How does the Department define full-time enrollment for Title IV aid purposes?

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1 Enrollment Status 34 CFR 668.2(b). Federal Student Aid Handbook, Vol. 1, Ch. 1. Federal Student Aid Handbook, Vol. 3, Ch Percent Direct Subsidized Loan Limit Information website. Accurate as of: July 1, 2015 What is a student s enrollment status? A measure of the number of hours in which the student is engaged in academic activities compared to the school s definition of full-time enrollment. The school may establish and track different definitions of full time for Title IV aid administration and for the school s own academic standards. The student s Title IV enrollment status helps determine the types and amounts of Title IV aid a student may receive and, under the 150 percent regulations, also factors into the calculation of the student s remaining Direct Subsidized loan eligibility. How does the Department define full-time enrollment for Title IV aid purposes? While the Department establishes minimum full-time enrollment standards for undergraduate students, schools may establish a definition of undergraduate full-time enrollment that is greater than the regulatory minimums. Schools define their own full-time enrollment standards for graduate students. Full-time Enrollment Requirements Undergraduate Program Type Standard term Minimum Full-Time Enrollment 12 semester or 12 quarter hours per term. The result of the following equation per term: Credit-hour nonstandard term Number of weeks of instructional time in the term Number of weeks of instructional time in the academic year X Credit hours in the academic year Credit-hour nonterm Clock hour Series courses or seminars Cooperative education Correspondence coursework Graduate Program Type All programs 24 semester or 36 quarter hours per academic year, or the prorated equivalent for programs shorter than one academic year. 24 clock hours per week. 12 semester or 12 quarter hours in a maximum of 18 weeks. Work performed that is equivalent to a full-time student in a classroom setting. Coursework proportionate to a full-time student; at least half of the coursework must be non-correspondence. Minimum Full-Time Enrollment School-defined. Must the school use the same enrollment status definition for all programs? No. The school may establish different enrollment statuses for different programs, provided the statuses meet the minimum requirements previously outlined. The definition must apply consistently to all students in the same program. Page 1

2 How does the school define less-than-full-time enrollment for Title IV aid purposes? Once the school establishes full-time enrollment status for Title IV aid purposes, it may calculate all other enrollment statuses (threequarter time, half time and less than half time) proportionally. Alternately, the school may establish the half-time enrollment status as half of the federally-defined minimum full-time standard, even if this results in fewer hours than the proportional calculation. There are two exceptions to the proportional calculation: u A student enrolled only in correspondence courses cannot be considered to be enrolled more than half time, regardless of the actual hours enrolled. u A student enrolled in a clock-hour program always is awarded Title IV aid as if enrolled full time, regardless of the actual hours enrolled. Standard-Term Example A school establishes a full-time enrollment status of 12 credit hours or more per term. When the school performs a proportional calculation, it determines that a minimum enrollment of 9 credit hours is three-quarter time and a minimum enrollment of 6 credit hours is half time. Enrollment for fewer than 6 credit hours is less than half time. 12 credit hours 9-11 credit hours 6-8 credit hours 1-5 credit hours Nonstandard-Term Example A school establishes a full-time enrollment status of 15 credit hours or more per term. When the school performs a proportional calculation, it determines that a minimum enrollment of credit hours is three-quarter time and 7.5 credit hours is half time. To simplify the enrollment status criteria, the school then rounds the results up to the nearest whole credit hour. Even though the school chose to establish a half-time enrollment status that is proportional to the established full-time standard, the school could alternately choose to use 6 hours as the half-time status, since that figure is half of the federally-defined minimum full-time enrollment status of 12 hours. 15 credit hours credit hours 8-11 credit hours 1-7 credit hours Can the student s enrollment status include courses that do not count toward the student s program? No. The school must count in the student s enrollment status only hours for those courses that count toward the student s degree or certificate, with the exception of any eligible remedial coursework. There is an exception when reporting enrollment statuses to NSLDS, see page 3. Page 2

3 Can the student s enrollment status include repeated coursework? In some cases, repeat coursework may count in the student s enrollment status and for purposes of awarding Title IV financial aid. Program Type Previously-Passed* Coursework Repeat Coursework Provisions Previously-Failed Coursework Term based** Undergraduate A school may include in the student s enrollment status and pay Title IV aid for one repeat of a previously-passed course.* A school may include in the student s enrollment status and pay Title IV aid for unlimited repeats of previously-failed courses, in accordance with the school s established policies. Term based Graduate Nonterm Undergraduate and Graduate A school may include in the student s enrollment status and pay Title IV aid for unlimited repeats of all courses, in accordance with the school s established policies. Re-entry within 180 days and leave of absence: A school cannot include in the student s enrollment status or pay Title IV aid for hours of coursework repeated while on an approved LOA. Re-entry after 180 days: A school may include in the student s enrollment status and pay Title IV aid for hours for repeat coursework. Re-entry into a new program or repeating a program: A school may include in the student s enrollment status and pay Title IV aid for hours for repeat coursework. * Passed refers to a course in which a student received a grade higher than F. ** An exception exists for courses taken in groups. If a student must retake an entire group of courses because he failed a single class in that group, the school counts the previously-failed course in the student s enrollment status, but not the previously-passed courses. How do modules relate to enrollment status? For term-based programs, schools that combine modules into terms use the total number of hours enrolled for the entire term to determine the student s enrollment status. The enrollment status for students registered for programs offered in modules still must meet the requirements previously outlined. Term-Based Program Example A school establishes a full-time enrollment status of 12 credit hours per term. The school offers 3 credit-hour courses in modular format every term. A student may enroll in classes during each module, or only certain modules, to achieve the requisite minimum number of hours for the enrollment status for each term. 12 credit hours 9-11 credit hours 6-8 credit hours 0 hrs 1-5 credit hours 0 hrs Are schools required to report enrollment status information to the Department? Yes. Schools must report enrollment status to the Department via the Common Origination and Disbursement system with the origination record. Before the school makes the initial disbursement of a Direct Loan, if the student s enrollment or borrowing pattern deviates from what originally was reported, the school must update the enrollment status accordingly. The school also must report enrollment status data to the National Student Loan Data System on a regular basis. When reporting enrollment status information to NSLDS, the school must calculate the student s enrollment status based on all hours enrolled, not just those for which the school pays Title IV aid. This exception does not apply when reporting to COD. What does the school report as the student s enrollment status? The school must report the student s enrollment status as full time, three-quarter time, half time or less than half time. Page 3

4 When does the school report the student s enrollment status? COD Reporting: The school may report an anticipated enrollment status when originating the loan in COD, and must update the status if different on the actual disbursement date for the initial loan disbursement in the payment period. The final reported enrollment status must be accurate as of the date that the school makes the initial disbursement of the loan for the payment period. NSLDS Reporting: ED will send reporting rosters to the schools every 60 days, and the school must respond to those requests with the most updated enrollment status information within 15 days of receipt. Are there any situations in which a school revises the student s enrollment status in COD? Yes. The school must report the student s enrollment status for each payment period when making the initial loan disbursement for that payment period. Once the first disbursement is made, the school does not update the student s enrollment status in COD during the remainder of that payment period. The following example illustrates one scenario under which a school must update a student s enrollment status. Example Payment Period 1 Payment Period 2 July 15 School originates loan and reports student s anticipated enrollment status in COD as full time for PP 1 and PP 2. Aug. 1 Oct. 15 School disburses loan for PP 1. Student still is enrolled full time, so school does not update enrollment status in COD. Student drops to half-time status for PP 1. School does not update enrollment status in COD because initial disbursement of loan was already made. Dec. 15 Student enrolls three-quarter time for PP 2. Dec. 20 Jan. 7 Jan. 8 School updates the student s anticipated enrollment status in COD to three-quarter time for PP 2. Student drops to half-time enrollment status for PP 2 prior to disbursement. School disburses loan for PP 2 and updates enrollment status in COD to half time. Why is reporting enrollment status required? Enrollment status affects the student s eligibility for certain types of aid and post-enrollment benefits. The enrollment status on record matters when: u Determining when the student enters the grace period on a Direct Subsidized and Unsubsidized loan. A student borrower of Direct Loans is entitled to a six-month grace period before entering repayment. The grace period begins the day after the student no longer is enrolled at least half time. The "Enrollment Effective Date" may be on or prior to the date the school certifies the student's enrollment status. u Determining whether a student or parent borrower qualifies for an in-school deferment on a Direct Loan. In-school deferment covers any period during which the borrower is enrolled at least half time at a school that is eligible to participate in Title IV aid programs. u Calculating continued eligibility for new Direct Subsidized loans and for continued interest subsidy on existing loans due to the 150 percent loan limit provisions. Page 4

5 Grace Period Example A school defines half-time enrollment as at least 6 credit hours of coursework. A student enrolls in 8 credit hours for the fall term, dropping to 5 credit hours on Nov. 5. She enrolls in 3 credit hours for the following spring term. The six-month grace period on her Direct Subsidized and Unsubsidized loans begins on Nov. 6, and her loans enter repayment in May with a first payment due within 60 days of the end of the grace period. Since she used the entire six-month grace period during this period of less than half-time enrollment, a grace period will not be available to her again for the loan(s). Considered in school Uses grace period 12 credit hours 9-11 credit hours 6-8 credit hours 1-5 credit hours In-School Deferment Example A school defines half-time enrollment as at least 8 credit hours of coursework. A student was in repayment on her loans and returned to school, enrolling in 17 credit hours. The school reported her enrollment and the student received notification that her loans were placed in an in-school deferment status. The student enrolled in 6 hours of enrollment for the following term. The school updated her enrollment status and the student s loan holder then notified her that her loans returned to repayment status. Eligible for in-school deferment Ineligible for in-school deferment 15 credit hours credit hours 8-11 credit hours 1-7 credit hours 150 Percent Direct Subsidized Loan Limit For students subject to these provisions who are enrolled in term-based programs, when the student s enrollment status is less than full time, the Department adjusts the subsidized usage period based on the enrollment information reported by the school. For three-quarter time enrollment during a loan period, the calculated SUP will be multiplied by 0.75; for half-time enrollment, the calculated SUP will be multiplied by The result is rounded up or down to the nearest tenth of a year. Subsidized Usage Period Enrollment Adjustment SUP x 1.0 SUP x 0.75 SUP x 0.50 N/A Page 5

6 Term-Based Programs The Department will apply the enrollment status adjustment at the payment period level, divide the result by the number of payment periods in the loan period, add the adjusted payment period SUP figures for the loan period together and then round the result up or down to the nearest tenth of a year. Example A student borrowed Direct Subsidized loans for a loan period that covers the entire academic year. The following chart illustrates the various resulting SUP calculations based on different enrollment statuses. Enrollment Status Payment Period 1 Payment Period 2 1/2 time 1/2 time 3/4 time 3/4 time Full-time 1/2 time 1/2 time 3/4 time SUP for the Academic Year PP 1: 0.50 x 0.50 = 0.25 PP 2: 0.50 x 0.50 = 0.25 PP 1: 0.50 x 0.75 = PP 2: 0.50 x 0.75 = PP 1: 0.50 x 1.00 = 0.50 PP 2: 0.50 x 0.50 = 0.25 PP 1: 0.50 x 0.50 = 0.25 PP 2: 0.50 x 0.75 = , rounded up to , rounded up to , rounded down to 0.60 Clock-Hour Programs Students in clock-hour programs always are considered enrolled full time for Title IV eligibility, even if enrolled in a clock-hour program defined as part time. The school may consider the full-time and part-time programs to be separate programs and report the separate program lengths, as appropriate, to COD and NSLDS. The SUP would not be prorated for students in a part-time clock-hour program. Student 1: Full-time Clock-Hour Program Student 2: Part-time Clock-Hour Program 35 clock hours per week 20 clock hours per week Program Length = 900 hours Program Length = 900 hours Time to complete the program = 26 weeks Time to complete the program = 45 weeks Academic year defined as 900 hours and 26 weeks A student enrolls in 35 hours per week and borrows Direct Subsidized loans for the entire program. Academic year defined as 900 hours and 45 weeks A student enrolls in 20 hours per week and borrows Direct Subsidized loans for the entire program. The SUP of 1.0 for is not prorated for the student in the part-time program. Both students are taking the maximum course load for their respective programs and are, therefore, both considered enrolled full time United Student Aid Funds, Inc. All rights reserved. Printed in the USA. Page 6