I have 256 students
with Unusual
Enrollment History!
Yeah, well I have
500 students who
are LEU and can’t
finish their degree!
Implementing LEU and UEH
Interpretation, implementation,
impact
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 Codes
UEH Flag
Value
C Code
Comment
Code
Flag Description
School Action to Resolve
Flag
1
No
None
Enrollment pattern
not unusual
No school action
required.
Possible enrollment
pattern problem
School must review
enrollment/
academic and financial
aid records
for past three years.
Questionable
enrollment pattern
School must review
enrollment/
academic and financial
aid records for past
three award years.
2
3
Yes
Yes
359
360
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 20102011, 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!