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STUDENT ELIGIBILITY REQUIREMENTS

Session FS8. STUDENT ELIGIBILITY REQUIREMENTS. Marcia Fediw and Mike Stein | Nov.-Dec. 2017 U.S. Department of Education 2017 FSA Training Conference for Financial Aid Professionals. AGENDA. Basic student eligibility requirements Resolving conflicting information Telecommunications

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STUDENT ELIGIBILITY REQUIREMENTS

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  1. Session FS8 STUDENT ELIGIBILITY REQUIREMENTS Marcia Fediw and Mike Stein | Nov.-Dec. 2017 U.S. Department of Education 2017 FSA Training Conference for Financial Aid Professionals

  2. AGENDA • Basic student eligibility requirements • Resolving conflicting information • Telecommunications • Written arrangements • Internships/Externships

  3. STUDENT ELIGIBILITY Eligibility Requirements For Federal Student Aid: • Be a citizen or eligible non-citizen of the United States • Have a valid Social Security Number (SSN) • Have a high school diploma or a General Education Development (GED) Certificate • Be enrolled at least half-time in an eligible program as a regular student seeking a degree or certificate • No drug convictions

  4. STUDENT ELIGIBILITY Eligibility Requirements For Federal Student Aid: • Maintain Satisfactory Academic Progress (SAP) • Not owe a refund on a federal student grant or be in default on a federal student loan • Have a valid ISIR/SAR on file with your institution • Verification not required—however, conflicting information on ISIR/SAR must be resolved before paying aid • Selective Service (males only)

  5. CONFLICTING INFORMATION • Conflicting information is information obtained which is different from information previously available to the institution which impacts a student’s eligibility for aid • Citizenship status • Accuracy of SSN • Default or overpayment status • Changes in student’s academic status • Cost of Attendance (COA) elements • Other student financial assistance or resources • Inconsistent information used in the calculation of the EFC

  6. REGULATORY REQUIREMENT 34 CFR §668.16(f) • Institution must develop and apply an adequate system to identify and resolve discrepancies • An adequate system obtains and reviews • All student aid applications, need analysis documents, Statements of Educational Purpose, Statements of Registration Status, and eligibility notification documents presented by or on behalf of each applicant

  7. REGULATORY REQUIREMENT • An adequate system obtains and reviews • Any documents, including any copies of State and Federal income tax returns, that are normally collected by the institution to verify information received from the student or other sources; and • Any other information normally available to the institution regarding a student’s citizenship, previous educational experience, documentation of the student’s SSN or other factors relating to the student’s eligibility for funds under the Title IV, HEA programs

  8. REGULATORY REQUIREMENT §668.16(b)(3) also requires that the institution “communicates to the individual designated to be responsible for administering Title IV, HEA programs, all the information received by any institutional office that bears on a student’s eligibility for Title IV, HEA program assistance.”

  9. SOURCES • External sources • Other offices within the institution • Other institutions • Information from ED • Information from the student to the financial aid office

  10. SOURCES External sources • Scholarships from outside sources • Agencies such as Immigration Department, etc. • Tips from outside sources

  11. SOURCES Other offices within the institution • Campus-wide effort • Must have a system to share information within institution, for example • Admissions • Registrar • Business Office • Athletics • Academic Departments

  12. SOURCES Other Institutions • Transcripts • Contact with an office at other institution (not just FAO)

  13. SOURCES Information from ED • SARs or ISIRs in general • C Flags • Reject Codes • Comment codes • Updated NSLDS information • COD

  14. SOURCES Information from the student to the financial aid office • Unsolicited submission of tax returns or schedules • Supplemental financial aid applications • Other information provided by student

  15. RESOLUTION • Why is it important to resolve conflicting information? • Because it ensures that the right students (eligible students) receive the right (correct) amount of aid • Resolution is the determination of the correct information • May be simply confirmation that an earlier determination is correct • Documentation of resolution required • You may not ignore a document in your files unless a student is no longer enrolled

  16. RESOLUTION • Should resolve the conflict as quickly as possible • Do not disburse aid or make additional disbursements until the conflict is resolved • If the conflicting information is unable to be resolved, the institution must consider the student in an overaward status for any need-based aid • Direct Subsidized Loans – Will be repaid under terms of the promissory note, but institution must record its determination

  17. RESOLUTION • No further action is needed if: • All aid for period of enrollment has been disbursed, • There was no conflicting information at the time of disbursement, and • Student is no longer enrolled at the institution (and is not intending to re-enroll) • If remaining aid is to be disbursed, must resolve the conflict before making late or post-withdrawal disbursement

  18. 2017-18 FAFSA • Increased possibility of conflicting information due to the inclusion of 2015 income and tax information on the 2016-17 and 2017-18 FAFSAs • ED will identify 2017-18 applications where conflicting information may exist that, if resolved, would result in a significant change in EFC Dear Colleague Letter GEN-16-14

  19. 2017-18 FAFSA • Central Processing System (CPS) will compare the last 2016-17 ISIR transaction with the 2017-18 ISIR to – • Determine if there is income/tax conflicting information between the two FAFSAs, and, • If any identified conflicting information would, once resolved, produce a significant change in the student’s expected family contribution (EFC) • CPS will flag the 2017-18 ISIR to require institutional resolution

  20. COMMENT CODES 395-399 • Comment codes 395-398 indicate possible conflicting information, but resolution is not required • Resolution IS required for comment code 399 • If comment code 399 does not appear on the 2017-18 ISIR, institutions are not required to resolve differences in income or tax information between the two ISIRs • Any other conflicting information must still be resolved

  21. COMMENT CODE 399 • ED Identification • Must compare the 2015 income and tax related items from both years to determine which item(s) are in conflict • If, for either year the institution had verified the item(s) or the IRS Data Retrieval Tool (DRT) had been used with no changes, assume that the verified or IRS DRT transferred values are correct and submit corrections to the other year’s ISIR

  22. COMMENT CODE 399 • Comment code 399 does not need resolution if • Institution never received a 2016-17 ISIR • Institution received a 2016-17 ISIR but did not and will not disburse Title IV aid based on either ISIRs • Aid was disbursed in 2016-17, but the student is no longer enrolled and is not expected to return in 2017-18

  23. COMMENT CODE 399 • If reprocessed ISIR no longer includes Comment Code 399, the institution is not required to take action • Any Code 399 on subsequent ISIRS must still be resolved • Code 399 need not be resolved for graduate students if the student is a graduate student in both 2016-17 and 2017-18

  24. OIG REFERALS • Fraud is an intent to deceive as opposed to a mistake • Fraud must be referred to Office of Inspector General (OIG) • Examples include • False claims of independent status • False claims of citizenship • Use of false identities • Forgery of signature of certifications • False statements of income

  25. TELECOMMUNICATIONS • Not permitted • Foreign institutions may use distance education technologies to supplement and support instruction offered in a classroom located in a foreign country where students and instructor are physically present

  26. TELECOMMUNICATIONS • A program offered in whole or in part through telecommunications, otherwise known as distance education • A program offered in whole or in part through correspondence • A program offered through direct assessment

  27. WRITTEN ARRANGEMENTS • Consortium Agreement • A written agreement between two or more eligibleinstitutions • Contractual Agreement • A written agreement between an eligible and an ineligible school • Foreign institutions may not enter into contractual agreements

  28. CONSORTIUM AGREEMENT • Student may take courses at a school other than the home school and have those courses count toward the degree or certificate at the home school • Home school must give credit for courses taken at other schools on same basis as if it provided the training itself • Home institution may decline to give credit

  29. CONSORTIUM AGREEMENT • Grades received through a consortium agreement do not have to be included when calculating GPA but must be included in calculating percentage of credits earned versus attempted

  30. REQUIRED DISCLOSURES • Institution must provide enrolled and prospective students a description of consortium agreements it has entered into including • Portion of the educational program the institution that grants the degree is not providing • Name and location of institutions that are providing that portion of the program

  31. REQUIRED DISCLOSURES • Method of delivery of that part of the program • Estimated additional costs to students

  32. DURATION OF AGREEMENT • Agreements between schools may go on indefinitely and do not need to be renewed unless terms of the agreement change • Individually initiated agreements or those for specific groups, continue for the length of time specified in the agreement

  33. DIVISION OF RESPONSIBILITIES • Either the home or host school may assume responsibility for disbursing loan funds and/or monitoring student • Home school generally assumes responsibility for disbursing and monitoring students

  34. DIVISION OF RESPONSIBILITIES • Under a consortium agreement, any participating institution may make direct loan calculations and disbursements without being considered a third-party servicer • Institution that disburses a direct loan to the student is responsible for maintaining information on the student’s eligibility, calculation of award, and money disbursed

  35. STRUCTURE OF AGREEMENT • Consortium agreement can be a blanket agreement between two or more eligible schools or it can be for a specific student • Institutional Options • One agreement for each student • Separate agreement with each host school • Blanket agreement with a group of schools

  36. STRUCTURE OF AGREEMENT • No limit on the portion of the eligible program that may be provided by the host institution(s) • Agreement contents may vary widely depending upon the interests of the institutions involved • No consortium agreements with institutions in the United States

  37. CONTENTS OF AGREEMENT • Agreement Must Include: • Institution that will grant the degree or certificate • Student’s tuition, fees, room and board costs at each school • Student’s enrollment status at each school • School that will be responsible for disbursing direct loan funds and monitoring the student’s eligibility, and • Procedures for calculating awards, disbursing aid, monitoring SAP, and other requirements such as recordkeeping and returning funds if a student withdraws

  38. INTERNSHIPS • Foreign institution may not permit direct loan recipients to enroll in any course offered by the foreign institution in the United States

  39. INTERNSHIPS • Independent research must • Be conducted during the dissertation phase of a doctoral program • Be done under the guidance of faculty • Be research that can only be performed in the United States • Internships/Externships are, with exception, subject to the written arrangement requirements

  40. INTERNSHIPS • Internships/Externships at a foreign institution must be subject to oversight by an accreditor or government entity • If the above cannot be demonstrated, the internship is subject to the requirements of written arrangements • If an internship is subject to the requirements for written arrangements and that internship is with a non-eligible entity (e.g., a local company), the program of which that internship is part would not be an eligible program

  41. CONTACTS • Email: FSA.Foreign.Schools.Team@ed.gov • Phone: 202-377-3168 • Fax: 202-377-3486 • Mail: U.S. Department of Education Multi-regional and Foreign School Participation Division Union Center Plaza, 7th Floor 830 First Street, NE Washington DC, 20202 (20002-5340 if Overnight/Courier)

  42. SCHOOL ELIGIBILITY SERVICE GROUP (SESG)Ron Bennett - Director, School Eligibility Service Group, Washington, DC 202-377-3181School Eligibility Service Group General Number: 202-377-3173 or email: CaseTeams@ed.gov Or call the appropriate School Participation Division manager below for information and guidance on audit resolution, financial analysis, program reviews, school and program eligibility/recertification, and school closure information. New York/Boston School Participation Division Connecticut, Maine, Massachusetts, New Hampshire, Rhode Island, Vermont, New Jersey, New York, Puerto Rico, Virgin Islands Betty Coughlin, Director 646-428-3737 Tracy Nave – Boston 617-289-0145Jeremy Early– Washington, DC 202-377-3620Chris Curry – New York 646-428-3738 Philadelphia School Participation Division District of Columbia, Delaware, Maryland, Pennsylvania, Virginia, West Virginia Nancy Gifford, Director 215-656-6436 Steven M. Marcucio – Philadelphia 215-656-5554 Sherrie Bell– Washington, DC 202-377-3349 Multi-Regional and Foreign Schools Participation Division Michael Frola, Director 202-377-3364 Joseph Smith − Washington, DC 202-377-4321 Mark Busskohl – Washington, DC 202-377-4572 Michelle Allred – Dallas 214-661-9466 Julie Arthur – Seattle 206-615-2232 Chicago/DenverSchool Participation Division Illinois, Minnesota, Ohio, Wisconsin, Indiana, Colorado, Michigan, Montana, North Dakota, South Dakota, Utah, WyomingDouglas Parrott, Director 312-730-1532 Brenda Yette – Chicago 312-730-1522 Sarah Adams − Chicago 312-730-1514 San Francisco/Seattle School Participation Division American Samoa, Arizona, California, Guam, Hawaii, Nevada, Palau, Marshall Islands, North Marianas, State of Micronesia, Alaska, Idaho, Oregon, WashingtonMartina Fernandez-Rosario, Director 415-486-5605 Gayle Palumbo − San Francisco 415-486-5614 or Seattle 206-615-3699 Dyon Toney − Washington, DC 202-377-3639 Erik Fosker – San Francisco 415-486-5606 Atlanta School Participation Division Alabama, Florida, Georgia, Mississippi, North Carolina, South CarolinaChristopher Miller, Director 404-974-9297 Vanessa Dillard – Atlanta 404-974-9418 Dallas School Participation Division Arkansas, Louisiana, New Mexico, Oklahoma, Texas Cynthia Thornton, Director 214-661-9457 Jesus Moya – Dallas 214-661-9472 Kim Peeler – Dallas 214-661-9471 Kansas City School Participation Division Iowa, Kansas, Kentucky, Missouri, Nebraska, TennesseeRalph LoBosco, Director 816-268-0440Dvak Corwin – Kansas City 816-268-0420 Angela Beam – Kansas City 816-268-0534 Jan Brandow – Kansas City 816-268-0409

  43. QUESTIONS?

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