Implementing LEU and UEHInterpretation, implementation, impact

I have 256 students with Unusual Enrollment History!

Yeah, well I have 500 students who are LEU and can’t finish their degree!

PELL GRANT LIFETIME ELIGIBILITY USED• Eligible Pell Grant recipients are now capped on

the number of years they can receive a Pell Grant over their lifetime. Eligible students can receive the Pell Grant for up to 6 years for full-time equivalent attendance. The maximum amount that can be received each year is 100%, so the sic year equivalent is 600 percent.

• It is important that students know their Pell Grant lifetime eligibility, since they will no longer be eligible to receive a Pell Grant after they have completed six years of eligibility, even if they still meet all Pell Grant requirements and qualifications.

Lifetime Eligibility Used—Pell Grant• In December 2011, President Obama signed into

law the Consolidated Appropriations Act, 2012 (Public Law 112-74).

• This law has significantly impacted the Pell Grant Program. Beginning in Fall 2012, students are now limited to 12 semesters (or 600%) of Pell Grant eligibility during their lifetime.

• This change affects all students regardless of when or where they received their first Pell Grant.– There was no “grandfather” clause

•  A student may view the percentage of Pell Grant used by logging into NSLDS.ed.gov.  The student’s ‘Lifetime Eligibility Used’ percentage will be displayed in the ‘Grants’ section.

LEU legislative guidance• The Consolidated Appropriations Act, 2012

(Public Law 112-74)• DCL ID: GEN-12-01 Changes Made To The Title

IV Student• DCL ID: GEN-13-14 , Federal Pell Grant Duration

of Eligibility and Lifetime Eligibility Used.– The COD System uses Pell Grant

disbursement information reported by schools to calculate a student's Pell Grant LEU by adding together each of the annual percentages of the student's Pell Grant award that was actually disbursed to the student.

LEU Electronic Announcements• August 13, 2012 Pell Grant Lifetime Eligibility

Used: Importance of Timely Reporting.• June 27, 2013 Guidance on the Pell Grant

Lifetime Eligibility Used Dispute Escalation Process.

• February 17, 2012 Preliminary Information—Implementation of the 12 Semester Lifetime Limit for Federal Pell Grants.

• June 14, 2012 Pell Grant LEU Information—Additional 2012-13 COD System Update

• And the list goes on…..

• Pell LEU Comments

Comment No.

Condition SAR Comment

345 Applicant’s Pell Lifetime Eligibility Used amount is high

There is a limit to the total amount of Federal Pell Grants that a student may receive, which is the equivalent of 6 years. Based on information reported to the NSLDS by the schools you have attended, you have received Pell Grants for the equivalent of between 4 and 5 school years.

346 Applicant’s Pell Lifetime Eligibility Used amount is close to the Pell Limit

There is a limit to the total amount of Federal Pell Grants that a student may receive, which is the equivalent of 6 school years. Based on information reported to the National Student Loan Data System (NSLDS) by the schools you have attended, you have received a total amount of Pell Grants that is close to the cumulative total you can receive. Therefore, your eligibility for

additional Pell Grants may be limited. 347 Applicant’s Pell Lifetime

Eligibility Used amount is met or has exceeded the limit

There is a limit to the total amount of Federal Pell Grants that a student may receive, which is the equivalent of 6 school years. Based on information reported to the National Student Loan Data System (NSLDS) by the schools you have attended, you may have received a total amount of Pell Grants that equals or exceeds the cumulative total you can receive.

LEU Issues• Rounding Rules—The COD System calculates

a student’s LEU to the third decimal point. Schools may not round that three-decimal LEU percentage because doing so could result in the student either not receiving his or her Pell Grant eligibility, or exceeding the statutory 600 percent limitation. In addition, schools should truncate at the cents place when calculating a student's Pell Grant annual award. If a school only awards Pell Grants in whole dollars, the award must be truncated down to the next whole dollar.

LEU Issues—School Liabilities• Before making any financial aid disbursement, schools are

required to review the student's records to ensure that the student is eligible for the disbursement. If a school disbursed Pell Grant funds beyond the student's eligibility because it failed to follow regulatory and operational procedures, the school is liable for the overpayment and must make the necessary COD System adjustments.

• Schools are required to submit Pell Grant disbursement information to the COD System within 15 days of disbursing funds. The 15-day requirement also includes submitting adjustments made to previously reported disbursements. A school that does not report Pell Grant disbursement within the required 15-day timeframe may be liable for any overpayment that results from another school disbursing Pell Grant funds with incomplete information because of the late reporting.

LEU—Disputing the Accuracy of LEU Information• There may be circumstances where a student disputes the

accuracy of his or her Pell Grant LEU information in the COD System. It is the responsibility of the school where the student is attempting to receive a Pell Grant to assist in resolving the student's assertion that the information is incorrect. The DCL provides helpful guidance for schools to follow on how to determine the accuracy of the information, and also when the school should instruct the student to contact Federal Student Aid's COD School Relations Center for assistance.

• June 27, 2013 Electronic Announcement ** In this announcement, ED provides guidance regarding the process a school may take to dispute a student’s Federal Pell Grant LEU, as reported in the Common Origination and Disbursement (COD) System.– Guidance indicates that the school must assist in the

dispute process.

LEU and School Issues• Suddenly students are notified that they

have no Pell eligibility left and they are unable to complete their program.– Is your school providing institutional assistance to

these students if they are near completion?• May be eligible for FSEOG (AskRegs

Knowledgebase)• May receive both Federal Perkins and FWS if

they are eligible.• May be eligible for Stafford Loans

– How has LEU affected your enrollment numbers?– How are you educating your students up front that

they must complete within 12 semesters?

LEU• Does your institution have any specific

programs that are being hit by the LEU regulations?– At my institution, our nursing students are

finding that they may loose their Pell before they complete the program.

– Does your institution have any funds to assist these students?

– Is your school revisiting some academic policies?

**Students need to think of full time as 15 to 18 credits per semester if they are to complete within the timeframe.**Students who need remediation are using a portion of their eligibility, possibly making a Bachelor’s degree out of reach.**Students who change majors frequently are at risk of not having enough Pell to complete a degree.

My advisor told me to take 18 credits this semester. I have to give up the foosball team.

UNUSUAL ENROLLMENT HISTORY• Beginning with the 2013-2014, the Department of

Education is flagging the ISIRs of students with unusual enrollment history for students who have received a Pell Grant at multiple institutions in the most recent three year period.

• This is the Department’s efforts to prevent fraud and abuse in the Federal Pell Grant Program and identifies students with unusual enrollment histories.– Specifically concerned about students who attend an

institution long enough to receive Title IV credit balance funds, leaves without completing the enrollment period, enrolls at another institution, and repeats the pattern.

UEH• Students are identified based on Pell Grant

history—the number of years Pell received and the number of schools attended

• New C code added to ISIR• New Unusual Enrollment History Flag (UEH FLAG)

added to ISIR• Flag value determines action needed.

UEH Flag on the ISIR• Indicates that the student has an unusual

enrollment history with regard to the receipt of the Pell Grant.– UEH Flag values of 2 or 3 generate a C code

on the ISIR, and indicates that the student’s must be reviewed.• UEH Flag value of 2 indicates an unusual enrollment

history that requires review of the student’s enrollment records.

• UEH Flag of 3 indicates that the institution must review academic records for the student, and in some cases, must collect additional documentation from the student.

– UEH Flag value of N indicates that no action is necessary.

UEH Comment CodesUEH Flag Value  C Code  Comment

Code  Flag Description  School Action to Resolve Flag 

 1 No  None  Enrollment pattern not unusual 

 No school action required.

 2 Yes  359  Possible enrollment pattern problem 

School must review enrollment/academic and financial aid recordsfor past three years. 

 3 Yes  360  Questionable enrollment pattern 

School must review enrollment/academic and financial aid records for past three award years. 

UEH Flag Value of 2• UEH Flag value '2': Indicates that there is an

unusual enrollment history that requires a school review of the student's records to determine if the school must collect additional information about the student's prior enrollment. An example of value '2' would be if the student received Pell Grant funds at three schools over two award years. The school must review the student's enrollment and financial aid records to determine if, during the three award year (AY) review period (AY 2010-2011, AY 2011-2012, and AY 2012-2013) the student received a Pell grant at the school that is performing the review.

UEH Flag Value of 2• No action is required if the institution performing

the review determines that the student received a Pell Grant at that institution, unless the institution has reason to believe that the student is one who remains enrolled just long enough to collect aid funds.

• If it appears that the student remained just long enough to collect aid funds (F grades, R2T4), then the institution must– Review enrollment/academic progress and financial aid

received at prior institutions (must have a transcript);– Determine, for each of the previously attended

institutions, whether academic credit was earned during the award year in which the student received a Pell Grant.

UEH Flag Value of 2• If the student did not earn academic credit at

any previously attended institutions, and, if applicable, at the current institution, the institution must obtain documentation from the student explaining why the student failed to earn academic credit.– Institution must determine if the

documentation supports the reasons given by the student and that the student did not enroll only to receive financial aid credit balance funds.

• If the documentation for each failure is not acceptable, the institution must deny the student any additional title IV funds.– Student must be provided the opportunity to

appeal this decision.

UEH Flag Value of 3• Was academic credit earned at each of the

institutions attended in the past three years where the student received a Pell Grant?– If not, you must obtain documentation from

the student explaining why the student failed to earn academic credit.

– The institution must determine if the documentation supports the reasons given by the student and that the student did not enroll only to receive financial aid credit balance funds.

UEH Flag Value of 3 • Based on the academic transcripts from each

institution attended, the institution must determine, for each institution previously attended during the relevant award years, if the student earned any credits.– If the student earned credit at each institution

reviewed, no further action needed.– If the student did not earn academic credit at

a previously attended institution, and, if applicable, at the institution doing the review, the institution must obtain documentation from the student explaining why the student did not earn any credit.

UEH Flag Value of 3• If the documentation for each failure is not

acceptable, the institution must deny the student any additional title IV funds.– Student must be provided the opportunity to

appeal this decision.• The institution must determine whether the

documentation supports (1) the reasons given by the student for the student’s failure to earn academic credit; and (20 that the student did not enroll only to receive credit balance funds.

• The financial aid administrator must determine whether the circumstances of the failure of the student support the continued eligibility for Title IV funds.

How will you implement?• Develop your policy

– Get input from the academic side– Will you require an academic plan for students

who appeal?– Will you require official academic transcripts

or unofficial transcripts?– How does a student regain eligibility for Title

IV funds?• Implement your policy

– Publicizing it to new and continuing students– How will you notify students that the eligibility

for federal aid is denied?

This is an opportunity to work with other campus divisions to improve student performance.

UEH is generally an issue for community colleges and proprietary schools.

I got my expense check and went shopping.

Yeah, well I blew mine at the casino!