Unusual enrollment history A GAME OF MUSICAL CHAIRS

TIME-LINE OF EVENTS November 2012 – US Dept.. of Education announced at the 2012 Fall Conference the addition of the unusual enrollment history flag as a component in the 2013/2014 verification process January 2013 – National Student Loan Data System Newsletter 41 March 2013 – US Dept. of Education GEN-13-09

What does it mean? In coordination with the Pell Grant lifetime eligibility usage, the flag will indicate if the student has an usual enrollment history with regards to fraud and abuse of funds. The institution who receives a valid ISIR must look at the last three years of enrollment to determine if the student received Pell and if it credit was earned in each of those three years

NSLDS Unusual Enrollment History Flag NSLDS will add edits to identify records with unusual enrollment histories and set a new NSLDS Unusual Enrollment History Flag Pre-Screening - Unusual Enrollment History Flag: Five flag values (N, Blank and 1- 3) 4

NSLDS Unusual Enrollment History Flag Values for the NSLDS Unusual Enrollment History Flag are described in the following table NSLDS Unusual Enrollment History Flag Description SAR C Flag? SAR Comment 1 For Federal Student Aid Use Only No N/A 2 Unusual Enrollment History 2 (Possible enrollment pattern problem, school may need to resolve) Yes 359 3 Unusual Enrollment History 3 (Questionable enrollment pattern, school must resolve) 360 N Enrollment pattern not unusual (No school action required) Blank Record not sent for match 5

NSLDS Unusual Enrollment History Flag SAR comments and the SAR C Flag will be generated for flags 2 and 3; resolution guidance will be provided to schools Comment No. SAR Comment School Action to include 359 Your school may request additional information to determine your eligibility for federal student aid.   Note: This comment will generate a SAR C flag as already documented. Action depends on whether the school is a new school for the applicant for 2013-2014. If not a new school, school not required to take any action but may look into the applicant’s enrollment history. If new school for applicant, school must take certain actions that will be developed by FSA and OPE policy. 360 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.” School must take certain enhanced actions that will be developed by FSA and OPE policy. 6

NSLDS Unusual Enrollment History Flag Post-Screening Reason Code: CPS will system-generate a new transaction with Reason Code 24 for records that have a change in the NSLDS Unusual Enrollment History Flag value after the initial pre-screening The new transaction will include the new value for the NSLDS Unusual Enrollment History Flag and a SAR Comment or C Flag as appropriate 7

Unusual enrollment flag 2 The institution must review the student’s enrollment and financial aid records to determine, if during the three award year period a(2011-2012, 2012-2013 and 2013-2014, the student received a Pell Grant at the institution that is performing the review If so, no additional action is required unless the institution has reason to believe that the student is one who remains enrolled just long enough to collect student aid funds, in this case, the institution must follow the guidelines under UEH flag 3. If not, the institution must follow the guidelines under UEH flag 3.

Unusual enrollment flag 3 The institution must review the student’s academic records to determine fi the student received academic credit at the institutions the student attended during the three year award period (2011-2012, 2012-2013 and 2013-2014). Using information from the National Student Loan Data System (NSLDS), the institution must identify the institutions where the student received funding over the past three award years. The institution uses academic transcripts already possessed, or by asking the student to provide academic transcripts or grade reports. The institution must determine if whether academic was earned during the award years in which the student received Pell Grant funds.

Ueh flag 3 continued Academic credit is considered to have been earned if the academic records show that the student completed any credit and/or clock hours. Academic Credit Earned: If the institution determines that the student earned any academic credit at each of the previously attended institutions during the relevant award years, then no further action is required. Academic Credit NOT Earned: If the student did not earn academic credit at a previously attended institution and, if applicable, at the institution performing the review, the institution must obtain documentation from the student explaining why the student failed to earn academic credit. The documentation should include: The reasons given by the student for failure to earn academic credit The student did not enroll only to receive credit balance funds

Continued eligibility: Approved or denied Approval: The institution may choose to require the student to establish an academic plan/degree plan, counsel the student about Pell Grant duration of eligibility, and the impact of the student’s attendance pattern on future Pell Grant eligibility. Denial: Student is placed on financial aid suspension of all Title IV funds. In some cases this can also include state and/or institutional aid as well. The student can regain eligibility based upon the institutions Satisfactory Academic Policy.

Questions and/or comments

References: National Student Loan Data System - U.S. Department of Education. (2013, January). NSLDS Newsletter. Retrieved from U.S. Department of Education Federal Student Aid: ifap.ed.gov/nsldsmaterials/attachments/NSLDSNewsletter41.doc Parkinson, M., & Sears, J. (2012). FAFSA Application Procssing Updates. Retrieved from U.S. Department of Education Federal Student Aid: fap.ed.gov/presentations/attachments/2012FSAConfSession26FAFSAAp plicationProcessingUpdate.ppt U.S. Department of Education. (2013, March 8). Dear Collegue Letters. Retrieved from U.S, Department of Education Federal Student Aid: http://ifap.ed.gov/dpcletters/GEN1309.html