Student Eligibility (excluding SAP and Citizenship)

1. Session 24 Student Eligibility (excluding SAP and Citizenship) Kim Wells and Aaron Washington | Dec. 2015 U.S. Department of Education 2015 FSA Training Conference for Financial Aid Professionals

2. School-Determined Eligibility

3. Regular Student/Eligible Program • Regular student = someone enrolled/accepted for enrollment in eligible institution to obtain degree or certificate • Conditional acceptance – only considered regular student if school officially accepts into eligible program • Remedial coursework – if admitted into eligible program and remedial part of program, may include up to one year’s worth in enrollment status for TIV purposes • One year=45 quarter credits, 30 semester/trimester credits or 900 clock-hours

4. Regular Student/Eligible Program • Regular student exceptions • Teacher certification • Can award Direct Loans, Federal Work-Study (FWS) and Federal TEACH Grant to otherwise eligible students enrolled in teacher certification programs that do not lead to degree/certificate awarded by school • Students with intellectual disabilities • Must be part of Comprehensive Transition and Postsecondary (CTP) Program

5. Elementary & Secondary Enrollment • Students cannot receive Title IV while enrolled in elementary or secondary enrollment, even if enrolled in college coursework at same time • Considered enrolled if pursuing HS diploma or if completed requirements for diploma, has not yet received it and is either • Taking college coursework for which HS gives credit, OR • HS still considers student enrolled there

6. Satisfactory Academic Progress (SAP) • Student must be making SAP and school must have reasonable policy that cumulatively measures qualitative and quantitative components • Qualitative = GPA or other comparable measure against norm • Quantitative = pace of completion ensures completion within maximum timeframe • 150% for undergraduate programs

7. Satisfactory Academic Progress • Other sessions offered • #25 –Satisfactory Academic Progress • 12:20 p.m. – 1:35 p.m., Tues., 12/01 • 1:55 p.m. – 3:10 p.m., Wed., 12/02 • 9 a.m. – 10:15 a.m., Fri., 12/04

8. Enrollment Status • Student must be enrolled at least ½ time for Direct Loan programs • In general, Federal Pell Grant, TEACH Grant, & Campus-Based programs don’t require ½ time status • Two exceptions that do require ½ time enrollment • Teacher education post-baccalaureate programs • Teaching credential programs – but only for FWS and Federal Perkins Loan • Minimum definition of FT for undergraduate students = 12 credits • School determines definition of FT for graduate programs

9. Drug Convictions • Federal or state conviction of possession or sale of drugs may disqualify student from TIV eligibility • Must be for offense that occurred during period of enrollment for which student was receiving TIV aid

10. Incarcerated Students • Incarcerated students not eligible for FSA loans but are eligible for FSEOG and FWS • Also Pell Grant eligible if not incarcerated in federal or state penal institution • Incarcerated = serving criminal sentence in federal, state or local penitentiary, prison, jail, reformatory, work farm, or similar correctional institution • Halfway house, home detention, or serving only weekends does NOT equal incarceration • School may accept student’s written self-certification that s/he is no longer incarcerated

11. Experimental Sites Initiative • Allows participating institutions to provide Federal Pell Grants to otherwise eligible students who • Are incarcerated in Federal or State penal institutions • But will be eligible for release into the community generally within 5 years

12. Waivers Second Chance Federal Pell Grant

13. Exceptions • Convictions for drug possession or sale while receiving Title IV aid (Section 484(r) of the HEA) • Involuntary civil commitment after incarceration for sexual offenses (Section 401(b)(6)) • Cost of attendance provision for incarcerated students (Section 472(6))

14. Academic Qualifications

15. High School Diploma • Certificate of graduation from a school providing secondary education • ED relies on a state's determination as to what constitutes a high school diploma

16. Recognized Equivalents of a H.S. diploma • A state certificate received by a student after the student has passed a state-authorized examination that the state recognizes as the equivalent of a high school diploma; • An academic transcript of a student who has successfully completed at least a two-year program that is acceptable for full credit toward a bachelor's degree; or • For a person who is seeking enrollment in an educational program that leads to at least an associate degree or its equivalent and who has not completed high school but who excelled academically in high school, documentation that the student excelled academically in high school and has met the formalized, written policies of the institution for admitting such students

17. Homeschool • Obtained a secondary school completion credential for homeschool provided for under state law; or • If state law does not require a homeschooled student to obtain the credential, the student has completed a secondary school education in a homeschool setting

18. Ability to Benefit • DCL GEN 15-09 & EA posted 10/22/15 • Students who are enrolled in an eligible career pathway program, on or after July 1, 2014, and who are not high school graduates, may be eligible to receive Title IV aid if the student meets one of the following ATB alternatives: • Passes an independently administered Department of Education approved ATB test • Completes at least 6 credit hours or 225 clock hours that are applicable toward a degree or certificate offered by the postsecondary institution • Completes a State process approved by the Secretary of Education. Note: To date, no State process has ever been submitted for the Secretary's approval

19. Eligible Career Pathway Programs • Concurrently enroll students in connected adult education and eligible postsecondary programs; • Provide students with counseling and supportive services to identify and attain academic and career goals; • Provide structured course sequences that— • Are articulated and contextualized; and • Allow students to advance to higher levels of education and employment;

20. Eligible Career Pathway Programs • Provide opportunities for acceleration for students to attain recognized postsecondary credentials, including degrees, industry relevant certifications, and certificates of completion of apprenticeship programs; • Be organized to meet the needs of adults; • Be aligned with the education and skill needs of the regional economy; and • Have been developed and implemented in collaboration with partners in business, workforce development, and economic development.

22. ED-Determined Eligibility

23. Citizenship • U.S. citizen • U.S. national • Permanent resident • Eligible noncitizen • in the United States for other than a temporary purpose with the intention of becoming a citizen or permanent resident

24. Match with DHS • Each student that provides and Alien Registration Number (ARN) is matched with DHS • Generally, if the student fails automated primary and secondary matches the school must complete the G-845 paper confirmation process before dispersing aid • There are special cases, ex. Freely Associated States, T-Visas, and J-Treaty students that will not go through the DHS Match • Use the 2015-16 FSA Handbook to determine eligibility • New Guidance: DCL GEN 15-08

25. Selective Service

26. Selective Service • Registration requirements • 18-25 year old males • Registering with SSS or on the FAFSA • When registration is NOT required • Active duty serving in the Armed Forces • Not yet 18 at the time that they complete their applications • Born before 1960 • Citizens of the Freely Associated States • Noncitizens who first entered the U.S. after age 26

27. Match with SSS • All male students go through match with SSS to verify compliance with requirements • Successful Match • The student is eligible for aid • Unsuccessful Match • Student must either register or provide evidence that he is registered or is exempt from registration or; • CPS won’t be able to forward the student for registration if certain information is missing

28. Failure to Register • Some students have been denied aid because they failed to register with the Selective Service before their 26th birthday • Students who knew of the registration requirement but chose not to register are considered to have knowingly and willfully failed to register and are therefore ineligible for FSA funds

29. Social Security Number

30. Social Security Number (SSN) • The FAFSA collects the student’s and dependent parents’ SSNs • The FAFSA will not be processed without an SSN

31. Match with SSA Match Flags on CPS • Successful match • No match on SSN • Wrong SSN on FAFSA • FAFSA data entry error • Error in SSA database • No match on name or DOB • Missing information • Date of death

32. Social Security Number • Death master file • CPS will verify that student SSNs do not appear on a master death file • SSN being used by more than one person • the student’s application will likely fail the SSN match • Citizens of the Freely Associated States and pseudo-SSNs

33. NSLDS History

34. NSLDS History • Ineligible statuses • Default • Owe overpayment on Title IV grant • Inadvertent over borrowing of annual or aggregate loan limits • Convicted of/pled no contest or guilty involving fraud in obtaining FSA funds • Property subject to judgment/lien for debt owed to U.S.

35. NSLDS History – Bankruptcy • Bankruptcy • If loan discharged in bankruptcy, student remains eligible for Title IV aid • If defaulted loan listed in active bankruptcy, student must provide documentation stating that debt is dischargeable

36. NSLDS History – Total and Permanent Disability • If student had previous loans discharged due to TPD • S/he must provide physician’s certification of her ability to engage in substantial gainful activity AND • S/he must sign statement acknowledging future loans may not be discharged due to current impairment unless it deteriorates so that s/he is totally and permanently disabled again • If s/he requests loans during conditional discharge period, must resume payment on old loan

37. NSLDS History – Regaining Eligibility • Default & inadvertent over borrowing • Pay in full or make satisfactory arrangements to repay with holder of loan • Inadvertent over borrowing – see GEN-13-02 • GEN-15-20 – New DL/FFEL Reaffirmation Agreement • When situation is resolved, regain eligibility for • Grants -- beginning with current payment period • Loans – beginning with start of current enrollment (loan) period

38. Program-Specific Eligibility

39. Federal Pell Grants • Generally, undergraduate students only • Pell Grant Lifetime Eligibility Used (LEU) • All students subject to 600% limit on Pell Grants • Incarcerated students • Incarcerated in local institutions = Pell Grant eligible • COA must only include tuition & fees, books & supplies necessary for student’s program of study • Sex offenders • Not Pell Grant eligible if subject to involuntary civil commitment following incarceration for sexual offense

40. Federal Pell Grants • Students enrolled in post-baccalaureate teacher certification/licensure program eligible for Pell Grant if the • program does not lead to a graduate degree; • school offering the program does not also offer a bachelor’s degree in education; • student is pursuing an initial teacher certification or licensing credential within a state; and • program consists of courses required by a state to receive a professional certification or licensing credential necessary for employment as a teacher in an elementary or secondary school in that state

41. Iraq and Afghanistan Service Grants • For eligible students whose parent/guardian died as a result of military service in Iraq or Afghanistan after 09/11/01 • Student was less than 24 years old when parent/guardian died; or • Student was 24 or older and was enrolled at postsecondary institution at time of parent/guardian death • If Pell Grant eligible, eligibility for all Title IV aid is calculated on EFC of 0 • If not Pell Grant eligible, awarded Iraq and Afghanistan Service Grant in amount equal to Pell for award year

42. Direct Loans • Preparatory coursework • Student (or parent in case of dependent student) may apply for DL for coursework school determines necessary for enrollment in eligible program (prerequisite for admission into program) • Coursework must be part of an eligible program at school • Student eligible for loans for one consecutive 12-month period

43. Federal TEACH Grants • Students must • be pursuing coursework necessary for career in teaching • sign an agreement to serve (ATS) • teach in a high-need field • at an elementary or secondary school or educational service agency serving low income students • for 4 complete years within 8 years of ceasing enrollment in TEACH Grant eligible program of study • If conditions in ATS aren’t met, TEACH Grant reverts to unsubsidized loan

44. QUESTIONS?