This guidance is specific to the 2024-25 award year and later. For 2023-24* award year guidance see AskRegs Q&A, Can We Award Or Increase a Federal Pell Grant For a Student Who Registers After the School's Census Date?
There are a few things to consider here, the first being, is this an initial calculation or a recalculation? Initial calculation is defined in Volume 7, Chapter 7 of the FSA Handbook:
An initial calculation is the first calculation that is made on or after the date the school has received a Department-produced EFC such as the student's initial SAR or ISIR with an official EFC. The initial calculation uses the enrollment status at the time of the initial calculation. If you’ve estimated the student’s eligibility before receiving a SAR or ISIR for the student, you must confirm prior estimated eligibility or determine the student’s eligibility at the time the SAR or ISIR is received.
You should document the date you initially calculate a student’s Pell Grant. The earliest date is the date of receipt of a Department-produced EFC, such as on a SAR or ISIR (assuming you have a documented or projected enrollment status for the student). If you fail to document the date of the initial calculation, you must use the later of:
Your school is considered to have received the ISIR on the date it was processed. This date is labeled 'Processed Date' on
the ISIR. In the case of a SAR, your school is considered to have received it on the date processed unless you document a
later date. The processing date on a SAR is the date above the EFC and, on a SAR Acknowledgment, the 'Transaction
In other words, if the student was never awarded a Federal Pell Grant, it is NASFAA's understanding that since the Federal Pell Grant is an entitlement, the student must be awarded based upon their enrollment intensity at the time of the award, regardless of whether this is after the institution's Pell recalculation date (PRD), sometimes referred to as the "census date" by schools. However, for the recalculation aspect, please refer to the following also in Volume 7, Chapter 7 of the FSA Handbook:
"The regulations don’t require recalculation for changes in enrollment status after the student has begun attendance in all of his or her classes. However, your school may have a policy of recalculating awards in this situation. Your school’s recalculation policy must be documented in writing, must consider any changes in the student’s COA, and must be applied consistently to all students in a program. If your school chooses to recalculate for a student whose enrollment status increases (for example, from half time to full time), it must also recalculate for a student whose enrollment status decreases.
Your school’s policy may set a date after which Pell Grants will not be recalculated for enrollment status changes during a payment period. This date is sometimes referred to as the "Pell recalculation date" or "PRD." For example, you could establish a policy that you will recalculate Pell awards only for enrollment changes that occur up to the “add/drop” date of a term. If you establish a policy that Pell Grants will not be recalculated after a certain date, the policy must be applied in all cases, even when there is compressed coursework.
Note that a school may establish more than one PRD within the same payment period. For example, if a term is divided into two or more modules, a school could establish a PRD within each module. However, in this case only one PRD will apply to a student, and that will be the PRD for the latest class or module in which the student begins attendance. Once the school determines which PRD applies to the student, the school must go back to the beginning of the term and review which courses the student dropped, added, or completed up until the student’s PRD to calculate the student’s Pell Grant enrollment status."
Whether or not you recalculate an already awarded Federal Pell Grant after your PRD depends on how your school's policy is written. As this is an optional recalculation, it is essentially the prerogative of the institution. Whatever your institutional policy states must be applied consistently to all students.
2024-25 Note: Effective with the 2024-25 award year, the expected family contribution (EFC) becomes the student aid index (SAI) and the Student Aid Report (SAR) becomes the FAFSA Submission Summary (FSS), but the guidance remains the same. Pell Grants will be calculated based on a student's enrollment intensity. See PEL-Q2/A2 on the U.S. Department of Education's (ED's) FAFSA Simplification Questions and Answers webpage.
Student Aid Reference Desk: For additional information, try the Student Aid Reference Desk. It is a central hub of all the important financial aid resources you need with direct links to legislation, regulation, Dear Colleague Letters, and other ED and NASFAA references. It is updated on a rolling basis with the latest news and changes. Search Pell Grant and Packaging.
AskRegs Q&As represent NASFAA's understanding of regulatory and compliance issues. They are FOR INTERNAL USE ONLY. While NASFAA believes AskRegs Q&As are accurate and factual, they have not been reviewed or approved by the U.S. Department of Education (ED). If you should need written confirmation of AskRegs information for audit or program review purposes, please contact your ED School Participation Division. NASFAA shall not be liable for technical or editorial errors or omissions contained herein; nor for incidental or consequential damages resulting from the furnishing, performance, or use of this material.
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