Request to Identify Burdensome Regulations: Pell Grants And Campus-Based Aid Programs

By Joan Berkes, Policy & Federal Relations Staff

As noted previously in Today's News, NASFAA is seeking help from members to identify regulations that should be recommended to the Department of Education (ED) as in need of repeal, replacement, or modification. The initial article in this series explained the basis of this solicitation and requested input on verification. The second article sought opinions on rules related to the return of Title IV funds for withdrawn students, and on the Direct Loan Program. Today we seek member thoughts on regulations governing the Pell Grant and campus-based programs, and issues related to non-traditional program formats.

Please give your recommendations either as a comment to this article, or in an email to, using the subject line "Regulatory Reform."

When submitting your recommendations, you may want to consider the following:

Many provisions related to Title IV administration are statutory in nature; regulations cannot alter law. This solicitation focuses on what can be accomplished solely through regulatory changes. (Efforts to amend the law are encompassed by NASFAA's reauthorization initiatives.) However, regulations represent ED's interpretations of statute and impose other requirements it deems necessary to implement the Title IV programs. For example, the law requires that an institution's procedures for selecting recipients are designed to award Federal Supplemental Educational Opportunity Grants (FSEOG) "first, to students with exceptional need" and to give "a priority… to students who receive Pell Grants." The law defines "students with exceptional need" to mean "students with the lowest expected family contributions at the institution." The requirement to award FSEOG in lowest Expected Family Contribution (EFC) order, rather than establishing an EFC cut-off, is ED's interpretation of the law.

In the Federal Work-Study (FWS) Program, the requirement to expend funds on tutoring and community service is set in law, as is the definition of community service. ED interprets the definition of community itself and establishes policies refining the allowable nature of FWS-eligible employment. In the Pell Grant Program, limitations on lifetime eligibility are set in law, as are the factors that lead to construction of the payment and disbursement tables. Regulations establish the formulas for calculating payments and payment periods within an award year. Recalculation requirements (including the ability to set census dates) are regulatory issues.

Most of the regulations governing the Title IV programs evolved at a time when academic program formats were traditionally standard. With changes in technology, institutional mission, and workforce needs, formats for offering education have expanded ever more into nontraditional modes. Complying with tradition-oriented regulations can be akin to forcing square pegs into round holes. If your school offers nontraditional program formats, what regulatory requirements do you find inhibit innovation?

Thank you for continuing to submit your suggestions on these and other topical areas.


Publication Date: 8/4/2017

Aaron R | 8/7/2017 2:35:17 PM

No scaling for Pell, you either qualify for the whole amount or none of it. No return calculations for "loan only" students, they borrow it, they can pay it back. Just return unearned Pell. Dependent students should be entitled to independent grade level limits.

Christina G | 8/7/2017 1:21:44 PM

The FWS community service requirement, especially the reading tutor requirement, is very burdensome. We already have ample (paid) community service programs available on our campus. I also agree that the Pell EFC maximum needs to increase.

Ashlee D | 8/4/2017 3:46:28 PM

Two Things in Particular:
1. PWDs are a waste of time and money. Students who drop all their classes before the census date should not be entitled to any funds. It's a waste of money to pay students who do not officially take a class or get a grade and don't even have tuition charges for anything because they dropped in time. We are just giving federal funds to students to pocket with no academic history to show for it. Not to mention the time it takes for FAAs to calculate them all.

2. I would like to see more funding opportunities for mid-range EFC students. Low EFC students get plenty of help, but those just out Pell Grant range, like 5329 - 10000 seem almost more needy than others because they don't get Pell and still don't have enough familial contributions to help pay for school. These students are also ones that end up with large loan debt in the end which is a burden.

Lisa P | 8/4/2017 11:11:15 AM

There are far too many EFC ranges for Pell. It should be reduced by at least half. For example, instead of EFC 1-100, the range should be 1-1000 with a full time Pell of $5470. Also maybe combining 3/4 & full time into one group (A) and LTHT & 1/2 time group together (B). Very difficult to administer from all aspects.
I also agree w the PPY comment. Repeal it. Very confusing for students & families & MANY Special Circumstances Appeals for reduction of income.

Raymond G | 8/4/2017 10:44:35 AM

Trimester schools who already pay Pell year round should be excluded from the Year Round Pell requirements. The only students that are eligible are transfer students that do not meet the definition of a regular student as stated in the FSA Handbook . They come and take summer classes then leave the following term, taking up class seats others could have used and lowering our completion rates. Their intent was not to complete a degree thus they are not be eligible for aid. And any loans they take out while attending the summer term, if they should default would hurt our default rate. Which I have found to be the case especially with summer only transfers from large universities to our community college.

DJ V | 8/4/2017 10:23:58 AM

Repeal PPY. It is not an accurate measure nor a "snapshot" of the family's financial strength. People who choose to file their taxes late should prepare for and accept the consequences of potentially having their FAFSA approved late. If they have a problem with that, they should do what is necessary to get their taxes filed earlier.

Eric A | 8/4/2017 10:17:21 AM

This comment belongs with the previous request about Direct Loans. We'd love to see the regulation changes that increases the amount of loans from year to year based on grade level. Instead, having one set amount in place each year would reduce considerable burden, as more and more, students change grade levels mid year when they start college with credits in place. Thus, rather than going from $5500 to $6500 as a dependent freshmen to sophomore, it would be great to give a student $7000 per year (or whatever amount), no matter their grade level.

Marguerite J | 8/4/2017 8:43:11 AM

SEOG should be a true block grant where the school (who is best fit to determine need) can award it to students who show greater need as a result of not being Pell eligible. ex: at our school, we award only to zero efcs. what of the student who has an efc of 50? is this student truly less needy?

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