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(Grants) Subject: Guidance on the Pell Grant Lifetime Eligibility Used Dispute Escalation Process (Updated April 18, 2014)

Posted Date:June 27, 2013

Author: Sue O'Flaherty, Service Director, Program Management, Federal Student Aid

Subject: Guidance on the Pell Grant Lifetime Eligibility Used Dispute Escalation Process (Updated April 18, 2014)

Note: On April 18, 2014, we removed the attachment to this announcement due to a change in how schools initiate a Pell Grant Lifetime Eligibility Used (LEU) dispute escalation on behalf of a student. The circumstances outlined below in which a Pell Grant LEU dispute will be considered by the Department of Education have not been altered. For updated information on how to initiate a Pell Grant LEU dispute escalation on behalf of a student, refer to the April 18, 2014 Electronic Announcement available at

As explained in Dear Colleague Letter (DCL) GEN-13-14 posted on the Information for Financial Aid Professionals (IFAP) Web site on May 16, 2013, one of the changes made by the Consolidated Appropriations Act, 2012 is a provision that limits the duration of a student's eligibility to receive a Federal Pell Grant (Pell Grant) to the equivalent of six years. This provision, effective with the 2012-2013 Award Year, applies to all Federal Pell Grant eligible students.

In earlier communications, including a February 17, 2012 Electronic Announcement and DCL GEN-13-14, we explained how we calculate a student's Pell Grant Lifetime Eligibility Used (LEU) by adding together each of the annual percentages of a student's Pell Grant Scheduled Award actually disbursed to the student. The six year limit is translated to a 600% LEU limit.

In this announcement, we provide guidance regarding the process a school may take to dispute a student's Federal Pell Grant LEU, as reported in the Common Origination and Disbursement (COD) System.

As a reminder, the reporting timeframe for disbursements that occur on or after April 1, 2013 has been changed from 30 days to 15 days. To ensure the most accurate information about each student's Pell Grant LEU, we urge schools to report Pell Grant disbursements and adjustments within the new 15 day requirement. Please reference Federal Register notice published February 28, 2013 and the August 13, 2012 Electronic Announcement for more information on the importance of timely reporting.

Dispute Escalation Process

In some cases, a school or student may dispute the accuracy of the student's COD Pell Grant information that resulted in the reported LEU. To address these cases, we have developed a dispute escalation process to allow a school to submit information to the Department of Education (the Department) for an evaluation of a student's Pell Grant LEU. Note: Because a school has NSLDS and COD access to its students' historical Pell Grant data, including information on Pell Grant funds received by the student for attendance at other schools, the student's current school is expected to coordinate with other schools, if applicable, about the Pell Grant LEU dispute.

In an attachment to this announcement, we provide detailed information about the steps to be taken by the student, the school(s), and the Department when there is a Pell Grant LEU dispute.

Note: If resolution of the disputed Pell Grant amount would not reduce the student's LEU to be less than 600%, the school should not escalate the matter. For example, if a student's Pell Grant LEU is 850% and she is disputing one award year's eligibility used of 100%, the school should explain to the student that even if the disputed amount is resolved in the student's favor, she would remain ineligible for additional Pell Grant funding because her adjusted Pell Grant LEU of 750% would still be over the 600% statutory limit.

Contact Information

If you have questions regarding the information included in this announcement, contact the COD School Relations Center at 800/474-7268. You may also e-mail

Last Modified: 06/26/2013