[Oasfaa] FW: [swasfaaL] Dept of Ed Update - R2T4, State Authorization, GE Training, Summer EFCs

[David Barron]

Here is some helpful information for those in OASFAA who may not be on the SWASFAA list serve.

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


-------------------------

Update provided by Dept of Ed Training Officer Dave Bartnicki

New R2T4 regulations 

One of the most asked questions in recent weeks has been, for my crossover summer payment period when do I have to implement the new rules around R2T4 (modules within terms and required to take attendance).  The answer can now be found in the Electronic Announcement dated May 6, 2011.  It states that the new R2T4 rules apply to students who withdraw from payment periods (terms) or periods of enrollment that BEGIN ON OR AFTER July 1, 2011.  The new rules do NOT apply to students who withdraw from a 2011 crossover payment period even if the student received Title IV, HEA program funds from the 2011-2012 award year for that crossover payment period.  

And remember, that if a school combines several modules/miniterms into one overall summer term that crosses over July 1, all of the modules are considered part of the one large crossover period and therefore, the new R2T4 rules would not apply to any of the modules that make up the overall summer crossover period - regardless of when the modules start and end.

State Authorization 

ED came out with a recently AMENDED DCL GEN-11-11 regarding State Authorization and distance education.  The amended version helps clarify a question many schools had regarding state authorization and distance education with regards to student "residency" or "location."  In the second paragraph (in red) ED changed the sentence that stated, "...does not have State authorization in the State in which the student resides" to, "...does not have State authorization in the State in which the student is located while receiving instruction."  Though it is a small change, these words can mean very different things and it is definitely something you want to be aware of when developing your policies around obtaining different State authorizations.

Gainful Employment Training

Schools have been calling me with numerous questions around GE programs.  I am pleased to announce that on May 25 and May 26 there will be a 90 minute Webinar hosted by FSA that will specifically talk about Gainful Employment programs.  It will discuss 3 main topics - GE program definitions, GE reporting requirements to ED and GE disclosure requirements to students.  Please see Dear Colleague Letter ANN-11-11 for specific times and registration requirements.  

Summer EFCs

I have also had several schools indicate that they are doing summer only packages (treating summer as a single loan period) and want to know how to properly determine an EFC for their summer term.  I just wanted to remind schools that we do not stipulate only one way to determine alternate EFCs for periods other than 9 months.  For a summer EFC, you could use a variety of methods as long as it is a reasonable approach to determine an appropriate EFC for the summer term.  Some common methods used to determine summer term EFCs include - subtracting the 9 month EFC from the 10, 11 or 12 month EFC (depends how long the summer is), dividing the 9 month EFC by 9 and then multiplying by the number of months in the summer term, or using the actual number of months EFC (2 month, 3 month, etc.) off of the ISIR.  And, of course, remember to consistently apply your policy.

2011-2012 Pell Funding availability

Finally, I have been getting asked a lot of questions about when 11/12 Pell funds will be available (especially due to crossover periods).  I am glad to report that 2011-2012 Pell funds are currently available for drawdown.    Remember, however, that 2011-2012 Federal Pell Grant funds are record driven meaning there is no initial Pell Grant authorization in G5.  11/12 Pell funding in G5 is directly tied to accepted and posted actual Pell disbursements in COD.  Please see the Electronic Announcement dated 2/11/11 for specific Pell funding issues in COD.