These are a few of the changes that have been passed down from David Bartnicki, our Federal Training Officer.
I know everyone wants to know all the details and have all the information to implement the 2013-2014 verification items right now. I promise you that ED is working hard to get information out to all of our schools outlining procedures, verification language that can be used when requesting data, possible documents, processing steps, etc. Please stay tuned to IFAP for more updates and guidance.
Speaking of verification, however, if you were not aware policy recently updated the program integrity website(http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/verification.html) with six new verification Q & As to help the current verification process – disbursing unsubsidized aid when verification is not complete (VER-Q11); what to do when SNAP or child support paid is not reported on the FAFSA but appears on the VWS (VI-Q2 and VI-Q6); acceptable transcript documentation (DOC-Q2 and DOC-Q10); and changing FAFSA data to include a rollover as a correction (CHD-Q2).
One important piece of information to point out under VI-Q2 and VI-Q6 is that a record of account transcript can now also be used as one of the possible items for acceptable documentation when verifying an amended return. Please see the program integrity Q & A website for more detailed information.
A lot of schools are still asking if a student has reached their Pell 600% limit can they receive FSEOG funds. The answer – possible but unlikely. Remember in the FSEOG program a school must set up two selection groups. The first selection group contains students with the lowest EFCs who will also receive a Pell Grant. However, remember that this provision does not require a student to receive a Pell Grant in the same payment period as FSEOG just that they receive Pell in the same award year they are receiving FSEOG.
The second selection group consists of those students with the lowest EFCs who are NOT receiving Pell Grants. The second selection group will be utilized only if there are remaining FSEOG funds after making awards to all Pell grant recipients in the first selection group. Please note that students not receiving any Pell Grant during the award year as a result of exceeding their Pell LEU limits would fall in the second selection group. And though it is possible to award FSEOG to students in the second selection group, many schools are unable to award FSEOG to students in the second group because they never get beyond awarding FSEOG to Pell recipients with low EFCs in their first selection group.
Another question I have been getting a lot is around how to award Pell to a student with less than 100% eligibility remaining in the award year due to reaching the Pell 600% limit. In those cases you would award the student Pell similar to how you handle a transfer student. You would award up to the normal full amount allowed in the first payment period and provide any remaining amount in the second or subsequent payment periods. For example, if a student is enrolled in a standard term semester program (fall and spring) with an annual Pell award of $4800 (100%) with a current LEU of 523.867% then their remaining eligibility is 76.133% of the annual award ($3654.384). Remember you do not round the percentages. Assuming the student is full-time, the school would disburse 50% of the annual award ($4800) in the 1st term ($2400) and would disburse the remainder of the annual award in the second term, up to the remainder of their LEU = $1254.384 (26.133%). Remember you may round the dollar amount down to $1254 (26.125%), or award the cents $1254.38 (26.133%). What the school would NOT do is take the remaining amount of Pell for the year ($3654) and spread it out evenly among the terms the student would be attending.
SAP and Clock Hour Programs
For schools with clock hour programs please note that policy did post examples of how to measure the quantitative component of SAP on the program integrity Q & A website (http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/sap.html) back in late August under the R-Q9 question. Three examples were provided to showcase how to measure the quantitative requirement at the end of the 3 possible payment period scenarios allowed under clock hour programs. Please review the program integrity website for specific details.