Basics of Student Eligibility for Financial Aid Programs

1. Session 2 Basics of Student Eligibility Kim Wells and Aaron Washington| Dec. 2014 U.S. Department of Education 2014 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 • 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 a 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 • #3 – Basics of Satisfactory Academic Progress • 12:30 p.m. – 1:45 p.m., Tues., 12/02 • 10:30 a.m. – 11:45 a.m., Wed., 12/03

8. Enrollment Status • Student must be enrolled at least ½ time for Direct Loan programs • In general, Federal Pell, TEACH Grant, & Campus-Based programs don’t require ½ time status • Two exceptions – teacher education post-baccalaureate programs and for FWS and Federal Perkins Loan teaching credential programs require ½ time enrollment • 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 he is no longer incarcerated

11. Academic Qualifications

12. 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

13. 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

14. 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 home school setting

15. Ability to Benefit • For students who "first enroll in a program of study on or after July 1, 2012," and who are not high school graduates or do not meet the other eligibility criteria, the law eliminated the following ATB alternatives: • Passing an independently administered, Department of Education approved ATB test • Completing at least six credit-hours, or the equivalent coursework (225 clock-hours), that are applicable toward a degree or certificate offered by the postsecondary institution

16. ED-Determined Eligibility

17. 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

18. Categories of Eligible Noncitizens • Lawful permanent residents • Conditional residents • Refugees • Asylees • Parolees (at least 1 year) • Cuban-Haitian Entrants • T-visa • Battered immigrants-qualified aliens (VAWA)

19. Citizenship Match with SSA • All students go through match with Social Security Administration (SSA) to verify U.S. citizenship status • Match flags on CPS • Successful match • Data doesn’t match • Citizenship not confirmed

20. Citizenship Match with SSA (cont’d)

21. Citizenship Match with DHS • All noncitizens are provided with an alien registration number (A-Number) • Matched with both SSA and DHS • Match flags on CPS • Successful match • Record was not sent to DHS • DHS has not yet confirmed the student’s noncitizen status. DHS will continue to check its records.

22. G-845 Paper Secondary Confirmation • The Department provides a list of eligible noncitizens and documentation • Fill out the G-845 • Use the FSA Handbook to interpret the DHS-USCIS response

23. Freely Associated States • Federated States of Micronesia, Republic of Marshall Islands, and Palau • Eligible for limited FSA funds • Pseudo-SSNs • For the purposes of calculating Pell Grant lifetime eligibility • Documentation of citizenship is not required if information is consistent

24. Documenting Immigration Status in Later Award Years • When documentation is required for each award year • Students in certain eligible categories may have been redesignated • When documentation is not required for each award year • If the document associated with the G-845 has not expired

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 • She must provide physician’s certification of her ability to engage in substantial gainful activity AND • She must sign statement acknowledging future loans may not be discharged due to current impairment unless it deteriorates so that she is totally and permanently disabled again • If she 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 • 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 Lifetime Eligibility Used (LEU) • All students subject to 600% limit on Pell Grants • Incarcerated students • Incarcerated in local institutions = Pell eligible • COA must only include tuition & fees, books & supplies necessary for student’s program of study • Sex offenders • Not Pell 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 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 the 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 eligible, eligibility for all Title IV aid is calculated on EFC of 0 • If not Pell 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 eligible program of study • If conditions in ATS aren’t met, TEACH Grant reverts to unsubsidized loan

44. QUESTIONS?