Enrollment issues are strictly a Registrar’s problem, right? Wrong! Because a student’s eligibility is determined in part by his/her enrollment status, plus your school’s definition of academic year, program length, and terms (or non-terms) can impact packaging and disbursement, it’s easy to see how enrollment can definitely be an issue for the Financial Aid Office! There is a ton of information and many subtopics that can fall under a heading of “enrollment issues,” but here are some tips and resources for a few of the most common.
Full-time = 12 or more credits
If your school provides standard term, credit-hour programs, then you must define full-time enrollment as at least 12 credits a term, including summer. Your registrar or academic side may define full-time differently, especially for shortened semesters like summer, but for financial aid purposes, summer enrollment definitions must remain consistent.
Speaking of Summer…
If a term-based program contains summer mini-sessions (or modules), the school may, but is not required to, combine the mini-sessions into a single term. The benefit of doing so is being able to use Formula 1 to disburse Pell. Beware: if your school chooses NOT to combine mini-sessions into a single payment period, then you must treat each mini-session as a separate nonstandard term and generally must use Formula 3 to calculate Pell payments. If ANY of a student’s program contains ANY nonstandard terms (including summer), then NONE of the program may be considered a standard program. This means that if you do not combine summer mini-sessions into one standard term, you can no longer consider your fall and spring semesters as standard and cannot use Formula 1 for Pell calculations. When calculating Pell, you must also use the same formula for all years in a student’s program.
Change in enrollment status
Most FAAs know that if a student has a change in enrollment status (e.g., full-time, half-time, etc.) between semesters or terms, that eligibility must be reviewed and the Pell award prorated to the appropriate disbursement schedule amount. What is sometimes missed is that the student’s Cost of Attendance must also be adjusted in these cases. If a student never attended a course and the credits from that course impact enrollment status, Pell AND COA amounts must be recalculated (e.g., student is enrolled in 12 credits and was paid at full-time status but never attended three credits, his Pell AND COA must be recalculated to three-quarter-time status).
Federal regulations don’t require any recalculation for changes in enrollment after a student has begun attendance in all classes; however, your school can have a policy of using a “census date” to “lock in” or “freeze” awards as of a certain date in a term after which enrollment status changes will not impact aid (assuming attendance in each class). This must be applied consistently to all students in a program. In other words, if the school chooses to increase Pell for a student whose enrollment status increases from half-time to full-time, it must also recalculate aid for a student whose enrollment status decreases. In the case of programs with modules, the school may have a policy of setting one census date based on the add/drop date of the last class in which the student enrolls (or is expected to enroll), but must take into account ALL adjustments to the enrollment status—both increases and decreases—up to that census date.
In a term-based program, a student may be repeatedly paid for taking the same course multiple times if she withdraws from the course or fails the course (normal SAP policy still applies). However, if the student passes a class (any grade higher than an “F” regardless of school policy) that was federally funded once, she can only receive funding for one retake of the class, no matter if she passes, fails, or withdraws from it a second time. You may not pay the student for retaking previously passed courses if she is required to retake those courses because she failed a different course.
Does your school have a way to track how many remedial/developmental credits each student has? A student enrolled solely in a remedial program is not considered to be in an eligible program for federal aid; however, if the student is admitted into an eligible program and takes remedial coursework within that program, he can be considered a regular student, even if he is taking all remedial courses before taking any regular courses. Only one year (or up to 30 semester or trimester hours) may be counted toward a student’s enrollment status for federal aid and qualitative assessment of Satisfactory Academic Progress, so you must be able to track these credits overall.
R2T4 and enrollment
Only courses counted toward TIV eligibility are counted in R2T4 calculations; therefore, if a student stops attending TIV-eligible courses but IS attending non-Title IV courses, he is still considered a withdrawal for Title IV purposes and R2T4 calculations must be performed.
2014 FSA Conference Session 9: “Basics of Determining Academic Calendars”
2014 FSA Conference Session 21: “All About Modules”
National Student Loan Data System Enrollment Reporting Guide
NASFAA’s Webinar: Student Eligibility – Enrollment Issues (requires specific membership level or for purchase); archived version available until August 24, 2015
NASFAA’s Webinar: Summer Aid Issues (free to NASFAA members); archived version available until November 10, 2015
This Tip of the Month was provided by your RMASFAA Training Committee