Pell Grant Duration of
Eligibility Limitation
Robert Vallas, Trainer
U.S. Department of Education
Agenda
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Limitation on Pell Eligibility
Calculating Reduced Awards
Liability for Exceeding the 600% Lifetime Eligibility Used (LEU) Max
Timely Reporting
Pell Award History
Pell LEU Information for Students
Pell LEU in COD
Pell LEU COD Edits
Pell LEU on COD Reports
Pell LEU Dispute Guidance
Pell LEU Dispute Process
Limitation on Pell Eligibility
The Consolidated Appropriations Act, P.L. 112-74 was
enacted on December 23, 2011.
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Duration of a student’s Federal Pell Grant eligibility is limited to 12
semesters (or its equivalent)
Effective beginning with the 2012-2013 award year
Not limited to students who received their first Federal Pell Grant
on or after the 2008-2009 award year
Includes all Pell Grant/Basic Grant disbursements back to the
1973-1974 award year
Limitation on Pell Eligibility
How is the 12 semester equivalent determined?
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Twelve semester equivalency is calculated by adding the annual
percentages of a student’s scheduled award that was disbursed
to the student
The total of the annual percentages is the student’s Pell Grant
LEU limit
When a student reaches 600% LEU, he/she has reached his/her
Federal Pell Grant eligibility limit
Calculating Reduced Awards
How to calculate a student’s Pell Grant eligibility when the
student has:
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LEU of 500% or Less: A student with an LEU of 500% or less is
eligible to receive up to 100 percent of the full Scheduled Award for
the award year, since the student has at least 100% LEU remaining
LEU of 600% or More: A student whose Pell LEU is 600% or more
may not receive additional Pell Grant funds
LEU of Greater Than 500% But Less Than 600%: A student with an
LEU of greater than 500% but less than 600% is not eligible to receive
a full Scheduled Award, but may receive a partial Pell Grant award of
the difference between 600% and the student’s LEU
Calculating Reduced Awards
Scenario 1:
Student is full-time in a semester program and has 0 EFC
and a $5,645 scheduled award
Action:
Calculate student’s Pell eligibility by subtracting the Pell
LEU from the Pell LEU Report from 600.000%
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Report says 534.255%
600.000% - 534.255% = 65.745%
65.745% x $5,645 = $3,711.30525 ($3,711.30)
First semester award = $2,822.50
Second semester award = $888.80 or $888.00 (do not round up)
Calculating Reduced Awards
Scenario 2:
Student is full-time in a semester program and has 525
EFC and a $5,095 scheduled award
Action:
Calculate student’s Pell eligibility by subtracting the Pell
LEU from the Pell LEU Report from 600.000%
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Report lists LEU of 566.425%
600.000% - 566.425% = 33.575%
33.575% x $5,095 = $1,710.64
First payment period = $1,710.64 or $1,710
Second payment period = $ 0
Calculating Reduced Awards
There is no de minimus award amount for purposes of
determining a student’s award because of the 600% LEU
limitation.
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Even a student with a very small remaining LEU is eligible to
receive the calculated amount of Pell Grant
For example, a student with an EFC of 2550 and an LEU of
599.500% would be eligible for the remaining 0.500% which is
$15.475 truncated to $15.47 or, if necessary, rounded down to
$15.00
Liability for Exceeding the 600% LEU Max
Institutional
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If the LEU was >600% prior to the 2012-13 award year, no
adjustment is necessary
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Institution may be liable for the overpayment if it had information
at the time of disbursement that indicated that the student would
exceed 600% LEU
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Institution does not report Pell Grant disbursement within the
required 15 day timeframe may be liable for any overpayment that
results from another institution disbursing Pell Grant funds with
incomplete information because of the late reporting
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Rounding rules do not apply if the amount disbursed would place
the student’s LEU > 600.000%
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Liability for Exceeding the 600% LEU Max
Student
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Student is liable for the Pell Grant overpayment if the institution
was compliant with all disbursement and reporting requirements
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Institution should follow the normal procedures for handling an
overpayment:
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Contact student and enter into satisfactory repayment arrangement
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Refer to the Department for collection
Timely Reporting
Electronic Announcement posted on August 13, 2012
http://ifap.ed.gov/eannouncements/081312PellGrantLifetimeEligibilityUsed.html
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Reminds institutions of the importance of reporting Pell Grant
disbursements AND adjustments
Federal Register posted February 28, 2013
http://www.ifap.ed.gov/fregisters/FR022813.html
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Reduced the timeframe for reporting disbursements (or
disbursement adjustments) made on or after 4/1/13 for Federal
Pell Grant disbursement records to no later than 15 days after
making the disbursement or becoming aware of the need to
adjust a student's previously reported disbursement.
Pell Award History
Summer 2012
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Gathered all Pell Grant information from 1973-1974 across all Pell
legacy systems
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Loaded the calculated LEU percentage to existing students
records in NSLDS
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COD began returning Pell LEU on common record responses for
ALL Pell recipients, and returned warning edits
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COD began displaying Pell LEU on the COD website for ALL Pell
recipients
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Pell LEU History page created to record all historical Pell student
data to determine how Pell LEU was calculated
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Pell LEU Information for Students
CPS
For the 2012-2013 award year
• CPS began reporting Pell LEU information on SARs, using
comment codes to alert applicants who are close to or have
exceeded 600% LEU
For the 2013-2014 award year
• SAR comments are consistent with the student’s Pell history at the
time of the SAR (pre-screening) & from NSLDS post-screening if
LEU changes
• SAR comments will refer to the equivalent of “school year”
• SAR Codes 345-357 contain new or revised comments
• See SAR Comment Codes and Text Guide
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Pell LEU Information for Students
NSLDS
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MyStudentData allows students to download their loan, grant,
and aid overpayment history but does not display Pell LEU
percentage
To minimize confusion, do not refer students to MyStudentData
Download for LEU information
Note: COD is the official system of record for Pell LEU.
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Pell LEU in COD
On the COD website, institutions can also lookup a student’s
LEU using:
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Person Pell Information page
Pell LEU History page
Within COD batch processing:
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Common Record Response File
Edits
Pell LEU in COD
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Pell LEU in COD
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Pell LEU in COD
<Pell>
<FinancialAwardYear>2014</FinancialAwardYear>
<CPSTransactionNumber>01</CPSTransactionNumber>
<FinancialAwardAmount>5645.00</FinancialAwardAmount>
<AttendanceCost>15000.00</AttendanceCost>
<EnrollmentDate>2013-07-03</EnrollmentDate>
<Response>
<ResponseCode>A</ResponseCode>
<YTDDisbursementAmount>1881.66</YTDDisbursementAmount>
<TotalEligibilityUsed>33.333</TotalEligibilityUsed>
<ScheduledGrant>5645.00</ScheduledGrant>
<LifetimeEligibilityUsed>233.333</LifetimeEligibilityUsed>
</Response>
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Pell LEU COD Edits
Three Pell LEU edits are given, as applicable, with
origination and/or disbursement common record response:
Edit #
Message
177
Warning
Lifetime Percentage of Eligibility Used is
near the lifetime limit
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Warning
Lifetime Percentage of Eligibility Used has
exceeded the lifetime limit
201
Reject/
Correcting
Pell LEU exceeds the Pell LEU Limit of
600%
Edit 201 is new as of June 2013!
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Pell LEU on COD Reports
Utilize the 2013-2014 Pell LEU Report to identify Pell-eligible
CPS applicants with LEUs > or = 450%.
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Includes students who listed the school’s Federal School Code on
their 2013-2014 FAFSA
Generated weekly in an institution’s SAIG mailbox
CSV format so it can be easily imported and sorted
COD also provides the Pell LEU on these Pell Grant reports:
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Pell Grant Multiple Reporting Record (MRR)
Pell Grant Reconciliation Report
Pell Grant Year to Date File
Pell LEU within NSLDS
For the 2013-2014 award year
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NSLDS sends the Pell LEU to CPS for inclusion on the ISIR
NSLDS Professional Access website displays Pell Grant
Warning Icons to indicate the student is close to, or has met or
exceeded the Pell LEU limit
Pell LEU within NSLDS
NSLDS also provides reason codes to reflect the Pell LEU
limits.
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Only students who are Pell Grant eligible will be considered for
post-screening with the following reason codes
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Warning
E
Meets or Exceeds Pell Grant LEU Limit
Greater than or equal to 600.000%
C
Close to Pell Grant LEU Limit
Between 500.001% and 599.999%
H
High Percentage Warning
Between 400.000% and 500.000%*
N
No Problem
Less than 399.999%
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Threshold
Pell LEU from CPS
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The applicant’s Pell Lifetime Eligibility Used field appears on the
ISIR in the format 9999.999%
NSLDS Pell Lifetime Limit Pre-Screening Flags Identify whether
an applicant is close to or exceeding his/her total Pell Grant
eligibility limit
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H High (450% to <500%)
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C Close (500% to <600%)
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E Meets or Exceeds (600% or greater)
2013-2014 ISIR Guide was updated on 2/21/2013
http://ifap.ed.gov/isirguide/1314ISIRGuideFeb2013Update.html
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Pell LEU Dispute Guidance
Pell Awards Over 600% LEU
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There is no provision in the law to ‘disregard’ any Pell Grant in the
calculation of a student’s LEU in a case of fraud or a Closed
School Discharge as there is in the discharging of loans
Compliance will be monitored and added to audit and program
review procedures
The new COD reject edit 201 was added to prevent schools from
disbursing Pell Grant to a student with an LEU > 600%
Pell LEU Dispute Guidance
DCL 13-14 posted to IFAP on May 16, 2013
http://www.ifap.ed.gov/dpcletters/GEN1314.html
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Responsibility of the institution to advocate for the student in
resolving Pell data discrepancy
If the amount disputed would not, if corrected, provide additional
Pell eligibility, the issue should not be escalated to the Department
Current and prior schools need to work together to document the
student’s enrollment and receipt of Pell Grant funds for the
disputed award year
Pell LEU Dispute Process
If a student or institution believes the underlying Pell data in
COD is inaccurate, the dispute process was outlined in the
Electronic Announcement posted to IFAP on June 27, 2013.
http://ifap.ed.gov/eannouncements/062713PellGrantLEUDisputeEscalationProcess.html
What the student needs to do:
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Needs to have filed a FAFSA
Needs to work with their current institution
Needs to supply all documentation requested
Pell LEU Dispute Process
Non-Dispute Issues- Admitted Pell Reporting Errors
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2008-09 through 2013-2014 are active in COD and should be
corrected by schools, are not considered disputes, and do not
need to be escalated to the Department
Prior to 2008-2009 cannot be corrected by schools directly
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Contact the COD School Relations Center
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Submit documentation
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The Department will make the corrections based on documentation
Pell LEU Dispute Process
What the current institution needs to do:
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Work as advocate for the student by facilitating the dispute
process
Research the student history in institutional records, COD, and
NSLDS
Contact former school(s) and work together to document the
enrollment and disbursed funds for the disputed period of time
Determine if there is cause for a dispute, and escalate if
appropriate
Inform the former school(s) of the dispute case number assigned
Pell LEU Dispute Process
What the former institution needs to do:
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Cooperate with current school request for information regarding the
alleged discrepancy
Research the student history in institutional records, COD, and NSLDS
Use the case number, obtained from the current school, and include it
on all requested documentation submitted to the Department
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Pell LEU Dispute Process
Escalation
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If it is determined that the case should be escalated to the
Department, the current school contacts the COD School Relation
Center and obtains a dispute case number
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1-800-474-7268 or CODSupport@ed.gov
The COD School Relations Center will advise what
documentation is required
All documentation is submitted electronically and should include
the dispute case number
Pell LEU Dispute Process
What the Department will do:
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Department staff will review all supporting documentation of the case,
and render a decision
Based on the decision, the Department will provide the school(s) with:
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EITHER… An approval notification with the amount of the Pell Grant LEU
adjustment. The school may then disburse Pell Grant funds
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OR… A denial notification. The school will not be able to disburse
additional Pell Grant funds
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AND… A notification that can be given to the student documenting the
Department’s decision
Pell LEU Dispute Process
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COD System changes in June 2013 accommodate Pell LEU
adjustments. If the dispute escalation results in an adjustment by the
Department, the new adjustments section of the Pell LEU History
Screen will reflect this, and the LEU will update accordingly
The updated LEU will flow to NSLDS when the current school submits
a disbursement(s) for the student
Pell LEU Dispute Process
Spring 2014 changes to the Pell LEU Dispute Process
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COD System will further streamline the Pell LEU dispute process
with the creation of a new COD web portal. Authorized users will
be able to:
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Create
View
Update
Upload all documentation
Pell LEU History page will display the Pell LEU Dispute status
Pell LEU Dispute Process
Pell LEU Dispute
portal will allow
schools to enter
dispute information
for Department of
Education review
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Pell LEU Dispute Process
On the Pell LEU Dispute
portal, the required
dispute documentation
should be uploaded to
the COD web
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Pell LEU Dispute Process
After a dispute has been approved,
the student’s Pell LEU History page
will provide details of the dispute and
adjustment.
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Pell LEU Posting References
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DCL, GEN 12-01, 1/18/12 -- Changes Made To The Title IV Student
Aid Programs By The Recently Enacted Consolidated Appropriations
Act, 2012
EA, 6/14/12 -- Pell Grant LEU Information - Additional 2012-2013
COD System Update
EA, 6/29/12 -- Pell Grant LEU Information - July 2012 System
Updates for Lifetime Limit for Federal Pell Grants
EA, 8/13/12 -- Pell Grant Lifetime Eligibility Used: Importance of
Timely Reporting
DCL, GEN 13-14, 5/16/13 -- Federal Pell Grant Duration of Eligibility
and Lifetime Eligibility Used
EA, 6/27/13--Guidance on the Pell Grant Lifetime Eligibility Used
Dispute Escalation Process
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Contact Information
If you have follow-up questions about this session, contact:
Robert Vallas, Trainer
robert.vallas@ed.gov
To provide feedback to my supervisor:
Mark Gerhard, Title IV Training
Supervisor
mark.gerhard@ed.gov
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QUESTIONS?
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