In response to questions raised in NASFAA's article regarding GEN-06-18, the Department of Education (ED) has provided the following clarification.
1. Can ED's guidance extending a student's eligibility for a fourth year SMART Grant be applied to a second-year ACG for a student in an eligible two-year program?
Yes. A student in a two-year program is considered a second-year student from the point he or she achieves that status until he or she accumulates the minimum number of credits required for graduation.
Remember, however, that a student may not receive more than one full second-year ACG. Thus, a student who already received $1,300 as a second-year student is not eligible for any more payments at that grant level, whether still in the two-year program or as a transfer student to a longer program.
For example, Doug, Ernie, Fritz, and Gary are all enrolled in a 60-credit hour, two-year semester-based associate degree program in which the Title IV academic year is defined as 24 credits and 30 weeks. They all received first-year ACG awards, earned 24 credits during their first year, and achieved a 3.0 GPA at the end of their first year. All remain Pell Grant-eligible throughout their enrollment.
Doug enrolls full-time during both terms of his second year and receives his full $1,300 second-year ACG. He has earned 48 credits during his two years and so needs one more full-time semester to graduate. He enrolls full-time for the fall term of his third year at the school.
Doug is still regarded as a second-year student as defined for ACG purposes since he has not yet earned 60 credits. However, he has already received a full second-year ACG and may not receive any more ACG payments.
Ernie attends part-time both semesters of his second year and finishes the year with 36 credits. He enrolls in the fall of his third year at the school for 12 credits, which is full-time, and plans to attend full-time in the spring as well.
Ernie is still regarded as a second-year student for ACG purposes since he has not yet earned 60 credits. He has not yet received any second-year ACG because he was not full-time. He may receive a second-year ACG for his third year at school as long as he attends full-time.
Fritz attends the summer term following his first year and the next fall term, both on a part-time basis. He then enrolls full-time for the spring semester of his second year at the school. He receives the first half of a second-year ACG for the spring term. He has earned a total of 60 credits by the end of his second spring term but he lacks two required courses for graduation. He enrolls full-time for the fall term of his third year at the school.
Fritz has passed out of his second-year ACG status because he has earned 60 credits, even though he has not fulfilled his graduation requirements. Even though he has received only half of a second-year ACG, he may not receive any more ACG payments.
Gary attends the summer term following his first year as a full-time student, and then enrolls full-time for fall. He receives half of a second-year ACG during summer and half during fall, after which he has earned a total of 48 credits. He enrolls full-time for spring, intending to graduate and transfer to a four-year program. The day after add-drop period has ended, he finds out that not all of his courses will transfer; he will have 42 transfer credits when he starts his new program.
Gary is still regarded as a second-year student for ACG purposes at the beginning of his second spring, since he has not yet earned 60 credits. However, he has already received a full second-year ACG for summer and fall. He may not receive an ACG payment for spring. Further, once he transfers to his new school, he is not eligible for any more ACG regardless of his classification.
2. GEN-06-18 addresses tracking weeks for standard term programs. How are weeks assessed for a transfer student entering a nonstandard term or nonterm program?
A school may use the assumption method to determine how many weeks the student attended prior to transfer, even if the student is entering a nonstandard term or nonterm program. The school would use the number of transfer credits it is accepting toward the student's degree, and the number of credits and weeks it uses in its own definition of Title IV academic year applicable to the student's new program. The school need not ascertain what type of program structure the student previously attended.
Note, however, that the assumption method in this case is used only to determine the student's starting status. The weeks component for academic year progression must be determined using the actual count method for the coursework subsequently taken in the student's new program if that program is nonstandard term or nonterm.
By Joan Berkes
NASFAA Senior Associate Director for Regulatory Assistance
Posted October 26, 2006 on www.NASFAA.org, the Web Site of the
National Association of Student Financial Aid Administrators (NASFAA).
Copyright 2006. Redistribution to non-NASFAA institutions is prohibited
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