Q3. What will happen if a contributor doesn't sign the FAFSA/consent to FA-DDX?

A3.  The consent and approval to the access, disclosure, and use of federal tax information (FTI) from the IRS is required for the student and each applicable contributor (student spouse, parent, and parent spouse or partner). This consent is only valid for a single award year (e.g., 2024-25) at a time and will be required annually. If the ISIR indicates that it is missing the consent of one or more contributors, it will be assigned a contributor-specific comment code and a rejected status. FAAs can use the comment code to identify which contributor needs to provide consent to determine the next step.

If the ISIR indicates that the student’s consent was missing (CC 044), the student should log in to https://studentaid.gov/h/apply-for-aid/fafsa and select “Make a Correction” to provide their consent.

If the ISIR indicates that the consent of a contributor other than the student is missing (CC 080 – Parent, CC 100 – Parent Spouse or Partner, or CC 131 – Student Spouse) the student should log in to https://studentaid.gov/h/apply-for-aid/fafsa, select “Make a Correction,” and then invite the necessary contributors. Even those contributors without a Social Security number (SSN) will be able to create a StudentAid.gov account. If the contributors were already invited and have previously created their account, they simply need to log in and select “Make a Correction.” After logging in, they can complete the necessary steps to provide their consent. Note that if the IRS is unable to provide data for the contributor, they will be directed to manually enter their financial information.

In order to help identify these ISIRs, Global will be providing a pushed report that includes ISIRs that were rejected for missing contributor consent and other issues that require resolution from the FAA.

Q2. Will ISIRs contain both amended and original tax data?

A2. No, ED has indicated that the FTI information retrieved via FA-DDX will contain only original tax data consistent with the methodology used by the Data Retrieval Tool (DRT) for past years of the FAFSA. There were some early ISIRs processed for 24/25 that did contain a mix of both original and amended tax return data, but there was no indication on what data came from the original or amended returns.

Q3. How will we know if a contributor filed an amended return?

A3. Unlike past years when using the IRS DRT, the 24/25 ISIR will not include any indicators that an amended tax return was filed. Unless a contributor provides information indicating that an amended tax return was filed, there will not be a way for an FAA to determine this through review of the ISIR.

Q4. What should be done if a contributor successfully used FA-DDX (or the IRS indicated no return was on file), but it was determined that an update to that information was necessary, e.g., it was discovered that they filed an amended return or that they were required to file but did not?

A4. If during the review of a student’s ISIR it is determined that an update to FTI income information is necessary, the FAA will need to submit corrections for all of the applicable income fields and set the Professional Judgment (PJ) Flag to “Yes.” Note that any time the FAA wants to use different data in the SAI calculation than the provided FTI, a PJ must be a part of the correction.

Q2. Can the student or parent manually change their family size after using FA-DDX?

A2. Yes, there is a specific "Updated Family Size" field for this purpose. This question is available to the student and parent when they are initially completing the FAFSA as well as on subsequent ISIR transactions. If the student or parent is changing this field on a subsequent transaction, it will follow the same process as 23/24 and prior.

Q3. Can an unborn child be included in the student’s or parent’s family size?

A3. For 24/25, ED has indicated that unborn children should not be included in the family size. However, if the student is selected for verification (by ED or by the institution) and at the time of verification the child has been born, family size should be updated to include the newborn child if the student (or parent, if dependent) will provide more than half of that child’s support during the award year. Alternatively, if the addition of the newborn child changes the student’s dependency status and the student will provide more than half of that child’s support, then dependency status and family size must be updated.

Q2. If a program is reduced to 600 clock hours to not exceed the minimum hours required to enter the occupation for   the GE program as published by the state, is the program still eligible for Pell or loans only?

A2. If the program meets the minimum program length defined by ED, the program remains eligible for all approved Title IV aid; however, both Pell and Loans are subject to proration due to the program length is less than the full academic year that is established by the college and meets at least the minimum academic year requirements set forth by ED.

ED’s defined minimum requirements for academic year length for undergraduate programs and program length:

Academic Year (Hours/Credits) –

• 24 Semester or Trimester Hours;

• 36 Quarter Credits; or

• 900 Clock Hours

Academic Year (Weeks) –

• All Credit Hour Programs – 30 weeks

• Clock Hour Programs – 26 weeks

Program Length –

• 600 clock hours, 16 semester or trimester credit hours, or 24 quarter credit hours; or

• 300 clock hours, 8 semester or trimester credit hours, or 12 quarter credit hours AND only admits student who have completed the equivalent of an associate degree.

Short-term Program Length (See Q3/A3 for Program Restrictions)–

• At least 300 clock hours but less than 600 clock hours

Q3. If the GE program is reduced to 500 clock hours, what will the financial aid package look like?

A3. The program will only be eligible for Direct Loans. Any program that is less than 600 clock hours and at least 300    or more, is a “short-term” program. Short-term programs are only eligible for Direct Loans and must be awarded/disbursed on clock hours only. The college must request and wait for approval from ED before awarding and disbursing aid. Additionally, the college must track and report student completion and placement rates annually through the school’s annual compliance audit, including Single Audit Act schools.

Q4. Are short-term programs the only programs that require approval prior to offering Title TIV aid to students enrolled for a 7/1/2024 or after program start date?

A4.Yes. After receiving all applicable accreditation/state approvals, institutions must add the short-term program to its EAPP and submit all necessary supporting documentation to ED and must wait for ED’s approval. The college will receive an updated ECAR with the short-term programs listed. The college must also provide the ECAR for any program that is 300 or more hours but less than 600 hours to Global for the short-term program to be profiled.

Q5. Can schools choose to report the new program early before the last student from a legacy program has completed?

A5. Yes. Reporting the revised GE program length at the time there are no longer any legacy students enrolled in the legacy programs is not a requirement. Generally, ED requires institutions to report GE Program changes within 10 days of the change on their EAPP; however, ED is allowing for schools to wait to report these new programs (revised programs due to the recession of the 150% rule) at the time the legacy program no longer has any students enrolled.

Even though the college may report the revised program early, the college must report the legacy program’s end date within 10 days after the last student is enrolled in the program. Therefore, the institution will need to have a process in place to track the legacy students enrolled in the legacy program to ensure timely reporting.

Q6. If the institution’s state has a general diploma requirement, but not specific to a program, will the institution need to adjust the general requirement?

A6. Yes and No.

• No: The GE Program restrictions that are effective 7/1/24 are specifically related to the minimum training required to enter an occupation in the state where the college is located or a bordering state (as provided under § 668.14(b)(26)(ii)(B)), if the state has established such a requirement or established by any Federal agency. The minimum hours for entry in an occupation by the state sets the maximum number of hours that an institution may offer a program that provides training/education to enter the occupation.

• Yes: However, if your state reports minimum requirements for general diplomas and degrees, all programs will need to meet or exceed the statement minimum requirements.

Therefore, all programs (including GE programs) will need to meet or exceed the state’s minimum diploma/degree requirements to receive approval through your state and accreditation, and if the program is a GE program, the program may not exceed the minimum training hours published by the state, if your state publishes such requirements, to enter the occupation.

Q7. If the institution decides to not offer a program with Title TIV funding, is the institution still required to reduce the number of credits and/or clock hours due to GE changes?

A7.  No. The institution may still teach out the existing students in program; however, the institution may not disburse Title IV funds for any students who begin on or after 7/1/2024. The institution may still offer the program; however, may not disburse Title IV funds.

Q8. For programs that have start dates immediately before 7/1/2024, are they eligible for Title IV funding if after 7/1/2024 the program would not be eligible for Title IV funds?

A8. Yes. Students who start the program before 7/1/2024 will be eligible for Title IV funds for the entire program. New students (including re-entries) on or after 7/1/2024 would not be eligible for the Title IV aid for that specific program.

Q9. If the institution’s neighboring state’s requirements are reduced, do we have to change the GE program?

A9. To determine, the institution should evaluate the following questions:

• Does the institution have a campus in the neighboring state?

• Do the majority of the institution’s students live in the neighboring state?

• Do the majority of the institution’s students intend to work in the neighboring state?

If the answer is “No” to all the above questions, the neighboring state’s requirements are irrelevant and will not factor into the institution’s evaluation of programs for GE purposes. The institution will use the hours in their current state.

If any of the above questions were answered as “Yes,” the institution must take into account a neighboring state’s requirements when evaluating programs for GE purposes.

Q3. What criteria does the student/parent have to meet to receive a Max Pell Flag?

A3. For Dependent Students:

• The student’s parent(s) is not required to file a federal income tax return.

• The student’s parent is a single parent and has an AGI greater than zero and less than or equal to 225% of the poverty guideline for the applicant’s family size and state of residence.

• The student’s parent is not a single parent and has an AGI greater than zero and less than or equal to 175% of the poverty guideline for the applicant’s family size and state of residence.

For Independent Students:

• The student (and spouse, if applicable) is not required to file a federal income tax return.

• The student is a single parent and has an AGI greater than zero and less than or equal to 225% of the poverty guideline for the applicant’s family size and state of residence.

• The student is not a single parent and has an AGI greater than zero and less than or equal to 175% of the poverty guideline for the applicant’s family size and state of residence.

Q4. What criteria does the student/parent have to meet to receive a Min Pell Flag?

A4. For Dependent Students:

• The student’s parent is a single parent and has an AGI greater than zero and less than or equal to 325% of the poverty guideline for the applicant’s family size and state of residence.

• The student’s parent is not a single parent and has an AGI greater than zero and less than or equal to 275% of the poverty guideline for the applicant’s family size and state of residence.

For Independent Students:

• The student is a single parent and has an AGI greater than zero and less than or equal to 350% of the poverty guideline for the applicant’s family size and state of residence.

• The student is not a single parent and has an AGI greater than zero and less than or equal to 275% of the poverty guideline for the applicant’s family size and state of residence.

Q5. Will the Max and Min Pell Flag be displayed on the Submitted/Confirmed Financial Aid Budget?

A5. Yes. These Max and Min Pell Flags will be displayed under the Scheduled Pell Award and Expected Pell Disbursement sections of the Financial Aid Budget.

Q6. Are students still eligible to receive up to 150% Pell for the award year?

A6. Yes, students are permitted to receive up to 150% Pell for the 2024-2025 award year; however, the student is no longer required to be enrolled in an at least half-time status.

Q7. Will the Pell calculations of 600% LEU be changing with the new Pell Enrollment Intensity percentage utilization?

A7. The way calculations are determined for the 600% Pell LEU will stay the same for the 2024-2025 award year. No changes.

Q8. How does rounding to the nearest $5 increment work?

A8. Rounding to the nearest $5 increment is only utilized for students that must have their Pell calculated. To calculate, subtract the student’s SAI from the award year's maximum Pell amount. This total will then be round to the nearest $5 increment to give you the Scheduled Pell Award for the student. 

General Rule: Calculated Schedule Pell amounts ending in 1, 2, 6, & 7 will round down to the nearest $5 increment. Calculated Schedule Pell amounts ending in 3, 4, 8, & 9 will round up to the nearest $5 increment.

***Note***

SAINT Director will do the calculation and rounding when awarding Pell on the Financial Aid Budget. The calculation does not show outside requirements, such as 150% or Pell LEU.

Q9. If a student was to withdrawal from a modular program, will the student’s Pell be recalculated be based on credits attempted at time of withdrawal?

A9. The answer to this question really depends on what you mean by withdrawal.

If the student withdraws from the Institution, the Pell eligibility does not change when the R2T4 calculation is completed.

If the student drops/withdraws from a class during a term, the Pell would recalculate to pay based on the Institutions Add/Drop policy.