Student Eligibility A NASFAA Authorized Event Presented by April Cross and Lester McKenzie 2017 TASFAA Annual Conference April 23, 2017

Lesson 1: Introduction to Student Eligibility

How Does a Student Become Eligible? Meet general and program-specific criteria: Before aid is awarded or disbursed Schools cannot impose additional eligibility requirements

General Eligibility Criteria

Other Factors Affecting Eligibility Educational coursework and programs Prior degrees Enrollment status Remedial coursework Correspondence study Distance education

Quick Quiz 1: 1. What are the three broad categories of student eligibility requirements? 2. Provide an example of how a prior degree may affect a student’s eligibility for Title IV aid. 3. A student who does not have her high school diploma or its equivalent, has not completed a state approved home school program, or has not demonstrated the ability to benefit from the training or education offered by the institution, can be admitted as a regular student.  True  False Page 4

Do you believe any of the general student eligibility criteria are fair or unfair? Why? Page 5

Lesson 2: Criteria Checked Via the Application Process

Source: studentaid.ed.gov/sa/resources Application Process Source: studentaid.ed.gov/sa/resources

Federal Agencies and Systems

Database Matches SSA DHS SSS NSLDS DoD VA DoJ

Reject Codes and C-Codes FAA Information section EFC not calculated Instructions for resolution C-Code Record is flagged with “C” Ineligible until resolved Collect documentation and submit any corrections EFC calculated, but cannot be used

Document eligible status (allow at least 30 days) Citizenship Status Confirmed C-Code FAFSA SSA citizenship match Document eligible status (allow at least 30 days) Eligible noncitizen View original documents May accept images, if ensure true and exact copies Maintain copies

Citizenship Status Applies as “eligible noncitizen” Alien Registration Number required DHS primary match DHS secondary match Paper third-step confirmation

Paper third-step confirmation for eligible noncitizens Citizenship Status Paper third-step confirmation for eligible noncitizens Status documented within 30 days School may accept images Submit Form G-485 within 10 business days Verification of valid documentation only If no response within 15 business days, school makes determination Required in subsequent years only if document expires or status is conditional

Citizenship Status Eligible noncitizen Paper third-step confirmation is not used for: Victims of human trafficking and qualifying relatives Battered immigrants and designated children Native Americans lawfully admitted under Jay Treaty of 1794 School is not liable if correct procedures are followed

Quick Quiz 1: 1. What is the name of the system ED uses to process FAFSA data? 2. What two items may appear on a student’s ISIR and SAR if there is a problem with her application? 3. With what federal agency does ED perform a database match to confirm a student’s claim to be a U.S. citizen? 4. In what situation does DHS perform a secondary match? Page 15

Quick Quiz 1: 5. How much time must a school give a student who claims to be a U.S. citizen, but who fails the database match, to document his or her status?  At least 7 business days  At least 15 business days  At least 15 calendar days  At least 30 calendar days Page 16

Quick Quiz 1: 6. A school must submit a copy of the student’s documentation of his or her status as an eligible noncitizen along with a copy of a completed G-845, Verification Request to the USCIS within how many days of receiving the student’s documentation?  7 business days  10 business days  15 business days  30 business days 7. Once a student’s status has been confirmed, the school must confirm it again in subsequent award years under what conditions? Page 16

Quick Quiz 1: 8. How often must the eligibility of a victim of human trafficking be confirmed? 9. U.S. noncitizens who are eligible for Title IV aid include which of the following?  Citizens of the Federated States of Micronesia, Marshall Islands, and Palau  Persons born in Puerto Rico  Persons born in Guam, the U.S. Virgin Islands, and Northern Mariana Islands  Foreign exchange students Page 16

Social Security Number CPS conducts three types of database matches: Student SSN Parent SSN Date of Death

Social Security Number Match Confirmed C-Code FAFSA Name, SSN, and DOB match Document eligible status (allow at least 30 days) Correct SSN with SSA, or file new FAFSA View documentation of correct SSN Award and disburse Title IV aid Maintain copies

Selective Service Registration Mandatory for males between 18-26 years of age Certain exemptions allowed No database match No Title IV aid until resolved Documentation of eligible status is required School determines whether knowingly and willfully failed to register

Defaults, Overpayments and Fraud No aid awarded or disbursed until resolved NSLDS: Pre- and post-screening Transfer Student Monitoring Parent PLUS borrowers

Resolving Defaults, Overpayments and Exceeded Loan Limits Satisfactory repayment arrangement (six on-time consecutive payments) Rehabilitate the defaulted loan (nine payments within 10 months) Compromise agreement with loan holder to settle the debt Direct Consolidation Loan after three on-time consecutive payments Direct Consolidation Loan under an income-driven plan Discharged through bankruptcy (or dischargeable in active bankruptcy) Overpayment repaid or arrangements for repayment made Documented resolution of issues identified in NSLDS

Unusual Enrollment History NSLDS reveals unusual enrollment patterns Recipients of Pell Grants and certain Direct Loans within previous four years Flag Indication Action Needed Resolution N No UEH None None needed 2 (code 359) Possible enrollment pattern problem Review enrollment and financial aid records for past four years If received Pell Grant or Direct Loan funds at current school at least once in the four years, no further action required* 3 (code 360) Questionable enrollment pattern Review NSLDS and transcripts for past four years If academic credit earned at each prior school while receiving Pell Grant or Direct Loans, no further action required* *Any current concerns must be resolved.

Unusual Enrollment History Resolution Undergraduate and graduate enrollment reviewed independently School may need to review enrollment, financial aid, and academic records If no academic credit earned, student must explain Student must have opportunity to appeal School’s decision is final

Drug Convictions Department of Justice Hold File Self-reported via FAFSA Question 23 Worksheet helps student determine status Loss of eligibility may be regained

Department of Defense Increased eligibility for certain students: Death of parent or guardian; Result of military service in Iraq or Afghanistan after September 11, 2001; and Student was under 24 or enrolled in college Qualify for maximum Pell or equivalent IASG award Apply sequestration reduction to IASG

Statement of Educational Purpose Comply by signing the FAFSA Not necessary to document unless selected for verification for this purpose

Learning Activity: Determining Whether a Student Knowingly and Willfully Did not Register with Selective Service Page 31

Learning Activity: Selective Service You have an appointment with a student who failed the database match with the Selective Service System because he did not register when he was eligible to do so. He wants to discuss what he needs to do to be eligible to receive Title IV aid. In reviewing his file before his appointment, it is unclear if he qualifies for an exemption. Page 31

Learning Activity: Selective Service 1. Should you ask the student to request a Status Information Letter from Selective Service? Why or why not? 2. What additional documentation could you request from the student? You should ask the student to request a Status Information Letter from the Selective Service System. It can help you determine if the student’s failure to register was knowing and willful. The additional documentation you could request from the student includes his passport, proof of prior addresses, and letters from third parties familiar with his situation. Page 31

Learning Activity: Selective Service 3. What factors could you consider when you review the student’s documentation? The additional factors you could consider include where he was living, his citizenship status, and whether he was incarcerated or institutionalized during the time he was eligible to register. Page 31

Learning Activity: Selective Service 4. If you determine that the student is not eligible for Title IV aid because he knowingly and willfully failed to register with Selective Service, what options does he have to pay his school-related expenses? The student may be eligible for institutional aid, state aid, and private aid including loans to cover his school-related expenses. Page 31

Why are database matches an effective way to check various student eligibility criteria? Why is it appropriate for a financial aid administrator to make the final determination of a student’s eligibility for a criterion such as registration with Selective Service? What do you think is the rationale for the Iraq and Afghanistan Service Grant Program? Page 32

Lesson 3: Criteria Checked and Monitored by the School

Academic Credentials Regular student with one of the following: High school diploma or recognized equivalent Home schooling at secondary level Ability to benefit Available if first enrolled prior to July 1, 2012 Different rules if first enrolled on or after July 1, 2014 and enrolled in an eligible career pathway program

Ability-to-Benefit Alternatives

Satisfactory Academic Progress Policy requirements Qualitative and quantitative standards Frequency of evaluation Appeals Financial aid warning Financial aid probation Academic plans

Satisfactory Academic Progress Qualitative Standard Grade point average (GPA) or comparable qualitative measure Equivalent of a “C” or better Quantitative (Pace) Standard Cumulative Hours Completed Cumulative Hours Attempted

Satisfactory Academic Progress “Same as or stricter than” General for All Students Quantitative Qualitative Maximum timeframe Evaluation Components Frequency of evaluation Appeals Assessment

TEACH Grant, Direct Unsubsidized Loan, and Direct PLUS programs Financial Need Federal Pell Grant, IASG, campus-based, and Direct Subsidized Loan (i.e., need-based) programs TEACH Grant, Direct Unsubsidized Loan, and Direct PLUS programs

Program Eligibility Requirements

Learning Activity: Satisfactory Academic Progress Page 53

Learning Activity: Satisfactory Academic Progress For the case study of “Joel” on page 53, use the sample policy for calculating pace described at the top of page 60 to answer the questions regarding Joel’s academic progress. Be sure to take into consideration the loan fees for both types of loans.   Page 53

Learning Activity: Satisfactory Academic Progress 1. Joel has completed 55 credits, but he has attempted 85 credits. What is his calculated pace? 2. Based upon the institution’s SAP policy, is Joel making SAP? Why or why not? 65 percent (0.647). No; Joel is not making SAP because his pace is only 65 percent. The school in the scenario requires a 67 percent completion rate. Page 53

Learning Activity: Satisfactory Academic Progress 3. If SSU adopted the staggered approach to pace instead, would Joel be making SAP? Why or why not? Yes; Joel’s pace is 65 percent and he has earned 55 credits. In this example of a staggered approach, a student who earned between 30 to 59 credits must maintain a pace of at least 60 percent to be making SAP. Page 53

Learning Activity: Satisfactory Academic Progress 4. If Joel is not maintaining satisfactory academic progress, what could he do? 5. What would Joel’s status be if you approve an appeal? Appeal the decision or re-establish SAP eligibility on his own without Title IV aid. Financial aid probation. Page 53

Criteria Not Specifically Checked Simultaneous enrollment Judgment lien Incarceration Fraud

Quick Quiz 2: 1. Criteria not specifically checked during the processing of the FAFSA, which must be resolved if conflicting information exists, include which of the following?  The student's citizenship status, fraud, and a judgment lien on property for a debt owed to the U.S.  Incarceration, fraud, and simultaneous enrollment in an elementary or secondary school  Fraud, Social Security Number of a parent, and incarceration  Bankruptcy, judgment lien on property for debts owed to the U.S., and simultaneous enrollment in elementary or secondary school Page 56

Quick Quiz 2: 2. Define conflicting information. 3. What types of Title IV aid are incarcerated students eligible to receive? 4. When a student attempts to secure funding under false pretenses, it is considered __________.  A judgment lien  Fraud  Unusual Enrollment History  Professional judgment Page 56

Quick Quiz 2: 5. If a school suspects a student may have engaged in criminal misconduct in the Title IV application process, the school must refer the information to whom? Page 56

Learning Activity: Interview Page 57

Learning Activity: Interview 1. Does your office have a procedure to follow if a financial aid administrator suspects a student may be committing Title IV aid fraud? If so, what is it? 2. How does your financial aid office work with other offices on campus, such as the Office of Admissions, the Office of the Registrar, or the Bursar’s Office, to resolve conflicting information? Page 57

Have you ever caught a student or suspected one of committing fraud? If so, how did you handle the situation? Did you involve other campus offices or your school’s legal counsel? Is there anything you would have done differently? Page 58

Lesson 4: Educational Coursework and Programs Affecting Student Eligibility

Educational Coursework Correspondence Eligible only if part of eligible degree program Distance Education No limitation; any type of credential Remedial Eligible only for courses within the eligible program One year limitation ESL Programs If solely ESL, only eligible for Pell or IASG Remedial, if within a program

Quick Quiz 1: 1. How is correspondence coursework defined? 2. How is distance education coursework different from correspondence coursework? 3. What are the accepted modes of delivery for distance education coursework? 4. For how long may a student receive Title IV aid to pay for remedial coursework? 5. What Title IV aid is a student enrolled in a program consisting solely of ESL coursework eligible to receive? Page 76

Programs Affecting Student Eligibility Direct assessment programs Comprehensive transition and postsecondary programs Short-term programs Eligible career pathway programs

Quick Quiz 2: 1. Define direct assessment program. 2. What is the definition of a student with an intellectual disability for the purpose of enrolling in a comprehensive transition and postsecondary program? 3. What types of Title IV aid may a student enrolled in a comprehensive transition and postsecondary program receive? 4. Define short-term program. 5. What types of Title IV aid may a student enrolled in a short-term program receive? Page 80

Learning Activity: Interview Page 81

Learning Activity: Interview 1. Does the institution offer any correspondence or distance education courses? If yes, how many students enroll in such classes each academic year? 2. Does the school offer remedial courses? If yes, what is the average number of remedial credits taken by the typical student? 3. Does the school offer or plan to offer a direct assessment program? Why or why not? Page 81

Clock/Credit-Hour Conversion Purpose Exempt programs Definition of clock-hour programs Impact on: Program eligibility Student eligibility

Learning Activity: Clock/Credit-Hour Conversion Page 84

Learning Activity: Clock/Credit-Hour Conversion For the case study described on page 84, use the worksheet provided to perform a clock-credit-hour conversion. Program: Legal Eagles Institute has a one-year, credit-hour certificate court reporting program, which it offers in semesters. Students enrolled in the program complete 24 semester hours over 33 weeks. Because the program does not lead to an associate degree or higher, and is not fully transferable, the clock/credit-hour conversion requirement applies. Legal Eagles Institute has determined the total number of clock hours of instruction is 600.   Page 84

 Learning Activity: Clock/Credit-Hour Conversion The credit-hour program has 600 clock hours of instruction.  600 clock hours divided by 37.5 hours of instruction = 16 credit hours. For Title IV purposes, the program is 16 semester credits/33 weeks. Page 84

Changes in Student’s Eligibility Status Gaining eligibility SAP Resolution of issues with SSN, citizenship and Selective Service registration Resolution of any other issues Losing eligibility

Learning Activity: Changes in Student Status and Eligibility for Title IV Aid Page 86

Learning Activity: Changes in Student Status and Eligibility for Title IV Aid For the scenarios described on page 86, determine whether or not the student appears to be eligible to receive Title IV aid. If so, what Title IV aid may he or she receive, and for what time period? Page 86

Learning Activity: Changes in Student Status and Eligibility for Title IV Aid   1. Yasmine begins attendance in Fall 2017 for the 2017–18 award year. She transposes the last two digits of her Social Security Number on her FAFSA, and it takes her until the middle of February 2018 to correct the problem. Her financial aid counselor tells her that, once she resolves the issue, she would be eligible for both a Federal Pell Grant and a Direct Subsidized Loan. Eligible? Types Yes, for Pell Grant and subsidized loan funds for the entire award year. Page 86

Learning Activity: Changes in Student Status and Eligibility for Title IV Aid   2. Ivan is a sophomore. For the 2017‒18 award year, he is awarded a Federal Perkins Loan, a Direct Subsidized Loan, and FWS. He receives his Federal Perkins Loan and FWS funds during the fall term. He completes the MPN for his Direct Loan on January 10. SAP is evaluated at the end of every payment period. After evaluating Ivan’s progress on January 5, his school determines that Ivan is not maintaining SAP. Eligible? Types No, as of 1/5. He may keep the fall Perkins payment and FWS earnings. Direct loan only if qualifies for it as a late disbursement. Page 86

Learning Activity: Changes in Student Status and Eligibility for Title IV Aid   3. Tatiana is a third-year student for the 2017–18 award year who previously attended a community college. She waited three years, during which time she did not make any loan payments. When her ISIR arrives, it indicates she is in default on that loan. Tatiana resolves the default on February 1, two weeks after the term starts. Tatiana is awarded a Federal Pell Grant, FSEOG, and a Direct Subsidized Loan. Eligible? Types Yes, Pell Grant and FSEOG for only the spring semester and Direct Loan funds for the entire period of enrollment. Page 86

What are the benefits of allowing students to receive Title IV aid while taking coursework in different formats, such as correspondence coursework and direct assessment programs? Why do you think certain student eligibility criteria are waived for students enrolled in a comprehensive transition and postsecondary program? What could be the rationale for allowing students who lose eligibility during the award year due to a change in eligibility status to receive Title IV aid for the remainder of the year? Page 87