Prerequisite Coursework and Title IV Financial Aid Eligibility
By Joan Berkes, Policy & Federal Regulations Staff
Recently, a number of aid administrators have raised questions regarding the treatment of coursework which does not itself advance the student towards graduation, but that the student must take as a prerequisite in order to register for a class that is needed to fulfill a graduation requirement.
For example, a two-year program offered by a community college requires 60 credits, consisting of core courses related to an associate level education, specified courses related to the academic major or degree area, and any college-level courses that the student elects to round out the 60-credit degree. As the student progresses, he finds that one of the specified courses requires a prerequisite, which itself does not satisfy any major requirement, but he has already filled his core and elective slots. If the prerequisite course is not counted as a course eligible for financial aid, the student may find himself not full time for aid purposes; depending on other life commitments, such a student might even fall short of half-time enrollment.
Depending on the major or degree area, the number of specified courses could be the bulk of the program and the number of electives could be quite small, if there are any at all. A general principle of federal student financial aid is that Title IV funds may only be used to pay for coursework that is part of the student’s program, leading to a degree or other recognized credential. In cases where a school tracking a student’s fulfillment of degree requirements finds that a prerequisite cannot be considered an elective because all of the elective “slots” have been filled by other courses, can that course be counted in enrollment status for the purpose of determining Title IV aid?
If the prerequisite course is viewed as a regular course, the answer would likely be “no.” However, the Department of Education (ED) recognizes that for some students, these prerequisite courses may be considered remedial coursework. As long as the student has not already reached the regulatory limit on payment for remedial courses (30 semester or 45 quarter credits, under 668.20), remedial courses may be included in enrollment status. A prerequisite required to enroll in a course that is required for the student’s program can be considered remedial for that student, as long as it meets the conditions noted in the regulation. In part, those conditions impose a minimum educational level for remedial coursework. (A remedial course may not be below the level needed to pursue successfully the degree or certificate program offered by that institution after one year in that remedial course, and, except for ESL coursework, may not be below the secondary level.) The regulation does not impose a level above which a course could not be considered remedial.
Thus, it is possible for a prerequisite course to be considered remedial in cases where the course could not otherwise be fitted into the student’s program. Note that this approach is meant to assist a student who could not graduate from his or her program without the course that required the prerequisite in question, and the prerequisite is not otherwise includable in the student’s program.
ED has given this response to schools asking for guidance and at some meetings for a couple of years now, but many schools remain unaware of this possible approach, or do not realize that the same course may be considered remedial for some students but a regular elective for others. This past fall, a number of financial aid administrators came together as a NASFAA Discussion Group chaired by Michael Bennett to address this issue, and were pleased to have this guidance confirmed. While the group continued to examine related issues since then, this particular scenario has an existing solution. The initial explanation of the issue giving rise to the discussion group appeared in a “Voices from the Aid Office” article authored by Michael Bennett.
Publication Date: 2/6/2017
You must be logged in to comment on this page.