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April 9, 2010. Two Pells in One Award Year. Fred Sellers Office of Postsecondary Education. Agenda. Legislation and negotiated rulemaking Basics on crossover payment periods 2009-2010 award year 2010-2011 and subsequent award years Summer 2010

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two pells in one award year

April 9, 2010

Two Pells

in One

Award Year

Fred Sellers

Office of

Postsecondary Education

agenda
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
budget scheduled award
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
legislation
Legislation
  • 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
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
negotiated rulemaking1
Negotiated rulemaking
  • No consensus
  • Notice of proposed rulemaking: August 21, 2009
  • Final regulations: October 29, 2009
  • Effective starting in 2010-11
  • Early implementation
crossover payment period
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
slide10

Crossover payment period

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.
crossover payment period and packaging
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
crossover payment period and packaging1
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.
crossover payment period1
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.
2009 2010 implementation
2009-2010 Implementation
  • No regulations for 2009-2010
  • Legally supportable ways to implement in ED: staff conference presentations, FSA Handbook, and new final regulations
2009 2010 implementation1
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
2009 2010 payments
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
2009 2010 payments1
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
credit hour example
Credit-hour example

Summer 2009

¾ time (6 hr)$1,875

Fall 2009

Full-time (6 hr)$2,500

Spring 2010

Full-time (12 hr)$2,500

Summer 2010

Full-time (12 hr)$2,500

  • $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

2009-10 Award Year

operationally

transparent

clock hour example
Clock-hour example

1st P.P.

450 cl hr/13 wk it$2500

2nd P.P.

450 cl hr/13 wk it$2500

3rd P.P.

450 cl hr/13 wk it $2500

4th P.P.

450 cl hr/13 wk it

$2500

  • $5,000 Scheduled Award for 2009-10
  • 1,800 clock-hour program with all payment periods in the 2009-2010 award year

2009-10 Award Year

two pells cod
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
aei cod screen
AEI: COD screen

Additional Eligibility Indicator Checkbox

reminders for 2009 2010
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
two pells final regulations
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

policy goals
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
basics eligible student
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 668

basics payment calculations
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
basics disbursements
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)

crossover payment period assignment
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

crossover payment period assignment1
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
crossover payment period assignment2
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))
crossover paym ent perio d assignment
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)

credit hour example1
Credit-hour example

Summer 2010Full-time (12 hr)

$2,000

Fall 2010

Full-time (12 hr)$2,000

Spring 2011

Full-time (12 hr)$2,000

  • $4,000 Scheduled Award for 2010-11
  • Fall, completes the hours of the first academic year
  • Spring, receives payment from second Scheduled Award

2010-11 Award Year

credit hour example2
Credit-hour example

Summer 2011

¾ time (9 hr)$1,875

Fall 2011

Full-time (15 hr)$2,500

Spring 2012

Full-time (15 hr)$2,500

Summer 2012

Full-time (12 hr)$2,500

  • $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

2011-12 Award Year

operationally

transparent

credit hour example3
Credit-hour example

Fall 2012¾ time (9 hr)

$1,500

Spring 2013

Full-time (12 hr)$2,000

Summer 2013

Full-time (12 hr)$2,000

  • $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

2012-13 Award Year

clock hour example1
Clock-hour example

1st P.P.

450 cl hr/13 wk it$2000

2nd P.P.

450 cl hr/13 wk it

$2000

3rd P.P.

450 cl hr/13 wk it $2000

  • $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

2010-11 Award Year

clock hour example2
Clock-hour example

3rd P.P.

450 cl hr/13 wk it $2500

4th P.P.

450 cl hr/13 wk it $2500

  • $5,000 Scheduled Award for 2011-12
  • Reassignment of 3rd payment period since student is now eligible for a $2,500 payment

2011-12 Award Year

crossover payment period assignment for 2010
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.
crossover payment period assignment for 20101
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
crossover payment period assignment for 20102
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
crossover payment period assignment for 20103
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
crossover payment period assignment for 20104
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)
transfer student
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)

transfer student assumption method
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:

Amount disbursed

at prior institution

Hours in current

institution’s academic year

X

Hours considered completed

=

Amount of Scheduled Award

at prior institution

transfer student assumption method1
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:

$2,000 disbursed

at prior institution

24 hours in current

institution’s academic year

X

=

12 hours considered completed

$4,000 Scheduled Award

at prior institution

transfer student assumption method2
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:

$3,000 disbursed

at prior institution

900 clock hours in current

institution’s academic year

X

=

675 clock hours considered completed

$4,000 Scheduled Award

at prior institution

transfer student assumption method3
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.
transfer student hours earned method
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.
transfer student hours earned method1
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.
transfer student hours earned method2
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.
transfer student hours earned method3
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.
transfer student1
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
nonapplicable hours
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)

nonapplicable hours1
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.
special circumstances
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)

special circumstances1
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
reminders for 2010 11 and subsequent years
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
contact information
Contact Information
  • Phone: 202 502-7502
  • Email: fred.sellers@ed.gov
  • Fax: 202 502-7874