Is It Acceptable To Recalculate the Pell Grant Enrollment Intensity Within the Term Based Upon Individual Course Census Dates?

Scenario: We are term based and offer both full-term and short-term courses within each term. Typically students have a combination of both full-term and short-term courses within the term. For example, a student might drop course #1 after the course #1 census date; however, the drop occurred prior to the census date of another course (course #2) within the same term.

Answer: An institution may not set a policy to establish a date after which no optional Federal Pell Grant recalculations (Pell census date) occur that is specific to each course. However, an institution that offers modules within a payment period has several options in establishing its "census date."

Under the optional Pell recalculation policy, whenever an adjustment is made to a student's initial Federal Pell Grant calculation based upon an enrollment intensity change, the award adjustment must take into account enrollment changes in all of the student's classes within that payment period. In the example you provided, an adjustment would occur for both course #1 and course #2. In fact, if the student dropped course #1, a recalculation must be performed even if the student's enrollment intensity did not change in course #2, as long as the course #1 drop occurred prior to the student's census date. It appears that your institution's optional Pell recalculation policy follows the second bullet point in the discussion that follows.

To clarify what the regulations allow, a single date must be established after which no further recalculations are made to the initial calculation of a student's Pell Grant based upon an enrollment intensity adjustment. Prior to that date, any enrollment intensity adjustment in any class would trigger a Pell Grant recalculation [please see 34 CFR 690.80(b)(2)(i)]. Of course, if a student does not initiate attendance in one or more classes, that falls within the category of mandatory adjustments, and an adjustment must be made to the student's Pell Grant if the nonattendance results in an enrollment status change.

There are several alternatives to consider when setting the date after which no Pell Grant recalculations are performed:

• A date within the semester may be set which applies to all students (most common);
• A date may be set based on the add/drop date of the last class in which the student is enrolled (This policy is sometimes used when the payment period includes modules which begin after the payment period start date. The Pell census date may vary from student to student, based upon the latest start date of the last class in which each student enrolls);
• An institution may allow recalculations to occur throughout the payment period; or
• An institution may elect to perform no recalculation of Pell Grants due to enrollment intensity changes which occur after the initial grant calculation.

 Regardless of the alternative selected, the following must occur:

• All enrollment intensity changes prior to the established Pell Grant "census date" must be included. This includes enrollment decreases as well as increases;
• The policy must be in writing and included in consumer information materials;
• The policy must be consistently applied to all students within an educational program;
• A student's cost of attendance (COA) must be recalculated when the student's enrollment status changes prior to the established date; and
• Mandatory recalculations must be always be performed, such as for classes in which the student did not establish eligibility.

Also, if a student completely withdraws from the payment period, a return of Title IV funds (R2T4) calculation is performed, rather than a Pell Grant recalculation.

References: 34 CFR 690.80(b)(2), Volume 7, Chapter 6 of the FSA Handbook.