KASFAA 2013
Fall Training
Diana VanDyke
Butler Community College
Unusual Enrollment History
Dear Colleague Letter
GEN 13-09
*Why?
(…to prevent fraud and abuse in the Federal Pell Grant
Program….) GEN-13-09
*How?
(…by identifying students with unusual enrollment
histories…) GEN-13-09
*Can you be more specific?
YES!
(The specific enrollment pattern we are concerned about is
one where the student attends an institution long enough to
receive title IV credit balance funds, leaves …, enrolls at
another institution, and repeats…) GEN-13-09
Unusual Enrollment History
Remember:
*NOT Verification
(Resolution of a UEH flag is separate and distinct from verification
and is not related to the new Verification Tracking Groups IV and
V….however, it is similar in that institutional action is required.)
GEN-13-09
*NOT SAP
(Satisfactory Academic Progress)
Unusual Enrollment History
Flags
UEH
Flag
Description
C?
SAR Code: Comment
2
Unusual Enrollment History 2
(Possible enrollment pattern
problem, school may need to
resolve)
Yes
359: Your school may request
additional information to determine
your eligibility for federal student
aid.
3
Unusual Enrollment History 3
(Questionable enrollment
pattern, school must resolve)
Yes
360: Based upon data provided by
the National Student Loan Data
System (NSLDS), your school will
request additional information to
determine your eligibility for federal
student aid and before disbursement
of funds can be made.
N
Enrollment pattern not unusual
(No school action required)
No
N/A
Unusual Enrollment History
Flag N and 2
UEH Flag value = N
*UEH Flag value = 2
No action is required
Must review student’s enrollment
and financial aid records to determine if, during the 3
award year review period, student received a Pell
Grant at your institution. (For 13/14 review period =
10/11, 11/12, 12/13)
*If YES, no additional action is required unless you
believe student remains enrolled just long enough to
collect student aid funds. In this case, must follow
guidance provided for a UEH Flag of 3.
*If NO, must follow guidance provided for UEH Flag of 3.
Unusual Enrollment History
Flag 3
*Must review student’s academic records to determine
if student received academic credit at institutions the
student received Pell during the 3 award year period
*Identify institutions through NSLDS
*Use transcripts or grade reports for each of the
previously attended institutions to determine whether
academic credit was earned during the award year in
which the student received Pell funds
(Academic credit is considered earned if
academic records show student completed any
credit hours or clock hours.)
Unusual Enrollment History
Flag 3
*Academic Credit Earned:
If determine student
earned any academic credit at each of the previously
attended institutions during the relevant award years,
no further action is required unless institution has
other reasons to believe student enrolls just to
receive credit balances
*If determine that academic credit was NOT earned
at one or more of the previously attended
institutions OR the school had reasons to believe
student just enrolls for title IV funds, the institution
must follow the “Academic Credit Not Earned”
guidance
Unusual Enrollment History
Flag 3
*Academic Credit NOT Earned:
If student did not earn
academic credit at a previously attended institution,
including your school if applicable, must obtain
documentation from student explaining why failed to
earn academic credit
*Must determine whether the documentation supports
(1) the reasons given by the student for the student’s failure
to earn academic credit; and
(2) that student did not enroll only to receive credit balances
*To extent possible, obtain third party documentation to
support student’s claim
Unusual Enrollment History
Flag 3
*Institution determines whether circumstances of
failure to receive credit warrant continuation of Title
IV Aid – if not, must deny further aid
*Reasons for decision must be documented and
maintained for possible review
*Notification of the decision must be provided to the
student
*Institutional determinations are final and can not be
appealed to the Department
Unusual Enrollment History
Flag 3
*Approving Continued Eligibility
*If school approves student’s continued eligibility, may:
*Require student to establish academic plan, like (SAP)
*Counsel student about the impact of the student’s
attendance pattern on future Pell Grant eligibility
(LEU, SAP and UEH future denials…etc)
Unusual Enrollment History
Flag 3
*Denying Continued Eligibility
*Student must be given opportunity to question and appeal
the decision
*Student must be given information on how to regain
eligibility at your institution
*Regaining Eligibility
*(it is expected that successful completion of academic
credit would form the basis for the student’s subsequent
request for renewal of title IV, HEA program eligibility.)
GEN-13-09
*Could include meeting requirements of an academic plan
Unusual Enrollment History
http://www.usafunds.org/Pages/
PolicyResources.aspx
Unusual Enrollment History
*Questions / Comment?
*Want to share?
*If not, let’s look at AskRegs!
Unusual Enrollment History
NASFAA AskRegs Knowledgebase
1.
Do We Look at Pell Received or Credits Earned When
Resolving an Unusual Enrollment History (UEH) Flag?
2.
Is Further Action Required to Resolve Unusual Enrollment
History Flag Value 2 If Pell Was Received in ANY of the 3
Award Years Reviewed?
3.
Are Schools Required to Resolve Unusual Enrollment
History Edits for Both Graduate and Undergraduate
Students?
4.
Are We Required to Review a Student's Unusual Enrollment
History If He Is Over the 600% Eligibility Limit?
Unusual Enrollment History
NASFAA AskRegs Knowledgebase
5.
Is an Unofficial Transcript Acceptable for Resolving the
Unusual Enrollment History Flag C-Code?
6.
Can a Student Appeal an Institution's Denial Based on
Unusual Enrollment History?
7.
Is the Completion of New Credit Hours as Part of an
Unusual Enrollment History Appeal a Requirement or
Recommendation?
8.
How Do We Handle a Subsequent ISIR Without an Unusual
Enrollment History Flag When the Previous Transaction
Had a Flag?