two pells in one award year fred sellers office of postsecondary education nysfaaa state-wide...

Two Pells

in One Award Year

Fred Sellers Office of

Postsecondary Education

NYSFAAAState-wide Training June 3, 2010

Corrected June 4, 2010

Agenda

• Legislation and negotiated rulemaking• Basics on crossover payment periods• Pell constants• 2009-2010 award year• 2010-2011 and subsequent award years• Summer 2010• Additional provisions starting in 2010-2011• Pell myths and Two Pells myths

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Legislationand

Negotiated Rulemaking

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Legislation

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• Higher Education Opportunity Act of 2008 Pub. L. 110-315 (effective 2009-2010)

• Eligibility for a second Scheduled Award in an award year– Must be in a program leading to associate

degree, baccalaureate degree, or certificate– Must be attending at least half-time in order to

receive any of second Scheduled Award

Negotiated rulemaking

• Team V-General and Nonloan Programmatic Issues met in March 2009, April 2009, and May 2009.

• Negotiations included two Pells in one award year

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Negotiated rulemaking

• No consensus• Notice of proposed rulemaking: August 21,

2009 • Final regulations: October 29, 2009• Effective starting in 2010-11• Early implementation

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Basics on Crossover Payment Periods

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Crossover payment period

• Is a payment period that includes June 30 and July 1, i.e., a payment period that occurs in two award years

• May be a term or a nonterm payment period• Must be assigned to one award year• Must have valid SAR/ISIR for assigned year• May assign two consecutive crossover payment

periods to the same award year• Through 2009-2010 award year, have always

been able to assign to either award year

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Example• A program has a semester calendar with two

summer sessions (6/1 – 7/14 and 7/20 – 8/28).• If combined in one term, the combined term is a

crossover payment period regardless of what classes students attend.

• If the two sessions are considered separate terms, only the 6/1 – 7/14 term is a crossover payment period.

• Note: if the two sessions are separate terms– Full-time must be 12 hours for each session to use Pell

Formula 1– Without a single summer term, the program may no longer

qualify to use an SAY for Stafford/PLUS loans.9


Crossover payment period and packaging

• Raises packaging issues• Must use same EFC, COA, and need for all

programs except Pell• Treat Pell as estimated financial assistance (EFA)

for other Title IV• For Pell, use EFC for the award year from which

the student will be paid

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Crossover payment period and packaging

EXAMPLE• Summer term normally assigned as last payment

period of award year.• Institution decides to pay 2010 summer Pell from

2010-11 ISIR. – Use 2010-11 ISIR/EFC for Pell– Use 2009-10 ISIR/EFC for packaging all other

aid• Amount of Pell received is applied as EFA to

determine need for other Title IV.

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• These requirements are not new.• The new “two Pell” requirements are in addition to

these requirements. • For example, if you have no summer crossover

payment period, the “two Pell” requirements still apply to the rest of an award year.

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Pell Constants

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Pell Constants

Unchanged by Two Pells• Scheduled Award is the amount that a full-time

student would receive for a full academic year based on the student’s EFC and COA.

• Scheduled Award is prorated by payment period based on hours and weeks of instructional time attended.

• Payment for a payment period calculations are unchanged.

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Pell Constants

Changed by Two Pells and no longer true• Student may receive only one Scheduled Award

in an award year.• Student is always eligible for payment as less-

than-half-time student.• Institution may assign a crossover payment

period to either award year as a general policy or on a case-by-case basis.

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2009-2010Award Year

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2009-2010 Implementation

• No regulations for 2009-2010• Legally supportable ways to implement: ED staff

conference presentations, FSA Handbook, and new final regulations

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2009-2010 Implementation

• Term-based program: no requirement that a student must−– Complete the hours of the first academic year

to be eligible, or– Be taking hours attributable to the second

academic year to be eligible• Clock-hour or nonterm credit-hour program: a

payment period requirement that student must complete the hours of an academic year to move to eligibility for a second Scheduled Award due to payment period definition

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2009-2010 Payments

• Institution determines payment for each payment period

• Calculation must be based on Scheduled Award for the award year– Pell Grant formulas have not changed– Each calculation is done using same amount

for Scheduled Award

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2009-2010 Payments

• Must pay an eligible student until reach 200 percent of his or her Scheduled Award for the award year

• Can begin paying from 2nd award while paying balance of 1st award if at least half-time student

• Must be enrolled in an eligible program, i.e., a program greater than one academic year in length to be an eligible program for a second Scheduled Award

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2010-2011 and

Subsequent Award Years

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Two Pells: Final regulations

• Must be used starting in the 2010-2011 award year

• May apply in some instances to summer crossover payment period considered to be in 2009-2010 award year

§§690.67, 690.64, 690.63

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Policy goals

• Accelerating completion• Maximizing the benefit of a second Scheduled

Award– Must attend full-time, or almost full-time, to

receive significant benefit• Applying student achievement and

accountability principles for use of funds under– ARRA (American Recovery and Reinvestment Act

of 2009)

– SAFRA (Student Aid and Fiscal Responsibility Act)

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Basics: Eligible student

• Is enrolled in credit or clock hours attributable to a student’s second academic year in the award year– Has successfully completed sufficient hours in

the award year that some hours in payment period are attributable to the second academic year in that award year

– Is a major change from proposed regulations

§690.67(a)

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Semester progression example

Conditions• A traditional semester-based academic

calendar has fall and spring semesters and a 12-semester-hour nonstandard summer term.

• Title IV academic year is 24 semester hours and 30 weeks of instructional time.

• In 2010-2011 award year, student– Is paid as full-time for fall and spring,– Earns 12 hours in the fall and 9 hours in the

spring, and – Enrolls for 6 hours in the summer.

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• Only consider hours in current award year– Do not consider prior award year hours or weeks of

instructional time

• Through spring earns 21 hours, after institution determines grades for spring

• Consider 3 hours of summer to be attributable to second academic year

• Eligible for half-time payment from second Scheduled Award 26

Fall 2010Earns 12 hr

Spring 2010Earns 9 hr

2010-11 Award Year

Summer 2011Enrolls 6 hr

Semester progression example

Clock-hour progression exampleConditions• Academic calendar is 1800 graded clock-hours

over 52 weeks of instructional time in the 2010-2011 award year.

• Program has 4 payment periods of 450 clock hours and 13 weeks of instructional time.

• Title IV academic year is 900 clock hours and 26 weeks of instructional time.

• In 2010-2011 award year, student– Is paid first Scheduled Award over the first

two payment periods, and – Enrolls in the third payment period after

passing first 900 clock hours. 27

• Only consider hours in current award year– Do not consider prior award year hours or weeks of

instructional time

• Through second payment period earns 900 clock hours

• Consider hours of 3rd and 4th payment periods attributable to the second academic year

• Is eligible for payment from second Scheduled Award for 3rd and 4th payment periods

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1st P.P. 450 cl hr

2nd P.P. 450 cl hr

2010-11 Award Year

4th P.P. 450 cl hr

3rd P.P. 450 cl hr

Clock-hour progression example

Basics: Eligible student

• Is enrolled in an eligible program leading to a bachelor’s or associate degree or other recognized educational credential– The program must be greater than one academic

year in length—in both hours and weeks of instructional time—to be an eligible program for a second Scheduled Award.

– An exception to the degree or certificate is provided for students with intellectual disabilities.

• Is enrolled at least as a half-time student§690.67(a)

Subpart O of part 66829

Basics: Payment calculations

• Use same amount for both Scheduled Awards in the award year

• Award consecutively• Calculate payment for each payment period• Have been no changes to the formulas to calculate

payments

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Basics: Disbursements

• Disburse to eligible students until reach 200 percent of the student’s Scheduled Award for the award year

• Begin disbursing from second Scheduled Award in a payment period while paying the balance of first award if student qualifies for second award

§690.63(h)

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Crossover payment period assignment

• Must assign the payment period to the award year in which the student receives the greater payment– If assigned to first award year, must pay with

first award year funds– If assigned to second award year must pay with

second award year funds

§690.64

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• Must determine the greater payment based on all requirements that apply

• Must not rely on EFC or Scheduled Award alone• If only have valid SAR/ISIR for one award year,

must rely on that record – For example, that award year payment is

higher if, for the other award year--• No SAR/ISIR• Rejected SAR/ISIR without an EFC• Incomplete verification

– May still need to pay on other year if receive a valid SAR/ISIR

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• A student is not eligible for second Scheduled Award in the first award year of a crossover payment, regardless of which award year is higher, if the student is not enrolled--– At least half-time, or – In hours attributable to the second academic

year of the first award year.

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EXAMPLE• $4,000 Scheduled Award for first award year and

$5,000 Scheduled Award for second award year• Receipt of ISIR with a higher Scheduled Award for

second award year after summer term is completed• Payment as full-time from first award year ($2,000)

although student only completed the term as half-time

• Higher payment in the first award year since payment from second award year would be based on half-time, i.e., $1,250 (lump sum payment rule, §690.76(b))

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• Must reassign if receive information that student would receive greater payment – within deadline date for the first award year

(2010 crossover payment period, September 10, 2010)

• May reassign if information received after initial deadline – but not later than the deadline date for

administrative relief for the first award year(2010 crossover payment period, February 1, 2011)

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Term example

Points illustrated• Academic year progression within each award

year to establish eligibility for second Scheduled Award

• Assignment of crossover payment period based on higher payment

• Assignment of two crossover payment periods to the same award year

• Payment from a second Scheduled Award not limited to crossover payment periods

• Payment for a payment period from two Scheduled Awards

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Term example

Conditions• Academic calendar: traditional semester-

based with fall and spring semesters and a 12-semester-hour nonstandard summer term.

• Title IV academic year: 24 semester hours and 30 weeks of instructional time.

• Formula 1 payment calculations

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Term example

• $4,000 Scheduled Award for 2010-11• Fall, completes the hours of the first academic

year• Spring, receives payment from second

Scheduled Award after institution determines student earns hours for fall

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Summer 2010Full-time (12 hr)

$2,000

Fall 2010Full-time (12 hr)

$2,000

2010-11 Award Year

Spring 2011Full-time (12 hr)

$2,000

Term example

• $5,000 Scheduled Award for 2011-12• Summer 2011 reassigned• Fall, completes the hours of the first academic

year• Spring, receives payment from first and

second Scheduled Awards– $ 625 1st award– $1,875 2nd award

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Summer 2011¾ time (9 hr)

$1,875

Fall 2011Full-time (15 hr)

$2,500

2011-12 Award Year


$2,500


$2,500

operationallytransparent

Term example

• $4,000 Scheduled Award for 2012-13• Spring, does not complete first academic year• Summer with 9 hours attributable to second

academic year• For summer payment of $500 from balance of first

award and $1,500 from second award• May need to assign summer to 2013-2014 if a

higher payment 41

Fall 2012¾ time (9 hr)

$1,500


$2,000

2012-13 Award Year


$2,000

Clock-hour example

• $4,000 Scheduled Award for 2010-2011• 1,800 clock-hour program over 52 weeks of

instructional time• $2,000 disbursement from second Scheduled

Award in 3rd payment period• 3rd payment period of program, a crossover

payment period42

1st P.P. 450 cl hr/13 wk it

$2,000

2nd P.P. 450 cl hr/13 wk it

$2,000

2010-11 Award Year

3rd P.P. 450 cl hr/13 wk it

$2,000

Clock-hour example

• $5,000 Scheduled Award for 2011-2012• Reassignment of 3rd payment period• Report $4,000 disbursed for 2010-2011 to

COD (a $2,000 reduction)• Report $2,500 disbursement in 3rd payment

period for 2011-2012

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3rd P.P. 450 cl hr/13 wk it

$2,500

4th P.P. 450 cl hr/13 wk it

$2,500

2011-12 Award Year

Two Pells: COD

• Added new field in COD Common Record– Additional Eligibility Indicator (AEI)

• Set AEI to “true” when awarding funds from the student’s second Scheduled Award• Track the 200 percent limit in COD

• With AEI set to “true,” is no POP MRR, but concurrent enrollment MRR can still be triggered if enrollment dates were within 30 days

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AEI: COD screen

Additional Eligibility Indicator Checkbox

Summer 2010

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Crossover payment period assignment for 2010

• Effective date of final regulations affects 2010 crossover period.

• Institution may designate based on options applied to all students or on student-by-student basis.

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• Institution may designate--– Prior to July 1, 2010, a student’s payment period

as being in the 2009-10 and not apply these regulations;

– A student’s payment period as being in the 2009-10 award year with regulations being applicable; or

– A student’s payment period as being in 2010-2011, in which case the regulations must apply.

• Before July 1, 2010, establish written policy

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EXAMPLES

• Prior to July 1, 2010, institution determines it will--– Treat 2010 summer payment periods as being in

09-10 and not apply these regulations.• Prior to July 1, 2010, institution determines it will--

– Treat 2010 summer payment periods as being in 09-10 and not apply these regulations, but

– Assign student’s payment period to 2010-2011 if the student would receive a larger payment.

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EXAMPLES

• Prior to July 1, 2010, an institution determines it will-- – Treat 2010 summer payment periods as being in

the 2010-2011 award year.• Prior to July 1, 2010, an institution determines it will--

– Make 2010 summer payment period assignments on a case-by-case basis.

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EXAMPLES

• Prior to July 1, 2010, the institution makes NO determination of policy to apply, and it-- – Must apply new regulations to all summer

disbursements, whether for 9-10 or 10-11 (does not affect 9-10 payment periods prior to summer 2010).

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Additional ProvisionsStarting in 2010-2011

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Transfer student

• Final regulations: two options– Assumption method

• Based on disbursements received

– Hours-earned method• Based on actual hours earned

• Method at option of institution: apply on a student-by-student basis or to all students

§690.67(b)53

Transfer student: Assumption method

• Assume completed first academic year if received all of first Scheduled Award at prior institution

• If less than first Scheduled Award was disbursed, calculate hours considered to have completed:

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Amount disbursedat prior institution X

Hours in current institution’s academic year

Amount of Scheduled Award at prior institution

=Hours

considered completed


EXAMPLE – credit hour• Fall transfer student received $2,000 of $4,000

Scheduled Award for summer at prior institution. • Current institution, without a summer term, defines

academic year, in part, as 24 semester hours.• Hours in award year considered to have earned

for prior attendance:

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$2,000 disbursedat prior institution X

24 hours in current institution’s academic year

$4,000 Scheduled Award at prior institution

= 12 hours considered completed


EXAMPLE – clock hour• Transfer student received $3,000 of $4,000

Scheduled Award at prior institution. • Current institution defines academic year, in part,

as 900 clock hours.• Hours in award year considered to have earned

for prior attendance:

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$3,000 disbursedat prior institution X

900 clock hours in current institution’s academic year

$4,000 Scheduled Award at prior institution

= 675 clock hours considered completed


• Round down any fractions of a credit or clock hour

• If courses are offered in fractions of a credit or clock hour, may retain fractions

• Example– Using the assumption method, a transfer

student is considered to have earned 12.7 credits in the award year at a prior institution.

– If the student’s program is offered in courses of 2.5 credit hours, the institution may consider the student to have 12.7 credits or 12 credits.

– If the program were offered in 3-hour courses, the student would have 12 credits.

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Transfer student: Hours-earned method

• The institution may determine the credit or clock hours actually earned at other institutions.

• The institution must have information that—– Includes the time periods when the credit or

clock hours were earned, and– Does not include nonapplicable credit or clock

hours.• Any hours earned are applicable. For example,

hours—– Need not be earned in an eligible program, or – Be accepted on transfer.

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• An institution must attribute to the current award year any credit or clock hours earned at other institutions that were earned in a summer crossover payment period.

• This requirement applies even though the institution does not have a summer payment period.

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EXAMPLE – credit hour• Current institution defines academic year, in part,

as 24 semester hours.• Student’s transcript shows earned 6 hours in the

summer term and 12 hours in the fall semester.• Transfer student received $2,000 of $4,000

Scheduled Award at prior institution and no payment for summer from the current award year.

• At the current institution, the student is considered to have earned 18 semester hours in the award year: 6 from summer and 12 from fall.

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EXAMPLE – clock hour• Current institution defines academic year, in part, as

900 clock hours.• Transcript shows student earned 600 clock hours in

the period from June 15 to September 30.• Transfer student received $3,000 of $4,000 Scheduled

Award at prior institution from the current award year. • At the current institution, the student is considered to

have earned 600 clock hours in the award year since the institution confirmed that the first payment period was a crossover payment period.

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Transfer student

• No requirement to apply additional information to disbursements for prior payment period in award year if receive additional information on a transfer student

• For example— – Assumption method: a payment is reported

late to NSLDS. – Hours-earned method: a transcript is received

indicating student earned additional hours in the award year at another institution.

• In clock-hour programs, a payment consisting of funds from a first and second Scheduled Award, only for a transfer student 62

Nonapplicable hours

• In determining eligibility for a second Scheduled Award in an award year, may not use hours based on:– Advanced Placement (AP) programs– International Baccalaureate (IB) programs– Testing out, life experience, or similar

competency measures• Are not earned by attendance in the award year

§690.67(d)63

Nonapplicable hours

• The equivalencies of reduced credit and noncredit remedial coursework do count toward determining eligibility for a second Scheduled Award in an award year.

• Any equivalent hours in excess of the 30 semester hours, 45 quarter credits, or 900 clock hours do not count unless they are equivalent hours of ESL coursework.

• In other words, reduced credit and noncredit remedial coursework does not count if the equivalent hours do not count toward determining Title IV eligibility.

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Special circumstances

• May waive requirement to be enrolling in hours attributable to the second academic year in the award year to pay from second Scheduled Award

• Must be due to circumstances beyond the student’s control

• Must be determined and documented on individual basis

§690.67(c)

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Special circumstances

• May include circumstances such as illness or classes not offered

• Does not include withdrawing to avoid a grade or failing to register for offered class

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Pell Mythsand

Two Pells Myths

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Pell and Two Pells mythsNone of the following are true:• An institution can ignore payment periods, for

example, crossovers or intersessions, and is not required to pay eligible students in those payment periods.

• An institution is not required to implement Pell and Two Pells requirements due to software deficiencies or the necessity to perform manual interventions.

• Only students who are first-time Pell recipients after July 1, 2008 are eligible for Two Pells.

• An institution is not required to make Pell disbursements for a summer term.

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Pell and Two Pells myths

None of the following are true:• An institution can choose to pay only the remaining

first award in the payment period without making a full payment that includes funds from a second Scheduled Award for student is eligible.

• An institution must review credits earned in a prior award year to determine eligibility for a second Scheduled Award.

• Determining the hours earned for Two Pells eligibility only applies to crossover payment periods.

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None of the following are true:• Half-time is always 6 credits when determining

eligibility for a second Scheduled Award in an award year.

• When determining program eligibility for Two Pells, if the program is one academic year in length, but SAP allows a student to attempt up to 150 percent of the hours of a program, the student can be eligible for a second Scheduled Award since the student can take more hours than the hours in the academic year.

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None of the following are true:• A student must be half-time in the summer to get

Pell from a first Scheduled Award. • An institution is not required to disburse Pell for a

less-than-half-time student when a student is eligible for payment from a first Scheduled Award, such as for a summer term.

• If I choose to pay the summer of the 2010 crossover as the last payment period of the 2009-2010 award year, Two Pells does not apply until the 2010-2011 award year.

• Academic year is the equivalent of grade level.• Pell uses headers and trailers.

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• Phone: 202 502-7502• Email: [email protected]• Fax: 202 502-7874

Contact Information

NYSFAAAState-wide Training June 3, 2010

mailto:[email protected]

two pells in one award year fred sellers office of postsecondary education nysfaaa state-wide...

Documents

payment period of award

payment period calculations

award yearmust

award year2010

award yearthrough

pellsscheduled award

award yearsmay

pell requirements