Title IV Foundations - Schedschd.ws/hosted_files/wasfaaspringconference2014/18/Clock Hour... ·...
Transcript of Title IV Foundations - Schedschd.ws/hosted_files/wasfaaspringconference2014/18/Clock Hour... ·...
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 1
2014 Spring Conference
April 9, 2014
Calculating and
Disbursing Title IV
Aid for Clock-hour
Schools
Agenda
• Basic definitions
• Payment periods
• Federal Pell Grants
• Federal Direct Loan
• Disbursements
• Satisfactory Academic Progress
2
Academic Year
• Must be defined by school using statutory
guidelines for each academic program
− Must use that definition for all students in the same
program
− Must use that definition for all Title IV purposes
• Program length may be longer or shorter than the
definition of an academic year
• Does not always correspond to a school’s
scheduled academic calendar
3
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 2
Academic Year
• Academic year is used to:
− Determine payment periods
− Calculate Direct Stafford Loan eligibility
• Sometimes confused with:
− Grade level classification, often set by Registrar
− Award year
4
Clock-hour Academic Year
• Statutory minimum definition for programs that
measure progress in clock hours
− 900 clock hours
− 26 weeks of instructional time
− A week is a 7-day period in which there is at least one day
of instruction or exams
− Need not correspond to a calendar week
5
Academic Year Examples
• 990 clock-hour, 42-week program
− Some academic year options
• 900 clock hours, 26 weeks
• 900 clock hours, 38 weeks
• 990 clock hours, 42 weeks
• 1,800 clock-hour, 48-week program
− Some academic year options
• 900 clock hours, 26 weeks
• 900 clock hours, 32 weeks
• 1,200 clock hours, 32 weeks
6
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 3
Clock-Hour Enrollment Status
• Minimum full-time standard for undergraduate
clock-hour programs is 24 clock hours per week
− A student attending 24 hours per week will complete
900 hours in 37.5 weeks
− If attending 30 hours per week, will complete 900 hours
in 30 weeks
− If attending 35 hours per week, will complete 900 hours
in 26 weeks
• Half-time is half of full-time (minimum 12 hours)
• Must be defined by the school for each eligible
program
7
TERM
Clock Hours and Terms
• How does this work with your term
structures?
− Rule 1—Ignore the fact that you have
terms!!
− Rule 2—Terms do not apply!!
− Rule 3—Regardless of terms, track
progression to the next payment period
using clock hours and weeks of instruction,
not terms!
8
9
Payment Periods
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 4
Payment Period
• The academic year is divided into payment periods
• Payment periods used for:
− Pell Grant calculations and disbursements
− Direct Loan disbursements
• Calculation of payment periods varies based on the
published length of the program
• A change in award years does not change the
defined payment periods
10
Payment Period
• For clock-hour programs, the payment period is
defined not only in clock hours but also in weeks of
instructional time
− Must know weeks of instructional time in program in
order to properly calculate Pell Grant awards
• A student must successfully complete the clock
hours AND weeks of instructional time in a
payment period to progress to the next payment
period
11
Programs of One Academic Year or Less
• The program is divided into two equal payment
periods
− CANNOT have more than two payment periods in an
academic year
− 1st payment period is the period of time when the student
completes half the number of clock hours and half the
weeks of instructional time in the program
− 2nd payment period is the period of time in which the
student successfully completes the remainder of the
program
− Applies to any program of 900 hours* or less
* Unless academic year is defined as longer than 900 hours
12
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 5
Payment Period Example
• Culinary Program, 700 clock hours, 32 weeks
− Academic year is 900 hours and 26 weeks
• Program is divided into two equal payment periods
− Payment period 1 - clock hours 1-350 and 18 weeks
elapse
− 2nd payment period is remainder of clock hours and weeks
in program
13
Payment Period Example
• Programs of one academic year in length
• Medical Assistant program is 900 clock hours with
38 weeks of instructional time
− Academic year is 900 clock hours and 38 weeks
• 1st payment period = Clock hours 1-450 and 19 weeks elapse
• 2nd payment period = Remainder of program – clock hours
451-900 and remaining 19 weeks
14
Program Greater Than One Academic Year
• For the first academic year and any full academic
year after that:
− First payment period is the period of time when the student
completes half the number of clock hours and half the
weeks of instructional time in the academic year
− Second payment period is the period of time in which the
student successfully completes the remainder of the
academic year
• Example – 1,800 clock hour program over 64
weeks with academic year of 900 clock hours and
32 weeks - Program has 4 equal payment periods
15
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 6
Program Greater Than One Academic Year
• If the remainder of a program than is more than
half an academic year but less than a full academic
year in length
− 3rd payment period is half the clock hours and half the
weeks of instructional time remaining in the program
− 4th payment period is the time necessary to complete the
remainder of the program
16
Program Greater Than One Academic Year
• If the remainder of a program than is less than half
an academic year in either weeks or clock hours
− 3rd payment period is the remainder of the academic
program
17
Payment Period Example
18
Cosmetology Program
• 1,800 clock hours and 48 weeks
• Academic year is 1,200 clock hours and 32 weeks
Year 1:
600 hours/16 weeks and 600 hours/16 weeks
Year 2:
600 hours/16 weeks
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 7
Payment Period Example
19
Practical Nursing Program
• 1,340 clock hours and 72 weeks
• Academic year is 900 clock hours and 26 weeks
Year 1:
450 hours/13 weeks and 450 hours/13 weeks
Year 2:
440 hours/46 weeks
Crossover Payment Periods
• Longstanding definition and policy
− Payment period that includes 6/30 and 7/1
− Established payment periods are determined by number of
clock hours and weeks of instructional time
− Must be assigned to and paid from one award year
• Any aid drawn down for crossover period may pay all costs
associated with the period (even if paying from next award
year)
• May use different award year for Pell than for other Title IV aid
− Must have valid SAR/ISIR for assigned year
20
Payment Period Disbursements
• At least one disbursement must be made in each
payment period
• The full amount due the student for a payment period should
be disbursed to the student before the end of the payment
period
• Disbursements must be made to best meet the
needs of the student
− Institution may not have a practice of delaying disbursement
beyond the 60% point in time to avoid R2T4 calculation
21
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 8
Re-Entry Students
• A student who ceases attendance and returns
within 180 days is considered to remain in the
same payment period
• A student who ceases attendance and returns after
180 days or begins a different program at the same
school within any time period starts a new payment
period
− All periods of a student’s attendance in a program are
subject to SAP maximum time frame
• Clock-hour students cannot usually be paid for
repeating a failed class
22
Re-entry Students and Maximum Time
• All periods of student’s enrollment count when
assessing progress, even if students don’t receive
Title IV funds
• Example – Student attends 25 weeks of a 40-week
program and withdraws. Student returns 1 year
later and is required to repeat the entire program
− Maximum time frame is 150%, or 60 weeks
− Student has attended 25 weeks, so only 35 weeks remain
toward maximum time frame
− Student is ineligible because he cannot mathematically
complete within maximum time
23
24
Federal Pell Grant Calculations
and Requirements
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 9
Five Calculation Steps
1. Determine enrollment status
2. Calculate Pell COA
3. Determine annual award
4. Determine payment periods
5. Calculate payment for each payment period
25
Pell Grant COA
• Is student at least half-time?
• If program is not equal to an academic year,
prorate COA up or down to reflect one full
academic year
− Pell COA always based on cost for full-time student for a
full academic year
26
Step 2 - Pell Grant COA Proration
27
Multiply program COA by the lesser of two
fractions to determine Pell COA
OR
Clock/credit hours in program’s defined academic year
Clock/credit hours to which the costs apply
Weeks of instructional time in program’s defined academic year
Weeks of instructional time in enrollment period to which costs apply
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 10
Annual/Scheduled Pell Award
• The maximum amount a student would receive
during a full academic year for a given enrollment
status, EFC and COA
• The annual award for a student in a clock-hour
program is always taken from the full-time payment
schedule, even if the student is attending less than
full-time
− Thus the annual award will always equal the scheduled
award
28
Pell Calculation for Payment Period
29
Formula 4
Scheduled Award times THE LESSER OF:
Number of clock hours in the payment period
Number of clock hours in program’s academic year
or
Number of weeks of instructional time in the payment period
Number of weeks of instructional time in program’s academic year
Pell Calculation Example 1
• Program less than one academic year
− 650 clock hour, 18 week program
− Academic year defined as 900 clock hours, 26 weeks
− Payment periods defined as 325 clock hours and 9 weeks
− Take lesser of 325/900 = .361 or 9/26 = .346 times the
annual award
• $5,000 X 9/26 = $1,730.77
30
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 11
Pell Calculation Example 2
31
$4,000 X 600 or 16 = $2,000
First Academic Year
1,800 clock hour program over 48 weeks
Academic year definition – 1,200 clock
hours and 32 weeks
1,200 32
Pell award for each payment period
Pell Calculation Example 2
32
$4,000 X 16 or 600 =
Second Academic Year
$2,000 32 1,200
Pell Calculations for Transfer Students
• Determine length of program at your institution
• Determine percentage of Pell received at previous
school during award year
− Subtract result from 100%
• End result remaining Pell eligibility
• Remember – use percentages, not dollars
33
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 12
Federal Direct Loan
Information
34
Determining Loan Periods
• Loan period may be the same as the period of
enrollment for programs one academic year in
length or less
− Loan periods may cross award years
• Loans must be disbursed equally by payment
period
− The loan period determines the payment periods
35
Determining Loan Periods
• Maximum loan period
− Generally school’s academic year.
− Can be the length of program if program longer than an
academic year (for example, program is 900 hours over 40
weeks and academic year is defined 26 weeks)
• Minimum loan period – the lesser of:
− The academic year, the student’s program, OR
− The remaining portion of the program, OR
− The remaining portion of an academic year
36
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 13
Monitoring Annual Loan Limits
• Borrower-based Academic Year (BBAY3)
− Must be used for clock-hour and nonterm programs and
− Moves with student’s attendance and progression in
program
− Student becomes eligible for new annual loan limit after
successful completion of clock hours AND weeks in
academic year
37
Prorating Annual Loan Limits
• Student enrolled in program less than an academic
year in length
• Student enrolled in program that is longer than an
academic year and is in a final period of study that
is less than an academic year
38
Prorating Annual Loan Limits
Final period less than an academic year
Use:
Hours enrolled Hours in academic year
Program less than an academic year
Use lesser of:
Weeks enrolled Weeks in academic
year
or
Hours enrolled Hours in academic year
39
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 14
BBAY – Clock-Hour Program
40
1,200 Clock-Hour/32 Week Program
900 Clock-Hour/26 Week Academic Year
450 hrs/13 wks 450 hrs/13 wks
1st BBAY
$3,500 annual loan limit
*You must prorate annual loan limit for final
period less than an academic year
$4,500 x 300 / 900 = $1,500 Sub
$2,000 x 300 / 900 = $667 Unsub
300 hrs/6 wks
2nd BBAY
$4,500 annual
loan limit*
Frequency of Annual Loan Limits Example
• Program is 1,800 clock hour overs 72 weeks
• Academic year is defined as 900 clock hours and
36 weeks
• Student completes 900 hours in 30 weeks
• Student not eligible for new annual loan limit until
36 weeks have elapsed
− Student will have completed 1,100 hours at that point
• Second loan prorated
− 700/900 X $4,500 = $3,500
41
Transfers Between Schools
• Upon transfer to second school
− New school certifies loan for remaining balance of annual
loan period for period that covers remaining portion of loan
period at first school
• After remaining balance completed, student
progresses to new loan period and annual loan
limit
42
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 15
43
Disbursements
Title IV Disbursements
• An institution makes a disbursement of Title IV
program funds on the date that the institution
credits a student’s account at the school or pays
the student directly with –
− Funds received from the Department
− Institutional funds used in advance of receiving funds from
the Department
• Schools must disclose the methods and frequency
of disbursements of Title IV aid
44
Disbursement Reporting to COD
• Report the actual disbursement date and amount
− Report as early as 7 days before actual (true) date of
disbursement
− Report no later than 15 days of crediting the student’s
account
• Disbursement date reported to COD must be the
actual date of disbursement to the student account
− Direct Loans – interest begins to accrue on the actual
disbursement date reported by the school
− See Electronic Announcement January 29, 2014
45
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 16
Disbursing by Payment Period
• Student must successfully complete the required
clock hours and weeks in a payment period before
receiving disbursements for a subsequent payment
period
• Excused absences may be included when
determining clock hours completed under certain
circumstances
46
Excused Absences
• Absences must be ones that the student does not
have to make up
• School must have written policy that permits
excused absences
• Number of excused absences may not exceed the
lesser of:
− Allowed excused absences per accrediting agency or state
authorizing agency
− 10% of the clock hours in the payment period
47
48
Satisfactory Academic Progress
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 17
Maximum Time Frame
• For undergraduate programs, must be no longer
than 150% of published length of educational
program
− For clock-hour programs, as measured in cumulative
clock hours required to complete and expressed in
calendar time
− A clock-hour program cannot establish the maximum
time in credits attempted
49
Maximum Time Example
• Program is 1,200 clock hours
• Students attend 30 hours per week
• Program scheduled to last 40 weeks
• 40 X 150% = 60 weeks maximum time frame
− A student must complete 20 hours per week in order to
complete 1,200 hours in 60 weeks
50
SAP Evaluation Points
• Schools may monitor progress by selecting 1 of 3
options for all students in a program
1. At the point where the student’s scheduled clock hours
for the payment period have elapsed, regardless of
whether the student attended them
2. At the point when the student has attended the
scheduled clock hours
3. At the point when the student successfully completes
the scheduled clock hours for that payment period
51
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 18
Option 1 Pace Evaluation
• School reviews SAP based on attended hours
• Students scheduled to attend 30 hours per week
• At 450 scheduled hours the student has
successfully completed 300 hours
• Both hours and weeks must be checked
− Hours calculation – 300/450 = 67%
− Weeks calculation – 10/15 = 67%
52
Option 2 Pace Evaluation
• School reviews SAP based on attended hours
• Students scheduled to attend 30 hours per week
• The student attended 450 hours at the time 600
hours were scheduled
• Both hours and weeks must be checked
− Hours calculation – 450/600 = 75%
− Weeks calculation – 15/20 = 75%
53
Option 3 Pace Evaluation
• School reviews SAP based on successfully
completed hours
• Students scheduled to attend 30 hours per week
• The student successfully completed 450 hours at
the time 600 hours were scheduled
• Both hours and weeks must be checked
− Hours calculation – 450/600 = 75%
− Weeks calculation – 15/20 = 75%
54
For Training/Discussion Purposes Only
April 2014
Byron Scott
U.S. Department of Education 19
55
Training Evaluation
To ensure quality training, we ask all participants to complete an online evaluation for each session
• Go to https://s.zoomerang.com/s/ByronScott
− Evaluation form is specific to Byron Scott
• Feedback is a tool to help us improve our training and to listen to our customers
Please provide any comments regarding this training or the trainer to:
Jo Ann Borel, Title IV Training Supervisor
409-579-3776
56
Contact Information
57
Your Chicago regional trainers
Byron Scott, Training Officer
312-730-1534
Angela Smith, Training Officer
312-730-1552