Carney McCullough & Marie Fitzpatrick | Dec U.S. Department of Education 2013 FSA Training Conference for Financial Aid Professionals Pell Grant Duration of Eligibility Limitation Session #3

Agenda Limitation on Pell Eligibility Calculating Reduced Awards Liability for Exceeding the 600% Lifetime Eligibility Used (LEU) Max Timely Reporting Pell Award History Pell LEU Information for Students Pell LEU in COD Pell LEU COD Edits Pell LEU on COD Reports Pell LEU Dispute Guidance Pell LEU Dispute Process 2

Limitation on Pell Eligibility The Consolidated Appropriations Act, P.L was enacted on December 23, Duration of a student’s Federal Pell Grant eligibility is limited to 12 semesters (or its equivalent) Effective beginning with the award year Not limited to students who received their first Federal Pell Grant on or after the award year Includes all Pell Grant/Basic Grant disbursements back to the award year 3

Limitation on Pell Eligibility How is the 12 semester equivalent determined? Twelve semester equivalency is calculated by adding the annual percentages of a student’s scheduled award that was disbursed to the student The total of the annual percentages is the student’s Pell Grant LEU limit When a student reaches 600% LEU, he/she has reached his/her Federal Pell Grant eligibility limit 4

Calculating Reduced Awards How to calculate a student’s Pell Grant eligibility when the student has: LEU of 500% or Less: A student with an LEU of 500% or less is eligible to receive up to 100 percent of the full Scheduled Award for the award year, since the student has at least 100% LEU remaining LEU of 600% or More: A student whose Pell LEU is 600% or more may not receive additional Pell Grant funds LEU of Greater Than 500% But Less Than 600%: A student with an LEU of greater than 500% but less than 600% is not eligible to receive a full Scheduled Award, but may receive a partial Pell Grant award of the difference between 600% and the student’s LEU 5

Calculating Reduced Awards Scenario 1: Student is full-time in a semester program and has 0 EFC and a $5,645 scheduled award Action: Calculate student’s Pell eligibility by subtracting the Pell LEU from the Pell LEU Report from % Report says % % % = % % x $5,645 = $3, ($3,711.30) First semester award = $2, Second semester award = $ or $ (do not round up) 6

Calculating Reduced Awards Scenario 2: Student is full-time in a semester program and has 525 EFC and a $5,095 scheduled award Action: Calculate student’s Pell eligibility by subtracting the Pell LEU from the Pell LEU Report from % Report lists LEU of % % % = % % x $5,095 = $1, First payment period = $1, or $1,710 Second payment period = $ 0 7

Calculating Reduced Awards There is no de minimus award amount for purposes of determining a student’s award because of the 600% LEU limitation. Even a student with a very small remaining LEU is eligible to receive the calculated amount of Pell Grant For example, a student with an EFC of 2550 and an LEU of % would be eligible for the remaining 0.500% which is $ truncated to $15.47 or, if necessary, rounded down to $

Liability for Exceeding the 600% LEU Max Institutional If the LEU was >600% prior to the award year, no adjustment is necessary Institution may be liable for the overpayment if it had information at the time of disbursement that indicated that the student would exceed 600% LEU Institution does not report Pell Grant disbursement within the required 15 day timeframe may be liable for any overpayment that results from another institution disbursing Pell Grant funds with incomplete information because of the late reporting Rounding rules do not apply if the amount disbursed would place the student’s LEU > % 9

Liability for Exceeding the 600% LEU Max Student Student is liable for the Pell Grant overpayment if the institution was compliant with all disbursement and reporting requirements Institution should follow the normal procedures for handling an overpayment:  Contact student and enter into satisfactory repayment arrangement  Refer to the Department for collection 10

Timely Reporting Electronic Announcement posted on August 13, Reminds institutions of the importance of reporting Pell Grant disbursements AND adjustments Federal Register posted February 28, Reduced the timeframe for reporting disbursements (or disbursement adjustments) made on or after 4/1/13 for Federal Pell Grant disbursement records to no later than 15 days after making the disbursement or becoming aware of the need to adjust a student's previously reported disbursement. 11

Pell Award History Summer 2012 Gathered all Pell Grant information from across all Pell legacy systems Loaded the calculated LEU percentage to existing students records in NSLDS COD began returning Pell LEU on common record responses for ALL Pell recipients, and returned warning edits COD began displaying Pell LEU on the COD website for ALL Pell recipients Pell LEU History page created to record all historical Pell student data to determine how Pell LEU was calculated 12

Pell LEU Information for Students CPS For the award year CPS began reporting Pell LEU information on SARs, using comment codes to alert applicants who are close to or have exceeded 600% LEU For the award year SAR comments are consistent with the student’s Pell history at the time of the SAR (pre-screening) & from NSLDS post-screening if LEU changes SAR comments will refer to the equivalent of “school year” SAR Codes contain new or revised comments See SAR Comment Codes and Text Guide 13

Pell LEU Information for Students NSLDS MyStudentData allows students to download their loan, grant, and aid overpayment history but does not display Pell LEU percentage To minimize confusion, do not refer students to MyStudentData Download for LEU information Note: COD is the official system of record for Pell LEU. 14

Pell LEU in COD On the COD website, institutions can also lookup a student’s LEU using: Person Pell Information page Pell LEU History page Within COD batch processing: Common Record Response File Edits 15

Pell LEU in COD 16

Pell LEU in COD 17

Pell LEU in COD A

Pell LEU COD Edits Three Pell LEU edits are given, as applicable, with origination and/or disbursement common record response: Edit #Message 177 Warning Lifetime Percentage of Eligibility Used is near the lifetime limit 178 Warning Lifetime Percentage of Eligibility Used has exceeded the lifetime limit 201 Reject/ Correcting Pell LEU exceeds the Pell LEU Limit of 600% Edit 201 is new as of June 2013! 19

Pell LEU on COD Reports Utilize the Pell LEU Report to identify Pell-eligible CPS applicants with LEUs > or = 450%. Includes students who listed the school’s Federal School Code on their FAFSA Generated weekly in an institution’s SAIG mailbox CSV format so it can be easily imported and sorted COD also provides the Pell LEU on these Pell Grant reports: Pell Grant Multiple Reporting Record (MRR) Pell Grant Reconciliation Report Pell Grant Year to Date File 20

Pell LEU within NSLDS For the award year NSLDS sends the Pell LEU to CPS for inclusion on the ISIR NSLDS Professional Access website displays Pell Grant Warning Icons to indicate the student is close to, or has met or exceeded the Pell LEU limit 21

Pell LEU within NSLDS NSLDS also provides reason codes to reflect the Pell LEU limits. Only students who are Pell Grant eligible will be considered for post-screening with the following reason codes CodeWarningThreshold EMeets or Exceeds Pell Grant LEU LimitGreater than or equal to % CClose to Pell Grant LEU LimitBetween % and % HHigh Percentage WarningBetween % and %* NNo ProblemLess than % 22

Pell LEU from CPS The applicant’s Pell Lifetime Eligibility Used field appears on the ISIR in the format % NSLDS Pell Lifetime Limit Pre-Screening Flags Identify whether an applicant is close to or exceeding his/her total Pell Grant eligibility limit  H High (450% to <500%)  C Close (500% to <600%)  E Meets or Exceeds (600% or greater) ISIR Guide was updated on 2/21/

Pell LEU Dispute Guidance Pell Awards Over 600% LEU There is no provision in the law to ‘disregard’ any Pell Grant in the calculation of a student’s LEU in a case of fraud or a Closed School Discharge as there is in the discharging of loans Compliance will be monitored and added to audit and program review procedures The new COD reject edit 201 was added to prevent schools from disbursing Pell Grant to a student with an LEU > 600% 24

Pell LEU Dispute Guidance DCL posted to IFAP on May 16, Responsibility of the institution to advocate for the student in resolving Pell data discrepancy If the amount disputed would not, if corrected, provide additional Pell eligibility, the issue should not be escalated to the Department Current and prior schools need to work together to document the student’s enrollment and receipt of Pell Grant funds for the disputed award year 25

Pell LEU Dispute Process If a student or institution believes the underlying Pell data in COD is inaccurate, the dispute process was outlined in the Electronic Announcement posted to IFAP on June 27, What the student needs to do: Needs to have filed a FAFSA Needs to work with their current institution Needs to supply all documentation requested 26

Pell LEU Dispute Process Non-Dispute Issues- Admitted Pell Reporting Errors through are active in COD and should be corrected by schools, are not considered disputes, and do not need to be escalated to the Department Prior to cannot be corrected by schools directly  Contact the COD School Relations Center  Submit documentation  The Department will make the corrections based on documentation 27

Pell LEU Dispute Process What the current institution needs to do: Work as advocate for the student by facilitating the dispute process Research the student history in institutional records, COD, and NSLDS Contact former school(s) and work together to document the enrollment and disbursed funds for the disputed period of time Determine if there is cause for a dispute, and escalate if appropriate Inform the former school(s) of the dispute case number assigned 28

Pell LEU Dispute Process What the former institution needs to do: Cooperate with current school request for information regarding the alleged discrepancy Research the student history in institutional records, COD, and NSLDS Use the case number, obtained from the current school, and include it on all requested documentation submitted to the Department 29

Pell LEU Dispute Process Escalation If it is determined that the case should be escalated to the Department, the current school contacts the COD School Relation Center and obtains a dispute case number  or The COD School Relations Center will advise what documentation is required All documentation is submitted electronically and should include the dispute case number 30

Pell LEU Dispute Process What the Department will do: Department staff will review all supporting documentation of the case, and render a decision Based on the decision, the Department will provide the school(s) with:  EITHER… An approval notification with the amount of the Pell Grant LEU adjustment. The school may then disburse Pell Grant funds  OR… A denial notification. The school will not be able to disburse additional Pell Grant funds  AND… A notification that can be given to the student documenting the Department’s decision 31

Pell LEU Dispute Process COD System changes in June 2013 accommodate Pell LEU adjustments. If the dispute escalation results in an adjustment by the Department, the new adjustments section of the Pell LEU History Screen will reflect this, and the LEU will update accordingly The updated LEU will flow to NSLDS when the current school submits a disbursement(s) for the student 32

Pell LEU Dispute Process Spring 2014 changes to the Pell LEU Dispute Process COD System will further streamline the Pell LEU dispute process with the creation of a new COD web portal. Authorized users will be able to: Create View Update Upload all documentation Pell LEU History page will display the Pell LEU Dispute status 33

Pell LEU Dispute Process Pell LEU Dispute portal will allow schools to enter dispute information for Department of Education review 34

Pell LEU Dispute Process On the Pell LEU Dispute portal, the required dispute documentation should be uploaded to the COD web 35

Pell LEU Dispute Process After a dispute has been approved, the student’s Pell LEU History page will provide details of the dispute and adjustment. 36

Pell LEU Posting References DCL, GEN 12-01, 1/18/12 -- Changes Made To The Title IV Student Aid Programs By The Recently Enacted Consolidated Appropriations Act, 2012 EA, 6/14/12 -- Pell Grant LEU Information - Additional COD System Update EA, 6/29/12 -- Pell Grant LEU Information - July 2012 System Updates for Lifetime Limit for Federal Pell Grants EA, 8/13/12 -- Pell Grant Lifetime Eligibility Used: Importance of Timely Reporting DCL, GEN 13-14, 5/16/13 -- Federal Pell Grant Duration of Eligibility and Lifetime Eligibility Used EA, 6/27/13--Guidance on the Pell Grant Lifetime Eligibility Used Dispute Escalation Process 37

Contact Information We appreciate your feedback and comments. We can be reached at: Carney McCullough Phone: Marie Fitzpatrick Phone:

QUESTIONS? 39