2016-17 NASFAA Webinar Series: Pell Recalculations ... · NASFAA’s Webinar Series Pell Recalculations: Required and Optional Presented February 1, 2017 Handouts For today’s handouts,

Pell Recalculations: Required and Optional

February 1, 2017

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February 2017

© 2017 NASFAA i Pell Recalculations Webinar 2/1/2017

NASFAA Webinar Pell Recalculations: Required and Optional

Table of Contents

Slides .................................................................................................................................................................... 1

Applicable Regulations ....................................................................................................................................... 27

Case Studies ...................................................................................................................................................... 31

Pell Recalculations Webinar 2/1/2017 ii © 2017 NASFAA

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NASFAA’s Webinar SeriesPell Recalculations: Required and Optional

Presented February 1, 2017

National Association of Student Financial Aid Administrators

NASFAA’s 2016–17 Webinar Series

Pell Recalculations: Required and Optional

February 1, 2017

Slide 1 © 2017 NASFAA

Introduction: NASFAA Staff


David TolmanInstructional Content Specialist

Debra LaGroneCompliance Products Specialist

NASFAA Training and Regulatory Assistance

Introduction: School Panelist


Nicole McMillinFinancial Aid Director

College of Western Idaho

© 2017 NASFAA 1 Pell Recalculations Webinar 2/1/2017



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Goals

• Explain the principles and concepts ofrequired and optional Federal Pell Grantrecalculations

• Discuss recalculation policy options

• Review case studies





Federal Pell Grant Recalculations


Census Date

Where is “census date” defined in regulation?

a. 668 (general provisions)b. 685 (Direct Loan)c. 690 (Federal Pell Grant)d. There is no census date in regulation


Census Date

Where did the term “census date” originate?





690.80(b)(2)(i)

• Recalculation of a Federal Pell Grant;• If the student’s enrollment status changes;• the institution may (but is not required to)

establish a policy;• to recalculate the student’s (Pell) award for

the payment period.


Key Terms

Optional

Federal Pell Grant

Recalculation

Enrollment Status Change





Key Terms

Optional

Federal Pell Grant

Recalculation


Optional

• Policy to set a date after whichno recalculations areperformed;

• Policy must be consistentlyimplemented for all students;

• Cannot override policy usingprofessional judgment (PJ)


Required Reasons to Recalculate

Recalculate

EFC change

Does not initiate

attendance

Enrollment status changes between terms


Key Terms

Optional

Federal Pell Grant

Recalculation


Federal Pell Grant

• Iraq and Afghanistan ServiceGrant (IASG)

• Federal TEACH Grant Optional, but recalculation

policy must match Pell policySlide 18 © 2017 NASFAA




Key Terms

Optional

Federal Pell Grant

Recalculation


Recalculation

In order to recalculate, must first have performed an initial calculation


Initial Calculation

Pell

Enrollment Status

COA

EFC

Valid ISIR


Key Terms

Optional

Federal Pell Grant

Recalculation

Enrollment Status ChangeEnrollment Status Change

• Overall enrollment status (full-time, three-quarter time, half-time, less-than-half time)

• Not specific classes that makeup the student’s enrollment status





Recalculate for

enrollment status

changes

Do not recalculate for enrollment

status changes

Payment Period

Pell Recalculation Date (PRD)


Importance of Initial Calculation

PRD

Initial calculation

FT 3/4 FT 1/2

A


QUIZ

At what enrollment status should the Pell Grant be based at Point A?

a. Full-timeb. ¾-timec. Half-time






PRD

Initial calculation

FT 3/4 FT 1/2

A



PRD

Initial calculation

FT 3/4 FT 1/2

A


QUIZ

At what enrollment status should the Pell Grant calculated?







PRD

Initial calculation

FT 3/4 FT 1/2


Importance of Disbursement Timing

PRD

Disburse based on enrollment status according to Pell

Recalculation Policy



PRD

Disburse based on retroactive payment

or late disbursement rules






PRD



Retroactive Payment



PRD



Late Disbursement



PRD



Recalculate for completed

credits






PRD

FT 3/4 FT 1/2

Initial calculation

Late disbursement


QUIZ

At what enrollment status should the Pell Grant be calculated?




PRD

FT 3/4 FT 1/2

Initial calculation

Late disbursement





QUIZ

At what enrollment status should the Pell Grant be disbursed?




PRD

FT 3/4 FT 1/2

Initial calculation

Late disbursement


Case Study 1Reynaldo completed his FAFSA on December 12, 2016. After resolving systems issues, Grand Howling College (GHC) packages Reynaldo on August 14, 2017. His aid package includes a Federal Pell Grant. GHC’s packaging policy is to package all students at a projected full-time enrollment status when packaging prior to the start of the quarter. GHC will then adjust students’ Pell Grants to actual enrollment when disbursing through the Pell Recalculation Date (PRD). The fall quarter begins on September 18, 2017.





Case Study 1GHC sets September 29, 2017, as its PRD. Reynaldo is enrolled 3/4-time when the quarter begins. However, due to an unresolved eligibility issue, no disbursement of aid is made to Reynaldo. Reynaldo decides he can manage a heavier schedule, and adds a class on September 28. This raises Reynaldo’s enrollment status to full-time. However, one week later, Reynaldo finds a job and a girlfriend. He determines that his college schedule is too hard to manage, and drops one of his classes on October 5th. This leaves his enrollment status at 3/4-time.


Case Study 1

Finally, on October 19, he resolves the eligibility issue, which, to that point, had prevented his ability to receive an aid disbursement.GHC is not sure what enrollment status to use in order to disburse Reynaldo’s Pell Grant. GHC verifies that Reynaldo has initiated attendance in all classes.At what enrollment status should Reynaldo’s Pell Grant be disbursed?


Case Study 1

At what enrollment status should Reynaldo’s Pell Grant be disbursed?






Case Study 1

Reynaldo – key information• Initial calculation date August 14• Pell Recalculation Date (PRD) Sept 29• Enrollment status on PRD full time• Any conditions that would

require a Pell recalculation? no


Reynaldo

PRD

Initial calculation

3/4 FTAug 14

3/4

Disbursement


Case Study 2Reynaldo again. All facts remain the same, other than the school did not have a process in place to verify attendance prior to making disbursements. Instead, the GHC financial aid office learned Reynaldo did not initiate attendance in one of his classes when he received an F grade at the end of the term, and the professor indicated Reynaldo never attended.Based on this information, must GHC recalculate Reynaldo’s Pell Grant?





Case Study 2

Based on this information, must GHC recalculate Reynaldo’s Pell Grant?a. Yes, there is an issue with Reynaldo not

attending a classb. No, Reynaldo’s enrollment status was

locked in on the Pell Recalculation Datec. No, GHC must first perform a return of Title

IV funds calculation


Case Study 2Based on this information, must GHC recalculate Reynaldo’s Pell Grant?• Yes – not initiating attendance prompts a

required recalculation.• The requirement to recalculate supersedes

GHC’s policy to not recalculate after the PRD.


Case Study 3

Alexa completes her FAFSA on July 1, 2017, and she has a Pell-eligible EFC. Eclipse College of Art and Design typically packages students at a projected full-time enrollment status, but it identifies conflicting information in Alexa’s financial aid application and does not package her with any Title IV aid.





Case Study 3The fall semester begins on September 5, 2017.

• Alexa’s enrollment status on that date is less-than half-time.

Eclipse College’s Pell Recalculation Date is September 8, 2017.• Alexa’s enrollment status on that date is half-time.

The conflicting information is finally resolved on September 22, 2017. Alexa remains Pell Grant eligible.

• Alexa’s enrollment status on that date is 3/4-time.

Eclipse College packages Alexa with Title IV aid on its next scheduled packaging run on September 26.

• Alexa’s enrollment status on that date is full-time.


Case Study 3

At what enrollment status should Alexa’s Pell Grant be calculated?

a. Less than half-timeb. Half-timec. Three-quarter timed. Full-time


Alexa

PRD

Initial calculation

< 1/2 1/2July1

3/4

Conflicting information resolved

FAFSA

FT





Case Study 4Jean attends the Mattucci Mathematical Institute (MMI). MMI offers classes in a fall semester, spring semester, and a summer term.Jean enrolls in the fall semester. On MMI’s Pell Recalculation Date, her enrollment status is half-time. However, during the semester she added additional courses and completed 15 credits (full-time) with straight A’s.


Case Study 4During the spring semester, Jean ran into some financial trouble. Her friend, Ally, suggested she apply for financial aid. Jean thought her parents made too much money, but she went ahead and applied. To her surprise, her Student Aid Report (SAR) indicated she would be eligible for a Federal Pell Grant. She eagerly awaited her award letter from the financial aid office.


Case Study 4Meanwhile, back in the MMI financial aid office, Tom wasn’t sure what enrollment status to use to calculate Jean’s fall semester Pell eligibility. Never before at MMI had a student waited until spring semester to apply for financial aid for the award year.What enrollment status should Tom use to calculate Jean’s Pell Grant for the fall semester?





Case Study 4

What enrollment status should Tom use to calculate Jean’s Pell Grant for the fall semester?a. Half-timeb. Full-timec. The same enrollment status used to

calculate the Spring Semester Pell Grant


Case Study 4What enrollment status should Tom use to calculate Jean’s Pell Grant for the fall semester?Full-timeThe payment period has ended. This is a retroactive payment and the Pell Recalculation Policy no longer applies. Pell payment is made on completed credits.


Modules

Two Policy Options:• One PRD applies to full payment period

– Adds or withdrawals after PRD do not promptrecalculation

– Required recalculations still apply (not initiatingattendance)

• One PRD applies to each module– Only one PRD applies to each student– PRD is based on the last class in which the

student enrolls





Case Study 5Yessica attends Sportsman State University (SSU). SSU offers a traditional semester calendar, with multiple modules in each semester. SSU’s policy is to set a Pell Recalculation Date (PRD) for each module, in addition to a PRD that applies to the full semester. SSU defines full-time enrollment as 12 credits.

Which Pell Recalculation Date(s) applyto Yessica’s enrollment?

Type Credit Hours PRDFull semester 6 Sept 8

Module 2 3 Oct 27

Module 3 3 Nov 17


Case Study 5

Which Pell Recalculation Date(s) apply to Yessica’s enrollment?

a. September 8, October 27, and November 17b. September 8 and November 17c. September 8d. October 27e. November 17


Case Study 5Sportsman State University (SSU) offers a traditional semester calendar. Within each semester are multiple modules. SSU’s policy is to set a Pell Recalculation Date (PRD) for each module, in addition to a PRD that applies to the full semester. SSU defines full-time enrollment as 12 credits.

Which Pell Recalculation Date(s) applyto Yessica’s enrollment?


Module 2 3 Oct 27

Module 3 3 Nov 17





Case Study 6As it turns out, Yessica decided to drop her Module 3 class on November 2. She also withdrew from one of her full semester classes on October 31.


Module 2 3 Oct 27

Module 3 3 Nov 17

• Withdraws from 3 credit hours on October 31

• Drops Module 3 course on November 2Which recalculation date now applies, and what is Yessica’s enrollment status for calculating Federal Pell Grant eligibility?


Case Study 6

Which recalculation date now applies, and what is Yessica’s enrollment status for calculating Federal Pell Grant eligibility?

a. September 8 / half-time

b. September 8 / three-quarter time

c. October 27 / three-quarter time

d. November 17 / half-time


Case Study 6As it turns out, Yessica decided to drop her Module 3 class on November 2. She also withdrew from one of her full semester classes on October 31.


Module 2 3 Oct 27

Module 3 3 Nov 17

• Withdraws from 3 credit hours on October 31

• Drops Module 3 course on November 2

Recalculation date: Oct 27Enrollment status: 3/4 - time





Cost of Attendance

• When recalculate Federal Pell Grant forenrollment status change, must alsorecalculate the student’s COA– Falls within Federal Pell Grant regulations, so

COA is the Pell COA• Programs in standard term format and

nonstandard term with substantially equalterms programs can set policy on performingTitle IV COA recalculations


Cost of Attendance

• Non-term, nonstandard term with terms notsubstantially equal, and clock-hour programs– Must recalculate Title IV COA when enrollment

status changes to determine eligibility forcampus-based funds


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NASFAA's Webinar Series

Gainful Employment IssuesFebruary 22, 2017



NASFAA Compliance Tools for Compliance Officers

March 8, 2017






Title IV Eligibility: Adding ProgramsMarch 15, 2017


2016 – 17 Course Schedule

Overview of the Financial Aid Programs – 9/12/16

Student Eligibility – 10/3/16

Cash Management – 10/18/16

Verification – 11/7/16

Return of Title IV Funds – 1/30/17

Consumer Information – 2/27/17

Gainful Employment – 3/27/17

Professional Judgment – 4/25/17

Overview of the Financial Aid Programs – 7/10/17





Thank you for joining us!





27 Pell Recalculations Webinar 2/1/2017

Pell Recalculations: Required and Optional Applicable Regulations

Sec. 690.80 Recalculation of a Federal Pell Grant award. (a) Change in expected family contribution. (1) The institution shall recalculate a Federal Pell Grant award for

the entire award year if the student's expected family contribution changes at any time during the award year. The change may result from—

(i) The correction of a clerical or arithmetic error under Sec. 690.14; or

(ii) A correction based on information required as a result of verification under 34 CFR part 668, Subpart E. (2) Except as described in 34 CFR 668.60(c), the institution shall adjust the student's award when an

overaward or underaward is caused by the change in the expected family contribution. That adjustment must be made—

(i) Within the same award year—if possible—to correct any overpayment or underpayment; or

(ii) During the next award year to correct any overpayment that could not be adjusted during the year in which the student was overpaid.

(b) Change in enrollment status. (1) If the student's enrollment status changes from one academic term to another term within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance.

(2)(i) If the student's projected enrollment status changes during a payment period after the student has

begun attendance in all of his or her classes for that payment period, the institution may (but is not required to) establish a policy under which the student's award for the payment period is recalculated. Any such recalculations must take into account any changes in the cost of attendance. If such a policy is established, it must apply to all students.

(ii) If a student's projected enrollment status changes during a payment period before the student begins

attendance in all of his or her classes for that payment period, the institution shall recalculate the student's enrollment status to reflect only those classes for which the student actually began attendance.

(c) Change in cost of attendance. If the student's cost of attendance changes at any time during the award

year and his or her enrollment status remains the same, the institution may (but is not required to) establish a policy under which the student's award for the payment period is recalculated. If such a policy is established, it must apply to all students.

Sec. 690.76 Frequency of payment.

(a) In each payment period, an institution may pay a student at such times and in such installments as it

determines will best meet the student's needs.

(b) The institution may pay funds in one lump sum for all the prior payment periods for which the student was an eligible student within the award year. The student's enrollment status must be determined according to work already completed.

Pell Recalculations Webinar 2/1/2017 28

Sec. 686.35 Recalculation of TEACH Grant award amounts. (a) Change in enrollment status. (1) If the student’s enrollment status changes from one academic term to

another academic term within the same award year, the institution must recalculate the TEACH Grant award for the new payment period taking into account any changes in the cost of attendance.

(2)(i) If the student’s projected enrollment status changes during a payment period after the student has

begun attendance in all of his or her classes for that payment period, the institution may (but is not required to) establish a policy under which the student’s award for the payment period is recalculated. Any such recalculations must take into account any changes in the cost of attendance. In the case of an undergraduate or post-baccalaureate program of study, if such a policy is established, it must be the same policy that the institution established under 34 CFR 690.80(b) for the Federal Pell Grant Program and it must apply to all students in the TEACH Grant-eligible program.

(ii) If a student’s projected enrollment status changes during a payment period before the student begins

attendance in all of his or her classes for that payment period, the institution must recalculate the student’s enrollment status to reflect only those classes for which he or she actually began attendance.

Sec. 668.164 Disbursing funds. (j) Late disbursements— (1) Ineligible student. For purposes of this paragraph (j), an otherwise eligible

student becomes ineligible to receive title IV, HEA program funds on the date that— (i) For a Direct Loan, the student is no longer enrolled at the institution as at least a half-time student for

the period of enrollment for which the loan was intended; or (ii) For an award under the Federal Pell Grant, FSEOG, Federal Perkins Loan, Iraq-Afghanistan Service

Grant, and TEACH Grant programs, the student is no longer enrolled at the institution for the award year.

(2) Conditions for a late disbursement. Except as limited under paragraph (j)(4) of this section, a student

who becomes ineligible, as described in paragraph (j)(1) of this section, qualifies for a late disbursement (and the parent qualifies for a parent Direct PLUS Loan disbursement) if, before the date the student became ineligible—

(i) The Secretary processed a SAR or ISIR with an official expected family contribution for the student for

the relevant award year; and (ii)(A) For a loan under the Direct Loan program or for an award made under the TEACH Grant program,

the institution originated the loan or award; or (B) For an award under the Federal Perkins Loan or FSEOG programs, the institution made that award to

the student. (3) Making a late disbursement. Provided that the conditions described in paragraph (j)(2) of this section

are satisfied— (i) If the student withdrew from the institution during a payment period or period of enrollment, the

institution must make any post-withdrawal disbursement required under Sec. 668.22(a)(4) in accordance with the provisions of Sec. 668.22(a)(5);

29 Pell Recalculations Webinar 2/1/2017

(ii) If the student completed the payment period or period of enrollment, the institution must provide the student or parent the choice to receive the amount of title IV, HEA program funds that the student or parent was eligible to receive while the student was enrolled at the institution. For a late disbursement in this circumstance, the institution may credit the student's ledger account as provided in paragraph (c) of this section, but must pay or offer any remaining amount to the student or parent; or

(iii) If the student did not withdraw but ceased to be enrolled as at least a half-time student, the institution

may make the late disbursement of a loan under the Direct Loan programs to pay for educational costs that the institution determines the student incurred for the period in which the student or parent was eligible.

(4) Limitations. (i) An institution may not make a late disbursement later than 180 days after the date the

institution determines that the student withdrew, as provided in Sec. 668.22, or for a student who did not withdraw, 180 days after the date the student otherwise became ineligible, pursuant to paragraph (j)(1) of this section.

(ii) An institution may not make a late second or subsequent disbursement of a loan under the Direct Loan

programs unless the student successfully completed the period of enrollment for which the loan was intended.

(iii) An institution may not make a late disbursement of a Direct Loan if the student was a first-year, first-

time borrower as described in 34 CFR 685.303(b)(5) unless the student completed the first 30 days of his or her program of study. This limitation does not apply if the institution is exempt from the 30-day delayed disbursement requirements under 34 CFR 685.303(b)(5)(i)(A) or (B).

(iv) An institution may not make a late disbursement of any title IV, HEA program assistance unless it

received a valid SAR or a valid ISIR for the student by the deadline date established by the Secretary in a notice published in the Federal Register.

(k) Retroactive payments. If an institution did not make a disbursement to an enrolled student for a payment

period the student completed (for example, because of an administrative delay or because the student’s ISIR was not available until a subsequent payment period), the institution may pay the student for all prior payment periods in the current award year or loan period for which the student was eligible. For Pell Grant payments under this paragraph (k), the student’s enrollment status must be determined according to work already completed, as required by 34 CFR 690.76(b).




Pell Recalculations: Required and Optional Case Studies

Case Study 1

Reynaldo completed his FAFSA on December 12, 2016. After resolving systems issues, Grand Howling College (GHC) packaged Reynaldo on August 14, 2017. His aid package includes a Federal Pell Grant. GHC’s packaging policy is to package all students at a projected full-time enrollment status when packaging prior to the start of the quarter. GHC will then adjust students’ Pell Grants to actual enrollment when disbursing through the Pell Recalculation Date (PRD). The fall quarter begins on September 18, 2017. GHC sets September 29, 2017, as its PRD.

Reynaldo is enrolled 3/4-time when the quarter begins. However, due to an unresolved eligibility issue, no disbursement of aid is made to Reynaldo.

Reynaldo decides he can manage a heavier schedule, and adds a class on September 28. This raises Reynaldo’s enrollment status to full-time. However, one week later, Reynaldo finds a job and a girlfriend. He determines that his college schedule is too hard to manage, and drops one of his classes on October 5th. This leaves his enrollment status at ¾-time.

Finally, on October 19, he resolves the eligibility issue, which, to that point, had prevented his ability to receive an aid disbursement.

GHC is not sure what enrollment status to use in order to disburse Reynaldo’s Pell Grant. GHC verifies that Reynaldo has initiated attendance in all classes.

At what enrollment status should Reynaldo’s Pell Grant be disbursed?

Case Study 2

Reynaldo again. All facts remain the same, other than the school did not have a process in place to verify attendance prior to making disbursements, Instead, the GHC financial aid office learned Reynaldo did not initiate attendance in one of his classes when he received an F grade at the end of the term, and the professor indicated Reynaldo never attended.

Based on this information, must GHC recalculate Reynaldo’s Pell Grant?

Case Study 3

Alexa completes her FAFSA on July 1, 2017, and she has a Pell-eligible EFC. Eclipse College of Art and Design typically packages students at a projected full-time enrollment status, but it identifies conflicting information in Alexa’s financial aid application, and does not package her with any Title IV aid.

The fall semester begins on September 5, 2017. Alexa’s enrollment status on that date is less-than half-time.

Eclipse College’s Pell Recalculation Date is September 8, 2017. Alexa’s enrollment status on that date is half-time.

The conflicting information is finally resolved on September 22, 2017. Alexa remains Pell Grant eligible. Alexa’s enrollment status on that date is 3/4-time.


Eclipse College packages Alexa with Title IV aid on its next scheduled packaging run on September 26. Alexa’s enrollment status on that date is full-time.

At what enrollment status would Alexa’s Federal Pell Grant be calculated, if disbursed within the paymentperiod?

Case Study 4

Jean attends the Mattucci Mathematical Institute (MMI). MMI offers classes in a fall semester, spring semester, and a summer term.

Jean enrolls in the fall semester. On MMI’s Pell Recalculation Date, her enrollment status is half-time. However, during the semester she added additional courses and completed 15 credits (full-time) with straight A’s.

During the spring semester, Jean ran into some financial trouble. Her friend, Ally, suggested she apply for financial aid. Jean thought her parents made too much money, but she went ahead and applied. To her surprise, her Student Aid Report (SAR) indicated she would be eligible for a Federal Pell Grant. She eagerly awaited her award letter from the financial aid office.

Meanwhile, back in the MMI financial aid office, Tom wasn’t sure what enrollment status to use to calculate Jean’s fall semester Pell eligibility. Never before at MMI had a student waited until spring semester to apply for financial aid for the award year.

At what enrollment status should Tom use to calculate Jean’s Pell Grant for the fall semester?

Case Study 5

Sportsman State University (SSU) offers a traditional semester calendar. Within each semester are multiple modules. SSU’s policy is to set a Pell Recalculation Date (PRD) for each module, in addition to a PRD that applies to the full semester. SSU defines full-time enrollment as 12 credits.

Yessica enrolls in the following:

Type Number of credits PRD

Full semester 6 September 8

Module 2 3 October 27

Module 3 3 November 17

Which Pell Recalculation Date(s) apply to Yessica’s enrollment?

Case 6

As it turns out, Yessica decided to drop her Module 3 class on November 2. She also withdrew from one of her full semester classes on October 31.

Which Pell Recalculation Date now applies, and what is Yessica’s enrollment status for the semester?


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Documents

2016-17 NASFAA Webinar Series: Pell Recalculations ... · NASFAA’s Webinar Series Pell Recalculations: Required and Optional Presented February 1, 2017 Handouts For today’s handouts,