1. Carney McCullough and Marty Guthrie | Nov. 2012 U.S. Department of Education 2012 Fall Conference Another Look at the Student Eligibility Toolkit Session 3

2. 2 Today’s Agenda High School Diploma & Alternatives Ability to Benefit Satisfactory Academic Progress Professional Judgment Dependency Status Unusual Enrollment History

3. General Resources 6/18/10 NPRM preamble: http://www.ifap.ed.gov/fregisters/attachments/FR061810Pr ogramInterityIssuesNPRM.pdf 10/29/10 final rule preamble and reg text: http://www.ifap.ed.gov/fregisters/attachments/FR102910Fin al.pdf Dear Colleague Letters Q&As posted on OPE website: http://www2.ed.gov/policy/highered/reg/hearulemaking/200 9/integrity-qa.html 3

4. High School Diploma & Alternatives 4

5. Eligible Student §668.32(e) Has a high school diploma Has the recognized equivalent of a high school diploma Completed secondary school in a homeschool setting For students enrolled prior to July 1, 2012, demonstrated the ability to benefit from the education or training 5

6. High School Diploma §668.16(p) Requires institutions to develop and follow procedures to evaluate the validity of a student’s high school diploma if the institution or the Secretary has reason to believe that the diploma is not valid or was not obtained from an entity that provides secondary school education 6

7. High School Diploma §668.32(e)(1) Additional question on the FAFSA requesting the name, city, and state of high school Dropdown box on FOTW with a list of high schools No requirement to collect high school diplomas No requirement to compare with information collected by the Admissions Office No comments related to high school completion status on the ISIR for 2012-13 7

8. High School Diploma Receipt of diploma is a student eligibility item Procedure is an institutional requirement, not a verification item Action required if the institution or Secretary has concerns about the validity of a student’s diploma 8

9. High School Diploma When would an institution have reason to believe that there is an issue with the student’s high school diploma? ED tells you The financial aid office knows there is a problem Another office at the institution, such as admissions, identifies an issue 9

10. High School Diploma List used to populate FAFSA dropdown box No ED list of “bad” schools 10

11. High School Diploma Resources – State Department of Education in the state in which high school is located State Regulation of Private Schools (http://www2.ed.gov/admins/comm/choice/regprivschl/index.html)http://www2.ed.gov/admins/comm/choice/regprivschl/index.html Companies that determine validity of foreign high school diplomas Other institutions of higher education Membership organizations that evaluate the validity of high schools 11

12. High School Diploma Issues with prior year awards Dear Colleague Letter GEN-12-03 Need information for School Participation Team If credible information that the student may have engaged in fraud, report to the Office of Inspector General 12

13. High School Diploma Details of determination that high school diploma is not valid Information about circumstances under which initially accepted high school completion status Payment period(s) when aid was received Types and amounts of aid received by payment period 13

14. Recognized Equivalent of a High School Diploma §§600.2 and 668.32(e)(1) A General Education Development Certificate (GED); 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 14

15. Recognized Equivalent of a High School Diploma 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 that postsecondary institution for admitting such students 15

16. Homeschool §668.32(e)(4) Has completed a secondary school education in a homeschool setting that is treated as a homeschool or private school under State law and has obtained a homeschool completion credential, or If State law does not require a homeschool credential, has completed a secondary school education in a homeschool setting that qualifies as an exemption from compulsory school attendance requirements under State law 16

17. Ability to Benefit 17

18. Ability to Benefit §668.32(e)(2), (3), & (5) A student enrolled in a Title IV eligible program prior to July 1, 2012, may demonstrate the ability to benefit by— Passing an independently administered, Department of Education approved ATB test, 18

19. Ability to Benefit Completing at least six credit-hours, or the equivalent coursework (225 clock-hours), that are applicable toward a degree or certificate offered by the postsecondary institution, or Completing a State process approved by the Secretary of Education. NOTE: No State process has ever been submitted for the Secretary’s approval 19

20. Ability to Benefit For students who “first enroll in a program of study on or after July 1, 2012,” and who do not have a high school diploma or its recognized equivalent or who have not completed a homeschool program, the Consolidated Appropriations Act, 2012 (Public Law 112-74) eliminated the ability to benefit (ATB) alternatives. See Dear Colleague Letters GEN-12-01 and GEN-12-09 20

21. Ability to Benefit – Grandfathering Test Question 1: Did or will the student attend an eligible program at any Title IV institution prior to July 1, 2012? IF YES – The student may use any of the ATB alternatives to become eligible for Title IV, HEA student assistance. IF NO – Continue to Question 2. 21

22. Ability to Benefit – Grandfathering Test Question 2: Did the student, prior to July 1, 2012, officially register at a Title IV institution, and is the student scheduled to attend a eligible program? IF YES – The student may use any of the ATB alternatives to become eligible for Title IV, HEA student assistance. IF NO – The student may not use the ATB alternatives to become eligible for Title IV, HEA student assistance. 22

23. Ability to Benefit – Grandfathering Test If the response to either question is YES, the student is eligible for Title IV aid if— Met one of the ATB alternatives prior to July 1, 2012 Establishes eligibility under one of the ATB alternatives on or after July 1, 2012 23

24. Satisfactory Academic Progress 24

25. Satisfactory Academic Progress Purpose: to ensure that student is making progress toward educational credential or degree SAP policy reminders— Must review at each payment period, annually, or less often than each payment period but always at the end of a payment period Must review both qualitative (grade-based) and quantitative (time-based or “pace”) measures at each evaluation 25

26. Satisfactory Academic Progress Policy at least as strict as policy for non-Title IV recipients Policy must say how GPA and pace are affected by— Course incompletes Course withdrawals Course repetitions Transfers of credit 26

27. Satisfactory Academic Progress Issues— Must tell students about SAP terms and how they work For transfer students—accepted coursework is included in attempted/completed hours For students who return after long gap in attendance—no automatic amnesty but could appeal 27

28. Satisfactory Academic Progress Issues (continued)— Reviews Must review SAP after one payment period for a student on probation even if SAP reviewed annually for all other students Must review SAP after one payment period for a student on an academic plan because the first payment period is probation Monthly reviews permitted but don’t replace required review at end of payment period 28

29. Satisfactory Academic Progress Issues (continued)— Quantitative measure includes maximum time frame (not new) and pace (new) Ineligible when student cannot finish within maximum timeframe (150% of published length of program) Graduated pace is allowed but must also measure cumulative pace Sliding GPA is allowed but must also measure cumulative GPA 29

30. Satisfactory Academic Progress Issues (continued)— Appeals Institution identifies acceptable appeal situations No automatic amnesty provisions but interrupted attendance could be basis for appeal Documentation is determined by the institution & must support appeal decision 30

31. Satisfactory Academic Progress Implementing SAP at clock-hour schools Electronic Announcement, posted 6/6/11 Offers review options for clock-hour schools Examples posted 8/22/12 Student is ineligible if not making SAP 31

32. Satisfactory Academic Progress Guidance— Q&A on OPE website Describes treatment of coursework Clarifies how new terms interact New questions added as needed 32

33. Professional Judgment 33

34. Professional Judgment (PJ) In general— PJ addresses special circumstances of an individual student, not a class of students Documentation from verifiable third party is the goal Focusing today on student eligibility PJ 34

35. Professional Judgment DCLs GEN-09-04 (4/02/09) and GEN-09-05 (5/08/09)— Reminders that you can— Recognize changes in financial conditions, including loss of job Project income for a 12-month period Adjust income and unemployment benefits DCLs are still in effect 35

36. Professional Judgment DCL GEN-11-04, issued 2/28/11— Reminds you about the combat pay exclusion and to consider changed circumstances, as appropriate Changed circumstances include— Loss of income due to service member’s return to college Deployment of service member 36

37. Dependency Status DCL GEN-11-15, issued 7/26/11— Reviews conditions and documentation to support dependency overrides Not exactly PJ but similar Student-by-student basis Documentation is critical Third party documentation is the goal 37

38. Dependency Status GEN-11-15 includes examples & possible documentation Describes conditions that don’t qualify— Parent refuses to contribute Parent is unwilling to provide information Parent does not claim student as tax dependent Student demonstrates self-sufficiency 38

39. Dependency Status Homeless determination by FAA Not PJ or dependency override but similar Determination normally made by school district homeless liaison, director of HUD-funded emergency shelter program, or director of runaway or homeless youth basic center or transition program If student does not have, and cannot get, documentation from any of these authorities, FAA must determine if student is an unaccompanied youth who is homeless or is self-supporting and at risk of being homeless Details and documentation described in AVG 39

40. New—Unusual Enrollment History Students identified based on Pell Grant data New C code added to ISIR New Unusual Enrollment History Flag added to ISIR Flag value will determine needed action Guidance on how to resolve forthcoming 40

41. QUESTIONS? 41

42. 42 Contact Information We appreciate your feedback & comments and can be reached at: Phone: 202-219-7031 E-mail: Marty.Guthrie@ed.govMarty.Guthrie@ed.gov Phone: 202-502-7639 E-mail: Carney.McCullough@ed.govCarney.McCullough@ed.gov Fax: 202-502-7874