Can We Prorate the Student Aid Index For Periods Other Than Nine Months?

No. The Student Aid Index (SAI) is not prorated for periods other than nine months, and there is no option for schools to choose to prorate in these circumstances. The parent and student contribution proration provisions previously included in Section 475(i) and (j) of the Higher Education Act of 1965, as amended, [20 USC 1087(i), (j)] have been removed from the statute. Therefore, you will use the full nine-month SAI when calculating aid for summer and any other periods of enrollment that are less than or greater than nine months. There are no exceptions and you cannot use professional judgment (PJ) to prorate the SAI. See Dear Colleague Letter GEN-23-11 for more information.

The U.S. Department of Education (ED) provided an example in its July 13, 2023 webinar, Better FAFSA Better Future Question & Answer Session 2:

The above information is true even though the cost of attendance (COA) can only reflect costs for the period of enrollment. For more information on treatment of the COA in such instances, see OFA-Q6/A6 on the FAFSA Simplification Questions and Answers webpage.

NASFAA is unaware as to why the proration provisions were removed from the law, though it may be due to the simplification part of FAFSA Simplification. NASFAA and ED are aware of the impact on students’ eligibility for need-based aid associated with this issue and are working to see if a resolution is possible. The SAI cannot be regulated by ED and any changes will require Congress to make statutory changes. That said, a change is highly unlikely for 2024-25.