7-9: Operational Guidance on Reporting Student Eligibility Codes for All Students, Including Those Who Are Enrolled in an Eligible Career Pathway Program

Posted Date: July 9, 2015

Author:  Sue O'Flaherty, Service Director, Program Management, Federal Student Aid

Subject: Operational Guidance on Reporting Student Eligibility Codes for All Students, Including Those Who Are Enrolled in an Eligible Career Pathway Program

As explained in Dear Colleague Letter (DCL) GEN-15-09, posted on the Information for Financial Aid Professionals (IFAP) Web site on May 22, 2015, one of the changes made by the Consolidated and Further Continuing Appropriations Act of 2015 was to allow a student who does not have a high school diploma (or its recognized equivalent), or who did not complete a secondary school education in a homeschool setting, but who is enrolled in an eligible career pathway program, to be eligible for Title IV aid through ability to benefit (ATB) alternatives.

In this Electronic Announcement we provide the following:

  • Operational guidance about how schools will report Student Eligibility information to the Common Origination and Disbursement (COD) System, for students receiving aid under the new ATB provisions, as well as the existing student eligibility provisions.  This guidance also includes an important clarification regarding the correct reporting for graduate and professional students;

  • Reminders about the Career Pathway Alternative Pell Grant Payment Schedules; and

  • Information on additional resources about COD System processing of ATB information.

Operational Guidance for Reporting Student Eligibility Information to the COD System

As GEN-15-09 explains, there are no changes to the student eligibility provisions for those students who have a high school diploma or a recognized equivalent, or who have a homeschool completion credential.  There are, however, changes for those eligible career pathway students who are eligible through one of the alternatives: completing and passing an approved ATB test or completing at least 6 credit hours or 225 clock hours that are applicable toward a degree or certificate offered by the postsecondary institution.

Beginning with the 2013-2014 Award Year, awards submitted to the COD System for all relevant Title IV programs require a Student Eligibility Code (previously Ability to Benefit Code) to report how the student (including graduate and professional students) meets the student eligibility requirement of having a high school diploma or its equivalent.

As a reminder, the <StudentEligibilityCode> tag is used to report student eligibility on the COD Common Record.  In the attachment to this announcement, we provide tables to show the acceptable values for the <StudentEligibilityCode> tag.

  • Table 1 shows the Student Eligibility Code values to report for students with a high school diploma or its equivalent.  Note:  This table includes an important clarification regarding the correct reporting code for graduate and professional students.

  • Table 2 shows the Student Eligibility Code values to report for students eligible through an ATB alternative.

Reminders about the Career Pathway Alternative Pell Grant Disbursement Schedules

As noted in Dear Colleague Letter GEN-15-09, a student who is enrolled in an eligible career pathway program and is eligible through one of the ATB alternatives, and who first enrolled in any Title IV eligible postsecondary program on or after July 1, 2015 is subject to a reduced Pell Grant amount.  The Pell Grant award amount for these students must be based on the 2015-2016 Career Pathway Alternative Pell Grant Disbursement Schedules.

IMPORTANT: Schools are responsible for determining student eligibility and the correct award amount for students who receive a Federal Pell Grant award under the Career Pathway Alternative Pell Grant Disbursement Schedules.  The COD System does not contain these schedules and there are no system edits on the Pell Grant award amount related to these schedules.

We urge schools to take special care when awarding Pell Grant funds to students who are eligible as a result of one of the ATB criteria in order to avoid overpayments for which the school is liable.

Additional Resources

For additional information about reporting Student Eligibility, refer to the 2015-2016 COD Technical Reference or the attachment to a March 13, 2013 Electronic Announcement.

Contact Information

If you have questions regarding the information included in this announcement or its attachment, contact the COD School Relations Center at 800/474-7268 for Grants or 800/848-0978 for Direct Loans.  You may also e-mail CODSupport@ed.gov

Attachments/Enclosures:

COD System Reporting - Student Eligibility Code Values in PDF Format, 246KB, 3 Pages

 

Publication Date: 7/9/2015


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