awarding and processing aid for modular session programs pamela moran and dan klock u.s. department...

Awarding and Processing Aid for Modular Session

Programs

Pamela Moran and Dan Klock

U.S. Department of Education

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Topics

• Awarding Aid for Programs Using Modules

• Disbursing Aid for Programs Using Modules

• Handling Intersessions

• R2T4 Regulations Affecting Modules

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Awarding and Disbursing Aid for Programs Using Modules

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Use of ModulesChanging Patterns in Education

• Short term and sequential course enrollment• Courses are often offered in modules (usually 1-8

weeks in length) • Programs with modules may -

– compose an entire program; or – be offered in conjunction with other full-term

length courses

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Use of ModulesChanging Patterns in Education

• Used in Standard and Non-Standard Term and Non-Term Settings

• Sometimes involve overlapping terms• Courses offered as modules may begin in

one term and end in another term• Enrollment can begin at beginning of any

module• Students may skip one or more modules

Basics: Term

A term:

•Defined as a discrete period of time during which all courses are scheduled to begin and end

•Within a term: full-length courses, compressed courses or modules, and courses offered sequentially

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• Standard Term: a semester or trimester (generally 14-17 weeks long) or a quarter (generally 10-12 weeks long)

• Non-standard Term: all coursework begins and ends within a set period, but it is not a semester, trimester, or quarter

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Basics: Standard and Non-Standard Terms

Basics: Non-Term

• Courses do not all begin and end within a discrete period of time and may:

- contain self-paced or independent study courses without fixed timeframes

- consist of sequential modules or courses that do not begin and end within a term

• Clock-hour programs are always non-term

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Other Title IV Factors• Definitions:

Academic year – 30 (credit hours) or 26 weeks (clock hours) of instructional time, and for undergraduates: 24 semester/trimester hours, 36 quarter credits, or 900 clock hours; for graduates, institutional minimum full-time standard

Full-time – greater than statutory minimum or adjusted for summer or intersession?

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Modules - Operating Principles

• Schools may combine a series of modules into a single term

• Enrollment can begin at beginning of any module

• Students may skip one or more modules within the term

• Loan period includes entire term


• Up-front enrollment (registered courses) should support aid eligibility and award amount

• Cost of attendance excludes periods of non-attendance

• Student must begin attendance in all credits or recalculation required (except loans)

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Module - Operating Principles • For loans, student must commence

attendance or is ineligible borrower for entire term

• No disbursement can be scheduled during period of non-enrollment

• Earliest attendance dictates first disbursement; payment period begins with module that includes first date of attendance

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Change in enrollment status to less-than-half-time results in cancellation of subsequent loan disbursements.

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Modules - Operating Principles within a Standard Term or Substantially Equal Non-Standard Term of

at Least Nine Weeks

• Pell Formula 1 applies• Standard Term loan disbursement and annual

loan limit progression applies• Warning: Structure of modular terms can

transform standard term program into non-standard term module begin/end date must be within 2 weeks of duration of standard term (Ex #2 & #3)

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ModulesCommon Term Configurations

Example #1 - A series of modules within a standard 16-week term

Semester- 16 Weeks/ 12 cr. Module I- Module II- Module III- Module IV-

Four Weeks /3 cr. Four Weeks/3 cr. Four Weeks/3 cr. Four Weeks/ 3cr. Module 1 Module 2 Eight Weeks - 6 cr. Eight Weeks – 6 cr.

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ModulesCommon Term Configurations

Example #2 - A standard term with several

concurrent and overlapping modules

Module I- Module II- Module III-

6 Wks/ 5 cr. 4 Wks/ 3 cr. 6 Wks/ 4 cr.

Module V-4 Wks/3 cr.

Semester- 16 Weeks/12 cr.

Module IV-Beginning at

4Wks/ 3cr.

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ModulesCommon Term ConfigurationsExample #3

A 16-week standard term with three modules offered concurrently; module begin and/or end dates within two weeks of standard term’s duration

Semester-16 Weeks/ 12 cr.

Module I- 6Wks/4cr. Module II- 6Wks/4cr. Module III-6Wks/4cr.

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• Student enrolls in I, II, & IV 3-credit hour modules• Student enrolls in 2nd 8-credit hour module only

- adjust the COA downward to reflect the costs of the actual period of enrollment

- loan period is entire semester

Example #1 – Standard Term

Example #1- Standard Term - low cohort default rate school – single disbursement for the term scheduled for actual attendance; otherwise multiple disbursement with 2nd disb. at calendar midpoint of term

- if no enrollment in 3 cr. Module III, 2nd disb. not at calendar midpoint

- Pell and campus-based payment period is term; recalc. required if no attendance in all registered classes

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Examples #2 and #3 – Standard Term

• Module duration within 2 weeks of semester’s duration, therefore standard term treatment maintained

• Pell Formula 1 applies

• Total enrollment in all modules, including overlapping modules used to determine COA if student registered for all modules

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Example #4 - Non-Standard Terms8 weeks 10 weeks 9 weeks 10 weeks 3 weeks

6 cr 9 cr 3 cr 3 cr 3 cr 9 cr 3 cr

Term Term Term Term Term

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2nd Loan DisbursementStart Week Week Week Weekdate* 8 18 27 37

• Academic Calendar: 36 semester credits over 40 weeks of instructional time

• Title IV academic year: 24 semester credits and 30 weeks of instructional time

Example #4- Non-Substantially Equal Non-Standard Term

• Pell Grant Formula 3 applies• Term = Payment Period for Pell and

Campus-Based • Minimum BBAY loan period =

36cr/37wks• Loan must be multiply disbursed; 2nd

Disbursement after completion of 18 credits and 21 instructional weeks

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Example #4 – Non-Substantially Equal Non-Standard Term

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• Calculation of Full-Time Enrollment Status for each payment period:

# of credit hrs. in academic year

X

wks of instruct.time in pay.period

wks of instruct.time in acad. year

Example #4- Non-Substantially Equal Non-Standard Term

• Pell Grant Formula 3 applies• Term = Payment Period for Pell and

Campus-Based • Minimum BBAY loan period =

36cr/37wks• Loan must be multiply disbursed; 2nd

Disbursement after completion of 18 credits and 21 instructional weeks

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Modules: Non-Term ConfigurationExample #5 – Non-term Undergrad Cert. Program

5 hrs 5 hrs 5 hrs 5 hrs 5 hrs 5 hrs 10 hrs 10 hrs 10 hrs

5 wks 5 wks 5 wks 5 wks 5 wks 5 wks 8wks 8 wks 8 wks

• Academic Calendar: 60 quarter hours over 54 weeks of instructional time; not self-paced

• Title IV academic year = 36 quarter hours and 30 weeks of instructional time

• Full-time = 36 quarter hours over 30 weeks of instructional time

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Modules: Non-term ConfigurationExample #5 – Non-term Undergrad Cert. Program

• Minimum BBAY loan period = academic year; first 10-hour module must be included to meet 36 hour requirement; 40 quarter hours and 38 weeks of instructional time

• Loan must be multiply disbursed ; 2nd Disbursement of Loan #1 after completion of 20 quarter hours and half the weeks of instructional time

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Modules: Non-term ConfigurationExample #5 – Non-term Undergrad Cert. Program

• Second loan period is remaining balance of program – 20hrs/16 weeks for multiply-disbursed, prorated loan amount calculated as 20/36 (hrs in loan period over hours in the academic year

• Pell uses Formula 4 and Pell and Campus-Based observe same payment periods

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Handling Intersessions

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Intersessions • Generally offered at schools using standard terms • May be a short session between two standard terms –

for example, 3 weeks of instructional time between two 15-week semesters

• May be a shorter summer term – for example, 12 weeks of instructional time with a 12-semester hour full-time standard

• Must offer aid to eligible students in these sessions

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Intersessions – Applicable Title IV Definitions

• Academic year:

- 30 weeks of instructional time

- 24 semester hours for undergraduate programs• Full-time:

- 12 semester hours for semesters and summer term;

3 semester hours for intersession treated as

separate term

3 wks in term X 24 hrs in acad.year

30 wks in acad. year = 3 hrs (2.4 rnd up)

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Intersession as Separate Term• Creates Non-Standard Term Environment

• Pell – Formula 3

• Direct Loans;

- BBAY only; No longer qualifies to use SAY

- Payment Period and Disbursement for unequal terms

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Intersession as Separate Term - Pell

• Payment period calculations vary under Formula 3

• Prorate payments based on weeks in each payment period:

-Semesters: 15/30 annual award

-Summer: 12/30 annual award

- Intersession: 3/30 annual award

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Intersession as Separate Term – Direct Loans

• Loan Period: Minimum is lesser of Title IV acad. year, program length, or remaining balance of acad. year; for grad/prof, hours a full-time student completes in acad. year – No one-term loans

• Payment period is non-term; disburse at beginning and midpoint after completing 1/2 hours and instructional weeks

• Annual loan limit progression: completion of both weeks and hours in the acad. year

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Intersession Merged with Standard Term

• Pell - Formula 1

• Direct Loans:

- Choice of SAY or BBAY

- Loan periods, payment periods, disbursement, and loan limit

progression based on standard term, traditional calendar treatment

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Intersession Merged with Standard Term - Pell

• Same payment period calculations for all terms if Formula 1 used

• Payments for payment periods same for all terms in an award year for particular award year

• Payments: (e.g., semester )

- Semesters: ½ annual award

- Summer: ½ annual award

- Intersession: None; part of the term

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Intersession Merged with Standard Term – Direct Loan Requirements

• Loan Period Options:

- SAY with summer as header or trailer

- Standard Term BBAY

- one term loan• Loan Limit Progression: after completion of

SAY or Standard Term BBAY • Payment Period: term, which may include

addition of intersession• Disbursement Frequency: Next term

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Case Study #1-Treated as Separate Term

• Anticipated Enrollment: 12 credits each semester; 3 credits for intersession

• Pell Scheduled Award: $4,000 for award year

• Loan Period for DL: Fall and Spring

• Non-standard term treatment for loans; Pell remains by term

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Case Study #1-Treated as Separate Term

Student’s Actual Enrollment:Fall 1 - 12 credits (drops to 6 before

drop/add) Intersession – 3 creditsSpring - 6 creditsSummer – 6 credits (fails 3 credits)

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Case Study #1- Treated as Separate Term – Pell Formula 3

• Fall 1 – half-time [withdrew before census date]: 15/30 X $2,000 = $1,000

• Intersession – full-time:

3/30 X $ 4,000 = $400• Spring – half-time:

15/30 X $2,000 = $1,000• Summer – half-time:

12/30 X $2,000 = $80039

Case Study #1 – Treated as Separate Term – Direct Loan

• Loan Originated for Fall through Spring (24 attempted credits over 33 instructional weeks)

• Student must complete credits and instructional weeks – non-standard term treatment

• Two disbursements; 2nd scheduled for Spring

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Case Study #1 – Treated as Separate Term- Direct Loan

• Due to enrollment changes and non-completion, 2nd disbursement rescheduled and loan limit progression at completion of following Fall term rather than originally anticipated Spring term

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Case Study #2 – Merged with Term

• Anticipated Enrollment: 12 credits for Fall and 15 credits for Spring (includes intersession)

• Pell Scheduled Award: $4,000 for award year

• Loan Period: Fall and extended Spring (includes intersession)

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Case Study #2 – Merged with Term

• Student’s Actual Enrollment: Fall 1: 12 credit hours (drops 6 before

drop/add) Intersession: 3 credits (toward Spring) Spring: 6 credit hours (fails 3 credits) Summer: 6 hours

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Case Study #2 – Merged with Term – Pell Formula 1

• Fall 1 – half-time [withdrew before census date] : ½ X $2,000 = $1,000

• Spring – three-quarter time with intersession credits: ½ X $1,500

• Summer – half-time: ½ X $2,000 = $1,000

• ½ used because there are two terms

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Case Study #2 – Merged with Term Direct Loan

• Loan originated for Fall through Spring

• 2nd Disbursement made for start of intersession as part of second term

• Remaining annual loan limit eligibility used for summer

• New academic year for loan limit begins following Fall term

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Other Considerations for Intersessions

• Must apply same treatment in an eligible program for all Title IV

• If merged, must merge with same term for all students in program for all Title IV

• Whether merged or not, must adjust COA for loans/campus-based for a period of non-attendance

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• If not merged:

- under §674.16 and 676.16 for Perkins and FSEOG, if student incurs uneven costs (e.g., short intersession) is a reduced payment for that payment period)

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If merged:

- census date for Pell recalculation may need to be reconsidered

- may support loan eligibility for otherwise ineligible term

- earliest Spring disb. date shifts with Spring and non-attendance

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R2T4 Regulations Affecting Modules

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Current Rules – 34 CFR 668.22• When a recipient ceases attendance before the

scheduled end of the program for which s/he received Title IV, HEA aid– The institution is required to determine the

amount of aid that the student earned– The institution also determines the unearned

portion

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Prior to 7/1/11 • Rules did not specifically deal with term-based

programs with courses that are less than the length of the term

• GEN-00-24 – (Dec. 2000) – we said when a student is in a modular program within a standard term and the student completes at least one of the modules, then R2T4 does not apply– Completing one compressed course is the equivalent of

completing a single course that spans the entire PP or POE

GEN-00-24 (Dec. 2000)Session 1

Session 2

Session 3

WD

Withdrawal after completing Session 1 and after beginning Sessions 2 and 3.

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Program Integrity – Final Regulations (75 FR 66832) 10/29/10

• Return of Title IV funds topics:

– Programs offered in modules

– When a student is considered a withdrawal

– Written confirmation

– Institution that is required to take attendance

– Academically-related activities

R2T4 – Definitions (eff. 7/1/11)

• “Offered in modules”

– If a course does not span the entire payment period (PP) or period of enrollment (POE)

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“Offered in Modules”• If the student ceases attendance before the period

for which aid was awarded, it is a withdrawal

• The denominator of the return calculation includes the full number of days used to determine the aid award, absent any institutionally scheduled breaks of five or more consecutive days or periods of time that the student was on an approved LOA

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When a Student is Considered a Withdrawal – (effective 7/1/11)

• In a program measured in credit hours– Student does not complete all the days

scheduled to complete in the PP or POE• In a program measured in clock hours

– Student does not complete all the clock hrs & wks of instructional time scheduled to complete in the PP or POE

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When a Student is Considered a Withdrawal – (effective 7/1/11) (cont.)

• In a non-term or non-standard term– Student is not scheduled to begin another

course within a PP or POE for more than 45 calendar days after the end of the module the student ceased attending

• Unless the student is on an approved LOA

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Written confirmation – effect. 7/1/11

• For courses offered in modules– A student is not considered to have withdrawn if,

• For standard term programs, the institution obtains written confirmation that the student will return to complete a later module within the same PP or POE

• For non-term and non-standard terms – the institution obtains written confirmation that module begins no later than 45 calendar days after the end of the module the student ceased attendance

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Written confirmation – eff. 7/1/11- (cont.)

• Student can revise the date of return to a later module, if– Student does so in writing, between the time

of the withdrawal, but prior to the return date– For non-term and non-standard term

programs, the later module begins no later than 45 calendar days after the end of the module the student ceased attendance

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• What happens when a student does return to a later module within the same PP or POE?– If this is a non-term program, the student reenters

the same program – student is eligible for the same amount of Title IV, HEA funds prior to WD

– As long as the student returns within 180 days TIV is restored

(see 668.4(f))

Written Confirmation – eff. 7/1/11- (cont.)

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Institution Required to Take Attendance• An outside entity (accreditor, state) has a requirement to

take attendance– (No change this is the current rule)– If the outside entity has a requirement for attendance

taking for a sub-group of students, then that sub-group are bound by the “Institution required to take attendance” rules in 668.22(b)

– If the outside entity has a requirement that attendance taking must occur for a limited time

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Institution Required to Take Attendance – eff. 7/1/11

(cont.)

• The institution has a requirement that attendance be taken– The Program Integrity – Final regulations do not require

institutions to take attendance, however– If an institution requires its faculty to take attendance at the

program, departmental, or institutional level– If there is no institutional requirement, but an individual

faculty member chooses to take attendance, those records could, but would not be required to be used (Therefore, the institution is not required to take attendance – 668.22(c))

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• Institution or an outside entity has a requirement that can only be met by taking attendance for the program or a portion of the program– Remember the regulations prior to July 1, 2011

– if an outside entity has a requirement that, as determined by the entity, the institution is required to take attendance

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• If the institution is required to take attendance or requires attendance for only some students– The attendance records must be used to

determine the withdrawal date for that cohort of students

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• If the institution is required to take attendance or requires attendance for a limited period of time

– The attendance records must be used to determine the withdrawal date for that limited period of time

– A student in attendance on the last day of the limited period, who subsequently WDs – will be treated as a student at an institution not required to take attendance

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Institution required to Take Attendance – eff. 7/1/11

• Only required to take attendance for a single day– “Census” snap-shot– Not considered “An institution required to

take attendance”– Follow the rules in 668.22(c)

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Academically-related activity – What’s Included

• Examples of an academically-related activity– Physically attending a class with direct interaction

between the instructor and students– Submitting an academic assignment– Taking an exam, an interactive tutorial, or

computer-assisted instruction

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• Examples of an academically-related activity – (cont.)– Attending a study group that is assigned by the

institution– Participating in an online discussion about

academic matters– Initiating contact with a faculty member to ask a

question about the academic subject studied in the course

Academically-related activity – What’s Included

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Academically-related Activity – What’s Not Included

• Effective 7/1/11 – you can no longer consider the following an academically-related activity for R2T4 purposes -– Living in institutional housing– Participating in the institution’s meal plan– Logging into an online class without active participation– Participating in academic counseling or advisement

EXAMPLES:

• The next slides provide additional examples of the concepts just discussed

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“Offered in Modules” - Example A

• Institution A:– Fall and Spring = standard terms

• Never considered to be “offered in modules”– Summer = three 5-week sessions (combined to be a

standard term)• Students can enroll in any of the summer sessions or all of them• Students enrolled in the 5-week summer sessions are considered

in programs “offered in modules” since none of the sessions span the entire length of the term (the 15-week period)

“Offered in Modules” – Example A

• Student #1 – Enrolls in all three summer sessions and ceases enrollment on Day 5 in the first 5-week session

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• The Results:– Step 1 – Recalculate Pell & Campus-based– Step 2 – Determine earned & unearned

amounts of Title IV aid (TIV)• Numerator = # of days attended in Course

1 (assume no breaks) 5 days• Denominator = Start date of Course 1 thru

end date of Course 3 (less any scheduled break of 5 or more consecutive days or approved LOAs) 105 days or .048 or 4.8%

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Session 15 weeks

Session 25 weeks

Session 35 weeks

35 days 35 days 35 days

Withdrawal Day 5

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Session 15 weeks

Session 25 weeks

Session 35 weeks


Withdrawal Day 5 student also drops remaining sessions.

Institution Required to Take Attendance: WD = Day 5. Denominator = 105 days. Per GEN 04-12, the institution must have a process to make this determination no later than 14 days after the LDA.

Institution not Required to Take Attendance: WD = 668.22(c). Denominator = 105 days.

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• Student #2: Enrolls in all three summer sessions– Day 4 of session 1, drops session 2– Day 8 of session 1, withdraws during the first 5-wk

session– Student does not provide written confirmation of

return within the payment period

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• The Results:– Step 1 – Recalculate Pell & Campus-based– Step 2 – Determine earned & unearned amounts

of TIV• Numerator = number of days attended (assume no

breaks) 8 days• Denominator = 35 days each in sessions 1 & 3, less

any scheduled breaks or approved LOAs 70 days or .114 or 11.4%

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Session 15 weeks

Session 25 weeks

Session 35 weeks


Day 4 – drops Session 2

Day 8 - Withdraws

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“Offered in Modules” – Example B

• Summer sessions include three 5-week sessions and 15-week sessions

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“Offered in Modules” – Example B

Session5 week

Session5 week

Session 5 week

Session 15- week

Student C enrolls in two 15-week courses – this student is not considered to be enrolled in a program offered in modules. Student D enrolls in one 5-week module and one 15-week course – this student is considered to be enrolled in a program offered in modules.

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“Offered in Modules” – Example CSession 15 weeks

Session 25 weeks

Session 35 weeks


Claire begins Module 1 in a non-term program, but drops Session 2 on Day 3. Then she withdraws on Day 5. She indicates that she wants to resolve some health issues and then return at the beginning of Session 3. What is her withdrawal date?

1 wk

break

1 wkbreak

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Session 25 weeks

Session 35 weeks


Claire drops Session 2.

What is Claire’s withdrawal date?

Day 5 – while it will be 79 days before Session 3 begins, it is 49 days after the end of the Session 1 until the start of Session 3, therefore a written confirmation is not an option (greater than 45 days).

1 wk

break

1 wkbreak

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Session 25 weeks

Session 35 weeks


Claire’s other option would be to seek a Leave of Absence beginning on Day 6 of Module 1 and ending the day before Session 3 begins.

1 wk

break

1 wkbreak

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“Offered in Modules” – Example D

• The Results:– Step 1 – Recalculation Campus-based –

has revised COA changed CB eligibility?• Pell is NOT recalculated for non-term modular

program since it is always based upon full time schedule

– Step 2 – No return calculation due to the fact that the student provides written confirmation of her/his planned return between the time of the withdrawal and before the start of the third module

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“Offered in Modules” – Example D

Session 15 weeks

Session 25 weeks

Session 35 weeks


Day 4 – drops Session 2

Day 5 – withdraws from Session 1 and provides written confirmation that student will return to Session 3.

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“Written Confirmation”

• Student #3 – Enrolls in all three summer sessions, drops session 2 on Day 4. Ceases enrollment on Day 5 in the first 5-week session, but provides written confirmation of future return

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Written Confirmation – eff. 7/1/11- (cont’d)

• What happens when the student doesn’t return for the future module?

• The withdrawal date (WD) is -• At an institution required to take attendance = the last

date of attendance (LDA)• At an institution not required to take attendance =

midpoint or the last date of an academically-related activity

“Written Confirmation”

Session 15 weeks

Session 25 weeks

Session 35 weeks


Day 4 – Withdraws from Session 1 and 2, but provides written confirmation of return to Session 3.

Day 71 – Student does not return. WD = Day 4 at Institution Required to Take Attendance; Midpoint or Academically-related activity at an Institution not Required to Take Attendance.

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Term I – 16 weeks

Program A – Daily attendance taking is required for the first 2- week period.

All students who withdraw during the first 2 wks = Institution required to take attendance.

All students who withdraw after the 2-wk period = Institution not required to take attendance.

2 wks

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Total # of Days in a PP or POE – eff. 7/1/11

• Includes all the calendar days within the period that the student was scheduled to complete, except– The number of institutionally scheduled breaks of

five consecutive days or more are not included in the total calendar days used in the return calculation, or

– The days in which the student was on an approved LOA

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Program “Offered in Modules” – eff. 7/1/11

• For programs “offered in modules” the total number of days does not include –– The days a student was on an approved LOA– Any institutionally scheduled break of five or

more consecutive days when the student was not scheduled to attend a module or other course offered during that time


Module 1 Module 2 Module 3

Student enrolls for three modules within a term each 35 days in length and with a weekend in between modules 1 & 2 and 2 & 3.

Cheryl begins and completes Module 1 and doesn’t return for Modules 2 & 3 and doesn’t contact the institution.

Institution Required to Take Attendance – WD = LDA- last day she took a final exam. The denominator = 109 days (35 x 3, plus 4 days between Modules).

Institution not Required to Take Attendance – WD = midpoint or last date of an academically-related activity. The denominator = 109 days (35 x 3, plus 4 days between Modules).

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Module 1 Module 2 Module 3

Student enrolls for three modules within a standard term each 35 days in length and with a week in between modules 1 & 2 and 2 & 3.

Anthony begins and completes Module 1 and doesn’t return for Modules 2 & 3 and doesn’t contact the institution.

Institution Required to Take Attendance – WD = LDA- last day he took a final exam. The denominator =105 days (35 x 3). The time between the Modules are more than 5 consecutive days and therefore excluded.

Institution not Required to Take Attendance – WD = midpoint or last date of an academically-related activity. The denominator =105 days (35 x 3).

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• Please Remember!– These events determined to be an academically-

related activity must be documented and retained by the institution in accordance with the recordkeeping requirements in 34 CFR 668.24

– Student self-documentation of an academically-related activity will not meet the requirement

Academically-related activity

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QUESTIONS ???

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Contact Information

Pamela Moran

Office of Postsecondary Education

202-502-7732

[email protected]

Dan Klock

Federal Student Aid

202-377-4026

[email protected]

mailto:[email protected]

mailto:[email protected]

awarding and processing aid for modular session programs pamela moran and dan klock u.s. department...

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