[Oasfaa] Bartnicki Bulletin - ACG/SMART, SAP, Prior Year Charges, Training

[David Barron]

Happy New Year everyone.
I wanted to pass along some good information that the Federal Trainer, David Bartnicki, sent to SASFAA.
Please review below and I hope it is helpful.

Thanks and have a great day,

David Barron
OASFAA President 2010-2011
Executive Director of Enrollment Management
Rogers State University
1701 W. Will Rogers Blvd.
Claremore, OK 74107-3252
918.343.7852
Fax: 918.343.7598


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Dear SASFAA,

Hope everyone had a great holiday because we now have to get to work (though some of you appear to have worked right through the holidays).
We had tons of snow up north and now we have snow and ice in Atlanta - I think it followed us home.

Just a couple of insights into some key areas:

ACG/SMART Crossover Period

As you know, 10/11 is the last year for ACG/SMART.  With that said, a lot of schools have been asking about ACG/SMART eligibility for the summer crossover period.  A student can receive ACG/SMART as long as the Pell received for the crossover period comes from 10/11.  If the Pell received comes from 11/12, the student will not be eligible for ACG/SMART since there is no ACG/SMART funds for 11/12. The regulations actually say that when a payment period occurs in 2 award years the ACG/SMART must come from the award year in which Pell was paid
from(691.64(a)(6)).   This can become an issue when comparing ISIRs from
both award years to determine which year will pay the higher dollar amount for Pell.

New SAP regulations (effective 7/1/11)

If using a "financial aid warning" period and/or "probationary" periods, the school must use ED's naming convention for these periods.

Prior Year Charges and Crossover Periods

When evaluating prior year charges you must do so by payment period.
Within a payment period you must first ask yourself if there is a Direct Loan or not. If there is a DL, then the prior year is considered any prior loan periods.  This definition is for all TIV aid in the payment period - both loan and non-loan aid.  If there is no DL, then the prior year is considered an award year.  Therefore, costs for the current year are defined as charges for education and services the institution will provide during (1) the current loan period for which the institution originates a Direct Loan, or (2) the current award year if there is no Direct Loan. (GEN-09-11)
 
So what does this mean if you have a summer crossover period?  If the summer crossover has a DL, then any charges assessed prior to the current loan period is considered prior year charges for all TIV aid awarded in the current loan period.  For example, if summer is a single term loan period, then any charges from spring would be considered prior year charges for any TIV aid received in the summer (regardless of what award year it may be considered part of).  If, however, the loan period was Fall, Spring, and Summer terms, then charges assessed in the Spring would not be considered prior year charges for any TIV aid received in the summer since they would be charges assessed during the current loan period.
 
However, if the summer crossover had no DL, then the prior year is considered a prior award year.  You would have to evaluate which award year TIV aid is considered part of.  For example, if Campus-Based aid was awarded and considered part of the current award year (10/11) then charges assessed in the spring would not be considered prior year charges for the Campus-Based aid.  However, if Pell was considered part of 11/12 (due to the ISIR comparison requirement), then charges assessed in the spring would be considered prior year charges for Pell purposes.
 
Again, the first key evaluation is to determine what is the prior year (loan period or award year) and then, if an award year, what award year is the aid assigned to.
 
As an aside, please note that any aid awarded for a payment period can be used to cover any charges for THAT payment period regardless of what award year it may be assigned to.

Training

The Department is planning to conduct stand-up training in the near future.  The training will provide insight into the new regulations, along with other timely and important topics (Pell Grants, Direct Loans, etc.).  Stay tuned for an announcement with locations and dates through IFAP.

Okay back to shoveling snow,

David Bartnicki
Federal Training Officer
ED/FSA/Atlanta
 



  


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