Carney McCullough and Kathleen Wicks| Nov U.S. Department of Education 2012 Fall Conference Pell Grant Program Update Session 4

Agenda 2 What are the main provisions in the Pell Grant Interim final rule? Why is there now a limitation on a student’s receipt of Pell Funds? What did ED do to collect Pell History? How do students know their Pell LEU? How do institutions know a Pell LEU? What to do if you believe the Pell Grant data may be inaccurate? What happens if a student receives more than 600% LEU? Timely Reporting How do you calculate remaining Pell eligibility? How do you calculate a Pell award with a LEU greater than 500%? May a student decline or return a Pell Grant?

3 Implemented the provision of the Department of Defense and Full-Year Continuing Appropriations Act, 2011 (Public Law ) that repealed the provisions that allowed an eligible student to receive a second Pell Grant Scheduled Award in a single award year Published in the Federal Register on May 2, 2012 (77 FR 25893) Received 10 comments Final rule will be adopted as final, without change, the interim final review and the publication is expected soon Pell Grant Interim Final Rule What are the main provisions in the Pell Grant Interim final rule?

4 The Pell Grant Interim regulations will no longer: Allow a student to receive more than one Pell Grant Scheduled Award in a single award year Require an institution to assign a payment period that occurs in two awards years to the award year in which the student would receive the greater payment for the payment period Pell Grant Interim Final Rule What are the main provisions in the Pell Grant Interim final rule?

5 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 Limitation on Pell Funds Why is there now a limitation on a student’s receipt of Pell Funds?

6 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 lifetime eligibility used (LEU) limit When a student reaches 600% LEU, he/she has reached his/her Federal Pell Grant eligibility limit Limitation on Pell Funds Why is there now a limitation on a student’s receipt of Pell Funds?

7 Gathered all Pell Grant information from across all Pell legacy systems Created logic to calculate semester equivalent as LEU percentage Loaded the calculated LEU percentage to existing students records in NSLDS in July 2012 LEUs were not added if there was not already an NSLDS record for the student NSLDS Grant information existed only since New records are added as loan or grant recipient information is accepted Pell Award History What did ED do to collect Pell History?

8 Also in July 2012, the COD System modified the existing LEU functionality: Returning the Pell LEU % in the common record response for ALL Pell recipients Modifying COD Warning Edits to reflect new limits Providing the LEU % on the Pell Grant Multiple Reporting Record (MRR), Pell Grant Reconciliation Report, and Pell Grant Year to Date File Displaying LEU % on the COD website for ALL Pell recipients, not just those with first Pell Grants beginning in Implementing a new COD Pell LEU History page on the COD website to allow institutions to view historical Pell Grant student data to determine how the LEU was calculated Pell Award History What did ED do to collect Pell History?

9 For the award year Between April 16 and July 1, COD sent targeted messages to FAFSA Pell-eligible applicants near, or exceeding, an LEU percentage of 600% In July 2012, the CPS began reporting Pell LEU information on SARs, using comment codes to alert applicants who are close to or have exceeded 600% LEU Using Comment Codes avoided mid-cycle changes to the ISIR record layout See SAR Comment Codes and Text Guide reissued June 2012 How do students know their Pell LEU?

10 For the award year, students can determine their Pell LEU by: Additional comments will be added to the SAR 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 October 2012 How do students know their Pell LEU?

11 MyStudentData allows students to download their loan, grant, and aid overpayment history but does not display Pell LEU To minimize confusion, do not refer to MyStudentData Download for LEU Institutions may provide transcripts from COD How do students know their Pell LEU? NSLDS

12 COD Transcript can be provided by the institution for the student How do students know their Pell LEU? COD System

13 Schools can utilize the COD Pell LEU Report to identify Pell-eligible CPS applicants with LEUs greater than or equal to 450%. Each institution’s report includes students who listed a Federal institution Code on their FAFSA Generated weekly in an institution’s Pell newsbox on COD Reporting website CSV format so it can be easily imported and sorted Generated for award year until 6/30/2013 For , the Pell LEU Report will be available via SAIG, not COD Reporting website How do institutions know a Pell LEU? COD System

14 On the COD website, institutions can also lookup a student’s LEU using: Pell Person Information page Pell LEU History Search Pell LEU History page How do institutions know a Pell LEU? COD System

15 How do institutions know a Pell LEU? COD System

16 How do institutions know a Pell LEU? COD System

17 How do institutions know a Pell LEU? COD System

18 Export Summary is in Excel format Transcript that may be printed and provided to students How do institutions know a Pell LEU? COD System

19 Two Pell LEU warning edits are given with origination and/or disbursement record: Edit #Message 177Lifetime Percentage of Eligibility Used is near the lifetime limit 178Lifetime Percentage of Eligibility Used has exceeded the lifetime limit Pell LEU within COD COD Warning Edits

A Pell LEU within COD COD Response Record

Pell LEU within COD COD Reports COD also provides the LEU on the following Pell Grant SAIG reports: Pell Grant Multiple Reporting Record (MRR) Pell Grant Reconciliation Report Pell Grant Year to Date File 21

22 The new Pell Lifetime Eligibility Used field provides the percentage of the total Pell Grant eligibility used by the applicant This percentage prints on the ISIR in the format % NSLDS Pell Lifetime Limit Pre-Screening Flag Three Pell Lifetime Limit 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 published on 10/29/ Pell LEU From CPS ISIR

23 NSLDS received a one-time update of Pell Grant LEU percentages from COD in July Included Pell Grant recipients from award year to present LEU percentages for students with no NSLDS record(s) were not loaded Since the one-time update, COD sends LEU percentages to NSLDS when Pell Grants are made or changed Pell LEU From NSLDS One-Time Update

24 Starting with award year, the following will be available via NSLDS: NSLDS will start sending the Pell LEU% to CPS for inclusion on the ISIR NSLDS Professional Access website to display Pell Grant Warning Icons – “Close to Pell Grant LEU Limit” and “Meets or Exceeds Pell Grant LEU Limit” Pell LEU within NSLDS Warning Icons

25 NSLDS will also provide reason codes to reflect the new 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 or equal to % *previously between % and % Pell LEU within NSLDS Reason Codes

26 If a student or institution believes a LEU is inaccurate, the following actions should be taken: Student Need to work with their current institution Institutions Need to work as advocates for the student Review the student history in COD and provide a copy to the student If data, the information that results in the student receiving partial or no Pell eligibility is still in question, the institution will receive direction on how to escalate the matter to FSA for adjudication Pell Data What to do if you believe the Pell Grant data may be inaccurate? Note: Documentation will be required. This may include student statement, institution attestation, etc.

27 If the Pell Grant data is determined to be wrong, both the student and the institution that wishes to pay the student, will be given documentation that must be maintained. Institution: Audit trail that the student payment is proper Student: To be used in the event of transfer COD, CPS, and NSLDS will continue to reflect the inaccurate information until future system modifications are made COD Edits 177 and 178 will continue to be returned Most common claim to date is that the student did not attend an institution listed or receive the funding listed in the LEU history Pell Data What to do if you believe the Pell Grant data may be inaccurate?

28 There is NO HARD REJECT EDIT in COD or EDExpress that prevents an institution from disbursing Pell awards to a student with an LEU of > 600% in the and award years There is no provision in the law to ‘disregard’ 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 New edits are planned for to prevent overawarding and reject disbursements that result in overawarding Awards Over 600% LEU What happens if a student receives more than 600% LEU?

29 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 Rounding rules do not apply if the amount disbursed would place the student’s LEU > % Student is liable for any Pell Grant overpayment Institution should follow the normal procedures for handling an overpayment: Contact student and enter into satisfactory repayment arrangements Refer to the Department for collection Awards Over 600% LEU What happens if a student receives more than 600% LEU?

30 Electronic Announcement posted on August 13, bilityUsed.html bilityUsed.html Reminds institutions of the importance of Pell Grant disbursements AND adjustments In future award years, may reduce the reporting timeframe Timely Reporting

31 Example 1 Scenario: Student is full-time in a semester program and has 0 EFC and a $5,550 scheduled award Action: Calculate student’s Pell eligibility by taking percentage on report from % Report says % % % = % % x $5,550 = $3, First semester award = $2,775 Second semester award = $ or $ (do not round up) Pell Calculation Examples How do you calculate remaining Pell eligibility?

32 Example 2 Scenario: Student is full-time in a semester program and has 525 EFC and a $5,000 scheduled award Action: Calculate student’s Pell eligibility by taking percentage on report from % Report says % % % = % % x $5,000 = $1, First semester award = $1, Second semester award = $0 Pell Calculation Examples How do you calculate a Pell award with a LEU greater than 500%?

33 See Dear Colleague letter, GEN A student may: Decline all or a part of a Pell Grant award Return, during an award year, all or a part of a disbursement already made within the same award year The student must provide a signed, written statement: Clearly indicating his/her decline/return of Pell Grant funds Acknowledges that funds may not be available at a later date Declining a Pell Grant May a student decline or return a Pell Grant? Note: An institution may not package need-based Title IV aid to compensate.

Contact Information 34 We appreciate your feedback and comments. We can be reached at: Carney McCullough Phone: Kathleen Wicks Phone:

QUESTIONS? 35