Unusual Enrollment History

1. Unusual Enrollment History Diana VanDyke Butler Community College KASFAA 2013 Fall Training

2. KASFAA 2013 Fall Training Unusual Enrollment History Dear Colleague Letter GEN 13-09 • Why? (…to prevent fraud and abuse in the Federal Pell Grant Program….) GEN-13-09 • How? (…by identifying students with unusual enrollment histories…) GEN-13-09 • Can you be more specific? YES! (The specific enrollment pattern we are concerned about is one where the student attends an institution long enough to receive title IV credit balance funds, leaves …, enrolls at another institution, and repeats…) GEN-13-09

3. KASFAA 2013 Fall Training Unusual Enrollment History Remember: • NOT Verification (Resolution of a UEH flag is separate and distinct from verification and is not related to the new Verification Tracking Groups IV and V….however, it is similar in that institutional action is required.) GEN-13-09 • NOT SAP (Satisfactory Academic Progress)

4. KASFAA 2013 Fall Training Unusual Enrollment History Flags UEH

5. KASFAA 2013 Fall Training Unusual Enrollment History Flag N and 2 • UEH Flag value = N No action is required • UEH Flag value = 2 Must review student’s enrollment and financial aid records to determine if, during the 3 award year review period, student received a Pell Grant at your institution. (For 13/14 review period = 10/11, 11/12, 12/13) • If YES, no additional action is required unless you believe student remains enrolled just long enough to collect student aid funds. In this case, must follow guidance provided for a UEH Flag of 3. • If NO, must follow guidance provided for UEH Flag of 3.

6. KASFAA 2013 Fall Training Unusual Enrollment History Flag 3 • Must review student’s academic records to determine if student received academic credit at institutions the student received Pell during the 3 award yearperiod • Identify institutions through NSLDS • Use transcripts or grade reports for each of the previously attended institutions to determine whether academic credit was earned during the award year in which the student received Pell funds (Academic credit is considered earned if academic records show student completed any credit hours or clock hours.)

7. KASFAA 2013 Fall Training Unusual Enrollment History Flag 3 • Academic Credit Earned: If determine student earned any academic credit at each of the previously attended institutions during the relevant award years, no further action is required unless institution has other reasons to believe student enrolls just to receive credit balances • If determine that academic credit was NOT earned at one or more of the previously attended institutions OR the school had reasons to believe student just enrolls for title IV funds, the institution must follow the “Academic Credit Not Earned” guidance

8. KASFAA 2013 Fall Training Unusual Enrollment History Flag 3 • Academic Credit NOT Earned: If student did not earn academic credit at a previously attended institution, including your school if applicable, must obtain documentation from student explaining why failed to earn academic credit • Must determine whether the documentation supports (1) the reasons given by the student for the student’s failure to earn academic credit; and (2) that student did not enroll only to receive credit balances • To extent possible, obtain third party documentation to support student’s claim

9. KASFAA 2013 Fall Training Unusual Enrollment History Flag 3 • Institution determines whether circumstances of failure to receive credit warrant continuation of Title IV Aid – if not, must deny further aid • Reasons for decision must be documented and maintained for possible review • Notification of the decision must be provided to the student • Institutional determinations are final and can not be appealed to the Department

10. KASFAA 2013 Fall Training Unusual Enrollment History Flag 3 • Approving Continued Eligibility • If school approves student’s continued eligibility, may: • Require student to establish academic plan, like (SAP) • Counsel student about the impact of the student’s attendance pattern on future Pell Grant eligibility (LEU, SAP and UEH future denials…etc)

11. KASFAA 2013 Fall Training Unusual Enrollment History Flag 3 • Denying Continued Eligibility • Student must be given opportunity to question and appeal the decision • Student must be given information on how to regain eligibility at your institution • Regaining Eligibility • (it is expected that successful completion of academic credit would form the basis for the student’s subsequent request for renewal of title IV, HEA program eligibility.) GEN-13-09 • Could include meeting requirements of an academic plan

12. KASFAA 2013 Fall Training Unusual Enrollment History http://www.usafunds.org/Pages/ PolicyResources.aspx

13. KASFAA 2013 Fall Training Unusual Enrollment History • Questions / Comment? • Want to share? • If not, let’s look at AskRegs!

14. KASFAA 2013 Fall Training Unusual Enrollment History NASFAA AskRegs Knowledgebase • Do We Look at Pell Received or Credits Earned When Resolving an Unusual Enrollment History (UEH) Flag? • Is Further Action Required to Resolve Unusual Enrollment History Flag Value 2 If Pell Was Received in ANY of the 3 Award Years Reviewed? • Are Schools Required to Resolve Unusual Enrollment History Edits for Both Graduate and Undergraduate Students? • Are We Required to Review a Student's Unusual Enrollment History If He Is Over the 600% Eligibility Limit?

15. KASFAA 2013 Fall Training Unusual Enrollment History NASFAA AskRegs Knowledgebase • Isan Unofficial Transcript Acceptable for Resolving the Unusual Enrollment History Flag C-Code? • Can a Student Appeal an Institution's Denial Based on Unusual Enrollment History? • Isthe Completion of New Credit Hours as Part of an Unusual Enrollment History Appeal a Requirement or Recommendation? • How Do We Handle a Subsequent ISIR Without an Unusual Enrollment History Flag When the Previous Transaction Had a Flag?