Unusual Enrollment History (UEH) BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Unusual Enrollment History History and overview Flags and codes Resolving UEH FAQs Scenarios Resources BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Unusual Enrollment History… History Developed by the Department of Education in 2013-14 to prevent fraud and abuse of Title IV federal aid. At that time, they only reviewed the past three aid years, but starting in 2015-16 they review the past four aid years. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

What Potentially Fraudulent Activity Is UEH Meant to Address? Enrollment pattern in which a student attends an institution: e Long enough to receive a refund (credit balance) from Title IV funds; Leaves without completing the enrollment period; Enrolls at another institution; AND Repeats the pattern of receiving a refund of Title IV funds without earning any academic credit. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

So All UEH Flags Are Students Committing Fraud? No! Some students have perfectly legitimate reasons for enrolling in multiple institutions and leaving without earning academic credit. However, institutions still need to review students with this type of enrollment history to determine if they have valid reasons. Resolving a UEH flag is separate from verification. So a student could be both UEH and selected for verification after the UEH is resolved. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

What Is the Evaluation Period? When looking for UEH, after a student submits their FAFSA, CPS looks at Pell Grant and Direct Loan disbursement for the past four award years to see if the funds were received at multiple institutions For 2018-19, that would mean reviewing from 2014-15 to 2017-18. Direct Consolidation Loans, Parent PLUS Loans, or Campus-Based Loans like Perkins are not counted. Starting in 2016-17, they also started reviewing undergraduate and graduate enrollment separately. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

UEH Flags If there is an UEH, they are assigned a flag of ‘N,’ ‘2,’ or ‘3’ on the Institutional Student Information Report (ISIR) based on the number of Pell Grant and/or loan disbursements that the student received compared to the number or schools that the individual was awarded aid. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

UEH Flags ‘N’ = No unusual enrollment history issue and no action required by the institution. Good to go! ‘2’ = An unusual enrollment history. There is a possible enrollment pattern that the school may need to resolve. The student has attended three institutions and received federal aid during the last four award years. The institution must review the student’s enrollment records. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

UEH Flags/C-Codes ‘3’ = An unusual enrollment history. There is a questionable enrollment pattern that the school must resolve. The student has attended three or more institutions and received federal aid during the last four award years. The institution must review the student’s enrollment and academic records for the student and may need to collect additional documentation. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

SAR Codes Students with a ‘2’ or a ‘3’ would have a comment on their Student Aid Report (SAR). ‘2’  Comment Number 359 ‘3’  Comment Number 360 359 Comment: “Your school may request additional information to determine your eligibility for federal student aid.” 360 Comment: “Based upon data provided by the National Student Loan Data System (NSLDS), your school will request additional information to determine your eligibility for federal student aid and before disbursement of funds can be made. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Resolving UEH: Flag ‘2’ If Pell Grant and/or Direct Loan funds were used at your institution during the last four award years, no further review is required. Unless… The student only enrolls long enough to receive a credit balance/refund, or The student has not used federal aid during the review period. If the student has not used federal aid during the review period at your institution OR you believe the student is only enrolling long enough to receive a refund, you must resolve the UEH the same way you would as a Flag ‘3.’ BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Resolving UEH: Flag ‘3’ Review the National Student Loan Data System (NSLDS) to determine where the student received federal student aid during the past four award years (reviewing each award period). Review the student’s academic transcripts to determine if credit was earned at all institutions where they received federal student aid during the past four award years (reviewing each award period). If you do not have transcripts or grade reports for any of the institutions for the years in question, you can ask the student to provide them. Academic credit is considered to be “earned” if the student’s transcripts show that the student completed any credit-hours or clock-hours… which could be an ‘F.’ BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Resolving UEH: Flag ‘3’ If the student earned credit at all institutions (even if it just was one credit at each institution for each award period where they received aid), you can clear the flag and move forward unless you believe the student enrolls for a refund and then withdraws. If you believe the student is enrolling only to receive a refund before withdrawing, you may treat it as if academic credit was not earned at all institutions. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Resolving UEH: Flag ‘3’ If academic credit is not earned at all institutions during the award periods the student received federal aid within the past four aid years… The institution must obtain documentation from the student explaining why the student failed to earn academic credit. The institution must determine whether the documentation supports: The reasons given by the student for the student’s failure to earn academic credit; and The student did not enroll only to receive credit balance funds. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Justification for UEH Personal Reasons Academic Reasons Illness, family emergency, a change in where the student is living beyond the student’s control, and military obligations. Academic Reasons The student might explain that the first enrollment was at an institution where they met unexpected academic challenges, or The academic program did not meet the student’s needs (as determined by the student) Your institution should, to the extent possible, obtain third-party documentation to support the student’s justification. They must justify each failure to earn academic credit while receiving Title IV aid during the review period. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Approved? If the student’s reasons for UEH and documentation are valid, you can approve continued eligibility for financial aid. You can establish an academic plan (such as an SAP appeal plan); and/or You can counsel the student on Pell Grant duration of eligibility (LEU) and loan limits; and/or You can require the student to sign an Identity and Statement of Educational Purpose verifying they intend to use the Title IV funds received for educational purposes only. What you do after approval is part of your institutional policy for UEH and must be consistently applied to all UEH students. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Denied? You must deny additional Title IV aid if no academic credit was earned at one or more institutions and no documentation or acceptable explanation was provided for each failure. The student cannot appeal your denial to the Department of Education. However, you must give the student the opportunity to appeal the decision with your institution. You must also provide students with information on how they may subsequently regain eligibility for Title IV aid. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Regaining Eligibility Student may appeal your denial and be approved. Student may successfully complete academic credit during a payment period (without receiving Title IV aid). This could include meeting the requirements of an academic plan you establish with the student. Eligibility for Pell Grant and campus-based aid begin with the payment period in which the student regains eligibility. Direct Loan eligibility is retroactive to the beginning of the enrollment period for the award year. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

FAQ What if the student had a flag of ‘2’ or ‘3’ on 2017-2018 but an ‘N’ on 2018- 2019? If you already resolved the 2017-18 issue, no further action is needed. If you have not resolved the 2017-18 issue, you should, but are not required to, hold disbursement of Title IV aid for 2018-19 until the 2017-18 UEH flag is resolved. In doing so, you would review the student’s academic year for 2013-14 (the starting point for a 2017-18 review) through 2017-18 (not just 2016-17). BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

FAQ What if you suspect the student of unusual enrollment or receiving Title IV aid for purposes other than to provide financial support for their education? You may choose to hold disbursement of Title IV aid until you review the academic history of the student. If you do, you must be able to document the reasons why you took this action, as well as the specific steps the institution took to resolve the institutional selection for a UEH review. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Scenario 1 Maria’s 2018-2019 ISIR comes in with as an Unusual Enrollment History ‘2.’ Maria received Pell Grant at your institution for Fall 2017 and Spring 2018. What should you do? BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Unless… you believe the student is intentionally enrolling only long enough to receive a refund of Title IV funds to use for non-educational purposes. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Scenario 2 Josh’s 2018-2019 ISIR comes in with an Unusual Enrollment History ‘3.’ You review NSLDS for the past four award years and his transcripts on file. You can verify he earned academic credit for every payment period he received Pell/Direct Loans for the past four award years except for three semesters. You don’t have complete transcripts for Spring 2016, and he’s showing as all W’s and/or incompletes for Fall 2015 and Spring 2017. Josh provides transcripts for Spring 2016 that show academic credit earned. What does Josh need to provide for Fall 2015 and Spring 2017? BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Scenario 2 Joshua must provide documentation explaining why he failed to earn academic credit for BOTH Fall 2015 and Spring 2017. Joshua’s reasons must meet justification for UEH (personal and/or academic reasons). Joshua must also provide third-party documentation supporting his reasons. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Scenario 3 Lacey’s ISIR came in with an Unusual Enrollment History ‘3.’ She’s unable to provide sufficient reasons or documentation to show she did not enroll only to receive credit balance funds. How can Lacey regain eligibility for Title IV funds? BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Scenario 3 She can appeal the decision to her institution. She can successfully complete academic credit during a payment period without receiving Title IV aid. BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Scenario 4 Mark’s ISIR came in with an Unusual Enrollment History ‘3.’ There are two semesters over the past four aid years where he received PELL and Direct Loans but did not earn academic credit. For the first semester in question, he provides a statement that he pursued engineering as a first-time freshman only to find he engineering was not something he could grasp. He was also in a remedial mathematics course the same semester. After speaking with his advisor, he decided to leave the engineering program. He withdrew because he did not want his time in engineering to impact his overall GPA. He provides a letter from his academic advisor. For the second semester, his statement and third-party records show he was in a car accident which put him in the hospital for three months of the first semester in question. Should he be approved or denied? BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Scenario 4 This is a professional judgment, so it’s up to the FAA! If approved, the school potentially could do/require what as part of their policy? BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Scenario 4 Academic Plan Counseling on Pell and loan limits Identity and Statement of Educational Purpose BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Resources Dear Colleague Letter: GEN-15-05 – https://ifap.ed.gov/dpcletters/GEN1505.html Dear College Letter: GEN-13-09 – https://ifap.ed.gov/dpcletters/GEN1309.html IFAP Handbook (search for UEH) – https://ifap.ed.gov/ifap/byAwardYear.jsp?type=fsahandbook 2018-19 SAR Comment Codes and Text – https://ifap.ed.gov/sarcommcodestxt/attachments/1819SARCommCodesTxtOct201 7.pdf BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE

Questions? Nicole Solomon Assistant Director, Student Financial Support & Services West Virginia University nicole.solomon@mail.wvu.edu BUILDING ON OUR MOMENTUM! WVASFAA FALL 2017 CONFERENCE