By Luke Hoey & Greg Rinderle
The Department of Education (ED) recently announced that the selection criteria that are used in determining whether a student has an Unusual Enrollment History (UEH) have been modified. Beginning with the 2015-16 FAFSA processing year, NSLDS will flag an application based on a student’s receipt of Pell grants and/or Direct Loans for the prior four award years, instead of three. So if you receive a 2015-16 ISIR that has been flagged because of UEH, you must consider the student’s Pell and Direct Loan disbursement history from the 2011-12 award year through the 2014-15 award year.
This update came out in the Dear Colleague Letter published on March 16th, 2015 (GEN-15-05). That is an important date to keep in mind because although the language in GEN-15-05 states that these changes are to take effect for the 2015-16 FAFSA processing year, we confirmed with ED that only 2015-16 ISIRs (with UEH Flags) that were processed on or after 3/16/15 need to be resolved based on this new guidance. So if you happened to already resolve a UEH C-Code from a 2015-16 ISIR on or before March 16th , you will not have to go back and review it based on the new procedures.
The process for verifying whether a student has earned academic credit at a previously attended institution will stay the same. Students still need to prove that they earned academic credit (or had a sufficient reason for not earning credit) at all previously attended institutions that are in question. You know the drill. Full guidance is included in Dear Colleague Letter GEN-13-09, which can be found at ifap.ed.gov/dpcletters/GEN1309.html
ED has made it clear in both Dear Colleague Letters that the UEH Flag was developed in an effort to uncover and curtail what some are calling “Pell jumpers” or “stipend chasers,” i.e., people that only attend schools long enough to receive Title IV credit balance funds. ED has also emphasized that, although there are opportunities (as outlined in GEN-13-09) for a student to explain and validate why they did not earn academic credit at a previous institution, if you as a financial aid administrator still have reason to believe that the student is only there for a credit balance refund, you are permitted to deny that student any additional Title IV, HEA program assistance. The authority for an institution to deny Title IV, HEA program assistance under these circumstances is section 484(a)(4)(A) of the Higher Education Act of 1965, as amended. Remember to use your professional judgment when making these determinations. You have the final say, be fair.
Volume 2, Issue 2