Unusual Enrollment History Richard V. Silva, Director Student Financial Aid Alamo Colleges – Processing Center

 U.S. Department of Education (ED) is trying to prevent fraud & abuse in the Federal Pell Grant Program  Dear Colleague Letter – GEN posted March 8, 2013  Two new SAR ‘C’ Codes added to ISIR  Two new ‘UEH’ Flags added to ISIR  Flag value determines action needed UEH – Background Information

 1.UEH Flag Value: ‘2’  Will generate SAR – Comment Code: 359  Student received Pell Grant funds at 3 institutions over 2 AYs  2.UEH Flag Value:‘3’  Will generate SAR – Comment Code: 360  Student received Pell Grant funds at 3 or more institutions in 1 AY UEH Flag Value & SAR – C Code NSLDS – UEH Flag DescriptionSAR C Flag? SAR Comment 1For Federal Student Aid Use OnlyNoN/A 2Unusual Enrollment History 2 (Possible enrollment pattern problem, school may need to resolve) Yes359 3Unusual Enrollment History 3 (Questionable enrollment pattern, school must resolve) Yes360

 UEH Flag value of ‘2’  Determine if student received a Pell Grant at the institution that is performing the review.  If yes, no additional action is required, unless institution has reason to believe the student is one who remains enrolled just long enough to collect SFA funds. If so, follow the guidance for UEH Flag value of 3.  If no, institution must follow the guidance provided for UEH Flag value of ‘3’  In Summary of Changes for the Application Processing System: , new edits were added by CPS to set new NSLDS Postscreening Reason Code, 24, which identifies applicants who have a change in the UEH History Flag after initial prescreening. Resolution Guidance

 UEH Flag value of ‘3’  Institution must review academic records to determine if student received academic credit at the institutions the student attended during the three award year period (AYs 10-11; 11-12; & 12-13).  Using information from NSLDS, institution must identify where the student received Pell Grant funds over the past three award years (10-11; 11-12; & 12-13) Resolution Guidance (continued) NSLDS UEH FlagDescription SAR C Flag? SAR Comment NEnrollment pattern not unusual (No school action required) NoN/A BlankRecord not sent for matchNoN/A

 If institution determines student earned any academic credit at each of the previously attended institutions during relevant AYs, no further action is required unless the institution has other reasons to believe the student is one who enrolls just to receive the credit balance.  If the student did not earn any academic credit at a previously attended institutions and, if applicable, at the institution performing the review, institution must obtain documentation from student explaining why he/she failed to earn academic credit. At this point, this situation may be handled like professional judgment as provided by section 479A of the Higher Education Act (HEA). Academic Credit Earned/Not Earned

 If institution approves student’s continued eligibility, FAA may choose the following:  Require student to establish an academic plan, similar to the type used to resolve SAP appeals;  Counsel student about Pell Lifetime Eligibility Used (LEU) and impact of student’s attendance pattern on future Pell Grant eligibility described in DCLs GEN & GEN and Announcement posted on IFAP on August 13, Approval of Continued Eligibility

 If a student did not earn academic credit at one or more of the relevant institutions and does not provide, to the FAA’s satisfaction, an acceptable explanation and documentation for each of those failures, the institution must deny the student any additional Title IV, HEA program assistance.  Student must be provided an opportunity to question & appeal the decision, consistent with the opportunities to question & appeal similar FA determinations such as SAP & PJ decisions. Denial of Continued Eligibility

 If institution denies a student continued Title IV, HEA program assistance under circumstances described in previous slide, it must provide a student with information as to how he/she may subsequently regain Title IV, HEA program eligibility. Since basis of denial is student’s academic performance, it is expected the following is could include:  Meeting the requirements of an Academic Plan school established; and  Meeting the school’s standards to regain eligibility for Title IV. Regaining Aid Eligibility

 ISIR Guide –  Posted to IFAP on September 29, 2012  SAR Comment Codes and Text,  Posted to IFAP on October 30,  Summary of Changes for the Application Processing System:  Posted to IFAP on November 8, 2012  GEN-13-09: Students with an Unusual Enrollment History Flag--- ”C” code on the ISIR Resources