Topic Number2.3.1(a)Effective Date

March 26, 2003

January 18, 2017 (rev)

May 22, 2017 (rev)

August 23, 2017 (rev)

May 1, 2018 (rev)

August 21, 2018 (rev)

ProcedureTitle IV Student Financial Aid Eligibility & Coordination of Services
Purpose
  • To document protocols for the determination of Title IV Student Financial Aid Eligibility under the Higher Education Act of 1965, as amended, and for the coordination of services applied to students without a valid High School Diploma or its recognized equivalent
  • To document internal standards for the processing, storage, and disposal of FAFSA applications and PELL Grant Records that provide safeguards and protection of personally identifiable information in client records.
Accountability Indicators
  • There is evidence of efficient and effective management of WWRC’s Title IV Student Financial Aid Eligibility business processes that are operated in compliance with federal laws and regulations governing access to federal financial aid.
  • There is evidence of proper safeguards in the processing, storage, and disposal of FAFSA applications and PELL Grant Records, with no audit findings relative to security breaches. 
Policy Reference

WWRC Policy 3.3.1:  Title IV Student Financial Aid Eligibility

Detailed Governance ReferenceN/A
Executive Staff Contact  James Hall, Division Director, Career and Workforce Development

 

 Every Day in Every Way We…..  

Put Clients First

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Provide It All Under One Roof

Are Organized, Utilized, and Valuable

Preserve Leadership Ethics, Accountability, Center Values, and Public Trust 

 

Definitions 

  • Ability to Benefit (ATB) Provisions:  Alternate path to eligibility for federal financial aid that enables a person without a high school diploma or its recognized equivalent to qualify for Title IV PELL grants, Federal work study, and federal student loans (NOTE:  WWRC only participates in the Title IV PELL Grant Program)
  • Eligible Career Pathway Program:  Program that combines rigorous and high quality education, testing, and other services that meet Title IV statutory requirements
  • Qualification:  The process through which educational requirements for federal student aid eligibility are validated and verified
  • Qualifying Exams:  a listing of USDOE-approved Ability to Benefit Tests 


Governance Procedures

WWRC is a recognized Institution of Higher Education under the Higher Education Act of 1965, as amended, and as such, is eligible to participate in federal student financial assistance programs under a written Program Participation Agreement (PPA) that serves as a contract between WWRC and the United States Department of Education (USDOE).  A designated position within the WWRC Vocational Training Department is accountable for maintaining the WWRC/USDOE PPA in compliance with stated standards and expectations.  

To be eligible for federal student aid through the need-based Title IV PELL Grant Program, a WWRC client must be financially eligible, meet educational qualifications (directly or through Ability to Benefit Provisions), and be enrolled in an USDOE-approved training program as documented in the written PPA.  Financial eligibility is determined annually through submission of the Federal Application for Financial Student Aid (FAFSA).  

It is WWRC's intent to comply with the Higher Education Act of 1965, as amended, and with the corresponding Consolidation Appropriations Act of 2016 (P.L. 114-113) which further amended the most recent HEA changes in the determination of federal student aid eligibility for students fully enrolled in USDOE-approved training programs.  This set of governance procedures documents roles and responsibilities as well as business processes for determining eligibility and for related coordination of services.   This set of governance procedures further defines standards for the processing, storage, and disposal of FAFSA Applications and PELL Grant files that provide safeguards and protection of personally identifiable information in client records.

Educational Qualification 

A WWRC client enrolled in an USDOE-approved training program is qualified as meeting educational requirements under the HEA, as amended, if there is documented validation of one of the following:

  • High school diploma

Students enrolled in Virginia public school systems may earn one of many types of high school diplomas:   advanced; standard; modified standard; and, applied studies.  For purposes of meeting educational qualifications for participation in the PELL Grant Program under the Higher Education Act, a student must have earned an advanced or standard diploma to meet the federal requirement. 

Verification of an approved high school diploma type may be documented by the Rehabilitation Counselor in AWARE or provided as part of the WWRC Admissions application package.  If not available at time of admission, a designated WWRC staff member will contact the local school division to request an official transcript.  Business processes will be defined later in this governance procedure.

  • Recognized equivalent or a high school diploma

Virginia recognizes successful completion of the General Educational Development (GED) Program and full GED attainment as the equivalent of a high school diploma. 

Verification of GED attainment may be documented by the Rehabilitation Counselor in AWARE or provided as part of the WWRC Admissions application package.  WWRC's Vocational Training Department offers GED preparation and testing through its Education & Workforce Supports Unit for those who require this service. 

 

  • Completion of an approved secondary school curriculum in a home schooled setting as defined by state law

According to the 2017 Guidelines for Home Instruction in Virginia, published by the Virginia Department of Education, Office of Policy, "Neither the Department nor public school divisions maintain any academic records, such as transcripts or diploma status, for students who have been home schooled. Thus, the Department cannot verify a home schooled student's high school graduation status for military recruiters, colleges, universities, technical schools, employers, or any other entity. With the parent's permission or the student's permission if the student has reached the age of 18, organizations or individuals may contact the relevant local school division for information as to whether the student completed the home instruction process."

Completion of an approved secondary education curriculum in a home schooled setting may be documented through either: (1) certification of a passing score on a state-authorized equivalent of a high school diploma (2) a signed letter from the parent who was approved by the Virginia Department of Education to provide home schooled instruction stating that the student successfully completed an approved secondary education program of studies, with a transcript listing secondary education courses completed; or (3) a letter from the local school division the student would have attended that states the student completed the home instruction process.

OR

  • Meet Ability to Benefit (ATB) Provisions

In order to gain eligibility through ATB Provisions, a WWRC student must pass an independently administered exam approved by the U.S. Department of Education.   WWRC is an approved College Board Test Administration Site for ACCUPLACER, one of the currently USDOE- approved exams.

Approved ATB Tests.png

If the student who is otherwise qualified for participation in the PELL Grant Program does not pass the ACCUPLACER exam, s/he must be dually enrolled in an eligible career pathway program and a GED preparation program.  Once the student attains a GED, Title IV PELL grant program participation restrictions are removed, including the requirement to be enrolled in an eligible career pathway program (assuming the student meets financial eligibility through the FAFSA submission and is enrolled in an USDOE-approved training program). 

 

Career Pathways Program Basis of Determination

  • Dual Statutory Requirements

 

    • Title IV Eligible Postsecondary Program Component (34 CFR 668.8)

P.L. 114-113 amended the definition of an eligible career pathway program for purposes of Title IV aid eligibility under the HEA section 484(d)(2) to align with the Workforce Innovation and Opportunity Act {WIOA - 29 U.S.C. 3102(7)}.  An eligible career pathway program combines rigorous and high quality education, training, and other services that:

      • aligns with skill needs of industry in state/regional economy
      • prepares an individual to be successful in a full range of secondary/postsecondary options
      • includes counseling to support the individual
      • includes education offered concurrently with and in the same context as workforce preparation activities and training
      • organizes education, training, and other services
      • enables an individual to attain a high school diploma or its recognized equivalent and  at least 1 postsecondary credential
        AND
      • helps an individual enter or advance within a specific occupation or occupational cluster

 

    • GED Preparation Component 

 

The Career Pathways Program basis requires dual enrollment in a GED preparation program.  The GED preparation program component may not be paid for using Title IV aid and should not be incorporated into a student's Title IV enrollment status or Title IV cost of attendance as defined in section 472 of the HEA.   

 

  • Eligible Career Pathway Program Determination

An attachment to the GEN-16-09 USDOE Dear Colleague Letter states that each institution of higher education must make its own determination of whether a program is an eligible career pathway program based on statutory definition in section 484(d)(2) of the HEA and as described in the GEN-16-09 Dear Colleague Letter. 

 

  • Documentation Requirements
    • Program Level:  Institutions of higher education are required to document their basis for eligible career pathway program determination which must include documentation that the program includes workforce preparation activities and training for a specific occupation or occupational cluster and is aligned with skills needs of the State or regional economy. 
    • Student Level:  For each student who received Title IV aid for enrollment in an eligible career pathway program by successfully completing one of the ATB alternative paths, the institution of higher education must document: (1) evidence that the student passed an approved ATB test (ATB alternate path #1) OR (2) evidence that the student met dual statutory requirements and attained a GED (ATB alternate path #2).  

 

Standards for the Processing of FAFSA Applications and PELL Grant Records

 

FAFSA Applications and PELL Grant Records contain personally identifiable information.   The WWRC Admissions and Records Management Services Departments have established joint internal standards for the processing, storage, and disposal of these documents that protect client information and provide adequate safeguards against potential security breaches.   Specifically:

 

  • Active, working files that are in current processing status shall be secured when not in use through a locked drawer or file cabinet in the office of the designated Student Financial Representative.
  • FAFSA Applications and records shall be scanned to DocFinity once the PELL file has reached closure status such as:
    • PELL approved and training program completed and paid in full (Comparable Benefits Letter with PELL award amount will be the last step and is what triggers closing the PELL file)
    • PELL approved but client discharged before finishing program
    • PELL applications that were entered into the PELL system but denied because of over income or other issues such as another PELL grant on file, default of a federal student loan etc. 

Incomplete PELL records that could not be processed due to parental non-response shall be sent to the shred box when the client graduates or is otherwise discharged.

 

 Roles and Responsibilities

 

WWRC's Vocational Training and Admissions Departments share primary accountability for the implementation of this set of governance procedures in accordance with federal laws, regulations, and guidance.  The WWRC Records Management Services Department scans the FAFSA application and PELL file contents into DocFinity as provided by the WWRC Admissions Department. The WWRC Business Office disburses funds, as authorized, and the OD&QA Division provides system QA checks, as indicated.   Effective communication is essential to ensure timely and responsive application of policy and procedures.

 

WWRC Admissions Department

 

  • Identify WWRC applicants to be enrolled in an USDOE-approved training program who may be potentially eligible for federal student financial aid.
  • If the application package does not include verification of required educational qualifications to access federal financial aid, notify the Vocational Training Department Education & Workforce Supports Supervisor to document verified educational qualifications and/or to schedule ability-to-benefit (ATB) testing, as indicated.
  • Schedule and meet with fully enrolled WWRC vocational training students who may be potentially eligible for federal student financial aid to complete the FAFSA application. Contact the Vocational Training Department Education & Workforce Supports Supervisor if there are questions about verification of educational qualifications. 
  • When a PELL award is granted, update the AWARE client financial profile with PELL as the funding source, using the following information:
  • Payor: Other 
  • Plan: OTHXB - OTH-BOTH  
  • Name: PELL GRANT
  • Address:   PELL GRANT

                         DEPT OF EDUCATION

                         PELL GRANT AWARD

                         WASHINGTON DC 20024

  • When a fully enrolled vocational training student completes a minimum of 450 clock hours, or after fifteen (15) weeks of training, request disbursement of half of the Title IV federal aid allocation through the WWRC Business Office (requests are batched for quarterly processing).   Request disbursement of the final half immediately following graduation from the approved training program (processed to the Business Office quarterly).
  • Notify the referral source when Title IV PELL Grant funding is received, including the name of the client, assigned training program, and award amount to facilitate documentation of Coordination of Benefits.   

 

WWRC Vocational Training Department

 

  • Administer the written Program Participation Agreement (PPA) serving as a written contract between WWRC and the USDOE for participation in Title IV federal student financial assistance programs.  At least annually, and more frequently if changes occur, notify the WWRC Admissions Department of USDOE-approved training programs that meet Title IV PELL Grant Funding requirements.  Indicate this distinction on the WWRC website, as part of the description for each approved training program. 
  • Maintain current documentation of each eligible career pathway training program that meets ATB Provision requirements delineated in this governance procedure.   Indicate this distinction on the WWRC website, as part of the description of each eligible training program. 
  • Document validated proof of meeting educational qualifications for Title IV federal student financial aid for identified students referred through the WWRC Admissions Department.  Scan the validated proof into DocFinity and notify the WWRC Admissions Department Student Financial Representative.
    • Submit requests to local school divisions, as indicated, for verification of high school graduation, with signed release of information forms – if the school division participates in the Parchment online access program, submit Parchment request for verification of high school graduation.  Include cost of Parchment processing in client charges as part of the total cost of attendance. 
    • For home schooled youth, request a signed letter from the parent, with required documentation or from the local school division the student would have attended, in accordance with this governance procedure.
    • For identified students who do not possess a valid high school diploma or recognized equivalent, administer an USDOE-approved ATB exam.   Document proof of passing scores for ease of retrieval. Include cost of the ATB exam in client charges as part of the total cost of attendance. 
    • For identified students who do not pass an USDOE-approved ATB exam and who are enrolled in an eligible career pathway training program within the WWRC Vocational Training Department, enroll the student in a GED preparation course of studies.
  • Maintain GED preparation progress records for each student who received Title IV aid for enrollment in an eligible career pathway training program and document GED passing scores when attained for ease of retrieval.
  • Notify the WWRC Admissions Department Student Financial Representative when educational qualifications are fully met for Title IV federal student financial aid. 

 

WWRC Records Management Services (RMS) Department 

 

  • Scan the FAFSA application and PELL file contents into DocFinity as provided by the WWRC Admissions Department.
  • Facilitate access to client records, as needed, in response to any internal or external audit of PELL grant processes, per internal RMS procedures and in accordance with federal and state policies.

 

WWRC Business Department

  • Process disbursement of Title IV federal student financial aid through established protocol. 
  • Maintain records of award levels by quarter and annually, for ease of retrieval and required reporting. 

 

WWRC Organizational Development & Quality Assurance (OD&QA) Division

  • Facilitate timely updates to the WWRC website, by training program, as indicated under this governance protocol.
  • As requested by the CWDD Director, conduct periodic audits of WWRC's compliance with Title IV Student Financial Aid Eligibility business processes, as defined under federal law and regulatory guidance and documented in WWRC's governing policies and procedures.