Jacquelyn Cottom

Assistant Director of Financial Aid Compliance and Support at Northern Virginia Community College

Monday, April 24

Unusual Enrollment History (UEH)

V4/V5 Reporting

Multiple Reporting Record (MRR)/ Potential Overaward (POP)

Pell Lifetime Eligibility Used (LEU)

Conflicts with High School Completion and Bachelor Degree

Best Practices

Beginning with the 2013-2014 award year, the Department added an Unusual Enrollment History (UEH) flag that indicates that a student has an unusual enrollment history based on the receipt of Federal Pell Grant (Pell Grant) funds

• GEN-13-09 was provided on March 8, 2013 from US Dept. of Education with guidance

The UEH Flag is intended to address possible abuse in the Title IV student aid programs

There was concern about an enrollment pattern in which a student attends an institution:

• Long enough to receive a Title IV credit balance,

• Leaves without completing the enrollment period,

• Enrolls at another institution, and

• Repeats the pattern of remaining just long enough to collect a Title IV credit balance without earning any academic credit.

As a result 3 UEH Flags and 2 ISIR C-Codes were established as a result

Some students who have an unusual enrollment history have legitimate reasons for enrollment at multiple institutions.

However, such an enrollment history requires a review to determine whether there are valid reasons for the unusual enrollment history.

Resolution of a UEH flag is separate and distinct from verification

Dear Colleague Letter : GEN-15-05 (March 16, 2015)

The new changes included:

1. Prior receipt of a Federal Direct Loan (not including a Direct Consolidation Loan or parent PLUS Loan) and

2. Reviewing the prior four, instead of three, award years

UEH Flag values of ‘2’ or ‘3’ generate a ‘C’ Code to indicate to institutions that the student’s records must be reviewed.

For students, Student Aid Report (SAR) Comment Code 359 is included when the UEH Flag value is ‘2, ’ and SAR Comment Code 360 is included when the UEH Flag value is ‘3’.

If the school has reason to suspect a student of abusing the Title IV aid programs, but the Department did not assign a UEH flag to the student's ISIR, the school may elect to review the student using the criteria for UEH flag “3.”

ISIR codes 359 and 360 will create checklist items that require the same documentation as students in V4 tracking group.

• In addition to transcripts from all schools attended (with requests for evaluation), and an academic plan that must be signed off by advisor.

• Students with 359 comment values of 2 will be reviewed immediately to determine whether credit has recently been earned at NOVA. If so, all characteristics will be reviewed to determine if C code can be overridden.

V4- Custom Verification Tracking Group:

• High School Completion Status

• Identity/Statement of Educational Purpose

V5 – Aggregate Verification Tracking Group:

• Tax Filers (V1) Documentation

• Nontax Filers (V1) Documentation

• Number of Household Members

• Number of Household Members in College

• High School Completion Status

• Identity/Statement of Educational Purpose

You must report verification results of identity and high school completion status for any student with V4 or V5 tracking flag and request documentation.

Report the information on FAA Access to CPS Online Menu

FAA Access does not store a list of these verification results to retrieve it is recommended you print and keep the conformation pages.

Institutions must report on FAA Access the verification results of Identify and High School Completion status for applicants in the V4 or V5 Tracking Groups.

Options include:

1. Verification completed in person, no issues found

2. Verification completed remotely, no issues found

3. Verification attempted, issues found with identity

4. Verification attempted, issues found with high school completion

5. No response from applicant

6. Verification attempted, issues found with both identity and HS completion

Identity Verification Results should be reported 60 days following the institution’s first request to the student to submit the required V4 or V5 documentation.

High School Diploma;

Final official high school transcript

Homeschool credential, transcript or the equivalent, signed by the parent or guardian

Has completed one of the ability-to-benefit (ATB) alternatives

GED Certificate/Transcript

State authorized certificate

Academic Transcript (completed a 2 year program acceptable for full credit towards BA Degree)

DD Form 214 Certificate of Release or Discharge from Active Duty, if it indicates that the individual is a HS graduate or equivalent

Diploma Mills

Review Process

Reports and Queries

Acceptable (and Unacceptable) High School List

Establish a standard approach

Communicate openly and timely with students

MRR identifies originations and disbursements being reported by more than one institution for the same student during the same period of time.

The multiple report records are designed to provide institutions with information to identify and resolve potential overaward payments and concurrent enrollments before they occur.

During specific times of the year it is our process to always check COD prior to awarding.

The question then leads to: Are you truly our student?

• Enrollment Periods

• Transient Students

• Consortium Agreements

• Transfer Credits

• Intent to Enroll

Established the duration of a student’s Pell eligibility as 12 semesters (6 years) or its equivalent

Effective with 2012-2013 award year

No “grandfathering”

Amount of Federal Pell Grant funds a student may receive is limited to the equivalent of six years of Pell Grant Funding

Since the maximum amount of Pell Grant funding a student can receive each year is equal to 100%, the six year equivalent is 600%.

If LEU is more than 500% but less than 600% only partial eligibility for next award year.

An applicant will appear on the Pell LEU Report, if the student:

• Submitted a FAFSA for the award year

• Is Pell-eligible for the award year as determined by CPS

• LEU is greater than or equal to 450% as determined by COD system

Advising/Counseling Students who have been reported

Do you have a Bachelor’s Degree?

• Yes….No….I’m not sure?

Admissions & Records vs. FAFSA

Queries, Reports, Interviews and more

Request for clarification