M Intent Policy Workgroup
Recommendation
August 10, 2015
Background
As part of the data dictionary work for the new PeopleSoft system, the Data Governance committee
charged a small task force (made up of representatives from research, instruction, and student services)
with reviewing legacy intent codes for language appropriateness and relevancy. This review resulted in
successful clarification of the purpose of each existing intent code, with the exception of the M (multiple
goal seeker). There was disagreement among the group members on whether M was a necessary or
redundant code, based on vague information that it was related to financial aid issues. The task force
was unable to resolve the issue given the amount of information that was needed to fully understand
the history and reasons for the code. At the same time, state board staff was receiving questions from
the colleges about the appropriate use of the M code, to which there was no clear answer given the
ambiguous definition and lack of understanding about the origination and reason for the code.
Subsequently, the Data Governance committee (Carmen McKenzie) requested that a group of state
board staff discuss the issue from a policy perspective and come up with a recommendation about the
retirement of the code or clarification about its meaning. The group of state board staff that
participated in the workgroup on the issue are as follows:
Workgroup Members
Darby Kaikkonen, Policy Research, facilitator
Mat Carlisle, BFET program
Scott Copeland, Financial Aid and Student Services Policy
Joyce Hammer, Transfer Education Policy
Kendra Hodgson, Workforce Policy
Katherine Mahoney, Worker Retraining program
Mason Norman, Workforce programs
Anna Nikolaeva, Perkins program
Project Approach
The issue and trajectory to a solution was approached from a process improvement perspective, with
the following steps to achieve the desired outcome. The results of each step are outlined in the
following pages to provide the full context for the recommendation.
1. Define the problem statement
2. Define the goal statement, or end state of what we want to accomplish
3. Review existing workforce program (BFET, Worker Retraining, Perkins) and financial aid
guidelines for a common understanding and interpretation
4. Assess the “as-is” state of the use of the M code; meaning, how are colleges using it today and
what is their rationale for the use
5. Conduct a gap analysis between the as-is and the goal statement (why is there is a problem?)
6. Establish the most likely causes for the problem
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7. Make a recommendation that will achieve the desired end state
Problem Statement
The group considered the question “what is the problem we are trying to solve?” prompted for deeper
discussion by the question “why is the M code necessary?” The exercise resulted in the following
problem statement:
Colleges’ inconsistent application of the M intent code, in accordance with individual interpretations
of policies and guidelines.
Goal Statement
Given the problem statement, the desired outcome of the workgroup’s recommendation is captured in
the following goal statement:
Consistent and accurate coding of students according to clear and concise system-wide policies and
guidelines.
As-Is
In June and July, the workgroup gathered and analyzed data on the current use of the M code and
talked to college staff for their insights and rationale for why they use it, or do not use it. This
information created the “as-is” or current state, which was a full development of the problem
statement. The findings from the investigation of the current state revealed the following key points:
Data Analysis:
 Only 20 colleges use the M intent in any capacity
 The majority of students coded with an M intent have a nursing (RN) EPC/CIP code. The
remaining students are primarily coded to an EPC/CIP that signifies a selective admissions
process.
 Of those students with an M intent and a nursing EPC/CIP, only 9 percent had taken at least one
nursing course in the given year, suggesting the M intent is used to designate students taking
prerequisites to get into the program
 12 colleges use the G intent code exclusively to code students who are taking prerequisites for a
selective admissions program
Discussions with College Staff
The workgroup exchanged emails and phone calls with colleges who use the M intent regularly (as well
as those who do not) to ask a series of questions about their procedural practices and rationale for its
use. These discussions revealed some consistency among M intent users (nursing is the primary focus
program), although the rationale differed somewhat. Most importantly, these discussions uncovered a
difference in interpretation regarding loan only eligibility for students working on prerequisites for a
selective admissions program. Below is a summary of college practices:
 In one scenario, all students with an expressed interest in nursing are coded as M, and the code
does not change to an F (workforce program) after the student is admitted. Students are
encouraged to work on both an associate in arts degree at the same time as their nursing
degree pathway to provide them greater flexibility for transfer options. Students within this
multiple degree pathway are eligible for full federal financial aid.1
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“Full federal financial aid” henceforth means Pell grants and not loans only
2
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In another scenario, colleges code only those students who have expressed an interest in
pursuing multiple degree pathways as an M. The remaining students who are prerequisite only
are coded with a G. The financial aid practice is inconsistent, where some colleges award full
financial aid to G intent students, while others award loans only.
In another scenario, colleges code all of their selective admissions students as M while they are
working in prerequisites to get into their program. Once the student is admitted (or not), the
code is changed accordingly depending which type of program the student pursues (in sum, the
M is not a terminal intent code). One of these colleges awards full financial aid to M intent
students, and loans only to G intent. The other college does not use G in any capacity.
Some colleges do not use M intent in any capacity even though they have nursing programs, and
use G to signify a student working on prerequisites. Each of these colleges have been awarding
full financial aid to G intent students; however, some are in the process of changing their
practice to an M following the DOE guidelines of loan only for prerequisite students (see
Appendix A).
Some financial aid officers have determined that some students who had been coded an M
before should now be coded a B so that the student can receive aid.
Causes for the inconsistency in coding:
The workgroup evaluated the current coding practices for the colleges who use the M code (as well as
G) as markers for students in a selective admission path. The following categories emerged as the most
probable causes for the inconsistency:
Category
Financial aid
Cause
Differing interpretations of federal financial aid
guidelines AND confusion regarding eligibility
rules
Considerations regarding the best interest of the
student within the boundaries of what is allowed,
based on interpretation of federal financial aid
guidelines
System and structure
The legacy system is old and the schema does not
allow for new and innovative programs (new
nursing DTA as an example of both a transfer and
a workforce program) so colleges have had to
innovate in inconsistent ways
Confusion about what a “multiple goal seeker”
really means (multiple pathways versus multiple
degrees), in light of a selective admissions
program
Some colleges use codes to flag students for
program markers and for advising purposes,
while others do not use certain codes at all or for
different reasons
Colleges are seeking FTES and funding
(enrollments and workforce funding
Student goals and pathway to degree
Enrollment
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Theories for recommendation
Differing interpretations of federal financial aid guidelines appears to be the most common cause for
inconsistent coding. Some colleges interpreted the guidelines (and in some cases specifically told by a
federal aid program officer) to say students who are working on prerequisites for a selective admissions
program are not actually in a program yet, and therefore can only receive loans for up to one year for
that coursework. This situation appears to have resulted in the creation of the M code in order to call a
student not a preparatory student, but a “multiple goal seeker” while they are working on prerequisites.
However, from the colleges’ reports, it was not clear if multiple goal seeker means two degrees
(student’s actual goal is to earn both an academic transfer and a workforce degree), or preparatory
coursework for the selective admissions workforce program could be used for multiple pathways to a
degree. Regardless, the colleges who use M intent code for their students working on prerequisites to a
selective admissions program and are able award full financial aid to these students, as well as include
them in workforce program counts so long as they carry the M code.
However, some colleges have always awarded full financial aid to students doing prerequisites, thus
there was never any reason to utilize the M code to signify a possible multiple degree pathway approach
that should be separate from preparatory coursework only for the purposes of financial aid. the
overarching practice, however, has been to recode their G and M students to their appropriate intent
code once the student is either accepted into the selective admissions program or has moved on to
something else. This suggests that the concept of a multiple goal seeker is preliminary while students
are exploring their potential options, but that there is a marked event in which one path is solidified, in
accordance with the student’s final intended degree program. Financial aid guidelines support this
notion in that a student must declare which program they plan to pursue, and the requirements for
satisfactory progression align with the allowable coursework for that program.
The concept of a multiple degree seeker or dual intent student has also become more pertinent with the
development of new BAS programs and the state’s new nursing DTA. The latter program is the system’s
first true hybrid of an academic transfer and workforce degree in that a student can either transfer into
a baccalaureate program, or go right into the workforce with the degree. The challenge to the coding
schema of the legacy system is that it only allows for one program code, to which intent codes are
mapped for the purposes of financial aid tracking and allowable FTES for workforce funding2. However,
the new PeopleSoft system will allow for multiple program and plan codes, which introduces the need
for a solution that is not driven by the parameters of the existing system.
Additionally, the prerequisite requirements for the new nursing DTA degree differ somewhat across
colleges. Some colleges still only require the standard 35-45 credits of prerequisites before a student
may apply for admission, while others have built the additional general education courses (support
courses) into the admission ratings system. The latter situation means that a student who plans to
submit an application for the nursing DTA would complete at a minimum 50 credits in preparation for
the program. This is more than halfway to a standard associate in arts degree, suggesting the pipeline
process to a selective admissions degree could lead to multiple paths, especially given the competitive
nature of selective admissions programs. This is also the case for new Dental Hygiene BAS programs
currently slated to begin at Clark and Pierce College next year, where the total number of prerequisite
credits are even greater (approximately 68), putting the student a “stone’s throw away” from earning an
2
See Appendix B for eligibility requirements for federal funding for workforce programs
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associate in arts degree at the conclusion of the perquisite coursework. Therefore it is unreasonable to
consider that student in preparatory status only (thus eligible for loans only) for the entire length of the
pre-program requirements, which could be several years.
Recommendation for Intent Coding
The goal statement for the outcome of this work is “consistent and accurate coding of students
according to clear and concise system-wide policies and guidelines.” The following principles and coding
practices are recommended for colleges with this outcome in mind:
Principles
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Intent codes assigned by college staff represent the student’s intended program goal; meaning,
when they arrive at the college, what do they want to walk away with when they have
accomplished their goal.
A delineation between an academic transfer degree goal and a workforce degree goal is
necessary, due to eligibility requirements for workforce programs for FTE counts and funding
However, new programs that are strongly linked to baccalaureate requirements as well as the
Guided Pathways Initiative have shifted the way we need to think about the potential multiple
paths ahead of the student as they begin working on their goals.
There should be flexibility for coding for multiple pathways at the beginning of a student’s
degree planning process, but students should be advised to focus on a definitive path by the
start of second year of college, in alignment with guided pathway and student achievement
progression framework principles
The ability to count FTES for the purposes of funding should not be a driving factor in student
intent coding, but rather the full range of options and implications for financial aid for the
student’s expressed program goals need to be explained and explored with the student through
regular advising.
Coding
Intent Code M (multiple programs):
Student is enrolled in prerequisites for a selective admissions workforce program and intends to
concurrently complete a transfer degree (to include a Nursing DTA) or intends to complete a transfer
degree if not admitted to the selective admissions workforce program. At a time when the student is no
longer pursuing multiple programs (acceptance into selective admissions for example), the intent code
should adjust accordingly.
Intent Code G (preparatory coursework only)
Student has no interest in preparing for multiple degree pathways and does not intend to remain at the
institution if they do not get accepted into the selective admissions program. At a time when the
student is no longer in preparatory status (acceptance into selective admissions for example), the intent
code should adjust accordingly.
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Appendix A: Federal Financial Aid Guidelines
Preparatory coursework
A student not enrolled in a degree or certificate program is eligible for Direct Subsidized/Unsubsidized
Loans (and a parent may receive Direct PLUS Loans on behalf of a dependent student) for up to one year
if she is taking coursework necessary for enrollment in an eligible program.
Remedial coursework
Remedial coursework prepares a student for study at the postsecondary level (as opposed to preparatory
coursework, which prepares a student for a given program), and a student enrolled solely in a remedial
program is not considered to be in an eligible program. If acceptance into an eligible program is
contingent on completing remedial work, a student cannot be considered enrolled in that program until
she completes the remedial work.
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. You may count up to one academic year’s worth of these courses in his enrollment
status for federal aid. For the purpose of this limit, that is 30 semester or trimester hours, 45 quarter hours,
or 900 clock hours. If the remedial classes are non-credit or reduced-credit, you must determine how
many credit hours they are worth to count toward the student’s enrollment status
Source: http://ifap.ed.gov/ifap/byAwardYear.jsp?type=fsahandbook&awardyear=2015-2016
Email from Kimberly Wells, DOE, regarding guidelines for preparatory coursework
Guidance from Dept
of ED on FA for special admission programs, prerequisite classes, and preparatory classes.pdf
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Appendix B: Eligibility Requirements for Workforce Funding
Worker Retraining
1. Student work attend code = 80 series (corresponding with the student’s eligibility category)
2. Student intent code must be one of the following: D, F, G, H, J, K or M OR the student must be
enrolled exclusively in basic skills. Students not coded in this manner will not count towards
enrollment targets nor are they eligible for WRT financial supports.
WORKFIRST
1. Student work attend code = 60 or 70 series (corresponding with the student’s eligibility category)
2. Student intent code must be one of the following: D, F, G, J or M OR the student must be enrolled
exclusively in basic skills. Students not coded in this manner will not count towards enrollment
targets nor are they eligible for WorkFirst financial supports.
BFET
1. Student unusual action code = B!
2. Student intent code must be one of the following: D, F, G, J or M OR the student must be enrolled
exclusively in basic skills. Students not coded in this manner will not count towards enrollment
targets nor are they eligible for BFET financial supports.
OPPORTUNITY GRANT
1. Student must be enrolled in a high wage-demand Opportunity Grant approved workforce program
2. Student Intent Code must be a workforce intent, currently F, G, or M
3. B intent codes do not count for eligibility
PERKINS
90% of funding based on enrollment:
10% based on rural colleges
All colleges eligibility for counts:
1. Pell and Bureau of Indian Affairs AND
intent code F, G, H, J, or M
2. Worker retraining flag
3. TANF current or former (within last 3 years)
1. Rural based on census
2. Pro rata share for those with
high prof-tech FTE
Total up the shares, and colleges received pro rata share of total $
Accountability:
All six performance measures only use students with intent codes F or H. Rationale is the denominator
issue; M intent was not designed to serve as a terminal program intent code.
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