DETERMINING ELIGIBILITY FOR CHILDREN OF FALLEN HEROES SCHOLARSHIP

The Children of Fallen Heroes Scholarship (CFH) is a new Federal Grant (Scholarship). It was established by Congress as part of the 2018 Omnibus Spending Bill passed last march. Beginning with the 2018-2019 award year, children whose parent or guardian died in the line of duty while serving as a public service officer are eligible for maximum Pell Grants, Direct Loans and Campus-Based funds based on a zero Expected Family Contribution. Schools are responsible for determining eligibility for CFH and documenting students’ eligibility.

According to a recent electronic announcement from Federal Student Aid, to qualify for CFH, there are several conditions that a student must meet.

First, a student must be Pell-eligible. In addition to having a Valid EFC between 0 and 5486, the student must meet all other eligibility requirements (i.e. resolved all C-Codes, completed Verification, etc.). CFH is only available to students who are 24 years old and under or enrolled at an institution of higher time of his or her parent’s or guardian’s death.

To determine if a student qualifies, it is important to understand what a public safety officer is. For purposes of the Children of Fallen Heroes Scholarship, a public safety officer is defined on one of two ways. Since this is a Federal Law, a public safety officer is primarily defined by Federal Statutes but the CFH rules include in its definition of a public safety officers certain state and local fire police.

The Federal definitions are found in section 1204 of title I of the Omnibus Crime Control and Safe Streets Act of 1968 (42 U.S.C. 3796b). It includes a variety of individuals serving public agencies in various capacities such as chaplains, firefighters and law enforcement officers, including unpaid volunteers such as volunteer firefighters (who aren’t compensated) as long as they are serving in an official capacity. Law enforcement officers can also be police, corrections, probation, parole, and judicial officers. Public Service Officers may also be members of certain public or non-profit rescue squads and ambulance crews that provide rescue services or emergency medical services as part of an emergency response system. Finally, Section 1204 includes in its definition of public safety officers, FEMA employees who performed duties hazardous duties related to a major disaster or emergency.

A state or local fire police officer, is defined for CFH purposes as an individual who is a fire police officer who was serving in accordance with State or local law as an officially recognized or designated member of a legally organized public safety agency and provides scene security or directs traffic in response to any fire drill, fire call, or other fire, rescue, or police emergency, or at a planned special event.

Recent guidance from FSA notes that a single, national data source of individuals who died in the line of duty while serving as a public safety officer doesn’t exist, so school Financial Aid offices will have to make a determination of eligibility on a case by case basis in conjunction with each student. Students who meet the criteria for CFH must provide supporting documentation to the Financial Aid Office in order to determine a student’s eligibility for CHF. The Financial Aid office must gather certain supporting documentation and maintain it on file as supporting documentation along with documentation of their eligibility determination. That documentation should include evidence that the student was less than 24 years of age or enrolled at an institution of higher education at the time of his or her parent’s or guardian’s death. FSA provided some examples of acceptable documentation that may be used to determine eligibility for this scholarship:

• 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 as defined above;
• 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 consistent with the definition in 42 U.S.C. 3796b, or as a fire police officer as noted above; or
• Other documentation the school determines to be from a credible source that describes or reports the circumstances of the death and the occupation of the parent or guardian.
• Institutions must maintain all evidentiary documentation related to the determination of the student’s eligibility for the Children of Fallen Heroes Scholarship.

Once a student’s eligibility has been determined a student will continue to be eligible in future award years, as long as the student remains Pell eligible and continues to be enrolled.

CHILDREN OF FALLEN HEROES SCHOLARSHIP ACT

The Consolidated Appropriations Act of 2018, which was signed into law last spring included a new federal grant program called the Children of Fallen Heroes Scholarship, or CFH for short. Although its name would lead you to believe otherwise, it’s not really a scholarship in the traditional sense and it’s not quite a grant either. The CFH Scholarship simply makes students eligible for full Pell grant awards, Direct Loans and Campus-Based funding by treating eligible students like zero EFC students.
Under CFH, a Pell-eligible student whose parent or guardian died in the line of duty while performing as a “public safety officer” is eligible to receive a maximum Pell Grant, beginning with the 2018-2019 award year. Students who qualify for CFH will also be awarded Direct Loans and Campus-Based programs based on a zero EFC. To accomplish this, Financial Aid Administrators will be required to determine and document a student’s eligibility and report information about each eligible student to Common Origination and Disbursement (COD) and Central Processing System (CPS).
COD system changes are scheduled for December 9, 2018 and will include the implementation of a new CFH indicator as part of the Pell award record which institutions will use to report eligible students. Unfortunately, eligibility information entered into the COD system will not be carried on the ISIR, nor visible in NSLDS. As a result, CPS will not recalculate a student’s EFC when an institution makes the determination that a student qualifies for a Children of Fallen Heroes Scholarship.
Additional system modification are reportedly in the works to add additional functionality to CPS which would allow schools to certify students’ eligibility on CPS. Look for more guidance from FSA next month about processing these awards.

IPEDS 2018-2019 WINTER SURVEY

The IPEDS Winter Data Collection for the 2018-2019 year opens on December 12, 2018. The deadline for the Winter IPEDS is February 13, 2019. The Winter Collection includes: Student Financial Aid, Graduation Rates, 200% Graduation Rates, Admissions, and Outcome Measures. To login to the 2018-2019 data collection system, please go to the following link: https://surveys.nces.ed.gov/ipeds/
All institutions that participate in the Title IV Federal Financial Assistance programs are required to complete all IPEDS surveys.

ACTIVE CONFIRMATION TG NUMBERS DUE DECEMBER 14

It’s time to review your school’s TG numbers again. Mark your calendars for December 14, this year’s TG deadline.

Every year, each school must review the services associated with each of its SAIG mailboxes (i.e. Destination Points and TG numbers) and Electronic Services accounts (it’s a two-step process) and validate that each user is still active and requires access. If not, their access should be adjusted or removed as needed. This annual process has come to be known as “Active Confirmation of TG numbers”. During the review process school administrators should be sure to remove access to any services or systems that a staff member no longer needs, for example when someone changes jobs and no longer needs access. School administrators must also be sure to delete any people who are no longer employed by the school from their list.

As in previous years, the Department of Education has announced that in an ongoing effort to ensure the security of Federal Student Aid’s data systems, they are continuing a process by which every school that is enrolled in the Student Aid Internet Gateway (SAIG) must review and validate its assigned TG numbers. After conducting the review, you will be required to provide active confirmation that all your staff members with TG numbers still need that access. This review and validation must be completed by December 14, 2018. Failure to complete this process may result in the loss of access to the Federal Student Aid data systems, including your ability to access NSLDS, COD CPS and even receive ISIR data.
To properly validate any TG numbers and FAA Access accounts associated with your institution, you must follow these steps:
• Go to the SAIG Enrollment Web site (https://fsawebenroll.ed.gov) and click the “Primary Destination Point Administrator Access” link.
• Once logged in you may “Validate Your Organization’s SAIG Mailboxes” by clicking the link and entering your institution’s Primary TG number.
• Then simply validate or delete the services you want associated with your TG.
• Then repeat this for each remaining TG number.
• Once all of the TG numbers have been removed from the list you’re done. Simple.
• The process for confirming or removing old users is easy too.
• To validate or delete electronic service users, click the “Manage Electronic Services” link and enter the TG number that is currently enrolled to send and receive CPS batch services for your organization.
• Next select “Validate Existing Users” to get a list of employees at your institution who are enrolled for FAA online access.
• Click either Validate or Delete. *Remember, you should delete old users’ access.
For more information check out the latest Electronic Announcement from Federal Student Aid here.

FAFSA QUESTION 23 DRUG CONVICTION WORKSHEET UPDATED

STUDENT AID ELIGIBILITY WORKSHEET FOR FAFSA QUESTION 23
Some of the ideas put forth for Reauthorization of the HEA, include eliminating the drug-related eligibility questions on the FAFSA. Presently, students who report on their FAFSA that they were convicted of possessing or selling illegal drugs must complete the Student Aid Eligibility Worksheet for Question 23 to determine if they are eligible for Federal Student Aid. The 2019-2020 Student Aid Eligibility Worksheet for FAFSA Question 23 can be found here.

DHS-SAVE SYSTEM IS BACK ONLINE FOR THIRD-STEP VERIFICATION REQUESTS

Earlier this year the new DHS SAVE system was taken off line temporarily due to system glitches causing errors and delays for school users trying to process third-step verification requests online. The SAVE system hierarchy issue returned a “No Record Found” error and has been resolved. Institutions may resume submitting third step verification requests to the SAVE system.

According to an electronic announcement from FSA, there remain a few circumstances under which the “No records found” error may continue to appear after entering the identifiers for students for whom the institution has received an ineligible second step response. FSA and DHS have identified the issue and expect to have it resolved in the next several weeks.

FSA says, if the “No records found” error message appear after entering the student’s DHS verification number correctly, the department has another workaround.

If the DHS Verification number was created more than 2 months ago, send the DHS verification number to applicationprocessingdivision@ed.gov and ask them to generate a new DHS Verification number or a successful secondary confirmation of the student’s status.

If this does not result in a successful confirmation, the institution should hold the record until the SAVE solution is implemented in the next several weeks. SAVE access will be available immediately for all records encountering the “No records found” error message once the SAVE solution is implemented. A subsequent Electronic Announcement will notify SAVE users of the change.

FSA announced several other changes to the DHS SAVE system too, including minor changes to the process PDPAs managing multiple Federal School Codes under a consolidated User ID will need to follow to add or delete users, and a procedure for users reopening closed cases. One of the major changes relates to “Parolee” or “Other” status responses.

According to FSA, for a student to be eligible for Title IV aid under a DHS “Parolee” status, financial aid administrators must collect the following immigration documentation: a document such as a Form I-94 showing the student’s unexpired Parolee status and a document providing evidence that the student is in the U.S. for other than a temporary purpose, which the student may provide on an I-797 Notice. In the past, the DHS paper Form G-845 response required a check mark in the box indicating that the student was paroled for at least one year. Instead, the SAVE system response screen will contain the message, “Application Pending I-485.” Form I-485 is an application for “Lawful Permanent Resident Status” and may be considered evidence that the student is in the U.S. for other than a temporary purpose. This comment must be present in the SAVE system for the student to be eligible for Title IV aid when designated by DHS as having Parolee status.

A SAVE response of “Other” indicates that the student is not eligible for Title IV aid. See the SAVE response comments box for details.

NEW NSLDS TRANSFER STUDENT MONITORING OPTIONS

Since students can’t receive Pell Grants for concurrent attendance at two or more schools, Financial Aid Administrators must be vigilant in monitoring transfer students for Potential Overawards of Pell (POP). Similarly, excess borrowing might occur if a school is unaware of loans a student received at another school. Transfer monitoring can help prevent these kinds of overpayments. Transfer Monitoring is a process through which schools send student information to NSLDS, so the schools can be notified of relevant changes to a student’s financial aid history and eligibility. If a student indicates they have attended or if, for example the FA office learns of a transfer from a student’s SAR or ISIR, the school should request transfer monitoring of the student on NSLDS.

On NSLDS the Transfer Student Monitoring School Transfer Profile displays information about the school for the Transfer Student Monitoring process.

Under new enhancements to the Transfer Student Monitoring Systems, school users can now elect to have students that have been submitted to NSLDS for TSM, FAH, or both added to their Enrollment Roster automatically. The Roster Options, found on the Organization Profile page of the ORG tab, display whether a school has selected to have students added to their Enrollment Roster via TSM, FAH, or both. Schools can select the eight-digit OPEID specific to the location associated with the user updating the Roster Options (TSM/FAH) or All Branches.

NSLDS UNVEILS NEW MAXIMUM ELIGIBILITY TIMELINE PAGE

Enhancements to the National Student Loan Data System known as NSLDS were implemented recently. These changes include the new Maximum Eligibility Timeline Page to help NSLDS Professional Access users understand when and why events such as Loss of Subsidy (LOS) or Reinstatement of Subsidy occurred. This page displays a chronological, full history of a student’s subsidized usage and enrollment under the 150% Direct Subsidized Loan Limit (SULA) and shows the Direct Subsidized Loan awards and school-certified program enrollment information that can be useful in determining the cause.

Other related enhancements were also added, including changes to the Program Enrollment Detail, and Subsidized Usage pages. Updates on the Transfer Student Monitoring (TSM)/Financial Aid History (FAH) process, new Loan Discharge Reason Codes, and a reminder about the availability of the updated Perkins DataPrep software and Perkins Data Provider Instructions are also provided. Check out NSLDS Newsletter 60 for information about these recent enhancements.