Filed under Title IV Specific Policies

Unusual Enrollment History

With the introduction of a new Unusual Enrollment History Flag on ISIRs beginning with the 2013-14 award year, ABTU will be closely monitoring students with a “C” code on their ISIRs with a value of “2” or “3.” ABTU will strictly adhere to the guidelines established by the Department of Education to monitor these students.   The UEH Flag indicates whether the student has an unusual enrollment history with regard to the receipt of Federal Pell Grant funds and is intended to address possible fraud and abuse in the Title IV student aid programs.  The Department of Education has indicated that “the specific enrollment pattern we are concerned about is one where the student attends an institution long enough to receive Title IV credit balance funds, leaves without completing the enrollment period, enrolls at another institution, and repeats the pattern of remaining just long enough to collect another Title IV credit balance without having earned any academic credit.”

ABTU has established an admissions policy which is consistent with the above concern.  A portion of the admissions policy reads as follows: Qualified applicants at ABTU are ordinarily accepted only into a technical certificate program. Once students have proven their ability to successfully benefit from the educational opportunities at ABTU by completing the technical certificate program, they may be eligible to immediately transfer to an Associate’s Degree program. The technical certificate programs are comprised exclusively of the core courses required in the related associate’s degree program; therefore, a student would be enrolled in exactly the same classes regardless of their formal enrollment in the technical certificate program or the associate’s degree program.

A further portion of the admissions policy makes provision for students whose academic record contains no hint of the enrollment history concerns expressed by the Department of Education as indicated above. That policy follows: Entry directly into an associate’s degree program:  On occasion students in exceptional circumstances may appeal for entry directly into an associate’s degree program.  An email should be sent to financialaid@abtu.edu  to initiate the appeal process. Appeals are invited from students of any age who have never previously attended college, from students whose sponsoring agency requires enrollment in an associate’s degree program, and from highly qualified transfer students who provide official transcripts from ALL previous schools attended, demonstrating a GPA of 2.75 or better. Every student whose record reflects prior attendance in college must meet the above requirement to complete this appeal. If a student cannot or does not wish to provide these official academic transcripts, no appeal will be considered. ABTU will make use of all records, including VA-ONCE, NSLDS, and application materials, to make certain that students have accurately reported all previous schools attended. Falsification of this information on application materials is grounds for the denial of admission, or immediate dismissal. ABTU understands that many students take college classes when, for a variety of reasons, they are not fully prepared for or committed to the challenge of college work.   We welcome applications from students who have overcome these prior challenges and who now feel ready to engage in the kind of educational training offered at ABTU.

The admissions policy at ABTU typically means that either: 1) the student will demonstrate a commitment to their educational program (as opposed to the receipt of Title IV credit balance funds) by the completion of their 12-month technical certificate program, or 2) the student will successfully appeal entry into the associate’s degree program and provide appropriate evidence of no pattern of unusual enrollment history.

In either case, if a student enrolled in the associate’s degree program has an Unusual Enrollment History Flag “2” or “3” indicated on their ISIR, ABTU will proceed according to the required guidelines of the Department of Education. If the student is entering the associate’s degree program, they should not have received Pell funds at ABTU and therefore will be processed according the guidelines for Flag 3. Students already enrolled at ABTU and receiving Title IV funds would have their unusual enrollment history clarified according to the Department of Education’s procedures for Flag 2 or Flag 3. Students who have successfully appealed for entry directly into the associate’s degree program will likely have already provided the necessary information to satisfy the issues required to be addressed with Flag 3. Nevertheless, the student may be required to provide additional documentation or explanation as required by Department of Education guidelines, as a supplement to previously submitted materials. Students who have successfully completed the technical diploma at ABTU and who are transferring to the associate’s degree program will be required to meet all requirements to resolve unusual enrollment history issues as stipulated by the Department of Education guidelines.  However, very substantial weight will be given to the fact that the student has most recently demonstrated a commitment to their education (as opposed to the receipt of Title IV credit balance funds) by the successful completion of the technical diploma program without the benefit of Title IV funding.

The requirements of the Department of Education for resolving Unusual Enrollment History Flags 2 and 3 are summarized below:

 

Resolving Unusual Enrollment History Flags

An institution must take the following steps to resolve an ISIR-reported UEH Flag.

UEH Flag value is ‘N’: No action is necessary as the student’s enrollment pattern does not appear to be unusual.

UEH Flag value is ‘2’: The institution must review the student’s enrollment and financial aid records to determine if, during the three award year review period (Award Years 2010-2011, 2011-2012, and 2012-2013), the student received a Pell Grant at the institution that is performing the review.

  • If so, no additional action is required unless the institution has reason to believe that the student is one who remains enrolled just long enough to collect student aid funds. In this case, the institution must follow the guidance that is provided below for a UEH Flag of ‘3’.
  • If not, the institution must follow the guidance provided below for a UEH Flag of ‘3.’

UEH Flag value is ‘3’: The institution must review the student’s academic records to determine if the student received academic credit at the institutions the student attended during the three award year period (Award Years 2010-2011, 2011-2012, and 2012-2013). Using information from the National Student Loan Data System (NSLDS), the institution must identify the institutions where the student received Pell Grant funding over the past three award years (2010-2011, 2011-2012, and 2012-2013).

Based upon academic transcripts it may already possess, or by asking the student to provide academic transcripts or grade reports, the institution must determine, for each of the previously attended institutions, whether academic credit was earned during the award year in which the student received Pell Grant funds. Academic credit is considered to have been earned if the academic records show that the student completed any credit hours or clock hours.

  • Academic Credit Earned: If the institution determines that the student earned any academic credit at each of the previously attended institutions during the relevant award years, no further action is required unless the institution has other reasons to believe that the student is one who enrolls just to receive the credit balance. In such instances, the institution must require the student to provide additional information as discussed below under “Academic Credit Not Earned.” If it is determined that academic credit was not earned at one or more of the previously attended institutions, the institution must follow the “Academic Credit Not Earned” guidance below.
  • Academic Credit Not Earned: If the student did not earn academic credit at a previously attended institution and, if applicable, at the institution performing the review, the institution must obtain documentation from the student explaining why the student failed to earn academic credit. The institution must determine whether the documentation supports (1) the reasons given by the student for the student’s failure to earn academic credit; and (2) that the student did not enroll only to receive credit balance funds.
In some cases, the student may present personal reasons to explain the failure to earn academic credit. These reasons could include illness, a family emergency, a change in where the student is living, and military obligations. The institution should, to the extent possible, obtain third party documentation to support the student’s claim.
In other instances, the student may present academic reasons to explain the failure to earn academic credit. For example, the student might explain that the first enrollment was at an institution that presented unexpected academic challenges, or that the student determined, before completing any academic credit, that the academic program did not meet the student’s needs. Again, the institution should, to the extent possible, obtain third party documentation to support the student’s claim.
Much like the exercise of professional judgment, as provided by section 479A of the Higher Education Act (HEA), the financial aid administrator determines whether the circumstances of the failure of the student to receive academic credit, as evidenced by the student’s academic records and other documentation, support the continuation of title IV, HEA program assistance eligibility. Also, like professional judgment, these institutional determinations are final and not appealable to the Department, and the reasons for the decision must be documented and maintained for possible review.

 

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