NYSFAAA
State-wide Training
June 3, 2010
Two Pells
in One
Award Year
Corrected June 4, 2010
Fred Sellers
Office of
Postsecondary Education
Agenda
•
•
•
•
•
•
•
•
Legislation and negotiated rulemaking
Basics on crossover payment periods
Pell constants
2009-2010 award year
2010-2011 and subsequent award years
Summer 2010
Additional provisions starting in 2010-2011
Pell myths and Two Pells myths
2
Legislation
and
Negotiated Rulemaking
3
Legislation
• Higher Education Opportunity Act of 2008
Pub. L. 110-315 (effective 2009-2010)
• Eligibility for a second Scheduled Award in an
award year
– Must be in a program leading to associate
degree, baccalaureate degree, or certificate
– Must be attending at least half-time in order to
receive any of second Scheduled Award
4
Negotiated rulemaking
• Team V-General and Nonloan Programmatic
Issues met in March 2009, April 2009, and May
2009.
• Negotiations included two Pells in one award
year
5
Negotiated rulemaking
• No consensus
• Notice of proposed rulemaking: August 21,
2009
• Final regulations: October 29, 2009
• Effective starting in 2010-11
• Early implementation
6
Basics on Crossover
Payment Periods
7
Crossover payment period
• Is a payment period that includes June 30 and
July 1, i.e., a payment period that occurs in two
award years
• May be a term or a nonterm payment period
• Must be assigned to one award year
• Must have valid SAR/ISIR for assigned year
• May assign two consecutive crossover payment
periods to the same award year
• Through 2009-2010 award year, have always
been able to assign to either award year
8
Crossover payment period
Example
• A program has a semester calendar with two
summer sessions (6/1 – 7/14 and 7/20 – 8/28).
• If combined in one term, the combined term is a
crossover payment period regardless of what
classes students attend.
• If the two sessions are considered separate terms,
only the 6/1 – 7/14 term is a crossover payment
period.
• Note: if the two sessions are separate terms
– Full-time must be 12 hours for each session to use Pell
Formula 1
– Without a single summer term, the program may no longer
qualify to use an SAY for Stafford/PLUS loans.
9
Crossover payment period
and packaging
• Raises packaging issues
• Must use same EFC, COA, and need for all
programs except Pell
• Treat Pell as estimated financial assistance (EFA)
for other Title IV
• For Pell, use EFC for the award year from which
the student will be paid
10
Crossover payment period
and packaging
EXAMPLE
• Summer term normally assigned as last payment
period of award year.
• Institution decides to pay 2010 summer Pell from
2010-11 ISIR.
– Use 2010-11 ISIR/EFC for Pell
– Use 2009-10 ISIR/EFC for packaging all other
aid
• Amount of Pell received is applied as EFA to
determine need for other Title IV.
11
Crossover payment period
• These requirements are not new.
• The new “two Pell” requirements are in addition to
these requirements.
• For example, if you have no summer crossover
payment period, the “two Pell” requirements still
apply to the rest of an award year.
12
Pell Constants
13
Pell Constants
Unchanged by Two Pells
• Scheduled Award is the amount that a full-time
student would receive for a full academic year
based on the student’s EFC and COA.
• Scheduled Award is prorated by payment period
based on hours and weeks of instructional time
attended.
• Payment for a payment period calculations are
unchanged.
14
Pell Constants
Changed by Two Pells and no longer true
• Student may receive only one Scheduled Award
in an award year.
• Student is always eligible for payment as lessthan-half-time student.
• Institution may assign a crossover payment
period to either award year as a general policy or
on a case-by-case basis.
15
2009-2010
Award Year
16
2009-2010 Implementation
• No regulations for 2009-2010
• Legally supportable ways to implement: ED staff
conference presentations, FSA Handbook, and
new final regulations
17
2009-2010 Implementation
• Term-based program: no requirement that a
student must−
– Complete the hours of the first academic year
to be eligible, or
– Be taking hours attributable to the second
academic year to be eligible
• Clock-hour or nonterm credit-hour program: a
payment period requirement that student must
complete the hours of an academic year to move
to eligibility for a second Scheduled Award due to
payment period definition
18
2009-2010 Payments
• Institution determines payment for each payment
period
• Calculation must be based on Scheduled Award
for the award year
– Pell Grant formulas have not changed
– Each calculation is done using same amount
for Scheduled Award
19
2009-2010 Payments
• Must pay an eligible student until reach 200
percent of his or her Scheduled Award for the
award year
• Can begin paying from 2nd award while paying
balance of 1st award if at least half-time student
• Must be enrolled in an eligible program, i.e., a
program greater than one academic year in
length to be an eligible program for a second
Scheduled Award
20
2010-2011
and
Subsequent Award Years
21
Two Pells: Final regulations
• Must be used starting in the 2010-2011 award
year
• May apply in some instances to summer
crossover payment period considered to be in
2009-2010 award year
§§690.67, 690.64, 690.63
22
Policy goals
• Accelerating completion
• Maximizing the benefit of a second Scheduled
Award
– Must attend full-time, or almost full-time, to
receive significant benefit
• Applying student achievement and
accountability principles for use of funds under
– ARRA (American Recovery and Reinvestment Act of
2009)
– SAFRA (Student Aid and Fiscal Responsibility Act)
23
Basics: Eligible student
• Is enrolled in credit or clock hours attributable to a
student’s second academic year in the award year
– Has successfully completed sufficient hours in
the award year that some hours in payment
period are attributable to the second academic
year in that award year
– Is a major change from proposed regulations
§690.67(a)
24
Semester progression example
Conditions
• A traditional semester-based academic
calendar has fall and spring semesters and a
12-semester-hour nonstandard summer
term.
• Title IV academic year is 24 semester hours
and 30 weeks of instructional time.
• In 2010-2011 award year, student
– Is paid as full-time for fall and spring,
– Earns 12 hours in the fall and 9 hours in the
spring, and
– Enrolls for 6 hours in the summer.
25
Semester progression example
Fall 2010
Earns 12 hr
Spring 2010
Earns 9 hr
Summer 2011
Enrolls 6 hr
2010-11 Award Year
• Only consider hours in current award year
– Do not consider prior award year hours or weeks of
instructional time
• Through spring earns 21 hours, after institution
determines grades for spring
• Consider 3 hours of summer to be attributable to
second academic year
• Eligible for half-time payment from second
26
Scheduled Award
Clock-hour progression example
Conditions
• Academic calendar is 1800 graded clock-hours
over 52 weeks of instructional time in the 20102011 award year.
• Program has 4 payment periods of 450 clock
hours and 13 weeks of instructional time.
• Title IV academic year is 900 clock hours and
26 weeks of instructional time.
• In 2010-2011 award year, student
– Is paid first Scheduled Award over the first
two payment periods, and
– Enrolls in the third payment period after
passing first 900 clock hours.
27
Clock-hour progression example
1st P.P.
450 cl hr
2nd P.P.
450 cl hr
3rd P.P.
450 cl hr
4th P.P.
450 cl hr
2010-11 Award Year
• Only consider hours in current award year
– Do not consider prior award year hours or weeks of
instructional time
• Through second payment period earns 900 clock
hours
• Consider hours of 3rd and 4th payment periods
attributable to the second academic year
• Is eligible for payment from second Scheduled
Award for 3rd and 4th payment periods
28
Basics: Eligible student
• Is enrolled in an eligible program leading to a
bachelor’s or associate degree or other recognized
educational credential
– The program must be greater than one academic
year in length—in both hours and weeks of
instructional time—to be an eligible program for a
second Scheduled Award.
– An exception to the degree or certificate is
provided for students with intellectual disabilities.
• Is enrolled at least as a half-time student
§690.67(a)
Subpart O of part 668
29
Basics: Payment calculations
• Use same amount for both Scheduled Awards in
the award year
• Award consecutively
• Calculate payment for each payment period
• Have been no changes to the formulas to calculate
payments
30
Basics: Disbursements
• Disburse to eligible students until reach 200
percent of the student’s Scheduled Award for the
award year
• Begin disbursing from second Scheduled Award
in a payment period while paying the balance of
first award if student qualifies for second award
§690.63(h)
31
Crossover payment period assignment
• Must assign the payment period to the award year
in which the student receives the greater payment
– If assigned to first award year, must pay with
first award year funds
– If assigned to second award year must pay with
second award year funds
§690.64
32
Crossover payment period assignment
• Must determine the greater payment based on
all requirements that apply
• Must not rely on EFC or Scheduled Award alone
• If only have valid SAR/ISIR for one award year,
must rely on that record
– For example, that award year payment is
higher if, for the other award year-• No SAR/ISIR
• Rejected SAR/ISIR without an EFC
• Incomplete verification
– May still need to pay on other year if receive a
valid SAR/ISIR
33
Crossover payment period assignment
• A student is not eligible for second Scheduled
Award in the first award year of a crossover
payment, regardless of which award year is
higher, if the student is not enrolled-– At least half-time, or
– In hours attributable to the second academic
year of the first award year.
34
Crossover payment period assignment
EXAMPLE
• $4,000 Scheduled Award for first award year and
$5,000 Scheduled Award for second award year
• Receipt of ISIR with a higher Scheduled Award for
second award year after summer term is completed
• Payment as full-time from first award year ($2,000)
although student only completed the term as halftime
• Higher payment in the first award year since
payment from second award year would be based
on half-time, i.e., $1,250 (lump sum payment rule,
§690.76(b))
35
Crossover payment period assignment
• Must reassign if receive information that
student would receive greater payment
– within deadline date for the first award year
(2010 crossover payment period, September 10, 2010)
• May reassign if information received after initial
deadline
– but not later than the deadline date for
administrative relief for the first award year
(2010 crossover payment period, February 1, 2011)
36
Term example
Points illustrated
• Academic year progression within each award
year to establish eligibility for second
Scheduled Award
• Assignment of crossover payment period
based on higher payment
• Assignment of two crossover payment periods
to the same award year
• Payment from a second Scheduled Award not
limited to crossover payment periods
• Payment for a payment period from two
Scheduled Awards
37
Term example
Conditions
• Academic calendar: traditional semesterbased with fall and spring semesters and a
12-semester-hour nonstandard summer term.
• Title IV academic year: 24 semester hours
and 30 weeks of instructional time.
• Formula 1 payment calculations
38
Term example
Summer 2010
Full-time (12 hr)
$2,000
Fall 2010
Full-time (12 hr)
$2,000
Spring 2011
Full-time (12 hr)
$2,000
2010-11 Award Year
• $4,000 Scheduled Award for 2010-11
• Fall, completes the hours of the first academic
year
• Spring, receives payment from second
Scheduled Award after institution determines
student earns hours for fall
39
Term example
Summer 2011
¾ time (9 hr)
$1,875
Fall 2011
Full-time (15 hr)
$2,500
Spring 2012
Full-time (15 hr)
$2,500
Summer 2012
Full-time (12 hr)
$2,500
2011-12 Award Year
• $5,000 Scheduled Award for 2011-12
• Summer 2011 reassigned
• Fall, completes the hours of the first academic
year
• Spring, receives payment from first and
second Scheduled Awards
– $ 625 1st award
operationally
– $1,875 2nd award
transparent
40
Term example
Fall 2012
¾ time (9 hr)
$1,500
Spring 2013
Full-time (12 hr)
$2,000
Summer 2013
Full-time (12 hr)
$2,000
2012-13 Award Year
• $4,000 Scheduled Award for 2012-13
• Spring, does not complete first academic year
• Summer with 9 hours attributable to second
academic year
• For summer payment of $500 from balance of first
award and $1,500 from second award
• May need to assign summer to 2013-2014 if a
higher payment
41
Clock-hour example
1st P.P.
2nd P.P.
3rd P.P.
450 cl hr/13 wk it 450 cl hr/13 wk it 450 cl hr/13 wk it
$2,000
$2,000
$2,000
2010-11 Award Year
• $4,000 Scheduled Award for 2010-2011
• 1,800 clock-hour program over 52 weeks of
instructional time
• $2,000 disbursement from second Scheduled
Award in 3rd payment period
• 3rd payment period of program, a crossover
payment period
42
Clock-hour example
3rd P.P.
4th P.P.
450 cl hr/13 wk it 450 cl hr/13 wk it
$2,500
$2,500
2011-12 Award Year
• $5,000 Scheduled Award for 2011-2012
• Reassignment of 3rd payment period
• Report $4,000 disbursed for 2010-2011 to
COD (a $2,000 reduction)
• Report $2,500 disbursement in 3rd payment
period for 2011-2012
43
Two Pells: COD
• Added new field in COD Common Record
– Additional Eligibility Indicator (AEI)
• Set AEI to “true” when awarding funds from the
student’s second Scheduled Award
• Track the 200 percent limit in COD
• With AEI set to “true,” is no POP MRR, but
concurrent enrollment MRR can still be triggered
if enrollment dates were within 30 days
44
AEI: COD screen
Additional Eligibility
Indicator Checkbox
Summer 2010
46
Crossover payment period
assignment for 2010
• Effective date of final regulations affects 2010
crossover period.
• Institution may designate based on options
applied to all students or on student-bystudent basis.
47
Crossover payment period
assignment for 2010
• Institution may designate-– Prior to July 1, 2010, a student’s payment period
as being in the 2009-10 and not apply these
regulations;
– A student’s payment period as being in the 200910 award year with regulations being applicable;
or
– A student’s payment period as being in 20102011, in which case the regulations must apply.
• Before July 1, 2010, establish written policy
48
Crossover payment period
assignment for 2010
EXAMPLES
• Prior to July 1, 2010, institution determines it will-– Treat 2010 summer payment periods as being in
09-10 and not apply these regulations.
• Prior to July 1, 2010, institution determines it will-– Treat 2010 summer payment periods as being in
09-10 and not apply these regulations, but
– Assign student’s payment period to 2010-2011 if
the student would receive a larger payment.
49
Crossover payment period
assignment for 2010
EXAMPLES
• Prior to July 1, 2010, an institution determines it will-– Treat 2010 summer payment periods as being in
the 2010-2011 award year.
• Prior to July 1, 2010, an institution determines it will-– Make 2010 summer payment period assignments
on a case-by-case basis.
50
Crossover payment period
assignment for 2010
EXAMPLES
• Prior to July 1, 2010, the institution makes NO
determination of policy to apply, and it-– Must apply new regulations to all summer
disbursements, whether for 9-10 or 10-11 (does
not affect 9-10 payment periods prior to summer
2010).
51
Additional Provisions
Starting in 2010-2011
52
Transfer student
• Final regulations: two options
– Assumption method
• Based on disbursements received
– Hours-earned method
• Based on actual hours earned
• Method at option of institution: apply on a
student-by-student basis or to all students
§690.67(b)
53
Transfer student: Assumption method
• Assume completed first academic year if received
all of first Scheduled Award at prior institution
• If less than first Scheduled Award was disbursed,
calculate hours considered to have completed:
Amount disbursed
at prior institution
X
Hours in current
institution’s academic year
Amount of Scheduled Award
at prior institution
=
Hours
considered
completed
54
Transfer student: Assumption method
EXAMPLE – credit hour
• Fall transfer student received $2,000 of $4,000
Scheduled Award for summer at prior institution.
• Current institution, without a summer term, defines
academic year, in part, as 24 semester hours.
• Hours in award year considered to have earned
for prior attendance:
$2,000 disbursed
at prior institution
X
24 hours in current
institution’s academic year
$4,000 Scheduled Award
at prior institution
=
12 hours
considered
completed
55
Transfer student: Assumption method
EXAMPLE – clock hour
• Transfer student received $3,000 of $4,000
Scheduled Award at prior institution.
• Current institution defines academic year, in part,
as 900 clock hours.
• Hours in award year considered to have earned
for prior attendance:
$3,000 disbursed
at prior institution
X
900 clock hours in current
institution’s academic year
$4,000 Scheduled Award
at prior institution
=
675 clock hours
considered
completed
56
Transfer student: Assumption method
• Round down any fractions of a credit or clock
hour
• If courses are offered in fractions of a credit or
clock hour, may retain fractions
• Example
– Using the assumption method, a transfer
student is considered to have earned 12.7
credits in the award year at a prior
institution.
– If the student’s program is offered in
courses of 2.5 credit hours, the institution
may consider the student to have 12.7
credits or 12 credits.
– If the program were offered in 3-hour
courses, the student would have 12 credits.
57
Transfer student: Hours-earned method
• The institution may determine the credit or clock
hours actually earned at other institutions.
• The institution must have information that—
– Includes the time periods when the credit or
clock hours were earned, and
– Does not include nonapplicable credit or clock
hours.
• Any hours earned are applicable. For example,
hours—
– Need not be earned in an eligible program, or
– Be accepted on transfer.
58
Transfer student: Hours-earned method
• An institution must attribute to the current
award year any credit or clock hours earned
at other institutions that were earned in a
summer crossover payment period.
• This requirement applies even though the
institution does not have a summer payment
period.
59
Transfer student: Hours-earned method
EXAMPLE – credit hour
• Current institution defines academic year, in part,
as 24 semester hours.
• Student’s transcript shows earned 6 hours in the
summer term and 12 hours in the fall semester.
• Transfer student received $2,000 of $4,000
Scheduled Award at prior institution and no
payment for summer from the current award year.
• At the current institution, the student is considered
to have earned 18 semester hours in the award
year: 6 from summer and 12 from fall.
60
Transfer student: Hours-earned method
EXAMPLE – clock hour
• Current institution defines academic year, in part, as
900 clock hours.
• Transcript shows student earned 600 clock hours in
the period from June 15 to September 30.
• Transfer student received $3,000 of $4,000 Scheduled
Award at prior institution from the current award year.
• At the current institution, the student is considered to
have earned 600 clock hours in the award year since
the institution confirmed that the first payment period
was a crossover payment period.
61
Transfer student
• No requirement to apply additional information to
disbursements for prior payment period in award
year if receive additional information on a transfer
student
• For example—
– Assumption method: a payment is reported
late to NSLDS.
– Hours-earned method: a transcript is received
indicating student earned additional hours in
the award year at another institution.
• In clock-hour programs, a payment consisting of
funds from a first and second Scheduled Award,
only for a transfer student
62
Nonapplicable hours
• In determining eligibility for a second Scheduled
Award in an award year, may not use hours based
on:
– Advanced Placement (AP) programs
– International Baccalaureate (IB) programs
– Testing out, life experience, or similar
competency measures
• Are not earned by attendance in the award year
§690.67(d)
63
Nonapplicable hours
• The equivalencies of reduced credit and noncredit
remedial coursework do count toward determining
eligibility for a second Scheduled Award in an
award year.
• Any equivalent hours in excess of the 30 semester
hours, 45 quarter credits, or 900 clock hours do
not count unless they are equivalent hours of ESL
coursework.
• In other words, reduced credit and noncredit
remedial coursework does not count if the
equivalent hours do not count toward determining
Title IV eligibility.
64
Special circumstances
• May waive requirement to be enrolling in hours
attributable to the second academic year in the
award year to pay from second Scheduled Award
• Must be due to circumstances beyond the
student’s control
• Must be determined and documented on
individual basis
§690.67(c)
65
Special circumstances
• May include circumstances such as illness or
classes not offered
• Does not include withdrawing to avoid a
grade or failing to register for offered class
66
Pell Myths
and
Two Pells Myths
67
Pell and Two Pells myths
None of the following are true:
• An institution can ignore payment periods, for
example, crossovers or intersessions, and is not
required to pay eligible students in those payment
periods.
• An institution is not required to implement Pell and
Two Pells requirements due to software
deficiencies or the necessity to perform manual
interventions.
• Only students who are first-time Pell recipients
after July 1, 2008 are eligible for Two Pells.
• An institution is not required to make Pell
disbursements for a summer term.
68
Pell and Two Pells myths
None of the following are true:
• An institution can choose to pay only the remaining
first award in the payment period without making a
full payment that includes funds from a second
Scheduled Award for student is eligible.
• An institution must review credits earned in a prior
award year to determine eligibility for a second
Scheduled Award.
• Determining the hours earned for Two Pells
eligibility only applies to crossover payment
periods.
69
Pell and Two Pells myths
None of the following are true:
• Half-time is always 6 credits when determining
eligibility for a second Scheduled Award in an
award year.
• When determining program eligibility for Two Pells,
if the program is one academic year in length, but
SAP allows a student to attempt up to 150 percent
of the hours of a program, the student can be
eligible for a second Scheduled Award since the
student can take more hours than the hours in the
academic year.
70
Pell and Two Pells myths
None of the following are true:
• A student must be half-time in the summer to get
Pell from a first Scheduled Award.
• An institution is not required to disburse Pell for a
less-than-half-time student when a student is
eligible for payment from a first Scheduled Award,
such as for a summer term.
• If I choose to pay the summer of the 2010
crossover as the last payment period of the 20092010 award year, Two Pells does not apply until
the 2010-2011 award year.
• Academic year is the equivalent of grade level.
• Pell uses headers and trailers.
71
NYSFAAA
State-wide Training
June 3, 2010
Contact
Information
• Phone: 202 502-7502
• Email: fred.sellers@ed.gov
• Fax: 202 502-7874
72