1. MASFAA Conference November 17 - 18, 2015
“Maintaining Compliance in Non-Standard and Non-Term Program Environments”
Presented By:
Karyn Wright-Moore
VP, Compliance & Quality Assurance
MASFAA Conference
November , 2015
60 Walnut Street, 4th Floor
Wellesley, MA 02481

2. Discussion Topics Overview: Non- Standard and Non-Term Program
Academic Year Requirements
Payment Periods & Disbursement Requirements
Other Considerations
Attendance and other related academic requirements
Grade Level Progression & Satisfactory Academic Progress (SAP)
Withdrawal and Return to Title IV Funds (R2T4) Requirements
Institutional Considerations
Q & A

3. Overview: Non- Standard and Non-Term Program
A Term is defined as:
a discrete period of time during which all courses are scheduled to begin and end.
Within a term: full-length courses, compressed courses or modules, and courses offered sequentially.
Academic Calendar Definitions:
Standard Term: a semester or trimester (generally weeks long) or a quarter
(generally weeks long). Academic progress is measured in semester or quarter credit-hours, and full-time is at least 12 semester or quarter credits.
Non-standard Term: all coursework begins and ends within a set period, but it is not a semester, trimester or quarter. Terms may be of unequal length. length of the term is not associated with the type of credit-hours awarded.
Non-Term: Courses do not all begin and end within a discrete period of time and may:
- contain self-paced or independent study courses without fixed timeframes
- consist of sequential modules, or courses that do not begin and end within a term (overlapping).
- clock-hour programs are always non-term

4. Overview: Non- Standard and Non-Term Program
Back to Basics: Academic Year Definition
Academic Year: Weeks of instructional Time
For a credit-hour program: at least 30 weeks
For a clock-hour program, at least 26 weeks.
Academic Year: Credit or Clock Hours
24 semester or trimester credit-hours or 36 quarter credit-hours
900 clock-hours

5. Payment Periods & Disbursement Requirements
Academic Calendar & Terms:
Standard Term Example: Academic Year; 30 Weeks, 24 Credits
Non-Standard Term Example:, Academic Year; 40 Weeks, 28 Quarter Credits
Non Term Example: Academic Year; 26 Weeks, 24 Credits (or 26 Weeks, 900 hours)
13 Weeks/ 12 Credits
15 Weeks/12 Credits
15 Weeks/12 Credits
18 Weeks/ 14 Quarter Credits
22 Weeks/14 Quarter Credits
2 additional weeks per period if credit hour non-term)
4 wks/4 credits (or 150 hours)
4 wks/3 credits (or hours)
5wks/5credits (or hours)
13 Weeks/12 Credits (450 Hours)

6. Payment Periods & Disbursement Requirements
“Substantially Equal in Length”
34 CFR 668.4(h)(1) For purposes of measuring payment periods in programs offered in nonstandard terms, “substantially equal” means that no term in the program is more than 2 weeks of instructional time longer than any other term in that program. “Not substantially equal in length” means nonstandard terms that have at least 1 term more than 2 weeks of instructional time longer than another in the same program.
The following types of programs must use payment periods that are based on the time it takes for the student to successfully complete the credit or clock-hours and weeks of instructional time in the payment period:
Non-term credit-hour programs
Clock-hour programs
For Direct Loan purposes, nonstandard term credit-hour programs with terms not substantially equal in length

7. Payment Periods & Disbursement Requirements
If the program is one academic year or less:
Divided into two payment periods.
The first payment period is the period in which the student successfully completes half of the credit or clock-hours AND half of the weeks of instructional time in the program. The second payment period is the period in which the student completes the remainder of the program.
If the program is more than one academic year:
Use the rule for one academic year (above) for each full academic year in the program.
For any remaining portion of a program that is half of an academic year or less, the remaining portion is treated as a single payment period.
For any remaining portion of a program that is more than half of an academic year but less than a full academic year, the remaining portion is divided into two payment periods and the first payment period is the period in which the student successfully completes half of the credit or clock-hours AND half of the weeks of instructional time in the remaining portion.

8. Payment Periods & Disbursement Requirements
Academic Calendar & Terms:
Standard Term Example: Academic Year; 30 Weeks, 24 Credits
Non-Standard Term Example:, Academic Year; 40 Weeks, 28 Quarter Credits
Non Term Example: Academic Year; 26 Weeks, 24 Credits (or 26 Weeks, 900 hours)
13 Weeks/ 12 Credits
15 Weeks/12 Credits
PP1 (all aid sources)
15 Weeks/12 Credits
PP2 (all aid sources)
Formula 1
Not SE
Not SE
18 Weeks/ 14 Quarter Credits
Pell 2
22 Weeks/14 Quarter Credits
Pell 1, Loan 1
Formula 3
Loan 2 (20 wks)
PP2
Pell 2, Loan 2
2 additional weeks per period if credit hour non-term)
PP1
4 wks/4 credits (or 150 hours)
4 wks/3 credits (or hours)
5wks/5credits (or hours)
Pell 1, Loan 1
13 Weeks/12 Credits (or 450 Hours)
Formula 4

9. Payment Periods & Disbursement Requirements
Programs with nonstandard terms not substantially equal in length
For purposes of Pell Grants, TEACH, FSEOGs, and Perkins Loans, if the program uses nonstandard terms, the payment period is the term. This includes terms that are not substantially equal in length.
For Direct Loans, if a credit-hour program has nonstandard terms that are not substantially equal in length, the payment periods are based on the time it takes for the student to successfully complete the credit or clock-hours and weeks of instructional time in the payment period

10. Other Considerations
Schools may combine a series of modules into a single term
Enrollment can begin at beginning of any module
Students may skip one or more modules within the term
Students must progress to the next payment period based on hours and weeks completed
Cost of attendance excludes periods of non-attendance
Loan period includes entire term
Student must begin attendance in all credits or recalculation required (except loans)
Change in enrollment status to less than half-time may result in cancellation of subsequent loan disbursement
Up-front enrollment (registered courses) should support aid eligibility and award amount

11. Attendance and Other Related Academic Requirements
Enrollment Status:
Minimum full-time enrollment standard for undergraduate credit hour programs is 12 credits per term
Minimum full-time enrollment standard for undergraduate clock hour programs is 24 clock hours per week
24 hours per week will complete 900 hours in 37.5 weeks
30 hours per week will complete 900 hours in 30 weeks
35 hours per week will complete 900 hours in 26 weeks
For Credit Hour Programs, half-time is defined as half the load of full-time (minimum 6 credits)
Checking 1/2-time enrollment status in a clock hour program:
Enrollment status only makes a difference if the student is attending less than-halftime.
The annual Pell award for a student in a clock-hour program is taken from the full-time payment schedule even if the student is attending less than full-time.
Excused absences in clock-hour programs
Allowed to count a limited number of excused absences in a payment period
Excused absence may only be counted if the student is excused from hours that were actually scheduled, were missed, and do not have to be made up
Must be permitted in your school’s written policies
No more than 10% of the clock-hours in a payment period may be considered excused absences
Must follow stricter standard if required by accrediting agency or state

12. Grade Level Progression & Satisfactory Academic Progress (SAP)
Progression to a higher grade level and the beginning of a new academic year for loan limit purposes always happens at the same time;
Payment Period Progression requires that the student:
successfully complete both the weeks and the clock or credit hours in the program’s FSA academic year
Satisfactory Academic Progress Standards:
Quantitative Standards (Pace) standards apply (as defined by institution and/or regulation)
Qualitative Standards apply (GPA standard as defined by institution and/or regulation)
Financial Aid Warnings, Probation and Appeal Standards apply
Short term clock hour programs (one year or less) may forgo “warning” periods due to time constraints and require appeals and probationary periods (through and including maximum timeframe limitations)

13. Grade Level Progression & Satisfactory Academic Progress (SAP) cont…
Maximum Timeframe:
For an undergraduate credit hour program:
a period no longer than 150 percent of the published length of the program
For a Clock Hour Programs:
No longer than 150 percent of the published length of the program as measured by the cumulative number of clock hours the student is required to complete and expressed in calendar time.
26 weeks (program length) + 13 weeks (50% of program length) = 150% or 39 weeks, as expressed in calendar time

14. Withdrawal and Return to Title IV Funds (R2T4) Requirements
Return to Title IV – For schools required to take attendance:
Measuring the clock hours a student completes in a program is a requirement to take attendance for clock hour programs
If a school is required to take attendance, a student’s withdrawal date is always the last date of academic attendance as determined by the school from its attendance records. This date is used for all students who cease attendance, including those who do not return from an approved LOA, those who take an unapproved LOA, and those who officially withdraw.
Return to Title IV – For schools NOT required to take attendance:
Must take attendance for students enrolled in clock hour programs
Not required to take attendance for non-clock hour program students (unless the school is required by another entity)
If a school is not required to take attendance, the determination of a withdrawal date varies with the type of withdrawal. The chart on Withdrawal Dates in Volume 5—Withdrawals and the Return of Title IV Funds, 2015–2016 FSA Handbook, Page can be used as a tool to determine the withdrawal date.
Treatment Of Title IV Funds When A Student Withdraws From A Clock-Hour Program:
Scheduled hours used to determine the percentage completed (scheduled hours to date/total hours in the payment period or period of enrollment)
Excused Absences in calculating percent attended
100% earned after 60% of scheduled hours

15. Withdrawal and Return to Title IV Funds (R2T4) Requirements
Special Treatment of students who withdraw and then transfer or reenter a credit-hour, non-term-based program or a program that measures progress in clock hours
Reentry within 180 days
Reentry in a new award year
Reentry after 180 days
Transfer into a new program at the same institution
Transfer to a new institution

16. Institutional Considerations
Determine Program Title IV Eligibility PRIOR TO Enrollment and Registration
Student Information System Requirements
Financial Aid Staff Knowledge
Academic/Faculty Engagement in Understanding Title IV Administration
Policy Updates
Institution’s Capacity and Willingness to take and monitor attendance
Potential Disbursement Delays (due to payment period progression)

17. VP, Compliance & Quality Assurance
Questions?
Thank You to the MASFAA 2015 Conference Committee and To The Conference Attendees!!
“Maintaining Compliance in Non-Standard and Non-Term Program Environments”
Presented By:
Karyn Wright-Moore
VP, Compliance & Quality Assurance
60 Walnut Street, 4th Floor
Wellesley, MA 02481