 hrs and 13 wks Second AY Single payment period of 300 hrs and 8 wks 53 Payment Periods in a Program > an AY AY 1 = 900 clock hours and 26 weeks AY 2 = 900 clock hours and 26 weeks Program is 1200 clock hours and 34 weeks PP 1 450 CH & 13 wks PP 2 450 CH & 13 wks PP 1 300CH & 8 wks Award Year 1 July 1 >> June 30 Award Year 1 July 1 >> June 30 Award Year 2 Award Year 1 July 1 >> June 30 54 Award Year 2 27
Payment Period Question: What if the student completes 1000 hours in the two payment periods in the first AY when there was only 900 in the AY definition? 55 Payment Periods in a Program > an AY AY 1 = 900 clock hours and 26 weeks AY 2 = 900 clock hours and 26 weeks Program is 1200 clock hours and 34 weeks PP 1 450 CH & 13 wks PP 2 450 CH & 13 wks PP 1 300 CH & 8 wks << Pell and CB Student completes 1000 hours 200 CH & # weeks Pell and CB payment periods remain the same as originally created << Direct Loan DL loan period would only contain what remains in the program (200 clock hour & corresponding weeks) and there would be two disbursements unless exempt 56 28
and Terms How does this work with your term structures? t 57 Rule 1 Ignore the fact that you have terms!! Rule 2 Terms do not apply!! Rule 3 Regardless of terms, track progression to the next payment period using clock hours and weeks of instruction, not terms! TERM Confused yet? Don t panic! Payment Period This becomes easier once you understand: The AY definition for your clock hour programs (in weeks and clock hours). Your clock hour program s length (in weeks and clock hours). 58 29
Satisfactory Academic Progress For Clock Hour Programs 59 Satisfactory Academic Progress Successfully Completes A student successfully completes clockhours if your school considers the student to have passed the coursework associated with those hours 60 30
Satisfactory Academic Progress New regulations published Oct 29, 2010 and effective July 1, 2011 Crossover may be considered as part of 10-11 award year and not subject to new regs Satisfactory Academic Progress New SAP regulations consolidated into 34 CFR 668.34 Administrative capability 668.16 now only refers to policy Student eligibility in 668.32 still includes as eligibility requirement Satisfactory progress in 668.34 now contains all elements of SAP 31
SAP policy required elements include SAP Policy Measurement of student s t progress at each evaluation GPA that a student must achieve at each evaluation (qualitative standard) Pace of progression to ensure completion within the maximum time frame (quantitative standard) More guidance is coming on pace of progression for clock hour programs SAP Policy SAP policy required elements include How GPA and pace of completion affected by - Incompletes - Withdrawals - Repetitions - Transfers of credit from other schools At a minimum m you must count transfer hours accepted toward completion of student s program as both hours attempted and hours completed 32
Maximum Time Frame For undergraduate programs of study, must be no longer than 150% of published length of educational program For clock hour programs, as measured in cumulative clock hours required to complete and expressed in calendar time For graduate programs of study, institution defines the maximum period based upon length of educational program Maximum Time Frame Example If the program is 1200 clock hours and meets 30 clock hours per week, that means the program is 40 weeks in length. 150% of 40 weeks is 60 weeks. A student may receive aid while enrolled in this program, for up to the point you determine the student cannot complete the program within 150%. 66 33
How Often Is SAP Evaluated? For programs of study that are one academic year or less in length, school must evaluate SAP at end of each payment period For programs of study longer than one academic year School must evaluate at least annually to correspond with end of a payment period School may evaluate at end of each payment period When is SAP Evaluated? For clock hour programs, the SAP evaluation must be done at the end of a payment period. -See guidance from June 6, 2011 Electronic Announcement - The evaluation can be at the end of every payment period or once a year, but it must be assessed at the end of the payment period. 34
See Electronic Announcement from June 6, 2011 An institution may review a student s academic progress in a program at the end of each payment period to determine if a student is eligible by selecting one of the following options for all students in a program: At the point when the student s scheduled clock hours for the payment period have elapsed, regardless of whether the student attended them; or At the point when the student has attended the scheduled clock hours; or At the point when the student successfully completes the scheduled clock hours for that payment period. 69 Calculating Pell Grant Awards For Clock-Hour Programs 35
Pell Grant Formulas Did you know there are FIVE different Pell Grant Formulas according to 34 CFR 690.63? Which one do you use? Once a formula is chosen, you must calculate l Pell Grants for every student t in that program for the entire Award Year using that formula. Pell Grant Formulas Formula 1-Credit Hour program with terms At least 30 weeks of instructional time Formula 2-Credit Hour program with terms Less than 30 weeks of instructional time Formula 3-Credit Hour program with terms Nonstandard or standard terms Formula 4-Clock Hour program Formula 5-Correspondence Study 36
Formula 4 Calculation Example Student: John Van Winkle School: Your school Title IV Academic Year definition: 900 and 26 weeks Full-time enrollment is 35 clock hours/week Enrolled in 1400 clock hour program scheduled to take 40 weeks to complete Formula 4 Calculation Example COA: $20,000 EFC: $1,519 John is enrolled 35 hours per week John enrolls in October and expects to finish i in August. 37
Five Calculation Steps 1. Determine enrollment status t 2. Calculate Pell COA 3. Determine annual award 4. Determine payment periods 5. Calculate payment for each payment period Step 1: Determine Enrollment Status Clock hour programs Full-time is at least 24 clock hours per week Half-time is 12 clock hours per week Is John full-time? 38
Step 2: Calculate Pell COA You must understand there could be a difference between the COA and the Pell COA. COA=$20,000 Pell COA=??? Step 2: Calculate Pell COA How do you understand this? By prorating the COA if required. -If program is shorter than the defined academic year, prorate COA up to reflect one academic year s costs. 5 months 9 months 39
Step 2: Calculate Pell COA How do you understand this? By prorating the COA if required. -If program is longer than the defined academic year, and the budget reflects the entire cost of the program, prorate COA down to reflect one academic year s costs. 24 months 9 months Step 2: Calculate Pell COA How do you understand this? By prorating the COA if required. -If program length is the same as defined academic year, proration yields a 1:1 ratio and effectively no COA proration required. 9 months 9 months 40
Step 2: Calculate Pell COA If COA proration is required, keep these two things in focus: -Your school s defined Title IV AY definition in clock hours and weeks (example-900 clock hours/26 weeks) -The program s length in clock hours and weeks (example-1400 clock hours/40 weeks) Process Pell, Non-Term Step 2: Prorating John s COA You multiply the COA by the lesser of two fractions: Hours in the program s defined AY Hours to which the costs apply Or Weeks in defined AY Weeks in the enrollment period 41
Step 2: Prorating John s COA You multiply the COA by the lesser of two fractions: Hours in the program s defined AY (900) Hours to which the costs apply (1400) Or Weeks in defined AY (26) Weeks in the enrollment period (40) Step 2: Prorating John s COA Take the lesser of the two fractions: 900 26 OR 1400 40 $20,000 x 26 / 40 = $13,000 $20,000 x 900 / 1400 = $12,857 Which is less? 42
Step 2: Prorating John s COA All that being said, COA is almost ALWAYS the bottom line of the Pell Payment Schedule Step 3: Determine Annual Award Pell COA= $12,857 EFC = $1,519 Annual Award $4,000 43
Step 3: Determine Annual Award Which Pell Payment Schedule do I use? Annual/Scheduled Pell Award The maximum amount a student would receive during a full academic year for a given enrollment status, EFC, and COA. The annual award for a student in a clockhour program is taken from the full-time payment schedule, even if the student is attending less than full-time. Therefore, the annual award will always equal the scheduled award 88 44
John s Program Program of study is: 1400 clock hours 40 weeks of instruction AY definition is: 900 clock hours 26 weeks of instruction ti Step 4: Determine Payment Periods John 450 hrs/13 wks 450 hrs/13 wks 250 hrs/7 wks 250 hrs/7 wks 45
Step 5: Payment Per Payment Period Scheduled Award multiplied by the lesser of: clock hours in the payment period clock hours in program s academic year OR weeks of instructional time in the payment period weeks of instructional time in program s academic year Step 5: Payment Per Payment Period Scheduled Award multiplied by the lesser of: clock hours in the payment period (450) clock hours in program s academic year (900) OR weeks of instructional time in the payment period (13) weeks of instructional time in program s academic year (26) 46
Step 5: Payment Per Payment Period John s First Academic Year $4,000 X 450 or 13 = $2,000 900 26 -In this case both fractions equate to the same result -It may not always work out like this -Always compare and take the lesser amount What about John s Second Academic Year? John has 500 clock hours remaining, beginning i in May and ending in August Can John receive more Pell $ in his second academic year? 47
It depends.. Pell for Second AY Are there still Pell $ available for the award year? Is it a crossover payment period? Is the student still Pell eligible in the new award year? Step 5: Payment Per Payment Period for Second Academic Year Scheduled Award multiplied by the lesser of: clock hours in the payment period (250) clock hours in program s academic year (900) OR weeks of instructional time in the payment period (7) weeks of instructional time in program s academic year (26) 48
Step 5: Payment Per Payment Period for Second Academic Year $4,000 X 250= $1,111.11 900 -or- $4,000 X 7 = $1,079.92 92 26 Which is less? Step 5: Determine Pell Disbursements per payment periods John PP # 1 is 450 hrs/13 wks = $2,000 Pell PP # 2 is 450 hrs/13 wks = $2,000 Pell PP # 3 is 250 hrs/7 wks = $1,080 Pell PP # 4 is 250 hrs/7 wks = $1,079 Pell 49
Where can I get more information? FSA Handbook Volume 3, Chapter 3 Discusses all Pell formulas with examples Regulations at 34 CFR 690.63 Go to IFAP, Laws and Regulations, Code of Federal Regulations Calculating Campus Based Awards For Clock-Hour Programs 50
What about Campus Based Aid? Pell, Perkins Loans, FSEOG in clock-hour or nonterm programs For a clock-hour program, a school may disburse a Pell, Perkins Loans or FSEOG only after it determines that the student has successfully completed the credits or clock hours and weeks of instructional time in the prior payment period. What about Campus Based Aid? Pell, Perkins Loans, FSEOG in clock-hour or nonterm programs FSEOG and Perkins Divide the total award by the number of payment periods the student will attend in the AY You still can pay in unequal amounts for unequal costs if desired See FSA Handbook Volume 3, Chapter 7 51
What about Campus Based Aid? Federal Work Study Not disbursed on a payment period basis FWS wages are disbursed as work is performed, usually on a weekly or bi-weekly schedule Calculating DL For Clock-Hour Programs 52
What about DL? Standard term programs establish either a scheduled d academic year or a borrower based academic year (BBAY) for DL purposes Clock hour programs must use a BBAY for DL purposes What about DL? A loan period is typically going to be based on the BBAY A BBAY = the defined AY for Title IV purposes BBAYs do not have headers or trailers like a scheduled d academic year does 53
What about DL? Sometimes there are shorter loan periods If program is less than an AY, the loan period is the length of the program If a program is greater than one AY but less than two AYs then it will have a portion at the end. This is often referred to as the period that t remains Remember our example Payment Periods in a Program > an AY AY 1 = 900 clock hours and 26 weeks AY 2 = 900 clock hours and 26 weeks Program is 1200 clock hours and 34 weeks PP 1 450 CH & 13 wks PP 2 450 CH & 13 wks PP 1 300CH & 8 wks << Pell and CB Student completes 1000 hours 200 CH & # weeks Pell and CB payment periods remain the same as originally created << Direct Loan DL loan period would only contain what remains in the program (200 clock hour & corresponding weeks) and there would be two disbursements unless exempt 108 54
John s Loan & Payment Periods John s program has 1400 hours and 40 weeks with an AY of 900 clock hours and 26 weeks Loan Period 1 450 hrs/13 wks 450 hrs/13 wks 250 hrs/7 wks 250 hrs/7 wks Loan Period 2 Proration Required But if John had only 400 CH left, the loan period would be 400 & the remaining # weeks Supervisor of Training Officers Requests Feedback from FAAs How does this type of training work for you? Jo Ann Borel Supervisor of Training Officers United States Department of Education- Federal Student Aid Phone: 202-377-3930 joann.borel@ed.gov 110 55
Kevin Campbell Training Officer United States Department of Education Federal Student Aid Phone: 214-661-9488 Email: kevin.campbell@ed.gov Thank You! 111 56