Carney McCullough and Kathleen Wicks| Nov. 2012U.S. Department of Education

2012 Fall Conference

Pell Grant Program Update

Session 4

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AgendaWhat are the main provisions in the Pell Grant Interim final rule?Why is there now a limitation on a student’s receipt of Pell Funds?What did ED do to collect Pell History?How do students know their Pell LEU?How do institutions know a Pell LEU?What to do if you believe the Pell Grant data may be inaccurate?What happens if a student receives more than 600% LEU?Timely ReportingHow do you calculate remaining Pell eligibility?How do you calculate a Pell award with a LEU greater than 500%?May a student decline or return a Pell Grant?

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• Implemented the provision of the Department of Defense and Full-Year Continuing Appropriations Act, 2011 (Public Law 112-10) that repealed the provisions that allowed an eligible student to receive a second Pell Grant Scheduled Award in a single award year

• Published in the Federal Register on May 2, 2012 (77 FR 25893)

• Received 10 comments• Final rule will be adopted as final, without change, the interim

final review and the publication is expected soon

Pell Grant Interim Final RuleWhat are the main provisions in the Pell Grant Interim final rule?

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The Pell Grant Interim regulations will no longer:• Allow a student to receive more than one Pell Grant Scheduled

Award in a single award year• Require an institution to assign a payment period that occurs in

two awards years to the award year in which the student would receive the greater payment for the payment period

Pell Grant Interim Final RuleWhat are the main provisions in the Pell Grant Interim final rule?

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The Consolidated Appropriations Act, P.L. 112-74 was enacted on December 23, 2011.

• 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 FundsWhy is there now a limitation on a student’s receipt of Pell Funds?

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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 lifetime eligibility used (LEU) limit

• When a student reaches 600% LEU, he/she has reached his/her Federal Pell Grant eligibility limit

Limitation on Pell FundsWhy is there now a limitation on a student’s receipt of Pell Funds?

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• Gathered all Pell Grant information from 1973-1974 across all Pell legacy systems

• Created logic to calculate semester equivalent as LEU percentage

• Loaded the calculated LEU percentage to existing students records in NSLDS in July 2012• LEUs were not added if there was not already an NSLDS record for

the student• NSLDS Grant information existed only since 1993-1994

• New records are added as loan or grant recipient information is accepted

Pell Award HistoryWhat did ED do to collect Pell History?

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Also in July 2012, the COD System modified the existing LEU functionality:

• Returning the Pell LEU % in the common record response for ALL Pell recipients

• Modifying COD Warning Edits to reflect new limits• Providing the LEU % on the Pell Grant Multiple Reporting

Record (MRR), Pell Grant Reconciliation Report, and Pell Grant Year to Date File

• Displaying LEU % on the COD website for ALL Pell recipients, not just those with first Pell Grants beginning in 2008-2009

• Implementing a new COD Pell LEU History page on the COD website to allow institutions to view historical Pell Grant student data to determine how the LEU was calculated

Pell Award HistoryWhat did ED do to collect Pell History?

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For the 2012-2013 award year

• Between April 16 and July 1, COD sent targeted e-mail messages to 2012-2013 FAFSA Pell-eligible applicants near, or exceeding, an LEU percentage of 600%

• In July 2012, the CPS began reporting Pell LEU information on SARs, using comment codes to alert applicants who are close to or have exceeded 600% LEU

• Using Comment Codes avoided mid-cycle changes to the ISIR record layout

• See 2012-2013 SAR Comment Codes and Text Guide reissued June 2012

How do students know their Pell LEU?

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For the 2013-2014 award year, students can determine their Pell LEU by:

• Additional comments will be added to the SAR 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 October 2012

How do students know their Pell LEU?

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• MyStudentData allows students to download their loan, grant, and aid overpayment history but does not display Pell LEU

• To minimize confusion, do not refer to MyStudentData Download for LEU

• Institutions may provide transcripts from COD

How do students know their Pell LEU?NSLDS

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COD Transcript can be provided by the

institution for the student

How do students know their Pell LEU?COD System

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Schools can utilize the COD 2012-2013 Pell LEU Report to identify 2012-2013 Pell-eligible CPS applicants with LEUs greater than or equal to 450%.

• Each institution’s report includes students who listed a Federal institution Code on their 2012-2013 FAFSA

• Generated weekly in an institution’s Pell newsbox on COD Reporting website

• CSV format so it can be easily imported and sorted• Generated for 2012-2013 award year until 6/30/2013

For 2013-2014, the Pell LEU Report will be available via SAIG, not COD Reporting website

How do institutions know a Pell LEU?COD System

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On the COD website, institutions can also lookup a student’s LEU using:

• Pell Person Information page• Pell LEU History Search• Pell LEU History page

How do institutions know a Pell LEU?COD System

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How do institutions know a Pell LEU?COD System

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How do institutions know a Pell LEU?COD System

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How do institutions know a Pell LEU?COD System

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Export Summary is in Excel format

Transcript that may be printed and provided to

students

How do institutions know a Pell LEU?COD System

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Two Pell LEU warning edits are given with origination and/or disbursement record:

Edit # Message177 Lifetime Percentage of Eligibility Used is near the

lifetime limit

178 Lifetime Percentage of Eligibility Used has exceeded the lifetime limit

Pell LEU within CODCOD Warning Edits

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<Pell><FinancialAwardYear>2013</FinancialAwardYear><CPSTransactionNumber>01</CPSTransactionNumber><FinancialAwardAmount>3309.00</FinancialAwardAmount><AttendanceCost>4000.00</AttendanceCost><EnrollmentDate>2012-07-03</EnrollmentDate><Response><ResponseCode>A</ResponseCode><YTDDisbursementAmount>2309.00</YTDDisbursementAmount><TotalEligibilityUsed>57.012</TotalEligibilityUsed><ScheduledGrant>4050.00</ScheduledGrant><LifetimeEligibilityUsed>57.012</LifetimeEligibilityUsed></Response>

Pell LEU within CODCOD Response Record

Pell LEU within CODCOD Reports

COD also provides the LEU on the following Pell Grant SAIG reports:

• Pell Grant Multiple Reporting Record (MRR)• Pell Grant Reconciliation Report• Pell Grant Year to Date File

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• The new Pell Lifetime Eligibility Used field provides the percentage of the total Pell Grant eligibility used by the applicant• This percentage prints on the ISIR in the format 9999.999%

• NSLDS Pell Lifetime Limit Pre-Screening Flag • Three Pell Lifetime Limit Flags identify whether an applicant is

close to or exceeding his/her total Pell Grant eligibility limit• H High (450% to <500%)• C Close (500% to <600%)• E Meets or Exceeds (600% or greater)

• 2013-2014 ISIR Guide was published on 10/29/2012 • http://ifap.ed.gov/isirguide/1314ISIRGuide.html

Pell LEU From CPSISIR

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NSLDS received a one-time update of Pell Grant LEU percentages from COD in July 2012.

• Included Pell Grant recipients from 1973-1974 award year to present

• LEU percentages for students with no NSLDS record(s) were not loaded

• Since the one-time update, COD sends LEU percentages to NSLDS when Pell Grants are made or changed

Pell LEU From NSLDSOne-Time Update

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Starting with 2013-2014 award year, the following will be available via NSLDS:

• NSLDS will start sending the Pell LEU% to CPS for inclusion on the ISIR

• NSLDS Professional Access website to display Pell Grant Warning Icons – “Close to Pell Grant LEU Limit” and “Meets or Exceeds Pell Grant LEU Limit”

Pell LEU within NSLDSWarning Icons

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NSLDS will also provide reason codes to reflect the new Pell LEU limits.

• Only students who are Pell Grant eligible will be considered for post-screening with the following reason codes:

Code Warning Threshold

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 or equal to 399.999%

*previously between 450.000% and 500.000%

Pell LEU within NSLDSReason Codes

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If a student or institution believes a LEU is inaccurate, the following actions should be taken:

Student• Need to work with their current institution

Institutions• Need to work as advocates for the student • Review the student history in COD and provide a copy to the

student• If data, the information that results in the student receiving partial or

no Pell eligibility is still in question, the institution will receive direction on how to escalate the matter to FSA for adjudication

Pell DataWhat to do if you believe the Pell Grant data may be inaccurate?

Note: Documentation will be required. This may include student statement, institution attestation, etc.

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If the Pell Grant data is determined to be wrong, both the student and the institution that wishes to pay the student, will be given documentation that must be maintained.

• Institution: Audit trail that the student payment is proper• Student: To be used in the event of transfer• COD, CPS, and NSLDS will continue to reflect the inaccurate

information until future system modifications are made• COD Edits 177 and 178 will continue to be returned • Most common claim to date is that the student did not attend an

institution listed or receive the funding listed in the LEU history

Pell DataWhat to do if you believe the Pell Grant data may be inaccurate?

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• There is NO HARD REJECT EDIT in COD or EDExpress that prevents an institution from disbursing Pell awards to a student with an LEU of > 600% in the 2012-2013 and 2013-2014 award years

• There is no provision in the law to ‘disregard’ 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

• New edits are planned for 2014-2015 to prevent overawarding and reject disbursements that result in overawarding

Awards Over 600% LEUWhat happens if a student receives more than 600% LEU?

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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

• Rounding rules do not apply if the amount disbursed would place the student’s LEU > 600.000%

• Student is liable for any Pell Grant overpayment• Institution should follow the normal procedures for handling an

overpayment:• Contact student and enter into satisfactory repayment

arrangements• Refer to the Department for collection

Awards Over 600% LEUWhat happens if a student receives more than 600% LEU?

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• Electronic Announcement posted on August 13, 2012 http://ifap.ed.gov/eannouncements/081312PellGrantLifetimeEligibilityUsed.html

• Reminds institutions of the importance of Pell Grant disbursements AND adjustments

• In future award years, may reduce the reporting timeframe

Timely Reporting

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Example 1Scenario: Student is full-time in a semester program and has 0 EFC and a $5,550 scheduled awardAction: Calculate student’s Pell eligibility by taking percentage on report from 600.000%

• Report says 534.255%• 600.000% - 534.255% = 65.745%• 65.745% x $5,550 = $3,648.848• First semester award = $2,775• Second semester award = $873.85 or $873.00 (do not round up)

Pell Calculation ExamplesHow do you calculate remaining Pell eligibility?

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Example 2Scenario: Student is full-time in a semester program and has 525 EFC and a $5,000 scheduled awardAction: Calculate student’s Pell eligibility by taking percentage on report from 600.000%

• Report says 566.425%• 600.000% - 566.425% = 33.575%• 33.575% x $5,000 = $1,678.75• First semester award = $1,678.75• Second semester award = $0

Pell Calculation ExamplesHow do you calculate a Pell award with a LEU greater than 500%?

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See Dear Colleague letter, GEN-12-18 http://ifap.ed.gov/dpcletters/GEN1218.html

A student may:• Decline all or a part of a Pell Grant award • Return, during an award year, all or a part of a disbursement

already made within the same award yearThe student must provide a signed, written statement:

• Clearly indicating his/her decline/return of Pell Grant funds • Acknowledges that funds may not be available at a later date

Declining a Pell GrantMay a student decline or return a Pell Grant?

Note: An institution may not package need-based Title IV aid to compensate.

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Contact InformationWe appreciate your feedback and comments. We can be reached at:

Carney McCulloughPhone: 202-502-7639

E-mail: Carney.McCullough@ed.gov

Kathleen WicksPhone: 202-377-3110

E-mail: kathleen.wicks@ed.gov

QUESTIONS?

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