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Can a school retroactively pay a Federal Pell Grant after a student has been approved for a total and permanent disability (TPD) discharge? The student attended the spring 2015 term, but the discharge was not approved until after the semester ended and NSLDS has not been updated with the discharge. 


If the student meets the requirements for a late disbursement in section 668.164(g)(2)(i) of the Code of Federal Regulations, a student with a TPD discharge may still receive a Federal Pell Grant.

Section 668.164(g)(2)(i) states:

“(2) Conditions for a late disbursement. Except as limited under paragraph (g)(4) of this section, a student who becomes ineligible (or the student's parent in the case of a PLUS loan) qualifies for a late disbursement if, before the date the student became ineligible—

(i) The Secretary processed a SAR or ISIR with an official expected family contribution…”

Further guidance on TPD can be found in NASFAA's Student Aid Index tool.


Publication Date: 10/23/2015

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