Can We Pay Pell If the Student Shows No Enrollment On the Pell Recalculation Date But Later Enrolls In Classes?

Scenario: The school has a single Pell Recalculation Date (PRD or census date). The student enrolls in classes after the PRD has passed.

Answer: It depends upon when the initial Federal Pell Grant calculation was performed for the student for the award year/payment period in question.

Initial Pell Calculation Performed After the PRD: If the initial Pell calculation was not performed until after the PRD, you use the enrollment intensity from the initial Pell calculation without regard to the PRD. For example, the student enrolls in 10 credits after the PRD. The school then receives the student's ISIR and performs the initial Pell calculation for the student. The Pell is awarded and paid based on an enrollment intensity of ten divided by twelve (10/12 or 83%). If this same student later adds more credits or drops credits, you do not adjust the Pell Grant.

Initial Pell Calculation Performed Before the PRD: If the initial Pell calculation was performed before the PRD, the answer is different. Based on guidance NASFAA has received from the U.S. Department of Education (ED), if an institution’s PRD occurs on a date when a student is not enrolled in any classes, that PRD does not apply for that student. According to ED, there is no Pell enrollment status of “zero enrollment" or "no enrollment.” The PRD is not intended to “zero out” a student’s Pell Grant in a case where the student has already had an initial Pell calculation performed but does not enroll until later in the payment period (e.g., in a second module). When the student does not enroll until later in the payment period after the PRD, he or she may be paid based on the initial Pell calculation, assuming the student begins all classes on which that enrollment intensity was based.

For example, the school originally packaged the student's full-time Pell Grant for the fall and spring terms before the award year began--that was the student's initial Pell calculation for both the fall and spring terms. The school has one PRD/census date per term. The student enrolled and received a full-time Pell Grant for the fall term. For the spring term, the student did not enroll in any classes for the first 8-week module, nor any full 16-week courses. The student enrolled in two 3-credit classes in the second 8-week module after the spring PRD, or an enrollment intensity of 6/12 (50%). The student showed zero hours on the PRD.

According to ED, the school can use the six credits in the second module to substantiate up to, and including, the student's original enrollment intensity. In this case, the student does not enroll full time, so he or she cannot be paid a full-time Pell Grant. However, the student still can be paid up to the 6/12 (50%) enrollment intensity, even if the student was not enrolled in any classes on the PRD. Once the Pell Grant is calculated for the enrollment intensity as of the PRD, the school’s recalculation policy will apply. No further adjustments to the Pell Grant will be made for subsequent changes to the student’s enrollment intensity.

NASFAA understands that this appears to undermine the concept of having a single PRD, which is allowed by ED under longstanding policy.

Note: The above guidance does NOT apply in scenarios when the student's initial Pell calculation takes place before the PRD and the student is enrolled in at least one course on the PRD. In instances when the student is enrolled in at least one credit hour on the PRD, the Pell Grant must be recalculated based on the student's enrollment intensity on that date (i.e., 3/12 based on one three-credit course or 25%). For example, the student's initial Pell calculation takes place before the start of classes for the payment period and is based on full-time enrollment. On the PRD, the student is only enrolled in three credits. Pell must be adjusted and based on 3/12 (25%) enrollment intensity as of the PRD.

For more information, reference Volume 7 of the 2024-25 FSA Handbook and 2024-25 Draft Student Aid Index (SAI) and Pell Grant Eligibility Guide Supplement – Pell Formulas and Enrollment Intensity.

Note: The guidance in this article references a volume of the FSA Handbook that is not yet published. See the GENERAL-23-03 Electronic Announcement for more information.