Navigating Navigating R2T4R2T4MASFAAMASFAANovember 16, 2006November 16, 2006Allene Begley Curto, Springfield CollegeAllene Begley Curto, Springfield CollegeThomas Threlkeld, US EDThomas Threlkeld, US ED

Navigation Tools for Navigation Tools for Return of Federal AidReturn of Federal Aid When we are When we are requiredrequired to return to return

federal aidfederal aid When we are When we are requiredrequired to offer federal to offer federal

aid not yet disbursedaid not yet disbursed How a student How a student earnsearns federal aid based federal aid based

on attendanceon attendance How we know when a student has How we know when a student has

begun or has withdrawn (officially or begun or has withdrawn (officially or unofficially)unofficially)

What has changed with HERAWhat has changed with HERA

The Basic Concepts The Basic Concepts behind the behind the Requirements…Requirements…

If you never If you never beganbegan attending, you are attending, you are not eligible for federal aidnot eligible for federal aid

If you began but did not If you began but did not completecomplete the the term, you may not be eligible for all of term, you may not be eligible for all of the aid that you receivedthe aid that you received

If you began but did not If you began but did not completecomplete the the term, you may still be eligible for some term, you may still be eligible for some of the aid that you did not yet receiveof the aid that you did not yet receive

US ED US ED requiresrequires the school to know if a the school to know if a student began attendance and student began attendance and whether they completed the termwhether they completed the term

We are We are requiredrequired to to returnreturn federal aid… federal aid… If a student began attendance, If a student began attendance,

but withdrew before completing but withdrew before completing 60% of the term60% of the term

If a student failed to pass any If a student failed to pass any course in a term and the school course in a term and the school can not document that the can not document that the student completed at least 60% student completed at least 60% of the termof the term

We are We are requiredrequired to offer to offera post-withdrawal a post-withdrawal disbursement....disbursement.... If a student If a student beganbegan attendance, attendance,

did did notnot complete the term, but complete the term, but has has earnedearned aid which has not yet aid which has not yet

been disbursed, been disbursed, andand The student meets the The student meets the

requirements for a late requirements for a late disbursementdisbursement

What Aid has been What Aid has been earned?earned? Did they begin?Did they begin? Did they complete?Did they complete? If they began but didn’t complete, If they began but didn’t complete,

what percentwhat percent of the term of the term diddid they complete?they complete?

What do we know and when did What do we know and when did we know it? we know it?

Who Knows? Who Knows? Who Tells FAO?Who Tells FAO? How does the school How does the school knowknow if a student if a student

beganbegan attendance in at least one attendance in at least one course?course?

How does the school How does the school knowknow if the if the student student stoppedstopped attending? attending?

Who reviews students who fail to pass Who reviews students who fail to pass at least one course in a term? at least one course in a term?

How is FAO notified on any and all of How is FAO notified on any and all of the above?the above?

How is it documented by the How is it documented by the schoolschool??

Percentage CompletedPercentage Completed

Days Attended divided by Days in Days Attended divided by Days in the Term = Percentage the Term = Percentage completedcompleted

Exclude scheduled breaks that are Exclude scheduled breaks that are at least 5 consecutive days from at least 5 consecutive days from bothboth Days Attended Days Attended andand Days in Days in the Termthe Term

Nonterm Credit HoursNonterm Credit HoursClock HoursClock Hours Nonterm Credit Hour programs – Nonterm Credit Hour programs –

Number of Credit hours expected to be Number of Credit hours expected to be completed in payment period divided completed in payment period divided by number of credit hours completed by number of credit hours completed at withdrawal. at withdrawal.

Clock Hours – Total number of clock Clock Hours – Total number of clock hours hours scheduledscheduled to be completed at to be completed at time of withdrawal divided by total time of withdrawal divided by total clock hours in periodclock hours in period

HERA CHANGESHERA CHANGES

Effective for withdrawals that occurred on Effective for withdrawals that occurred on or after July 1, 2006or after July 1, 2006

Scheduled Clock Hours Scheduled Clock Hours Leaves of AbsenceLeaves of Absence Grant Overpayments Grant Overpayments Programs from which Funds are ReturnedPrograms from which Funds are Returned Return of Funds TimelineReturn of Funds Timeline Post-Withdrawal Disbursement CounselingPost-Withdrawal Disbursement Counseling

HERA Changes -HERA Changes -Clock HoursClock Hours

Only scheduled hours are used, no Only scheduled hours are used, no longer any formula to determine longer any formula to determine whether it should be scheduled or whether it should be scheduled or completedcompleted

A student earns 100% of his or her aid if A student earns 100% of his or her aid if the student’s withdrawal date is after the student’s withdrawal date is after the point that he or she was scheduled the point that he or she was scheduled to completed at least 60% of the to completed at least 60% of the scheduled hours in the payment period scheduled hours in the payment period or period of enrollmentor period of enrollment

HERA Changes –HERA Changes – Leaves of AbsenceLeaves of Absence US ED clarifies that an institution US ED clarifies that an institution maymay

grant more than one leave of absence grant more than one leave of absence to a studentto a student

Other LOA rules remainOther LOA rules remain No more than 180 days total in any 12 No more than 180 days total in any 12

month periodmonth period Must follow school’s written policyMust follow school’s written policy School may not asses any additional School may not asses any additional

chargescharges ……and all other LOA requirementsand all other LOA requirements

HERA Changes –HERA Changes –Grant OverpaymentGrant Overpayment Limited to the amount by which the Limited to the amount by which the

original grant overpayment is original grant overpayment is greater than half of the total Title IV greater than half of the total Title IV grant funds received by studentgrant funds received by student

A student does not have to repay a A student does not have to repay a grant overpayment of $50 or lessgrant overpayment of $50 or less

No changes to the grant repayments No changes to the grant repayments required to be made by the schoolrequired to be made by the school

HERA Changes – HERA Changes – Programs from which Funds Programs from which Funds are Returnedare Returned Pell Grant, SEOG, FFEL, Federal Pell Grant, SEOG, FFEL, Federal

Direct Loan, Federal Perkins Loan, Direct Loan, Federal Perkins Loan, ACG, SMARTACG, SMART

No longer applies to LEAP, SLEAP, No longer applies to LEAP, SLEAP, GEAR UP and SSSGEAR UP and SSS

No change to the exclusion of No change to the exclusion of FWSFWS

HERA Changes –HERA Changes – Post-Withdrawal Post-Withdrawal Disbursement CounselingDisbursement Counseling School required to contact student School required to contact student

prior to making a post-withdrawal prior to making a post-withdrawal disbursement of loan fundsdisbursement of loan funds

Explain obligation to repay loan fundsExplain obligation to repay loan funds Confirm loan funds still required by Confirm loan funds still required by

studentstudent Document result of contact in fileDocument result of contact in file Applies even if student owes balance Applies even if student owes balance

to schoolto school

HERA Changes – HERA Changes – Return of Funds TimelineReturn of Funds Timeline

Must return unearned funds within 45 Must return unearned funds within 45 days of the date that it determines days of the date that it determines that student ahs withdrawn (previously that student ahs withdrawn (previously 30 days)30 days)

Note that date that school determines Note that date that school determines student has withdrawn is not the date student has withdrawn is not the date that FAO became aware of the fact! that FAO became aware of the fact!

Note that Note that returnreturn is required in 45 is required in 45 days, not just the calculation! days, not just the calculation!

Why we Why we should should know if a know if a student began/completed student began/completed the term…the term… Successful completion of the Successful completion of the

educational program is the goaleducational program is the goal Enrollment retention requires Enrollment retention requires

knowledge of who is really hereknowledge of who is really here Students need Students need

response/support/action if not response/support/action if not attending or don’t registerattending or don’t register

QUESTIONSQUESTIONSANDAND

ANSWERSANSWERS