Dealing with Modular Courses and Other Unique Scheduling Options Carol Egan PHEAA Compliance Services

1. Dealing with Modular Courses and Other Unique Scheduling Options Carol Egan PHEAA Compliance Services

2. Agenda • Standard Term-Based Credit Hour Programs and Nonstandard Term-Based SE9W Programs offered in Modules. • Disbursement and Delivery of Loan Funds in Standard and Nonstandard SE9W Programs offered in Modules. • Withdrawal from a Standard or a Nonstandard SE9W Program offered in Modules. • Negotiated Rulemaking Topics. • Written Agreement between Schools. • Distance Education.

3. Definition of Modules A course or group of courses offered for a period of time that is different (usually shorter) than the program’s quarter, trimester, semester, other academic term, or period of enrollment.

4. Definition: Standard Term-Based Credit Hour Program • Standard Term Program may be comprised of 2 semesters (15 to 17 weeks each) or 3 trimesters (15 to 17 weeks each). Semesters are traditionally fall and spring. Trimesters are fall, spring, and summer. • Standard Term Program may be comprised of 3 quarters (10 to 12 weeks each). Quarters are traditionally fall, winter, and spring. • Semesters and trimesters measure academic progress in semester credits. Quarters measure academic progress in quarter credits.

5. Standard Term-Based Credit Hour Program offered in Modules • Example: Each of two15-week semesters is offered in 3 5-week modules. • Minimum loan period is the semester not a module even if student doesn’t enrolled in all 3 5-week modules . Maximum loan period is the academic year. • Payment period is the semester. Loan disbursements are each payment period. • If student does not attend the first module in the payment period, the date that the school uses to schedule disbursement is the starting date of the first module which the student is attending in the payment period.

6. Definition: Nonstandard Term-Based Credit Hour Program that is SE9W • SE9W = Substantially equal in length and at least 9 weeks of instructional time in length. • Example: 10 week terms in a program with an academic year of 40 weeks and 24 semester credits. Therefore, full time enrollment in each term is 6 semester credits, i.e. 10/40 x 24.

7. Nonstandard Term-Based Credit Hour Program that is SE9W and offered in Modules • Example: Each 10-week term is offered in two 5-week modules. • Minimum loan period is the term (10-week period) not a module even if student doesn’t enroll in both 5-week modules. Maximum loan period is the academic year. • Payment period is the term. Loan disbursements are each payment period. • If student does not attend the first module in the payment period, the date that the school uses to schedule disbursement is the starting date of the first module which the student is attending in the payment period.

8. Delivery of Loan Funds in a Credit Hour Program offered in Modules • Standard and Nonstandard SE9W: • If the loan period consists of one payment period and the school does not qualify for a multiple disbursement exemption, the school must deliver the second federal loan disbursement no earlier than the later of the calendar midpoint between the first and last scheduled days of class in the loan period, or the first day of the first subsequent module that the student will actually attend. • However; if a student is enrolled on at least a half time basis in one of the described programs offered in modules and the student dropped to less-than-half-time before receiving the first disbursement of his or her FFELP or Direct loan, the school must not make a late delivery, or as applicable, a post-withdrawal disbursement of loan funds because the school knows that the student did not reach half time enrollment status in the payment period.

9. Withdrawal from Standard Term-Based Credit-Hour Program offered in Modules • The following special principles apply with regard to the characteristics of the modules: • Some or all of the courses in the program are offered in modules that are scheduled sequentially rather than concurrently. (The modules may overlap.) • Two or more modules make up a standard term at the school. • A student may begin his or her program of study at the beginning of any module in the term. • A student may skip one or more modules in the term. • A student must enroll up front in all modules that he or she plans to attend within the term, although s/he may subsequently add or drop a course.

10. Withdrawal from a Standard Term Program offered in Modules • Calculation of R2T4 must be based on payment period. • Assumption: Payment period = semester. The semester has three 5-week modules. • Student enrolls for 3 credits in each module. Therefore, student’s enrollment is at least half time for loan purposes. Student withdraws after completion of 1 3-credit course in the first module of the payment period. • No Return of Title IV (R2T4) Funds calculation is required. Loan funds were delivered at the beginning of the payment period and student was – on the date of loan delivery – scheduled to attend at least half time. (For Pell purposes, a school must recalculate the cost of attendance and enrollment status.)

11. Withdrawal from a Standard Term Program offered in Modules (continued) • Student withdraws prior to the completion of at least one course in one module in the payment period. • With one exception (see next slide), a R2T4 Funds calculation is required. Since student withdrew before beginning at least half-time enrollment, the school must not include an undelivered loan disbursement as aid that could have been disbursed in the R2T4. The student is not eligible to receive a post-withdrawal disbursement of FFELP or Direct loan funds. • If the student’s withdrawal results in the student’s failure to begin attendance in the credits for which Pell funds were awarded, the school must recalculate cost of attendance and enrollment status before the R2T4 calculation. The school then uses the revised Pell in the R2T4 calculation.

12. Withdrawal from a Standard Term Program offered in Modules (continued) • Student withdraws prior to completion of at least one course in one module but student provides confirmation to the school – subsequent to his or her withdrawal from the course – that s/he plans to attend a module later in that term, the student is not considered to have withdrawn for R2T4 purposes. • However, if student fails to attend the module later in the term, the student is considered to be withdrawn as of the date that would have applied if the student had not indicated his or her intent to return in a subsequent module within the term.

13. Determining Percentage of Payment Period Completed • Student withdraws without completing one course in one module, the payment period used in the denominator includes the number of calendar days in all of the modules the student was scheduled to attend in the payment period (i.e. semester, trimester, or quarter). • Example: Payment period = semester. The semester has three 5-week modules. Each module has 35 calendar days. • Student was enrolled in 2 modules. • Denominator = 70 days not 105 days.

14. Determining Percentage of Payment Period Completed • Student withdraws without completing one course in one module. The number of calendar days used in the numerator begins on the first day of the first module that the student attended in the term and ends on the last day the student was in attendance, i.e. the numerator includes only the number of calendar days during which the student was in attendance. • For example – Student withdrew on day 30 of first module. Therefore numerator is 30. • With a numerator of 30 and a denominator of 70, the percentage of the payment period completed is 30/70 = 42.9%

15. Withdrawal from a Nonstandard Term Program offered in Modules • Calculation of R2T4 may be based on either payment period or period of enrollment. • Payment period = Term. In the sample program, all terms = 10 weeks of instructional time. • Period of enrollment = lesser of academic year or program. • School must use the same basis (payment period or period of enrollment) in its calculations for all students within the program. • Exception for students who transfer to and for students who reenter the program. However, all students in the defined group must be treated the same. • After selecting the payment period or period of enrollment, students who withdraw from nonstandard term-based credit-hour programs that are SE9W are processed in the same manner as students who withdraw from standard term-based credit-hour programs.

16. 09-10 Negotiated Rulemaking (Neg Reg) • Team I: Program Integrity • Team II: Foreign Schools

17. Neg Reg Team I • Team I Topics: • Definition of High School Diploma for the Purpose of Establishing Institutional Eligibility to Participate in Title IV Programs and Student Eligibility to Receive Title IV Aid. • Ability to Benefit. • Misrepresentation of Information to Students and Prospective Students. • Incentive Compensation. • State Authorization as a Component of Institutional Eligibility. • Gainful Employment in a Recognized Occupation. • Definition of a Credit Hour. • Agreements between Institutions of Higher Education. • Verification of Information on Student Aid Applications. • Satisfactory Academic Progress. • Retaking Coursework. • Return of Title IV: Term-based Programs with Modules or Compressed Courses. • Return of Title IV: Taking Attendance. • Disbursements of Title IV Funds.

18. Proposed Neg Reg Credit Hour Definition • Partial Summary of Issue: • Postsecondary schools have developed weekend programs, accelerated programs, and other innovative ways to serve students for whom the more traditional calendar is not convenient. Distance education and other non-traditional modes of instruction, such as competency-based learning, are increasingly prevalent. These ways of structuring and delivering education challenge the concept of “seat time” measures associated with credit hours. • Credit hour is used for Title IV purposes to define an eligible program, the academic year, and to determine enrollment status and the amount of student financial aid that may be disbursed per payment period. • Proposed Definition: Credit hour equals one hour of classroom or direct faculty instruction and a minimum of 2 hours of out of class work.

19. Proposed Neg Reg Treatment of Title IV Funds When Student Withdraws • A student is considered to have withdrawn from a payment period or period of enrollment if the student – enrolled in a credit-hour program – does not complete all the days in the payment period or period of enrollment that the student was scheduled to complete prior to withdrawing.

20. Written Agreements under Federal Regulations • Consortium agreement: Between 2 or more eligible schools. • Contractual agreement: Between an eligible school and an ineligible school. • Study-abroad: Through either a consortium agreement or a contractual agreement. • Underlying assumption: The home school* has found the other school’s academic standards to be equivalent to its own and a completely acceptable substitute for its own instruction. * Home school = The school in which the student is enrolled in a degree or certificate program.

21. Consortium Agreement • No limit on the portion of the eligible program that may be provided by the host school(s)*. • The school disbursing Title IV aid is responsible for maintaining information on the student’s eligibility, calculation of the Title IV aid, all documentation associated with Title IV aid, and the R2T4 calculation, if applicable. *Host school: The school where the student is taking a portion of his or her program.

22. Contractual Agreement • Limitation on the percentage of a program provided by the ineligible school. • The home school is always the eligible school. • The home school is responsible for all Title IV aid processing and disbursement functions and maintaining all records with regard to the eligibility for and receipt of Title IV funds.

23. Study-Abroad • Home school must be located in the U.S. • The credits earned in the study abroad must be acceptable by the home school toward graduation in the student’s program. • If a student’s cost of attendance (COA) in study abroad is higher than the home school, those costs should be included in the student’s COA.

24. Study-Abroad • When home school sends faculty and students to a foreign site: • This is considered an additional location as opposed to study abroad under a consortium or a contractual arrangement. • All schools are required to report (via the E-App) the adding of an additional accredited and licensed location where 50% or more of an eligible program will be offered, if the school plans to disburse Title IV aid funds to the students enrolled at the location. • The school must not disburse Title IV aid to students at the new location before reporting the location and before providing the required documentation to ED. After the new licensed and accredited location is reported to ED, a school may disburse Title IV funds to students enrolled at the location unless the school is required to apply for ED’s approval of a new location.

25. Proposed Neg Reg Requirement regarding Written Arrangements • Add requirement to include the following in consumer information: • A description of any written arrangements including, but not limited to, the following: • The portion of the educational program that the school enrolling the student is not providing. • The name(s) of the other schools or organizations that are providing the portion of the educational program that the school enrolling the student is not providing. • The method of delivery of the portion of the educational program that the school enrolling the student is not providing. • Any additional costs that students may incur as a result of enrolling in an educational program that is provided, in part, under the written arrangement.

26. Definition of Distance Education • Uses one or more technologies (see below) to deliver instruction to students who are separated from the instructor and to support regular and substantive interaction between students and the instructor, either simultaneously or at different times. The permissible technologies are: • The internet. • One-way and two-way transmissions through open broadcast, closed circuit, cable, microwave, broadband lines, fiber optics, satellite, or wireless communications devises. • Audio conferencing. Videocassettes, DVDs, and CD-ROMs may also be used in conjunction with any of the technologies listed above.

27. Program of Study offered in Whole or Part through Distance Education • If the program of study leads to a recognized certificate, or to an associate, bachelor’s or graduate degree, and • The school providing the program of study has been evaluated by an accrediting agency recognized by ED as having the evaluation of distance education within its scope of recognition; • An otherwise eligible student, enrolled in the program of study offered in whole or in part by distance education, is eligible for Title IV aid.

28. For additional information regarding the information presented, please contact Carol Egan, AES/PHEAA Compliance Services at: • 717.720.3663 • cegan@aesSuccess.org With general policy inquiries, please contact: • cmpolicy@aesSuccess.org • 717.720.3460

29. These materials have been developed and paid for by AES/PHEAA for informational purposes. The information contained herein is believed to be accurate at the time of printing. Due to the rapidly changing nature of the law and the industry, information contained in this document may become outdated and AES/PHEAA does not guarantee the accuracy of the information herein. You should verify that this information is correct.

30. These materials have been developed and paid for by AES/PHEAA for informational purposes. The information contained herein is believed to be accurate at the time of printing. Due to the rapidly changing nature of the law and the industry, information contained in this document may become outdated and AES/PHEAA does not guarantee the accuracy of the information herein. You should verify that this information is correct.