This announcement provides information to Title IV eligible schools on recent expansions to Veterans Affairs (VA) health care and other benefits for veterans who were exposed to toxic substances, and their effects on Title IV federal student aid. This expansion includes provisions which allow some survivors to be eligible for the Iraq and Afghanistan Service Grants (IASG) for 2023-24 award year. This announcement further explains the reporting and certification of eligibility for awarding IASG by institutions to dependent survivors of certain deceased veterans under this expansion.
This announcement also provides additional guidance for implementation of the Special Rule for Pell Grants (HEA Section 401(c)) beginning with the 2024-25 award year, which incorporates the programs formerly called IASG and “Children of Fallen Heroes (CFH) Scholarships”.
IASG Expansion for the 2023-24 Award Year
The “Sergeant First Class Heath Robinson Honoring our Promise to Address Comprehensive Toxics Act of 2022” or the “Honoring our PACT Act of 2022” (P.L. 117-168), commonly referred to as the PACT Act, expands VA health care and benefits for veterans exposed to burn pits, Agent Orange, and other toxic substances. The PACT Act adds to the list of health conditions that are assumed (or “presume”) are caused by exposure to these substances. Additionally, for the 2023-24 award year, the PACT Act may provide survivors of certain deceased veterans the ability to receive additional Title IV, HEA program funds in the form of additional funds from the Pell Grant or IASG programs. The expansion of IASG related to the PACT Act is only applicable for the 2023-24 award year due to changes made to the IASG program under the FAFSA® Simplification Act which become effective July 1, 2024 (explained further below).
The IASGs are made under the same terms and conditions as Pell Grants, and disbursements for each payment period are calculated in the same manner as described in Volume 7 of the Federal Student Aid Handbook. Before the expansion under the PACT Act, all eligible students eligible for an IASG would have the Department of Defense (DoD) Match Flag set to “yes” (“Y”) on the student’s Institutional Student Information Record (ISIR). The match flag is set to yes when the student matches with the DoD’s Defense Manpower Data Center (DMDC) database. When submitting an origination to the Common Origination and Disbursement (COD) system for additional Pell Grant funds or an IASG award, an institution must include the Central Processing System (CPS) transaction number containing the DoD Match Flag set to “Y” or the award will not be accepted.
Due to system limitations, the DoD DMDC database may not have an individual flagged in their records (i.e., DoD Match Flag set to no “N”) if the veteran’s death is related to expanded eligibility under the PACT Act because, for example, their determination may have occurred years after separation from military service. The PACT Act provides VA the authority to administer the new law and provide expanded care and benefits, but this does not include reporting to the DoD’s DMDC database. Therefore, affected individuals (and their survivors) must coordinate with the VA in addition to the institution’s financial aid office to determine and document eligibility and report and process additional Pell Grant or IASG eligibility to receive the grant.
Institutional Certification of IASG Eligibility/Award
Students who are survivors of a veteran who believe they would be eligible for IASG under the expansion of the PACT Act, should contact the VA for documentation to submit to the Financial Aid Administrator (FAA) at their school.
Once the FAA receives this documentation from the student, they should contact The Department of Education’s Federal Student Aid Office (FSA’s) Ombudsman to report a complaint that the lack of an indicator for eligibility for IASG on the students ISIR is inaccurate because the school has documentation from the VA that states the student is eligible and provide the VA documentation that meets IASG eligibility along with their report submission. Schools should be prepared to provide the following to the Ombudsman:
-
Students SSN
-
Student First Name
-
Student Middle Initial
-
Student Last Name
-
Student DOB
-
Parents Date of Death
Once the DoD database is updated to include the student, FSA will notify the school via the email contact provided to the Ombudsman that once the school receives the updated ISIR showing the Department of Defense (DoD) Match Flag set to “yes” (“Y”), that the school can move forward with originating and disbursing the otherwise determined eligible IASG. To note, reporting these students to the Ombudsman is limited to disbursement deadlines set for Title IV aid in general. Please see the disbursement deadlines provided in the June 23, 2023, Federal Register Notice.
2024-25 Award Year Implementation of the Special Rule for Pell Grants
On December 27, 2020, the FAFSA Simplification Act (“the Act”) was passed as part of the Consolidated Appropriations Act of 2021 and amended the Higher Education Act (HEA). The Act changed eligibility for what were formerly called “Iraq and Afghanistan Service Grants (IASG)” and “Children of Fallen Heroes (CFH) Scholarship” and removed instances of a separate IASG for students who met the IASG service eligibility requirements, but whom were not otherwise eligible for a Pell Grant. Beginning with the 2024-25 award year, students who meet the eligibility requirements for Pell Grants under the Special Rule in HEA Section 401(c), as amended, will receive maximum Pell Grant. To receive a maximum Pell Grant award based on eligibility under the Special Rule, a student must be:
-
The child of a parent or guardian who died in the line of duty while either (a) serving on active duty as a member of the U.S. Armed Forces on or after September 11, 2001; or (b) actively serving as and performing the duties of a public safety officer; and
-
Less than 33 years old as of the January 1 prior to the award year for which the applicant is applying (e.g., for the 2024–25 award year, a student must be less than 33 years old as of January 1, 2024, to be eligible).
In this situation, schools will award an eligible student a maximum Pell Grant award, regardless of student aid index (SAI). Other aid for these students will be based on their calculated SAI.
Identification of Eligibility
Because of the revisions under the Act, after the 2023–24 award year the Department of Defense will no longer provide confirmation that a service member killed in the line of duty meets the eligibility criteria. Further, no comprehensive federal database exists to effectively and efficiently identify public safety officers killed in the line of duty. Therefore, students will self-identify potential eligibility on the FAFSA form. The school will confirm eligibility by collecting supporting documentation from the student. Once you document and certify Special Rule eligibility for a maximum Pell Grant award, neither your school nor any other school is required to redetermine that student's eligibility for subsequent award years if the student continues to meet all other Pell Grant eligibility requirements and the age requirement for the Special Rule.
Acceptable Documentation
Acceptable documentation may include, but is not limited to, the following:
-
A copy of the servicemember’s DD Form 1300 (Report of Casualty) which documents death in the line of duty.
-
A copy of the servicemember’s DD Form 214 and death certificate, documenting that the date and cause of death occurred during and as a result of active duty.
-
A Department of Veterans Affairs Death Narrative Document.
-
A determination letter acknowledging eligibility for certain federal benefits under the Public Safety Officers Benefit (PSOB) program administered by the Department of Justice.
-
A written letter of attestation or determination made by a state or local government official with supervisory or other relevant oversight authority of an individual who died in the line of duty while serving as a public safety officer.
-
Documentation of the student qualifying for a state tuition or other state benefit accorded to the children or other family members of a public safety officer.
-
Other documentation the school determines to be from a credible source that describes or reports the circumstances of the death and the eligible occupation of the parent or guardian.
Legacy IASG and CFH Eligibility
Students who were eligible for and received IASG funds OR received Pell Grant funds based on IASG or CFH eligibility criteria for the 2023-24 award year but are not eligible for Pell Grant funds under the Special Rule beginning with the 2024–25 award year are eligible to receive Pell Grant funds based on prior IASG or CFH eligibility criteria. This includes students certified as eligible under the expanded eligibility due the PACT Act. Students remain eligible if they received at least one disbursement of funds from the IASG or CFH programs during the 2023-24 award year and continue to meet the age requirement for the Special Rule. Students who receive a maximum Pell Grant based on legacy IASG or CFH guidance continue to be eligible if the student received at least one disbursement of funds based on the grandfathered eligibility in each subsequent award year. If there is a break in disbursement of one award year, then the student must qualify under the Special Rule in HEA Section 401(c), as amended.
Note: Under the Special Rule for Pell Grants, the student’s parent or guardian must have died while serving in the line of duty. A student whose parent or guardian died due to a service-related injury or illness but was not serving on active duty at the time of the death is not eligible for maximum Pell Grant consideration under the Special Rule but may be eligible for legacy eligibility if they received an IASG or additional Pell Grant award in the 2023-24 award year.
Additional Information
We encourage institutions to coordinate with their students and on-campus veteran support services to reach their student population and inform students of this important additional benefit for eligible survivors.
For additional information and guidance on Pell Grant, IASG, and CFH awarding, see Volume 7 of the Federal Student Aid Handbook.
Contact Information
You may refer additional questions to the Department using the Contact Customer Support form in FSA’s Partner Connect Help Center. To submit a question, please enter your name, email address, topic, and question. When submitting a question related to this Electronic Announcement, please select the topic “Policy Guidance.”