1. Beginners & Advanced CLOCK HOUR SCHOOLS WVASFAA presentation 2016 Spring Conference, Updated presentation from 2012

2. DEFINITIONS Eligible Student: – Has a High School Diploma or GED – Meets school’s admission requirements – Is NOT in default on a Federal Student Loan or owe a Federal Grant Overpayment – Meets citizenship/permanent residency requirements – If male, has met Selective Service Registration requirements – Is enrolled in an eligible program

3. DEFINITIONS Eligible Program: – Is at least 600 clock hours in length and meets at least 12 clock hours per week – Has been approved by State Ed and school’s accrediting agency – Leads to a certificate in a recognized occupation

4. DEFINITIONS Clock Hour: – Is a 50 to 60 minute class – lecture, lab, or any combination – Must be supervised classwork – Attendance must be taken in some form – You CANNOT credit clock hours in excess of hours on the clock! An 8 a.m. to 2:30 p.m. schedule can be a maximum of 6 ½ clock hours (allows for a total of 65 minutes of “break time”) DO NOT calculate 6.5 hours on the clock x 60 minutes / 50 minutes and credit 7.8 clock hours!!

5. DEFINITIONS Award Year: July 1 st through June 30 th of any given year – current award year is 2015-2016, upcoming award year is 2016-2017 Academic Year: 900 clock hours – maximum number of hours a student can be awarded Pell Grant payment for in any given award year.

6. DEFINITIONS Payment Period: 450 hours (1/2 the academic year) or ½ course length if course is less than 900 hours. – Student must complete hours for which they have been paid before receiving payment for the next payment period – Students can ONLY be paid for the hours in the course; they cannot be paid to repeat hours, and cannot be paid for prior credit hours granted by the school. – Schools must confirm Satisfactory Academic Progress at the close of each payment period.

7. Definitions Crossover Payment Period: Any payment period which crosses over the June 30 th /July 1 st point from one award year to the next – Schools may pay crossover payments from either year in which the student has available Pell – A crossover payment period may NOT have more than 6 months fall in any one of the award years – The school must ensure that the student has not used their Pell eligibility for a given award year at a prior school – A school should consider what benefits the student best when determining crossover payment decisions as this may be a student by student decision

8. DEFINITIONS Enrollment Period: That number of hours the schools charges tuition and fees by. – Impacts school’s refund policy – Can be entire course, or any portion thereof – DOES NOT prevent the school from collecting total course cost in advance of enrollment period commencement

9. DEFINITIONS Cost of Attendance: – Tuition & fees (registration, application, lab fee) – Books & Supplies (books, equipment, uniforms) – Other Costs (testing, club dues, etc) – Room & Board (estimate based upon your area) – Transportation (estimate based upon your area) – Cost of Attendance (COA) includes all costs associated with a student’s attendance in a program – not just school charges! – COA helps a student make an informed decision!

10. DEFINITIONS PELL GRANT COA: – An adjusted COA used to determine a student’s Pell Grant award Tuition & fees are adjusted to 900 hours worth of cost Room, Board, Transportation, and Personal Expenses are adjusted to 900 hours worth of cost Books, Supplies and other costs may be “assigned” as belonging to “upfront” charges and need not be adjusted.

11. DEFINITIONS Refund Policy: – A school’s stated policy to deal with students who withdraw or are terminated from a program Identifies non-refundable fees, charges, and/or materials Identifies the period of enrollment for which the program charges are based – May be the entire program hours or a portion of the program hours – Whatever percentage refund is based ONLY upon the enrollment period the student is in.

12. POLICIES Satisfactory Academic Progress (SAP) – 3 basic requirements are QUANTITATIVE, QUALITATIVE, and APPEAL components Minimum “C” average Maximum timeframe of 150% of originally scheduled time to complete program A mechanism for a student to appeal a determination

13. SAP, Continued… Students status must be confirmed at the close of each payment period, regardless of the school’s grade periods, using one of the following options for all students in a given program: – At the point when the student’s scheduled clock hours for the payment period have elapsed, regardless of whether the student attended them; – At the point when the student has attended the scheduled clock hours; or – At the point when the student successfully completes the scheduled clock hours for that payment period.

14. SAP, continued… Should a student fail to maintain SAP at the close of a payment period, the school may, depending upon their policy: Terminate the student from the program Place the student on Financial Aid Warning for the following payment period Place the student on Probation

15. SAP, continued… Whatever the school’s policy is, THE SCHOOL – its administration and faculty – MUST ADHERE TO THE STATED POLICY!!!

16. POLICIES Attendance Policy: – The US Department of Education allows a school to “count” only 10% absences in any given payment period toward a student’s completion of hours In a 450 hour payment period where a student attends school 6 hours per day, at the student’s 75 th day there are 450 scheduled hours; the student may have no more than 45 hours absent at this point to have completed their payment period. If the student has 60 hours absent, the student must attend school the additional 15 hours before they are considered to have completed their payment period.

17. Attendance, continued…. Schools may use a percentage or hour based policy Should have a mechanism for periodic review, discussion, and student consequence Should be clearly and consistently applied to all students A school is obligated to a student for the scheduled hours in the student’s course; any hours required by the student in excess of the scheduled hours may be assessed as an additional cost which CANNOT be covered by Pell Grant.

18. Attendance, continued…. A school may schedule MORE hours for a course than the course length in order to account for inclement weather, etc., but the required hours would be what the school bases its tuition, payment periods, and attendance on!

19. POLICIES Approved Leave of Absence: – A leave of absence MAY be offered to students who, through no fault of their own, must temporarily withdraw from school, but fully intend to return and complete their program. – Must be requested in writing and approved in advance of the leave, and may generally not exceed 120 days in total – a LOA can be one period, or multiple periods – May be for medical, military, or family concerns

20. Leave of Absence, continued…. Leave of Absence CONCERNS: – Can the student return to the program, or must they wait until the program repeats? – Is the student maintaining SAP & adhering to the school’s attendance policy? – Students returning from a LOA DO NOT INCUR ANY ADDITIONAL CHARGES! – Students who are terminated/withdrawn and choose to return are re-enrolled with new charges. – Students who fail to return from a LOA must be withdrawn upon their failure to return.

21. POLICIES Inclement Weather Days: – Do adult students have to make up days the school is closed or delayed? – Do out-of-county adult students have to make up missed time when their home county is closed for weather concerns? – It is up to the school to ensure that it schedules enough hours for post-secondary students to complete their course hours!

22. POLICIES Prior Credit – School must have policy & procedure to determine whether or not to grant prior credit, along with the conditions and/or limitations on the number of hours credit granted – Course Cost and Financial Aid are based on a student’s course length – Should be determined prior to student beginning class so cost/attendance requirements/ aid can all be adjusted

23. Course Scheduling A school may only pay Pell Grant for 900 hours during any given award year - July 1 st – June 30 th. Payment periods for courses of MORE than 900 hours have specific rules for the hours over 900 hours – If the number of hours over 900 is less than 450, the payment period would be the remaining hours – If the number of hours over 900 IS 450, that is the payment period – If the number of hours over 900 is MORE than 450, the payment periods would be half the number of remaining hours

24. Course Scheduling, continued… Examples: – 1080 hour course 6 hours/day from 8/19/15 to 6/6/16: Payment periods are 450 hours, NO payment for remaining 180 hours 3 hours/day from 8/19/15 to 6/6/17: 1 st payment period 0-450 hours from 2015-2016 Pell. 2 nd payment period from 450-900 hours from EITHER 2015-2016 OR 2016-2017, and 3 rd payment period of 900-1080 hours from 2016-2017 The 2 nd payment period should be made from the year the student qualifies for the higher Pell award!

25. Course Scheduling, continued… – 1215 hour course 6 hr/day, 7/20/15 to 6/8/16: Payment periods are from 0-450, 450-900, NO PAYMENT for 900-1215 6 hr/day, 1/4/16 to 12/20/16: Payment periods are from 0-450, 450-900, 900-1215 – 1 st payment from 2015-2016 – 2 nd payment from EITHER 2015-16 OR 2016-17 – 3 rd payment from 2016-17

26. Course Scheduling, Continued… – 1350 hour course 6 hr/day, 7/1/15 – 6/23/16: Payment periods are 0- 450, 450-900, NO PAYMENT for 900-1350 6 hr/day, 8/1/15 – 7/23/16: Payment for 0-450, 450- 900 from 2015-16, with the last payment 900-1350 from 2016-17 Once a course exceeds 1350 hours, but is LESS than 1800 hours, the hours OVER 900 are evenly divided!

27. Course Scheduling, continued – 1400 hour course Payment periods are 0-450, 450-900, 900-1150, 1150-1400 Course must be scheduled so that the 900-1150 payment period is a crossover payment period OR the student will NOT be paid for these 250 hours! – 1800 hour course Payment periods are 0-450, 450-900, 900-1350, 1350-1800 Again, the 3 rd payment period MUST cross the June 30/July 1 point or the student would NOT be paid for these hours!

28. Pell Grant Calculation Determine the SCHEDULED AWARD – Cross reference the student’s Pell Grant Cost of Attendance with the student’s EFC on the FULL TIME Pell Scheduled Award Chart – clock hours school ALWAYS USE the FULL TIME CHART! – Calculate the expected disbursement for the payment period: – Scheduled award x hours in payment period / hours in academic year = expected disbursement for the payment period

29. Pell Grant Payments Pell Grant payments are ALWAYS made at the beginning of the payment period – A school is NOT required to make payment until a student has submitted all required documents and/or signatures – A school is NOT permitted to arbitrarily delay payment – A school which requires a student to purchase books/supplies outside the school MUST provide an eligible student with their Pell Grant payment within 7 days of the course start date!

30. Pell Grant Payments, continued A school may credit the Pell Grant payment to a student’s account, and then MUST issue a receipt for payment. If the Pell Grant payment results in a credit balance, the school must issue a refund check to an eligible student within 14 days.

31. Student Payments The school should have some sort of individual account card for each enrolled student which clearly identifies all charges, payments and receipt numbers, and refunds with corresponding check numbers. – Your county school board accounting office can instruct you on required “breakdown” of charge and fee types you need to report to them – your accounting system should reflect this for ease of reporting. – Different charges are dealt with differently in your refund policy – if you cannot identify these charges individually, you cannot consistently apply your refund policy. The school should have an itemized and individually priced list of books, supplies, and/or equipment which the school offers for sale to a student; the student must, in some way, acknowledge receipt of said items in order for the school to be sure the student received the items.

32. School Charges Application Fee – a non-refundable fee paid by the student PRIOR to admission to a program. This fee may cover any required testing but would also cover the school’s upfront expenses incurred prior to a student beginning school. Registration Fee – a non-refundable fee paid by the student upon admission/acceptance into a program – this fee may cover the cost of student scheduling Tuition – The amount charged for the course offering; a school may set an overall hourly price for all programs, or vary their tuition by program; tuition is a pro-rata charge for refund purposes Lab Fee – A set amount per course which should reflect the school’s disposables cost per student in a given program – this would include the cost of student paper, ink, computer usage, as well as the cost for ‘wear & tear’ on school owned equipment and school provided supplies. While a Lab Fee for a business-type program might be minimal, the fee associated with a welding course might be substantial.

33. School Charges, cont. Books, Supplies, Equipment – Some schools provide “book packages”, “supply kits” and/or “equipment sets” that the student purchases from the school, and remain the property of the student. These items should be charged at the point the student accepts possession of the items, as most schools label these items as “non-refundable”. Schools can often provide these items less expensively than the student could purchase them. A school MUST have a detailed list of all items being sold to the student, because the school cannot require the student to purchase these items from the school. A school CAN require that the student obtain the listed items. Uniforms – Uniforms are another example of “non-refundable” items, whether the school acts as an agent for an outside entity for uniform purchase or the school acts as an agent for uniform rental. Club Fees – A school CAN require a student to purchase membership in vocational or professional associations, and can collect these fees as a non-refundable item.

34. School Charges, cont. Testing/Certification – A school must itemize testing fees as either refundable or non-refundable, and may only retain certification fees for certifications applied for by the student. A charge for random drug screens can be non- refundable, even if the student is never screened. Certification fees can be nonrefundable if all students are given the opportunity to be certified as part of the course; Certification fees collected in advance of the student’s graduation & certification must be refunded if the student withdraws prior to graduation. Activity Fees – A school can charge a non-refundable activity fee to cover costs associated with the student’s course activities

35. School Charges, Cont. Other Charges: – Rental fees can be refundable or not – Parking fees can be non-refundable – Graduation fees are refundable if the student does not graduate – Contracted Services are usually charged at point of service and are non-refundable.

36. But let’s not forget DATA Every program at a clock hour school is a GAINFUL EMPLOYMENT program! - Keep your CIP codes up to date - Annual submission of the Gainful Employment Report using the Gainful Employment Template available at USDE’s SFA Software & Downloads; data is uploaded to GE via NSLDS. - Maintain required template data in easily accessed format The IPEDS surveys pull data from every area of school operations - identify your FIRST TIME FULL TIME students for detailed reporting Garbage in – garbage out

37. QUESTIONS? Contact Info: diannclothier@hotmail.com 304-655-7561 (home) 304-266-0655 (cell)