Kim Wells and Aaron Washington | Dec U.S. Department of Education 2015 FSA Training Conference for Financial Aid Professionals Student Eligibility (excluding SAP and Citizenship) Session 24

School-Determined Eligibility 2

Regular Student/Eligible Program Regular student = someone enrolled/accepted for enrollment in eligible institution to obtain degree or certificate Conditional acceptance – only considered regular student if school officially accepts into eligible program Remedial coursework – if admitted into eligible program and remedial part of program, may include up to one year’s worth in enrollment status for TIV purposes One year=45 quarter credits, 30 semester/trimester credits or 900 clock- hours 3

Regular Student/Eligible Program Regular student exceptions Teacher certification Can award Direct Loans, Federal Work-Study (FWS) and Federal TEACH Grant to otherwise eligible students enrolled in teacher certification programs that do not lead to degree/certificate awarded by school Students with intellectual disabilities Must be part of Comprehensive Transition and Postsecondary (CTP) Program 4

Elementary & Secondary Enrollment Students cannot receive Title IV while enrolled in elementary or secondary enrollment, even if enrolled in college coursework at same time Considered enrolled if pursuing HS diploma or if completed requirements for diploma, has not yet received it and is either Taking college coursework for which HS gives credit, OR HS still considers student enrolled there 5

Satisfactory Academic Progress (SAP) Student must be making SAP and school must have reasonable policy that cumulatively measures qualitative and quantitative components Qualitative = GPA or other comparable measure against norm Quantitative = pace of completion ensures completion within maximum timeframe 150% for undergraduate programs 6

Satisfactory Academic Progress Other sessions offered #25 –Satisfactory Academic Progress 12:20 p.m. – 1:35 p.m., Tues., 12/01 1:55 p.m. – 3:10 p.m., Wed., 12/02 9 a.m. – 10:15 a.m., Fri., 12/04 7

Enrollment Status Student must be enrolled at least ½ time for Direct Loan programs In general, Federal Pell Grant, TEACH Grant, & Campus-Based programs don’t require ½ time status Two exceptions that do require ½ time enrollment Teacher education post-baccalaureate programs Teaching credential programs – but only for FWS and Federal Perkins Loan Minimum definition of FT for undergraduate students = 12 credits School determines definition of FT for graduate programs 8

Drug Convictions Federal or state conviction of possession or sale of drugs may disqualify student from TIV eligibility Must be for offense that occurred during period of enrollment for which student was receiving TIV aid 9

Incarcerated Students Incarcerated students not eligible for FSA loans but are eligible for FSEOG and FWS Also Pell Grant eligible if not incarcerated in federal or state penal institution Incarcerated = serving criminal sentence in federal, state or local penitentiary, prison, jail, reformatory, work farm, or similar correctional institution Halfway house, home detention, or serving only weekends does NOT equal incarceration School may accept student’s written self-certification that s/he is no longer incarcerated 10

Experimental Sites Initiative Allows participating institutions to provide Federal Pell Grants to otherwise eligible students who Are incarcerated in Federal or State penal institutions But will be eligible for release into the community generally within 5 years 11

12 Waivers Law/RegulationDescription Section 401(b)(6) of the HEAProvides that students who are incarcerated in a Federal or State penal institution are not eligible to receive Federal Pell Grant funds. 34 CFR (c)(2)(ii)For purposes of the Federal Pell Grant Program— …Is not incarcerated in a Federal or State penal institution; Second Chance Federal Pell Grant

Exceptions The following student eligibility restrictions are not waived: 13 Convictions for drug possession or sale while receiving Title IV aid (Section 484(r) of the HEA) Involuntary civil commitment after incarceration for sexual offenses (Section 401(b)(6)) Cost of attendance provision for incarcerated students (Section 472(6))

Academic Qualifications 14

High School Diploma Certificate of graduation from a school providing secondary education ED relies on a state's determination as to what constitutes a high school diploma 15

Recognized Equivalents of a H.S. diploma A state certificate received by a student after the student has passed a state-authorized examination that the state recognizes as the equivalent of a high school diploma; An academic transcript of a student who has successfully completed at least a two-year program that is acceptable for full credit toward a bachelor's degree; or For a person who is seeking enrollment in an educational program that leads to at least an associate degree or its equivalent and who has not completed high school but who excelled academically in high school, documentation that the student excelled academically in high school and has met the formalized, written policies of the institution for admitting such students 16

Homeschool Obtained a secondary school completion credential for homeschool provided for under state law; or If state law does not require a homeschooled student to obtain the credential, the student has completed a secondary school education in a homeschool setting 17

Ability to Benefit DCL GEN & EA posted 10/22/15 Students who are enrolled in an eligible career pathway program, on or after July 1, 2014, and who are not high school graduates, may be eligible to receive Title IV aid if the student meets one of the following ATB alternatives: Passes an independently administered Department of Education approved ATB test Completes at least 6 credit hours or 225 clock hours that are applicable toward a degree or certificate offered by the postsecondary institution Completes a State process approved by the Secretary of Education. Note: To date, no State process has ever been submitted for the Secretary's approval 18

Eligible Career Pathway Programs Concurrently enroll students in connected adult education and eligible postsecondary programs; Provide students with counseling and supportive services to identify and attain academic and career goals; Provide structured course sequences that— Are articulated and contextualized; and Allow students to advance to higher levels of education and employment; 19

Provide opportunities for acceleration for students to attain recognized postsecondary credentials, including degrees, industry relevant certifications, and certificates of completion of apprenticeship programs; Be organized to meet the needs of adults; Be aligned with the education and skill needs of the regional economy; and Have been developed and implemented in collaboration with partners in business, workforce development, and economic development. 20 Eligible Career Pathway Programs

21

ED-Determined Eligibility 22

Citizenship U.S. citizen U.S. national Permanent resident Eligible noncitizen in the United States for other than a temporary purpose with the intention of becoming a citizen or permanent resident 23

Match with DHS Each student that provides and Alien Registration Number (ARN) is matched with DHS Generally, if the student fails automated primary and secondary matches the school must complete the G-845 paper confirmation process before dispersing aid There are special cases, ex. Freely Associated States, T- Visas, and J-Treaty students that will not go through the DHS Match Use the FSA Handbook to determine eligibility New Guidance: DCL GEN

Selective Service 25

Selective Service Registration requirements year old males Registering with SSS or on the FAFSA When registration is NOT required Active duty serving in the Armed Forces Not yet 18 at the time that they complete their applications Born before 1960 Citizens of the Freely Associated States Noncitizens who first entered the U.S. after age 26 26

Match with SSS All male students go through match with SSS to verify compliance with requirements Successful Match The student is eligible for aid Unsuccessful Match Student must either register or provide evidence that he is registered or is exempt from registration or; CPS won’t be able to forward the student for registration if certain information is missing 27

Failure to Register Some students have been denied aid because they failed to register with the Selective Service before their 26th birthday Students who knew of the registration requirement but chose not to register are considered to have knowingly and willfully failed to register and are therefore ineligible for FSA funds 28

Social Security Number 29

Social Security Number (SSN) The FAFSA collects the student’s and dependent parents’ SSNs The FAFSA will not be processed without an SSN 30

Match with SSA Match Flags on CPS Successful match No match on SSN Wrong SSN on FAFSA FAFSA data entry error Error in SSA database No match on name or DOB Missing information Date of death 31

Social Security Number Death master file CPS will verify that student SSNs do not appear on a master death file SSN being used by more than one person the student’s application will likely fail the SSN match Citizens of the Freely Associated States and pseudo-SSNs 32

33 NSLDS History

Ineligible statuses Default Owe overpayment on Title IV grant Inadvertent over borrowing of annual or aggregate loan limits Convicted of/pled no contest or guilty involving fraud in obtaining FSA funds Property subject to judgment/lien for debt owed to U.S. 34

NSLDS History – Bankruptcy Bankruptcy If loan discharged in bankruptcy, student remains eligible for Title IV aid If defaulted loan listed in active bankruptcy, student must provide documentation stating that debt is dischargeable 35

NSLDS History – Total and Permanent Disability If student had previous loans discharged due to TPD S/he must provide physician’s certification of her ability to engage in substantial gainful activity AND S/he must sign statement acknowledging future loans may not be discharged due to current impairment unless it deteriorates so that s/he is totally and permanently disabled again If s/he requests loans during conditional discharge period, must resume payment on old loan 36

NSLDS History – Regaining Eligibility Default & inadvertent over borrowing Pay in full or make satisfactory arrangements to repay with holder of loan Inadvertent over borrowing – see GEN GEN – New DL/FFEL Reaffirmation Agreement When situation is resolved, regain eligibility for Grants -- beginning with current payment period Loans – beginning with start of current enrollment (loan) period 37

Program-Specific Eligibility 38

Federal Pell Grants Generally, undergraduate students only Pell Grant Lifetime Eligibility Used (LEU) All students subject to 600% limit on Pell Grants Incarcerated students Incarcerated in local institutions = Pell Grant eligible COA must only include tuition & fees, books & supplies necessary for student’s program of study Sex offenders Not Pell Grant eligible if subject to involuntary civil commitment following incarceration for sexual offense 39

Federal Pell Grants Students enrolled in post-baccalaureate teacher certification/licensure program eligible for Pell Grant if the program does not lead to a graduate degree; school offering the program does not also offer a bachelor’s degree in education; student is pursuing an initial teacher certification or licensing credential within a state; and program consists of courses required by a state to receive a professional certification or licensing credential necessary for employment as a teacher in an elementary or secondary school in that state 40

Iraq and Afghanistan Service Grants For eligible students whose parent/guardian died as a result of military service in Iraq or Afghanistan after 09/11/01 Student was less than 24 years old when parent/guardian died; or Student was 24 or older and was enrolled at postsecondary institution at time of parent/guardian death If Pell Grant eligible, eligibility for all Title IV aid is calculated on EFC of 0 If not Pell Grant eligible, awarded Iraq and Afghanistan Service Grant in amount equal to Pell for award year 41

Direct Loans Preparatory coursework Student (or parent in case of dependent student) may apply for DL for coursework school determines necessary for enrollment in eligible program (prerequisite for admission into program) Coursework must be part of an eligible program at school Student eligible for loans for one consecutive 12-month period 42

Federal TEACH Grants Students must be pursuing coursework necessary for career in teaching sign an agreement to serve (ATS) teach in a high-need field –at an elementary or secondary school or educational service agency serving low income students –for 4 complete years within 8 years of ceasing enrollment in TEACH Grant eligible program of study If conditions in ATS aren’t met, TEACH Grant reverts to unsubsidized loan 43

QUESTIONS? 44