NCASFAA 2015 Fall

Pre-Conference New Aid Officers

Training Workshop

1

Overview ofFederal Student Eligibility

and Documentation Requirements

2

Federal Student Eligibility and Documentation Requirements

Objectives

• Present overview of general student eligibility requirements for Title IV (TIV) aid

• Review database matches and resolutions required if no matches

• Provide information on NSLDS

• Summarize eligibility for specific FSA Programs

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Eligibility for Title IV Aid

Student must:

Be enrolled or accepted for enrollment as a regular student for purpose of obtaining degree or certificate with three exceptions:

Program at least two years in length that is acceptable for full credit toward bachelor’s degree and qualifies student for admission into third year of bachelor’s degree program - 34 CFR 668.8 (b)(1)(ii)

Coursework necessary for student to receive a State professional teaching credential or certification if the institution itself does not provide a certificate or other credential. Otherwise eligible students may receive funding from any TIV student aid program - 34 CFR 668.8 (b)(1)(ii)

Preparatory courses of study that do not lead to a degree, certificate, or other credential awarded by the institution and that provide course work necessary for enrollment in an eligible program. Students are eligible for no longer than one-twelve-month period and only for the DL Program – 34 CFR 668.329a)(1)(ii)

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Eligibility for Title IV Aid (continued)

• Have high school diploma, equivalent, or have been home-schooled• Not be simultaneously enrolled in elementary or secondary school• Be U.S. citizen, national, or eligible noncitizen• Have valid Social Security Number (SSN)• Be registered with Selective Service, if required• File Statement of Educational Purpose (integrated as part of FAFSA)• Not be in default on TIV loan or owe overpayment on Title IV grant or loan• Not have borrowed in excess of annual or aggregate loan limits• Not have property subject to a lien for debt owed to U.S. (i.e. lien placed as result of student failing to

pay federal tax debt or have made satisfactory arrangements to pay)• Be maintaining satisfactory academic progress • Have financial need, if applicable• Not have been convicted or pled nolo contendere (no contest) or guilty to a crime involving fraud in

obtaining Title IV Funds• Ineligible until fraudulently obtained funds completely repaid to Secretary or loan holder(s)

See 2014-15 FSA Handbook, Volume 1, Student Eligibility for additional information

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Regular Student in Eligible ProgramEnrollment Status

• Stafford and PLUS loan programs – must be enrolled at least half-time

• Pell, TEACH Grant, and Campus-based programs do not require at least half-time enrollment

• Minimum Standards for Full-Time Enrollment– 12 semester hours or 12 quarter hours per academic term in an educational

program using a semester, trimester, or quarter system– 24 semester hours or 36 quarter hours per academic year for an educational

program using credit hours but not using a semester, trimester, or quarter system, or the prorated equivalent for a program of less than one academic year

– 24 clock hours per week for an educational program using clock hours

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Data Collected and/or Monitored by the School

• Statement of Educational Purpose on the FAFSA certifies the student will use all FSA funds received solely for educational or educationally-related purposes

• Schools must have written policies and procedures documenting their practices for determining a student meets criteria for Title IV aid

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Database Matches

• To establish student’s eligibility for Title IV aid and detect fraudulent attempts to receive Title IV aid, CPS performs database matches with:– Social Security Administration (SSA)

• Verifies Student’s and parents’ Social Security numbers (SSN)• Verifies Student’s U.S. citizenship

– Department of Homeland Security (DHS)/Primary and Secondary Matches (US Citizenship and Immigration Services (USCIS) in DHS actually handles

immigration matters)

– Selective Service (SS)/Match and Registration

– Veterans Affairs (VA)

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Database Matches (continued)

– National Student Loan Data System (NSLDS)– Department of Defense (DOD)

ISIR Guide: www.fsadownload.ed.gov/ISIRGuide1415.htm

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Social Security Number (SSN) Match

• Student’s SSN and date of birth (DOB) verified through match between CPS and SSA

• If match does not confirm a correct SSN, student must correct on SAR/ISIR

– Student’s original SAR ID will not change, but SSN will be changed to reflect corrected SSN

– Student must provide proof of DOB and confirm on SAR

• To obtain SAR with ID matching student’s correct SSN, new FAFSA must be filed under correct SSN

• Subsequent ISIR transactions must be reviewed for updated match flags

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Social Security Number Match (continued)

• Social Security Numbers and Dates of Birth must be verified through match for parents reported on FAFSA.

– Match must be confirmed for at least one parent for dependent student

If not confirmed, must be corrected to achieve match for at least one parent Recommended that data elements be corrected as appropriate to achieve a full

match for parents

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Citizenship

• Student must be:

– U.S. citizen or national

– U.S. permanent resident or other eligible noncitizen– Citizen of the Freely Associated States: Federated States of Micronesia and

Republics of Palau and Marshall Islands (can only receive aid from some of the FSA programs – see Handbook for additional information)

• U.S. citizenship verified through match with SSA

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Citizenship

• If Citizenship Match with SSA Fails

– Eligible noncitizen must:• Correct response to FAFSA citizenship question• Provide valid alien registration number, and • Resubmit SAR/ISIR for reprocessing

– U.S. citizen must provide:• U.S. passport (current or expired)

* U.S. passport card is acceptable • Copy of birth certificate showing student born in U.S.• Certificate of Naturalization• Other documents that definitely prove citizenship

Data from photocopied documentation may be used to calculate and package aid, but student mustpresent original documentation that verifies citizenship to be examined and copied and kept instudent’s file before disbursing Title IV aid.

2013-2014 FSA Handbook (Vol. 1 Ch. 2, p. 1-21)

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Eligible Noncitizens

• Permanent residents of U.S. who are successfully matched with DHS

• Persons in U.S. for other than temporary purposes with proper DHS documentation:

• Persons granted asylum

• Refugees

• Lawful permanent residents

• Conditional entrants

• Persons paroled in U.S. for at least one year

• Cuban-Haitian entrants

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Eligible Noncitizens (continued)

• Victims of human trafficking-- Trafficking and Violence Protection Act (VTVPA)-- Dept. of Health and Human Services (HHS) has responsibility

for certifying status and not Dept. of Homeland Security (DHS)

• Battered immigrants-qualified aliens-- Victims of domestic violence by their U.S. citizen or lawful

permanent resident spouse

2013-2014 FSA Handbook (Vol. 1 Ch. 2, p. 1-24 to 1-28)

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Eligible Noncitizens Confirmation

• Primary confirmation database match between CPS and DHS– If DHS match confirms eligible noncitizen status, no further proof required

• Secondary confirmation – Required if:

• Noncitizen status cannot be verified through primary confirmation• School has conflicting information, or• School believes information reported by student is incorrect

– Must use DHS Verification Number (15-digit confirmation number DHS returns when match conducted) appearing under Match Flags when paper/manual secondary confirmation necessary

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Eligible Noncitizens Confirmation

• Automated secondary confirmation

– Confirmation comment codes

• “Y”: citizenship confirmed; student eligible for aid

• “C”: in continuance; DHS not yet able to confirm eligible noncitizen

• “N”: citizenship not confirmed; school must begin paper secondary confirmation

• “X”: DHS needs more information. School must begin paper secondary confirmation

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Selective Service Registration

• Males between ages of 18 and 25 required to register with Selective Service System

• CPS conducts database match with Selective Service to confirm registration status

• Result of Selective Service match reported on SAR and ISIR– Student may register and school may check status on line at www.sss.gov. Printout of web page is acceptable documentation

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Selective Service Registration

• Exemptions to registration requirement

– Males currently in armed services and on active duty

– Males not yet 18 at time they complete FAFSA

– Males born before 1960

– Citizens of Federated States of Micronesia, Republic of Marshall Islands, or Republic of Palau

– Noncitizens who first entered U.S. after becoming 26; noncitizens who entered U.S. as lawful non-immigrant's on valid visa and remained in U.S. on terms of that visa until after they turned 26

Note: Student not required to register must be documented in file

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Veterans Affairs (VA)

• Match flag of 1 indicates match conducted, status confirmed, and no further documentation required

• C code with Match flag of 2, 3, 4, or 8 indicates match conducted, status not confirmed, and resolution required.– Applicant independent based on criteria other than veteran status, no further

resolution required and Title IV aid can be awarded

– Applicant dependent and documentation proves veteran status, FAA may perform dependency override. Title IV aid may be awarded after corrected ISIR received

– If documentation does not prove veteran status, form DD214 should be collected – available online via eVetsRecs at:

http://www.archives.gov/veterans/evetrecs/index.html

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Default and Overpayment

• Student must not be in default on any Title IV loan nor owe an overpayment on any Title IV grant or loan

– Also applies to parent seeking PLUS loan

• Student must sign “Certification Statement” on FAFSA certifying he or she in not in default on any FSA loan and does not owe overpayment on FSA grant or loan, or has made satisfactory arrangements to repay the overpayment or default

• Student ineligible if his property is subject to judgment lien for debt owed to U.S…also applies to parent applying for PLUS

• Student ineligible if he or she has exceeded annual or aggregate loan limits

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National Student Loan Data System (NSLDS)

National database containing selected federal financial aid information on Title IV recipients (www.nsldsfap.ed.gov)

• CPS matches student against NSLDS to determine:– If student is in default, owes repayment or has made satisfactory arrangements to

repay the overpayment or default or record contains unusual enrollment information

• FAA must resolve conflicts between NSLDS information and other information available prior to disbursing FSA funds

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National Student Loan Data System (NSLDS)

Unusual Enrollment History

• Students identified based on Pell Grant data

• C code on ISIR

• Unusual Enrollment History Flag on ISIR– Flag value will determine needed action

• Postscreening reason code ‘24’ = Unusual Enrollment History Pattern

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National Student Loan Data System (NSLDS)

Pell Lifetime Eligibility Used

• New field provides percentage of total Pell Grant eligibility used by applicant. Expressed in format 9999.999%

• New flag identifies whether applicant is close to or exceeding his or her total Pell eligibility limit.

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ISIR Value and Value Printed on ISIR

Description

C Close to Pell limit

E Met or Exceeded Pell limit

H High Pell percent

N No problem

Blank Record not sent for match

NSLDS

• Results of NSLDS match provided on SAR and ISIR on NSLDS Financial Aid History page

– “C” next to EFC indicates problems that must be resolved

• Successful match

– Provided only if identifying information matches database• “1” = successful match

• Unsuccessful match• “2”, “3”, or “4” = defaulted loan, overpayment, or both

– Must be resolved prior to awarding aid– Will not be provided on rejected application

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NSLDS

• Partial match– SSN in database, but first name and date of birth do not match

• Requires resolution

• Student not in database– Assume no financial aid history unless conflicting information

• Student in database, no relevant history– SSN matches record, no history, no resolution required

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NSLDS - Post screening

• Occurs when changes happen after initial database matches

– Alerts FAA to significant changes to student’s financial aid history

• New ISIR sent to schools listed for receipt of student’s FAFSA information

– Items changed are marked with “#” sign – System-generated flag of “N”

• Used to identify students ineligible for any FSA aid due to:– Default or overpayment on FSA grant or loan– Reaching program’s annual or aggregate limit

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NSLDS – Transfer Student Monitoring

• Institution must send NSLDS identifying information for students transferring to the school during the award year

• NSLDS – Alerts school to any relevant changes in transfer student’s financial aid history, other

than default and overpayment information reported in the postscreening process, that may affect student’s current award(s)

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FAFSA Drug Question

Not a Data Match

• Drug conviction can disqualify a student for FSA funds

– Ineligible only if convicted of sale or possession of illegal drugs occurring while student is enrolled in school and receiving Title IV aid

• Student self-certifies that he/she is eligible

– School is not required to verify unless there is conflicting information.

– Response of Yes results in worksheet mailed to applicant • If applicant has questions, he/she may call 1-800-433-3243

– C code or blank requires resolution

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Change in Status

• Student’s eligibility status can change during award year– Usually affects whether student can be paid

• Gaining eligibility– May receive aid for

• Payment period for Pell, TEACH and campus-based aid• Period of enrollment for Stafford and PLUS

– Special rule for meeting requirements for citizenship, receiving valid SSN or Selective Service registration – eligible for Pell, TEACH & campus-based aid for entire Award Year, not just the payment period

• Losing eligibility– Cannot receive any disbursements after losing eligibility unless qualify for late disbursement

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SAP Policy - Required Elements

• Measurement of student’s progress at each evaluation– GPA that a student must achieve at each evaluation (qualitative standard)– Pace of progression to ensure completion within the maximum time frame

(quantitative standard)– How GPA and pace of completion affected by

• Incompletes• Withdrawals• Repetitions• Transfers of credit from other schools

– Must count transfer hours accepted toward completion of student’s program as both hours attempted and completed

– May have more frequent informal SAP reviews of student’s progress, but reviews that trigger warning periods, probations or loss of eligibility can only take place at the end of a payment period

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SAP Policy - Maximum Time Frame

• For undergraduate programs of study, must be no longer than 150% of published length of educational program

• For graduate programs of study, institution defines the maximum period based upon length of educational program

• School’s policy must specify– Pace of progression required to ensure student completes within maximum time

frame and that pace is measured at each evaluation• Pace is calculated by dividing cumulative hours student successfully completed by

cumulative hours student has attempted

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SAP Policy - How Often Is SAP Evaluated?

• For programs of study that are one academic year or less in length, school must evaluate SAP at end of each payment period

• For programs of study longer than one academic year– School must evaluate at least annually to correspond with end of a payment

period– School may evaluate at end of each payment period

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SAP- Statuses

• Financial Aid WarningStatus assigned to a student who fails to make SAP at an institution

that evaluates SAP at the end of each payment period Student may continue to receive TIV aid for one payment period No appeal necessary for this status

• Financial Aid SuspensionStatus assigned to a student who fails to make SAP Student not eligible to receive TIV aid

• Financial Aid ProbationStatus assigned to a student who fails to make SAP, but has had TIVeligibility reinstated in response to an appeal Student may continue to receive TIV aid for one payment period School can impose conditions that must be met

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SAP Policy - SAP Notifications

• Required SAP notifications

– Institution must notify student of results of SAP review that impacts the student’s eligibility for TIV aid

– If the institution has an appeal process, must describe the specific elements required to appeal SAP

– If institution does not have an appeal process, must describe how a student who has failed SAP re-establishes eligibility for TIV aid

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Individual Program Requirements

• Study Abroad Programs

– Student eligible for aid if:• enrolled in program approved for credit by eligible school • enrolled as regular student at that eligible school

– School must have contractual agreement with foreign school or single written arrangement with study-abroad organization to represent an agreement between school and one or more foreign schools

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Readmission of Service Members

• An institution may not deny readmission to a service member on the basis of that service

• Student is entitled to readmission if:– Advance notice of call to military service is provided– Cumulative absence for service does not exceed 5 years– Notice of intent to return provided to appropriate office designated by institution

within 3 years after leaving military• Institution must readmit service member with same academic status as

student had when last attended– Student admitted to same program, or similar program if exact program no longer

offered, with same enrollment status and with same number of clock or credit hours completed

• Student readmitted to same program is assessed charges that student was or would have been assessed at time he left for 1st AY– Unless admitted to a different program

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Comments and questions

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