Pell Grant Duration of Eligibility Limitation

Carney McCullough & Marie Fitzpatrick

U.S. Department of Education

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Agenda

• Limitation on Pell Eligibility• Calculating Reduced Awards• Liability for Exceeding the 600% 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

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Limitation on Pell Eligibility

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

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Limitation on Pell EligibilityHow is the 12 semester equivalent determined?

• 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 Lifetime Eligibility Used (LEU) limit

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

Calculating Reduced AwardsHow to calculate a student’s Pell Grant eligibility when the student has:• 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.

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Calculating Reduced Awards• 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.

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Calculating Reduced AwardsScenario 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%

• 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)

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Calculating Reduced AwardsScenario 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%

• 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.

• 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.

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Liability for Exceeding the 600% LEU MaxInstitutional • If the LEU was >600% prior to the 2012-13 award year, no

adjustment is necessary. • 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

• 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.

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

Liability for Exceeding the 600% LEU Max

Student• Student is liable for the Pell Grant overpayment

if the institution was compliant with all disbursement and reporting requirements

• Institution should follow the normal procedures for handling an overpayment:

– Contact student and enter into satisfactory repayment arrangements

– Refer to the Department for collection

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Timely Reporting

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

• 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

• 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.

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Pell Award HistorySummer 2012• Gathered all Pell Grant information from 1973-1974

across all Pell legacy systems• Loaded the calculated LEU percentage to existing

students records in NSLDS• COD began returning Pell LEU on common record

responses for all ALL Pell recipients, and returned warning edits

• COD began displaying Pell LEU on the COD Website for ALL Pell recipients

• 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 StudentsCPSFor 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• 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 CODOn the COD website, institutions can also lookup a student’s LEU using:

• Person Pell Information page• Pell LEU History page

Within COD batch processing• Common Record Response File• Edits

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Pell LEU in COD

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Pell LEU in COD

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Pell LEU in COD

A COD Pell LEU Summary can be provided by the institution to the

student.

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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 EditsThree 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

178 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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Utilize the 2013-2014 Pell LEU Report to identify Pell-eligible CPS applicants with LEUs > or = 450%.• 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: • Pell Grant Multiple Reporting Record (MRR)• Pell Grant Reconciliation Report• Pell Grant Year to Date File

Pell LEU on COD Reports

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Pell LEU within NSLDSFor the 2013-2014 award year• 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.

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Pell LEU within NSLDSNSLDS also provides reason codes to reflect the 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 399.999%

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Pell LEU from CPS• 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

– H High (450% to <500%)– C Close (500% to <600%)– E Meets or Exceeds (600% or greater)

• 2013-2014 ISIR Guide was updated on 2/21/2013http://ifap.ed.gov/isirguide/1314ISIRGuideFeb2013Update.html

Pell LEU Dispute GuidancePell Awards Over 600% LEU• 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

• The new COD reject edit 201 was added to prevent schools from disbursing Pell Grant to a student with an LEU > 600%.

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Pell LEU Dispute GuidanceDCL 13-14 posted to ifap on May 16, 2013 http://www.ifap.ed.gov/dpcletters/GEN1314.html

• 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.

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Pell LEU Dispute ProcessIf 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:•Needs to have filed a FAFSA

•Needs to work with their current institution

•Needs to supply all documentation requested

Pell LEU Dispute ProcessNon-Dispute Issues- Admitted Pell Reporting Errors• 2007-08 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 2007-2008 cannot be corrected by schools directly.– Contact the COD School Relations Center– Submit documentation– The Department will make the corrections based on

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Pell LEU Dispute ProcessWhat the current institution needs to do:• 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

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Pell LEU Dispute ProcessWhat the former institution needs to do:• 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 ProcessEscalation:• 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.– 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

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Pell LEU Dispute ProcessWhat the Department will do:• 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:T EITHER… An approval notification with the amount of the Pell

Grant LEU adjustment. The school may then disburse Pell Grant funds.

T OR… A denial notification. The school will not be able to disburse additional Pell Grant funds.

T AND… A notification that can be given to the student documenting the Department’s decision.

Pell LEU Dispute Process

• 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.

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Pell LEU Dispute Process

Updated Pell LEU History Screen with Adjustments

Pell LEU Dispute Process

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Adjustments will also be listed on the

Pell LEU History

Summary

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

Carney McCullough

Phone: 202-502-7639

E-mail: Carney.McCullough@ed.gov

Marie Fitzpatrick

Phone: 312-730-1549

E-mail: Marie.Fitzpatrick@ed.gov

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QUESTIONS?