This guidance is specific to the 2024-25 award year and later.
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:
Regardless of the alternative selected, the following must occur:
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.
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