Publication Date:
October 2006
DCL ID: GEN-06-18
Subject: Implementation
of "Academic Year" Definition in the Academic Competitiveness Grant (ACG)
and National SMART Grant Programs
Summary: This letter
provides guidance to institutions concerning how to implement the "academic
year" definition within the ACG and National SMART Grant programs
for the 2006-07 and 2007-08 award years.
Dear Colleague:
I would like to express
the Secretary's thanks and appreciation for the efforts that everyone
in the postsecondary education community has put forth to successfully
implement the new Academic Competitiveness Grant (ACG) and National SMART
Grant programs, now included in Title IV of the Higher Education Act of
1965, as amended (HEA). I know the effective implementation of these new
programs has presented unique challenges to financial aid and other offices
on college and university campuses around the country. The number of students
receiving these grants is increasing daily, showing that these efforts
are working.
As you know, the
Department published interim final regulations on July 3, 2006, to govern
the awarding of ACG and National SMART Grants for the 2006-2007 award
year. We anticipate publishing any revisions to these final regulations
by November 1, 2006, based on public comments received in response to
the interim final regulations. Any such changes will govern the programs
for the 2007-2008 award year. Any changes to the regulations for the 2008-2009
award year and beyond will be developed through a negotiated rulemaking
process, which began on September 19, 2006.
Institutions that
participate in the Federal student aid programs are responsible for properly
implementing the requirements of these new programs, as provided in the
statute and in the regulations. Institutions are reminded that the administrative
capability regulations require them to have procedures in place for sharing
information among their offices if that information impacts a student's
eligibility for any Title IV, HEA funds, including funds from the new
ACG and National SMART Grant programs. That said, the Secretary understands
that many institutions are facing significant challenges in implementing
these new programs, with virtually no lead time. Department staff will
take this into consideration when reviewing an institution's implementation
of the new programs.
The Department will
use information that it has available in its application and delivery
systems to support institutions as they carry out their responsibilities
for the new grant programs. Beginning in December 2006, we will share
with institutions information about ACG and National SMART Grants already
received by students. These systems will also have safeguards in place
to assist institutions in ensuring that students do not receive more than
one first-year ACG, one second-year ACG, one third-year National SMART
Grant, or one fourth-year National SMART Grant award. We will also use
our systems to monitor for students who appear to be receiving more than
one full ACG or National SMART Grant in less than 30 weeks.
Academic Year
One provision of
the new grant programs that some institutions have indicated as particularly
difficult to implement relates to the use of the term "academic year,"
with respect to determining which academic year a student is enrolled
in or has completed. The term "academic year" is specifically
defined in section 481(a) of the HEA, and institutions are required to
develop a Title IV academic year definition for each of their academic
programs that meets or exceeds the minimum requirements of that statutory
definition.
HEA section 481(a)
states that, for a program that measures progress in credit hours, the
academic year must include at least 24 semester credit hours or 36 quarter
credit hours and, for both, a minimum of 30 weeks of instructional time.
In general, a week of instructional time is defined as any consecutive
seven-day period in which at least one day of regularly scheduled instruction
occurs. The definition of an academic year also provides that a program
offered in clock hours must have at least 900 clock hours and 26 weeks
of instructional time.
Institutions have
flexibility in defining the Title IV academic year for each of their academic
programs as long as the statutory minimums are met. In many cases, institutions
have defined their Title IV academic year to coincide with their normal
academic grade level progression (e.g., freshman, sophomore, etc.) and
their grade level progression for the Title IV student loan programs.
Credit Hour Component
of an Academic Year: An institution must define a Title IV academic
year for each of its academic programs in accordance with the statutory
minimums. For example, an institution may choose to use the same 30 semester
credit hours that it uses for other academic and financial aid purposes
or the minimum 24 semester credit hours.
When determining
a student's eligibility for an ACG or National SMART Grant, an institution
must use its defined Title IV academic year for that student's program.
The institution must use in that determination the number of credit hours
earned by the student at that institution or at another postsecondary
institution(s) if those credit hours will be accepted to meet a part of
the requirements for the student's eligible program. Credits earned by
a student from Advanced Placement (AP) coursework, International Baccalaureate
(IB) coursework, testing out, life experiences, etc. must also be included
if the institution uses those credits to meet a part of the requirements
of the student's eligible program.
Weeks of Instruction
Component of an Academic Year: Because of the difficulty facing many
institutions that use traditional term-based academic calendars in determining
the actual number of weeks of instruction it took a student to complete
the number of credit hours in an academic year, an institution whose academic
calendar includes at least 30 weeks of instructional time offered in standard
terms may, on a student-by-student basis, use either of the two following
approaches for the 2006-2007 and 2007-2008 award years:
- Assume that there
were 30 weeks of instructional time for each increment of credit hours
that comprises the institution's Title IV academic year definition (e.g.,
24 credit hours equals 30 weeks of instruction, or 30 credit hours equals
30 weeks of instruction). However, under this approach, an institution
must have controls in place to ensure that no student receives more
than one full ACG or National SMART Grant award in any 30 week period.
An institution must also determine the actual number of weeks of instruction
for a student who requests that such a determination be made or who
questions whether he or she has completed an academic year.
- Determine the
actual number of weeks of instruction that were included for the student
to complete the number of credit hours in the institution's Title IV
academic year definition by reviewing the student's academic record
to see how many weeks it took the student to complete the credit hours
earned. When performing this review, an institution may not assign any
weeks of instruction to credits earned by the student from Advanced
Placement (AP) coursework, International Baccalaureate (IB) coursework,
testing out, or life experience since those credits were not earned
during attendance at a postsecondary educational institution, even though
they apply toward completion of the student's program, and thus in the
credit hour component of a Title IV academic year.
Illustrative Example:
A student begins enrollment at an institution that defines its academic
year as 24 semester credits. The institution applies 24 credits that the
student earned through AP toward completion of the student's eligible
program. The institution chooses to review the student's academic record
to determine the actual number of weeks of instruction (or the student
requests that the institution do so). Since all the credits earned were
from AP and there are no weeks of postsecondary instruction associated
with AP credits, the student is still in her first academic year and is
eligible for a first year ACG award.
Fourth Year National
SMART Grants
We have been asked
whether an otherwise eligible student who has earned more than four times
the number of credit hours in the institution's defined academic year
is eligible for a fourth- year National SMART Grant. For example, is a
student eligible who has earned 120 semester credit hours in an academic
program that requires 132 semester credit hours to complete at an institution
that defines its academic year as 30 semester credit hours?
Generally, a student
who has earned more credits than four times the number of credits in the
institution's definition of its Title IV academic year is not eligible
for a National SMART Grant, since that would mean that the student has
completed his or her fourth academic year. However, for the 2006-2007
and 2007-2008 award years, we will consider a student's fourth academic
year to end when the student has completed the minimum number of credits
required for completion of that academic program, as published in the
institution's official academic publications. A student may only receive
one fourth-year National SMART Grant.
Illustrative Example:
A student enrolled in an engineering program that requires 132 credits
for completion ends his or her fourth academic year when the student has
earned 132 credits. Thus, the student is eligible for fourth year National
SMART Grant funds until he or she has earned 132 credits, assuming the
student has not already received the maximum amount of a fourth year National
SMART Grant. The same result would apply for a student who has completed,
for example, 96 credit hours of a program that requires 120 hours for
completion, where the institution defines its academic year as the completion
of 24 credit hours.
We hope that this
guidance helps institutions as they work to complete the process of awarding
ACG and National SMART Grants this year and for the 2007-08 award year,
and we thank you for your cooperation and patience.
Sincerely,
James F. Manning
Acting Assistant Secretary for
Postsecondary Education
Attachments/Enclosures:
GEN-06-18:
Implementation of "Academic Year" Definition in the Academic Competitiveness
Grant (ACG) and National SMART Grant Programs in PDF Format, 244KB, 4
pages
Posted October 23, 2006 on www.NASFAA.org, the Web Site of the
National Association of Student Financial Aid Administrators (NASFAA).
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