Must We Recalculate a Pell Grant If There Is a Change In Student Aid Index Or Enrollment Intensity?

It depends. Aside from student aid index (SAI) replacing expected family contribution (EFC) and enrollment intensity replacing enrollment status starting with the 2024-25 award year, the FAFSA Simplification Act does not change the Federal Pell Grant recalculation rules in 34 CFR 690.80. Required and optional recalculations based on school policies remain in place:

"Sec. 690.80 Recalculation of a Federal Pell Grant award.

(a) Change in [student aid index]. (1) The institution shall recalculate a Federal Pell Grant award for the entire award year if the student's student aid index changes at any time during the award year. The change may result from—

(i) The correction of a clerical or arithmetic error under Sec. 690.14; or        

(ii) A correction based on information required as a result of verification under 34 CFR part 668, Subpart E.

(2) Except as described in 34 CFR 668.60(c), the institution shall adjust the student's award when an overaward or underaward is caused by the change in the student aid index. That adjustment must be made—

(i) Within the same award year—if possible—to correct any overpayment or underpayment; or

(ii) During the next award year to correct any overpayment that could not be adjusted during the year in which the student was overpaid.

(b) Change in enrollment [intensity]. (1) If the student's enrollment [intensity] changes from one academic term to another term within the same award year, the institution shall recalculate the Federal Pell Grant award for the new payment period taking into account any changes in the cost of attendance.

(2)(i) If the student's projected enrollment [intensity] changes during a payment period after the student has begun attendance in all of his or her classes for that payment period, the institution may (but is not required to) establish a policy under which the student's award for the payment period is recalculated. Any such recalculations must take into account any changes in the cost of attendance. If such a policy is established, it must apply to all students.

(ii) If a student's projected enrollment [intensity] changes during a payment period before the student begins attendance in all of his or her classes for that payment period, the institution shall recalculate the student's enrollment [intendity] to reflect only those classes for which the student actually began attendance.

(c) Change in cost of attendance. If the student's cost of attendance changes at any time during the award year and his or her enrollment [intensity] remains the same, the institution may (but is not required to) establish a policy under which the student's award for the payment period is recalculated. If such a policy is established, it must apply to all students."

The above is true even if not all scenarios are noted in the U.S. Department of Education's (ED's) FAFSA Simplification Questions and Answers, PEL-Q2/A2. This Q&A could be misleading if read without considering the entire regulatory text.

PEL-Q2/A2 offers this example: "Using the example from the “Enrollment Intensity Adjustments for Pell Grant Awards” section in GEN-23-11, if full-time enrollment is 12 or more credit hours, and the student received a Pell Grant award for 7 credit hours, the enrollment intensity would be (7 ÷ 12) × 100% = 58%. However, if the student only began attendance in 5 credit hours, then the student can only be paid a Pell Grant award for 5 credit hours and the Pell Grant must be recalculated for an enrollment intensity based on 5 credit hours (5 ÷ 12) x 100% = 42%."