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(General) Subject: Operational Implementation of Increased Title IV Student Assistance to Children of Certain Deceased Members of the U.S. Military

Posted Date:November 6, 2009

Author: William Leith, Service Director, Program Management, Federal Student Aid

Subject: Operational Implementation of Increased Title IV Student Assistance to Children of Certain Deceased Members of the U.S. Military

The purpose of this announcement is to provide background information and operational guidance on the statutory provisions for increased Title IV student financial assistance for a student whose parent or guardian died as a result of military service in Iraq or Afghanistan after September 11, 2001.

BACKGROUND

Consistent with new provisions added to the Higher Education Act of 1965, as amended (the HEA), by the Higher Education Opportunity Act (HEOA), Public Law 110-315, under certain conditions an otherwise eligible student whose parent or guardian died as a result of U.S. military service in Iraq or Afghanistan after September 11, 2001, may receive increased amounts of Title IV student financial assistance. Such students are eligible for increased aid under these provisions if the student was 23 years of age or younger when the parent or guardian died or, if the student was over age 23, he or she was enrolled at an institution of higher education at the time of the parent or guardian’s death. As discussed below, beginning with the 2010-2011 Award Year this increased aid may include assistance from the new “Iraq and Afghanistan Service Grant” (IASG) Program.

To be eligible for increased Title IV aid under these provisions, the applicant must meet all Federal Pell Grant (Pell Grant) eligibility requirements, except for having a Pell-eligible Expected Family Contribution (EFC). These requirements include completing a Free Application for Federal Student Aid (FAFSA), not previously having received a bachelor’s degree (except for certain teacher certification candidates), and meeting all Title IV student eligibility requirements.

The types and amounts of increased assistance depend on the calculated EFC of the student and the award year for which the student is seeking assistance, as follows:

2009-2010 Award Year

Applicants with a Pell-Eligible EFC –

All Title IV aid that is awarded to an eligible student must be based on an EFC of zero without regard to the student’s calculated EFC. Thus the student is eligible for the maximum Pell Grant for his or her enrollment status and cost of attendance. In addition, the student’s eligibility for FFEL or Direct Loans and for Campus-Based Program aid must be based on an EFC of zero.

Applicants with an EFC that is not Pell-Eligible –

No increased amounts of Title IV aid for the 2009-2010 Award Year. All Title IV aid must be based on the calculated EFC.

2010-2011 Award Year and Beyond

Applicants with a Pell-Eligible EFC –

Same as for the 2009-2010 Award Year: All Title IV aid is to be awarded based on an EFC of zero, without regard to the student’s calculated EFC.

Applicants with an EFC that is not Pell-Eligible –

These students are eligible to receive an award under the new IASG Program, without regard to the calculated EFC. The amount of the IASG award is the same as the maximum Pell Grant for the award year, adjusted for the student’s enrollment status and cost of attendance. All other Title IV aid must be awarded based on the student’s calculated EFC.

OPERATIONAL GUIDANCE

Identifying Eligible Students for the 2009-2010 Award Year

In December 2009 or January 2010, we will begin receiving, on a monthly basis, a file from the Department of Defense (DoD) that contains the names of individuals who have lost a parent or guardian as a result of military service in Iraq or Afghanistan after September 11, 2001. We will match the identifiers of these individuals with 2009-2010 applicant records (FAFSA filers) in our Central Processing System (CPS) to identify students who may be eligible to receive increased aid under the new provisions of the HEA. When we find a match we will contact the financial aid administrator at all schools listed on the student’s FAFSA, first by phone and then with a follow-up e-mail.

As part of our contact with the school, we will provide the student’s identifying information as well as the parent or guardian’s date of death. If the student was over age 23 at the time of the parent or guardian’s death, the school can use the date of death when determining whether the student was enrolled at an institution of higher education at the time the parent or guardian died.

We will also send a personal letter to each student for whom a match is made that informs the student of his or her possible increase in eligibility for Title IV aid. The letter advises the student to contact his or her financial aid administrator for more information.

No Recalculation of EFC

It is important to note that the CPS will not recalculate a student’s EFC when the student’s CPS record matches the DoD file. In addition, a school should not make any changes to the student’s CPS record to adjust the EFC. Instead the school should award the student the types and amounts of Title IV aid based upon the discussion in the “Background” section above. See the following section for a description of the flags that must be set in the Common Origination and Disbursement (COD) System to support the increased aid amounts.

Origination and Disbursement of Maximum Pell for 2009-2010

To indicate that a student is eligible for increased aid under the new provisions and to allow the COD System to accept the increased award, a school must set the new “Post 9/11 Deceased Veteran Dependent Indicator” to ‘true’ using the COD Web site. As explained in a June 24, 2009 Electronic Announcement, several award-related pages on the COD Web site were updated on June 27, 2009 to include this new indicator.

If the indicator is marked as ‘true’, the COD System will edit the student’s Pell Grant award based upon the maximum Pell Grant Scheduled Award amount, regardless of the student’s calculated (but still Pell-eligible) EFC. If the indicator is not marked as ‘true’, the COD System will edit the Pell Grant award based upon the student’s Scheduled Award amount for the calculated EFC. For tracking purposes, we are asking schools to mark the indicator as ‘true’ for these students even if the calculated EFC is already zero.

For the 2009-2010 Award Year, setting the “Post 9/11 Deceased Veteran Dependent Indicator” is a Web-based process and can only be submitted using the COD Web site.

COD Warning Edit 168 (Post 9/11 Deceased Veteran Dependent Indicator is marked as ‘true’ on the COD System) will be returned to a school in a Common Record response when the indicator has a value of ‘true’.

The COD System will include the “Post 9/11 Deceased Veteran Dependent Indicator” in the student’s record sent to the National Student Loan Data System (NSLDS).

For a complete description of the COD System process for 2009-2010, refer to the June 24, 2009 Electronic Announcement and Volume II, Section 1 and Volume VI, Section 8 of the 2009-2010 COD Technical Reference.

Enhancements to the Student Identification Process for 2010-2011 and Beyond

Beginning with the 2010-2011 Award Year, we will implement an automated process for notifying schools when we match a CPS record with a record in the DoD file. We will do this by adding a new “DoD Match Flag” and comment to the Institutional Student Information Record (ISIR). The ISIR will also include the parent or guardian’s date of death. The new DoD Match Flag will print with the other ISIR match flag information and can be used by schools to identify affected students. The school will use the flag and date of the parent or guardian’s death, along with the student’s calculated EFC, to determine if the student is eligible for either a maximum Pell Grant award or an award under the IASG Program.

As in 2009-2010, we will also send a personal letter to each student for whom a match is made that informs the student of his or her possible increase in eligibility for Title IV aid. The letter advises the student to contact his or her financial aid administrator for more information.

Each time we receive a new file from the DoD we will check all records in the CPS for the active award year(s). If there is a match for a student who had previously applied for aid for the year but is newly added to the DoD file, we will system-generate a new CPS transaction for the student. The resulting ISIR will contain the new DoD match data to alert the school of the student’s potential increased eligibility.

Additional information about these enhancements for 2010-2011 is provided in the 2010-2011 Summary of Changes for the Application Processing System guide, posted in early November 2009 to the IFAP Web site.

Enhancements to the Origination and Disbursement Process for 2010-2011

Beginning in March 2010, the COD System will use the DoD match results from the student’s CPS record to populate the “Post 9/11 Deceased Veteran Dependent Indicator”, if the school includes the CPS transaction number containing the DoD match results when submitting the award. With this enhancement, the school will no longer set the indicator using the COD Web site.

Note: When submitting an increased Pell Grant award to the COD System for a student that meets this provision, schools must award using an ISIR transaction with the DoD Match Flag set to ‘Y’. Otherwise the award will not be accepted.

For 2010-2011, a value will always be displayed in the “Post 9/11 Deceased Veteran Dependent Indicator” field in the COD System. The field will never be blank on the COD Web site and will display as ‘yes’ if eligible, or ‘no’ if ineligible based on the student’s DoD match results.

COD Warning Edit 168 (Post 9/11 Deceased Veteran Dependent Indicator is marked as ‘true’ on the COD System) will be returned to a school in a Common Record response when the indicator has a value of ‘true’.

The COD System will include the “Post 9/11 Deceased Veteran Dependent Indicator” in the student’s record sent to NSLDS.

For a complete description of the COD System process for 2010-2011, refer to Volume II, Section 1 and Volume VI, Section 8 of the 2010-2011 COD Technical Reference that will posted in the near future.

Contact Information

If you have questions about the CPS/DoD match information in this announcement, contact CPS/SAIG Technical Support at 800/330-5947 (TDD/TTY 800/511-5806) or by e-mail at CPSSAIG@ed.gov.

If you have questions about the COD information in this announcement, contact the COD School Relations Center at 800/474-7268 for Grants or 800/848-0978 for Direct Loans. You may also e-mail CODSupport@acs-inc.com.