Two Pells in One Award Year
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Transcript of Two Pells in One Award Year
Two Pells
in One Award Year
Fred Sellers Office of
Postsecondary Education
April 9, 2010
Agenda
• Legislation and negotiated rulemaking• Basics on crossover payment periods• 2009-2010 award year• 2010-2011 and subsequent award years• Summer 2010• Additional provisions starting in 2010-2011
2
Legislationand
Negotiated Rulemaking
3
Budget: Scheduled Award
• FY 2009 (2009-2010)– Maximum Scheduled Award: $5,350
• FY 2010 (2010-2011)– Maximum Scheduled Award: $5,550– SAFRA: change in minimum award
calculation
4
Legislation
5
• Higher Education Opportunity Act of 2008 Pub. L. 110-315 (effective 2009-2010)
• Eligibility for a second Scheduled Award in an award year– Must be in a program leading to associate
degree, baccalaureate degree, or certificate– Must be attending at least half-time in order to
receive any of second Scheduled Award
Negotiated rulemaking
• Team V-General and Nonloan Programmatic Issues met in March 2009, April 2009, and May 2009.
• Negotiations included two Pells in one award year
6
Negotiated rulemaking
• No consensus• Notice of proposed rulemaking: August 21,
2009 • Final regulations: October 29, 2009• Effective starting in 2010-11• Early implementation
7
Basics on Crossover Payment Periods
8
Crossover payment period
• Is a payment period that includes June 30 and July 1, i.e., a payment period that occurs in two award years
• May be a term or a nonterm payment period• Must be assigned to one award year• Must have valid SAR/ISIR for assigned year• May assign two consecutive crossover payment
periods to the same award year• Through 2009-2010 award year, have always
been able to assign to either award year
9
Example• A program has a semester calendar with two
summer sessions (6/1 – 7/14 and 7/20 – 8/28).• If combined in one term, the combined term is a
crossover payment period regardless of what classes students attend.
• If the two sessions are considered separate terms, only the 6/1 – 7/14 term is a crossover payment period.
• Note: if the two sessions are separate terms– Full-time must be 12 hours for each session to use Pell
Formula 1– Without a single summer term, the program may no longer
qualify to use an SAY for Stafford/PLUS loans.10
Crossover payment period
Crossover payment period and packaging
• Raises packaging issues• Must use same EFC, COA, and need for all
programs except Pell• Treat Pell as estimated financial assistance (EFA)
for other Title IV• For Pell, use EFC for the award year from which
the student will be paid
11
Crossover payment period and packaging
EXAMPLE• Summer term normally assigned as last payment
period of award year.• Institution decides to pay 2010 summer Pell from
2010-11 ISIR. – Use 2010-11 ISIR/EFC for Pell– Use 2009-10 ISIR/EFC for packaging all other
aid• Amount of Pell received is applied as EFA to
determine need for other Title IV.
12
Crossover payment period
• These requirements are not new.• The new “two Pell” requirements are in addition to
these requirements. • For example, if you have no summer crossover
payment period, the “two Pell” requirements still apply to the rest of an award year.
13
2009-2010Award Year
14
2009-2010 Implementation
• No regulations for 2009-2010• Legally supportable ways to implement in ED:
staff conference presentations, FSA Handbook, and new final regulations
15
2009-2010 Implementation
• Term-based program: no requirement that a student must−– Complete the hours of the first academic year
to be eligible, or– Be taking hours attributable to the second
academic year to be eligible• Clock-hour or nonterm credit-hour program: a
payment period requirement that student must complete the hours of an academic year to move to eligibility for a second Scheduled Award due to payment period definition
16
2009-2010 Payments
• School determines payment for each payment period
• Calculation is based on Scheduled Award for the award year– Pell Grant formulas have not changed– Each calculation is done using same amount
for Scheduled Award
17
2009-2010 Payments
• Must pay an eligible student until reach 200 percent of his or her Scheduled Award for the award year
• Can begin paying from 2nd award while paying balance of 1st award if at least half-time student
18
Credit-hour example
• $5,000 Scheduled Award for 2009-10• Summer 09 and Fall
– Paid on ¾ time and full-time enrollment– Earns only 6 semester hours each term
• Spring, receives payment from first and second Scheduled Awards– $ 625 1st award– $1,875 2nd award
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Summer 2009¾ time (6 hr)
$1,875
Fall 2009Full-time (6 hr)
$2,500
2009-10 Award Year
Summer 2010Full-time (12 hr)
$2,500
Spring 2010Full-time (12 hr)
$2,500
operationallytransparent
Clock-hour example
• $5,000 Scheduled Award for 2009-10• 1,800 clock-hour program with all payment
periods in the 2009-2010 award year
20
1st P.P. 450 cl hr/13 wk it
$2500
2nd P.P. 450 cl hr/13 wk it
$2500
2009-10 Award Year
4th P.P. 450 cl hr/13 wk it
$2500
3rd P.P. 450 cl hr/13 wk it
$2500
Two Pells: COD
• Added new field in COD Common Record– Additional Eligibility Indicator (AEI)
• Set AEI to “true” when awarding funds from the student’s second Scheduled Award• Track the 200 percent limit in COD
• With AEI set, is no POP MRR but concurrent enrollment MRR is still triggered if enrollment dates were within 30 days
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AEI: COD screen
Additional Eligibility Indicator Checkbox
Reminders for 2009-2010
• Must pay eligible students, including less-than-half-time for first Scheduled Award
• Never had concept of headers and trailers; can choose award year to pay a crossover payment
• Cannot ignore payment periods, for example, crossovers or intersessions:– Must pay eligible students in any payment
period in an award year• Must implement “two Pells” regardless of software
capabilities, even if requires manual interventions for crossover or other payment periods
23
2010-2011Award Year
24
Two Pells: Final regulations
• Must be used starting in the 2010-2011 award year
• May apply in some instances to summer crossover payment period considered to be in 2009-2010
§§690.63, 690.64, 690.67
25
Policy goals
• Accelerating completion• Maximizing the benefit of a second Scheduled
Award– Must attend full-time, or almost full-time, to
receive significant benefit• Applying student achievement and
accountability principles for use of funds under the American Recovery and Reinvestment Act of 2009
26
Basics: Eligible student• Is enrolled in credit or clock hours attributable to a
student’s second academic year in the award year• Is enrolled in an eligible program leading to a
bachelor’s or associate degree or other recognized educational credential– The program must be greater than one academic
year in length to be an eligible program for a second Scheduled Award.
– An exception to the degree or certificate is provided for students with intellectual disabilities.
• Is enrolled at least as a half-time student
§690.67(a)
Subpart O of part 66827
Basics: Payment calculations
• Use same amount for both Scheduled Awards in the award year
• Calculate payment for each payment period• Have been no changes to the formulas to calculate
payments
28
Basics: Disbursements
• Disburse to eligible students until reach 200 percent of the student’s Scheduled Award for the award year
• Can begin disbursing from second Scheduled Award in a payment period while paying the balance of first award if student qualifies for second award
§690.63(h)
29
Crossover payment period assignment
• Must assign the payment period to the award year in which the student receives the greater payment– If assigned to first award year, must pay with
first award year funds– If assigned to second award year must pay with
second award year funds
§690.64
30
Crossover payment period assignment
• Must determine the greater payment based on all requirements that apply
• Must not rely on EFC or Scheduled Award alone• If only have valid SAR/ISIR for one award year,
must rely on that record – For example, that award year record is higher
if, for the other award year—• No SAR/ISIR• Rejected SAR/ISIR without an EFC• Incomplete verification
– May still need to pay on other year if receive a valid SAR/ISIR
31
Crossover payment period assignment
EXAMPLE• $4,000 Scheduled Award for first award year and
$5,000 Scheduled Award for second award year• Receipt of ISIR with a higher Scheduled Award for
second award year after summer term is completed• Payment as full-time from first award year ($2,000)
although student only completed the term as half-time
• Higher payment remains the first award year payment since payment from second award year would be based on half-time, i.e., $1,250 (lump sum payment rule, §690.76(b))
32
Crossover payment period assignment
• Must reassign if receive information that student would receive greater payment – within deadline date for the first award year
(2010 crossover payment period, September 10, 2010)
• May reassign if information received after initial deadline – but not later than the deadline date for
administrative relief for the first award year(2010 crossover payment period, February 1, 2011)
33
Credit-hour example
• $4,000 Scheduled Award for 2010-11• Fall, completes the hours of the first academic
year• Spring, receives payment from second
Scheduled Award
34
Summer 2010Full-time (12 hr)
$2,000
Fall 2010Full-time (12 hr)
$2,000
2010-11 Award Year
Spring 2011Full-time (12 hr)
$2,000
Credit-hour example
• $5,000 Scheduled Award for 2011-12• Summer 2011 reassigned• Fall, completes the hours of the first academic
year• Spring, receives payment from first and
second Scheduled Awards– $ 625 1st award– $1,875 2nd award
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Summer 2011¾ time (9 hr)
$1,875
Fall 2011Full-time (15 hr)
$2,500
2011-12 Award Year
Summer 2012Full-time (12 hr)
$2,500
Spring 2012Full-time (15 hr)
$2,500
operationallytransparent
Credit-hour example
• $4,000 Scheduled Award for 2012-13• Spring, does not complete first academic year• Summer, eligible with payment of $500 from
balance of first award and $1,500 from second award
• May need to assign summer to 2013-2014 if a higher payment
36
Fall 2012¾ time (9 hr)
$1,500
Spring 2013Full-time (12 hr)
$2,000
2012-13 Award Year
Summer 2013Full-time (12 hr)
$2,000
Clock-hour example
• $4,000 Scheduled Award for 2010-11• 1,800 clock-hour program over 52 weeks of
instructional time• 3rd payment period, a crossover payment
period
37
1st P.P. 450 cl hr/13 wk it
$2000
2nd P.P. 450 cl hr/13 wk it
$2000
2010-11 Award Year
3rd P.P. 450 cl hr/13 wk it
$2000
Clock-hour example
• $5,000 Scheduled Award for 2011-12• Reassignment of 3rd payment period since
student is now eligible for a $2,500 payment
38
3rd P.P. 450 cl hr/13 wk it
$2500
4th P.P. 450 cl hr/13 wk it
$2500
2011-12 Award Year
Summer 2010
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Crossover payment period assignment for 2010
• Effective date of final regulations affects 2010 crossover period.
• Institution may designate based on options applied to all students or on student-by-student basis.
40
Crossover payment period assignment for 2010
• Institution may designate:– Prior to July 1, 2010, a student’s payment period
as being in the 2009-10 and not apply these regulations;
– A student’s payment period as being in the 2009-10 award year with regulations being applicable; or
– A student’s payment period as being in 2010-2011, in which case the regulations must apply.
• Before July 1, 2010, establish written policy
41
Crossover payment period assignment for 2010
EXAMPLES
• Prior to July 1, 2010, institution determines it will--– Treat 2010 summer payment periods as being in
09-10 and not apply these regulations.• Prior to July 1, 2010, institution determines it will--
– Treat 2010 summer payment periods as being in 09-10 and not apply these regulations, but
– Assign student’s payment period to 2010-2011 if the student would receive a larger payment
42
Crossover payment period assignment for 2010
EXAMPLES
• Prior to July 1, 2010, an institution determines that it will--
– Treat 2010 summer payment periods as being in the 2010-2011 award year
• Prior to July 1, 2010, an institution determines it will make 2010 summer payment period assignments on a case-by-case basis
43
Crossover payment period assignment for 2010
EXAMPLES
• Prior to July 1, 2010, makes NO determination of policy to apply-- – Must apply new regulations to all summer
disbursements, whether for 9-10 or 10-11 (does not affect 9-10 payment periods prior to summer 2010)
44
Additional ProvisionsStarting in 2010-2011
45
Transfer student
• Final regulations: two options– Assumption method
• Based on disbursements received
– Hours-earned method• Based on actual hours earned
• Method at option of institution: apply on a student-by-student basis or to all students
§690.67(b)46
Transfer student: Assumption method
• Assume completed first academic year if received all of first Scheduled Award at prior institution
• If less than first Scheduled Award, calculate hours considered to have completed:
47
Amount disbursedat prior institution X
Hours in current institution’s academic year
Amount of Scheduled Award at prior institution
=Hours
considered completed
Transfer student: Assumption method
EXAMPLE – credit hour• Fall transfer student received $2,000 of $4,000
Scheduled Award for summer at prior institution. • Current institution, without a summer term, defines
academic year, in part, as 24 semester hours.• Hours in award year considered to have earned
for prior attendance:
48
$2,000 disbursedat prior institution X
24 hours in current institution’s academic year
$4,000 Scheduled Award at prior institution
= 12 hours considered completed
Transfer student: Assumption method
EXAMPLE – clock hour• Transfer student received $3,000 of $4,000
Scheduled Award at prior institution. • Current institution defines academic year, in part,
as 900 clock hours.• Hours in award year considered to have earned
for prior attendance:
49
$3,000 disbursedat prior institution X
900 clock hours in current institution’s academic year
$4,000 Scheduled Award at prior institution
= 675 clock hours considered completed
Transfer student: Assumption method
• Round down any fractions of a credit or clock hour
• Except if courses are offered in fractions of credits, may retain fractions
• Example– Using the assumption method, a transfer
student is considered to have earned 12.7 credits in the award year at a prior institution.
– If the student’s program is offered in courses of 2.5 credit hours, the institution may consider the student to have 12.7 credits or 12 credits.
– If the program were offered in 3-hour courses, the student would have 12 credits.
50
Transfer student: Hours-earned method
• The institution may determine the credit or clock hours actually earned at other institutions.
• The institution must have information that—– Includes the time periods when the credit or
clock hours were earned, and– Does not include nonapplicable credit or clock
hours.• Any hours earned are applicable. For example,
hours—– Need not be earned in an eligible program, or – Be accepted on transfer.
51
Transfer student: Hours-earned method
• An institution must attribute to the current award year any credit or clock hours earned at other institutions that were earned in a summer crossover payment period.
• This requirement applies even though the institution does not have a summer payment period.
52
Transfer student: Hours-earned method
EXAMPLE – credit hour• Current institution defines academic year, in part,
as 24 semester hours.• Student’s transcript shows earned 6 hours in the
summer term and 12 hours in the fall semester.• Transfer student received $2,000 of $4,000
Scheduled Award at prior institution for the fall term and no payment for summer from the current award year.
• At the current institution, the student is considered to have earned 18 semester hours in the award year: 6 from summer and 12 from fall.
53
Transfer student: Hours-earned method
EXAMPLE – clock hour• Current institution defines academic year, in part, as
900 clock hours.• Student’s transcript shows earned 600 clock hours in
the period from June 15 to September 30.• Transfer student received $3,000 of $4,000 Scheduled
Award at prior institution for the fall term and no payment for summer from the current award year.
• At the current institution, the student is considered to have earned 600 clock hours in the award year since the institution confirmed that the first payment period was a crossover payment period.
54
Transfer student
• No requirement to apply additional information to disbursements for prior payment period in award year
• For example— – Assumption method: a payment is reported
late to NSLDS. – Hours-earned method: a transcript is received
indicating student earned additional hours in the award year at another institution.
• In clock-hour programs, a payment consisting of funds from a first and second Scheduled Award, only for a transfer student
55
Nonapplicable hours
• In determining eligibility for a second Scheduled Award in an award year, may not use hours based on:– Advanced Placement (AP) programs– International Baccalaureate (IB) programs– Testing out, life experience, or similar
competency measures• Are not earned by attendance in the award year
§690.67(d)56
Nonapplicable hours
• The equivalencies of reduced credit and noncredit remedial coursework do count toward determining eligibility for a second Scheduled Award in an award year.
• Any equivalent hours in excess of the 30 semester hours, 45 quarter credits, or 900 clock hours do not count unless they are equivalent hours of ESL coursework.
• In other words, reduced credit and noncredit remedial coursework does not count if the equivalent hours do not count toward determining Title IV eligibility.
57
Special circumstances
• May waive requirement to be enrolling in hours attributable to the second academic year in the award year to pay from second Scheduled Award
• Must be due to circumstances beyond the student’s control
• Must be determined and documented on individual basis
§690.67(c)
58
Special circumstances
• May include circumstances such as illness or classes not offered
• Does not include withdrawing to avoid a grade or failing to register for offered class
59
Reminders for 2010-11 and subsequent years
• Must pay eligible students, including less-than-half-time for first Scheduled Award
• No concept of headers and trailers• Cannot ignore payment periods, for example,
crossovers or intersessions:– Must pay eligible students in any payment period
in an award year• Must implement “two Pells” regardless of software
capabilities, even if requires manual interventions for crossover or other payment periods
60