CLOCK HOUR CONVERSION REENTRIES AND TRANSFERS Presented by

CLOCK HOUR CONVERSION, RE-ENTRIES AND TRANSFERS Presented by: Steve Winters Senior Corporate Trainer Global Financial Aid Services, Inc. CASFAA Conference December 8, 2012

Clock to Credit Hour Conversion Purpose Determine Program Eligibility; and Determine the award amount.

Clock to Credit Hour Conversion Prior to 7/1/11

Determination of Clock to Credit Hour Program is at least 2 full academic years in length and provides an associate degree, bachelor degree, a professional degree; or Each course within the program is acceptable for full credit toward that school’s associate degree, bachelor degree, or professional degree and the degree offered by the school requires at least 2 full academic years of study.

Formula Prior to 7/1/11 FOR SEMESTER OR TRIMESTER HOUR PROGRAMS: FOR QUARTER HOUR PROGRAMS: Number of clock hours in credit hour program 30 20

Clock to Credit Hour Changes Based on Final Regulations 10/29/10 (75 FR 66832)

Regulation Provided A definition of a credit hour or its equivalent; Establish consistent measure of eligibility for awarding and payment of FSA. NOTE: The regulation does not prevent institutions for using a different definition for academic or other purposes.

Why develop a credit hour definition? � There was not a current definition for programs being funded under the HEA; � Established a consistent measure of eligibility for Federal funding; � Created procedures that accrediting agencies must use to determine if an institution’s assignment of a credit hour is acceptable; and � Modified provisions on when an institution must use clock or credit hours and standards for Clock-to-Credit hour conversions.

Clock to Credit Hour Evaluation On or After 7/1/11

School Must Use Clock Hours A GE program (a program that leads to gainful employment) must be considered a clock-hour program for purposes of FSA programs if: � A program is required to measure student progress in clock hours when a) receiving federal or state approval or licensure to offer the program; or b) completing clock hours is a requirement for graduate to apply for licensure or the authorization to practice the occupation that the student is intending to pursue; � The credit hours awarded for the program are not in compliance with the definition of a credit hour; or � The school does not provide clock hours that are a basis for the credit hours awarded for the program or each course in the program and, except for allowable excused absences (34 CRF 668. 4 (e)), requires attendance in clock hours that are basis for credit hours awarded.

Definition of Clock Hour 34 CFR 600. 2 Clock hour: A period of time consisting of – � A 50 - to 60 -minute class, lecture or recitation in a 60 -minute period; � A 50 - to 60 -minute faculty-supervised laboratory, shop training or internship in a 60 -minute period; or � Sixty minutes of preparation in a correspondence course.

Definition of Credit Hour 34 CFR 600. 2 Credit hour: Except as provided in 34 CFR 668. 8(k) and (l), a credit hour is an amount of work represented in intended learning outcomes and verified by evidence of student achievement that is an institutionally established equivalency that reasonably approximates not less than - � One hour of classroom or direct faculty instruction and a minimum of two hours of out of class student work each week for approximately 15 weeks for one semester or trimester hour of credit, or 10 -12 weeks for one quarter hour of credit, or the equivalent amount of work over a different amount of time; or � At least an equivalent amount of work as required in paragraph [1] of this definition for other academic activities as established by the institution including laboratory work, internships, practica, studio work or other academic work leading to the award of credit hours.

Determination of Clock to Credit Hour: �Program is at least 2 full academic years in length and provides an associate degree, bachelor degree, a professional degree or an equivalent degree as determined by the Department; or �Each course within the program is acceptable for full credit toward that school’s associate degree, bachelor degree, or professional degree or equivalent degree as determined by the Department provided that 1) the school’s degree requires at least two full academic years of study; and 2) the school demonstrates that students enrolled in and graduated from the degree program.

Clock/Credit Hour Conversion Formula On or After 7/1/11 For purpose of determining the number of credit hours in an educational program based on these requirements – �A semester or trimester hour must include at least 37. 5 clock hours of instruction; �A quarter hour must include at least 25 clock hours of instruction.

Formula On or After 7/1/11 For semester or trimester hour programs: Number of clock hours in the credit hour program 37. 5 For quarter hour programs: Number of clock hours in the credit hour program 25

Exception If an institution demonstrates that the credit hours meet new definition and there are no deficiencies identified by accreditor or State for assigning credits; however, meet these minimums – One semester or trimester credit hour is equal to 30 clock hours; or One quarter credit hour is equal to 20 clock hours.

Conversion Case Study (to semester hours) A program is 840 clock hours consisting of 6 classes at 120 clock hours each, and 120 clock hour externship with no out-of-class student work The institution determines that for – The first 3 classes a student generally has 40 hours of out-of-class work; The next 3 classes a student generally has 8 hours of out-of-class work

Two Options Default option – convert based on clock hours and ignore any out-of-class work; OR Full Formula Option (which takes into account both)

Default Option – Calculation: �Use the 37. 5 clock hours per semester hour, ignoring the out-of-class work (conversion course by course) = 6 classes at 120 clock hours /37. 5 = 3. 2 semester hours or rounded down to 3 = 6 classes X 3 = 18; and 1 externship or 120/37. 5 = 3. 2 or round down to 3 semester hours �Default Option Total Semester Credits = 21

Full Formula Option: �Must evaluate on individual coursework component of a program; �Total clock hours and out-of-class student work is immaterial; �Must meet limitation for the minimum number of clock hours per credit hour in addition to out-of-class work; �Excess out-of-class work does not carry over to other courses; �Use exact calculation including any fraction of credit hours or round down on fraction (this includes a fraction equal to or greater than. 5 or ½); and �Rounding on individual courses not on the total.

Full Formula Option - Calculation: �Courses #1 -#3 120 clock hours + 30* = 150 clock hours/37. 5 = 4 �Courses #4 -#6 120 clock hours + 8 = 128 clock hours/37. 5 = 3. 4 or 3 �Externship 120/37. 5 = 3. 2 or 3 semester credits �Full Formula Option Total Semester Credits = 24 semester credits *Limitation-the rules do not allow more than 7. 5 hours of out-ofclass prep for every 30 hours in class.

Transition Options – Effective Date July 1, 2011 The transition options for students in attendance in a program prior to July 1 st – �Apply pre-July 1 st regulations and policies until these students complete the program and amended regulations to students starting on or after July 1 st, or �Apply amended regulations to all students in the program in payment periods assigned to the 2011/2012 and subsequent award years.

Recap of Clock to Credit Hour Evaluation �Evaluate the program and determine is it a clock hour program or subject to clock to credit; �If yes to clock hour, then determine the set up of the program based on clock hours; �If yes to subject to clock to credit, then you must determine the method to be used for FSA awarding and disbursing: Default Formula; or Full formula �Once methodology is selected you must set up the program based on the clock to credit hours for FSA purposes.

Different Categories of Students (non-term) New student; Re-entries within 180 days; Re-entries after 180 days; and Transfer student

New Student Handled based on the clock to credit hour formula selected for awarding and disbursing.

Re-entries Within 180 Days A student who withdraws from a clock or credit hour non-term program and re-enters within 180 days.

Requirements of FSA �Student is considered to be in the same payment period that he or she was attending at the point of withdrawal; �Student is eligible to receive any FSA that was returned when the student ceased attendance; and �Any future FSA disbursements must be evaluated to determine when these will be eligible: Mid-point; and/or Anticipated graduation date.

Example: Bob withdraws and returns within 180 days in a credit hour, nonterm program. The program has 36 quarter credit hours and Bob withdrew after completing 20 hours. Bob had received his first disbursement of Federal Pell and subsidized/unsubsidized loans; however, the second disbursements were not processed prior to Bob’s withdrawal. None of the first disbursements were refunded. �What payment period is Bob being returned to? �What funds should be disbursed immediately? �What other dates should be evaluated? �If a portion of the first disbursement was refunded what action would the school need to take?

Answers: Question: What payment period is Bob being returned to? Answer: Second payment period of the academic year 19 – 36; Question: What funds should be disbursed immediately? Answer: Second disbursements of Federal Pell and loans. Question: What other dates should be evaluated? Answer: Graduation Date Question: If a portion of the first disbursement was refunded what action would the school need to take? Answer: The refunded funds should be requested and returned to the student’s account.

Example: Sue withdraws and returns within 180 days in a credit hour nonterm program. The program has 24 semester credit hours and Sue withdrew after completing 10 hours. Sue had received her first disbursement of Federal Pell and subsidized/unsubsidized loans; however, she had not reached mid-point of the academic year and none of the second disbursements were eligible at the time of Sue’s withdrawal. None of the first disbursements were refunded. �What payment period is Sue being returned to? �What funds should be disbursed immediately? �What other dates should be evaluated? �If a portion of the first disbursement was refunded what action would the school need to take?

Answers: Question: What payment period is Sue being returned to? Answer: First payment period of the academic year 1 - 12; Question: What funds should be disbursed immediately? Answer: None. Question: What other dates should be evaluated? Answer: Mid-point and Graduation Date Question: If a portion of the first disbursement was refunded what action would the school need to take? Answer: The refunded funds should be requested and returned to the student’s account.

Factors to Consider – Re-entries Within 180 Days �Is the student returning to the same program? �Is the return within 180 days? �How does your internal packaging system handle this type of student? Do you create a new budget; or Reinstate the prior budget. �Determine mid-point and graduation. �Determine funds that must be re-disbursed due to withdrawal and schedule any future funds based on new mid-point; �Recalculated mid-point could be in a different award year; and �A student could have additional loan funds not applied for in the original enrollment that the student may want to borrow in the re-entry period.

Re-entry After 180 Days A student who withdraws from a clock or credit hour non-term program and re-enters after 180 days.

Requirements for FSA �For purposes of calculating payment periods only, the length of the program is the number of credit hours or clock hours and weeks remaining; �If the remaining hours and weeks equal half of an academic year or less, the remaining hours equal one payment period; and �Repeat coursework may be considered in the remaining hours as long as the student is receiving credit for repeating the course.

Example: Bob withdraws and returns after 180 days in a credit hour nonterm program. The program has 36 quarter credit hours and Bob withdrew after successfully completing 12 hours and failing 4. Bob had received his first disbursement of Federal Pell and subsidized/unsubsidized loans; however, the second disbursements were not processed prior to Bob’s withdrawal and the original loan period has expired. Evaluate Bob’s re-entry: 36 hours in the total program - 12 hours completed 24 hours remaining Remaining hours are greater than one payment period so Bob would have two payment periods.

Example: Sue withdraws and returns after 180 days in a credit hour nonterm program. The program has 24 quarter credit hours and Sue withdrew after successfully completing 15 hours and failed 3 hours. Sue had received her first disbursement of Federal Pell and subsidized/unsubsidized loans; however, the second disbursements were not processed prior to Sue’s withdrawal and the original loan period has expired. Evaluate Sue’s re-entry: 24 hours in the total program - 15 hours completed 9 hours remaining Remaining hours are less than one payment period so Sue would have one payment period remaining to complete.

Example: Johnny completes 6 hours of a 36 credit hour program and withdraws. Johnny decides to re-enter the program after 180 days and receives credit for 4 hours. The program length for purposes of determining the new payment period and period of enrollment is 32 credit hours (the remainder of Johnny’s program). What are the new payment periods? 16 credits Note: If Johnny had received no credits for previously completed hours, how would this have changed his program length? The program would be 36 hours with 18 hours in each payment period.

Factors to Consider – Re-entries After 180 Days �Is the return after 180 days? �Has there been any change to the original program that may affect the student eligibility? �How many hours remaining to be taken to complete the program? �Consider remaining eligibility based on the length remaining; �Open loan period from prior enrollment; and �Award year may change.

Transfer Student A student that does not complete the nonterm program he or she initially enrolled in but chooses to transfer to a new nonterm program and the school accepts all or some of the hours earned in the prior program.

Two Types of Transfer Students One treated similar to re-entry after 180 days; or One that remains in same payment period.

Transfer Student – Type #1 If the student transfers to new program at your school you will need to determine the payment period lengths. The handling of a transfer student is very similar to a re-entry after 180 days.

Requirements for FSA �For purposes of calculating payment periods only, the length of the program is the number of credit hours or clock hours and weeks remaining; �If the remaining hours and weeks equal half of an academic year or less, the remaining hours equal one payment period; and �Repeat coursework may be considered in the remaining hours as long as the student is receiving credit for repeating the course.

Transfer Student – Type #2 Same payment period if all conditions are met: �Student is continuously enrolled at your school; �The coursework in the payment period the student is transferring out of is substantially similar to the coursework the student will be taking the program which he/she is transferring; �The payment periods are substantially equal in length in weeks of instruction and credit or clock hours; �There are little or no changes in school charges associated with the payment period; and �The credits from the payment period the student is transferring out of are accepted for credit in the new program.

Consideration for Transfer Students Open Loan Periods – OLP; and Calculating Remaining Eligibility for Federal Pell.

Open Loan Period (OLP) Student transfers at your campus between programs; or Student is transferring to your campus from another school.

Transfer at Your Campus – Between Programs �Establish the amount of remaining loan eligibility; �Determine the new payment periods* for the reduced loan; �Originate the loan for the reduced amount; and �Determine new payment periods for Federal Pell/CBF. *Note: The loan payment periods may not coincide with the payment periods for grants and Perkins loans.

Transfer to New School �The new school may originate a loan for the remaining portion of the program or academic year if: the new school accepts a student’s hours earned at the prior school; and the period of enrollment for the loan at the first school overlaps the period of enrollment at the new school. �NOTE: May not exceed the remaining balance of the loan and the loan period must cover the remaining hours and timeframe.

Federal Pell Calculation – Same as New Student Calculating Remaining Eligibility: Pell Disbursed at Prior School = % of Scheduled Award at Prior School Subtract the % from 100% and the result is the maximum percentage of the Scheduled Award that they student may receive.

Overlapping Academic Years – Hours Accepted Student transfers from ABC College to LMN College. The program at LMN College is a non-term program. LMN College accepts 4 classes completed at ABC College which are applicable to their program.

Overlapping Academic Years 1 st loan period at LMN College will start with the student’s attendance at LMN College and ends when the loan period established at ABC College ends. What are the options available to LMN College to establish the end date of the loan period?

Overlapping Academic Years LMN College has two options to determine the end date: Contact ABC College and obtain the information; or NSLDS. If a loan period is documented as longer than 30 weeks by ABC College or NSLDS, LMN College must consider that loan period to be ABC’s academic year.

Overlapping Academic Years �For the abbreviated loan period at LMN College the student may borrow the amount up to the amount of the annual loan limit at LMN College (less what was received at ABC College). �The amount during the LMN College’s loan period must be disbursed in two disbursements unless exempt due to low CDR’s. �If the student had used 100% of DL eligible at ABC College there would be no eligibility for loans at LMN College.

Examples: �ABC College disbursed $1800 in subsidized and $1000 unsubsidized loan. At LMN College the student is a grade level 1/independent so the remaining eligibility would be: Subsidized: $3500 - $1800 = $1700 Unsubsidized: $6000 - $1000 = $5000 �ABC College disbursed $3500 in subsidized and $1000 unsubsidized loan. At LMN College the student is a grade level 1/independent so the remaining eligibility would be: Subsidized: $3500 - $3500 = $0 Unsubsidized: $6000 - $1000 = $5000

Overlapping Academic Years For Direct Loans, the student’s first full academic year at LMN College will begin the first day following ABC College’s academic year ending. The corresponding loan period will be either the BBAY, OR The remainder of the program at LMN College, if less than one academic year.

Overlapping Academic Years – No Hours Accepted �Student transfers from ABC College to LMN College. �The program at LMN College is a non-term program. �LMN College accepts zero classes completed at ABC College which are applicable to their program. �Student’s loan period at LMN College must comply with the allowable loan period minimums.

Overlapping Academic Years – No Hours Accepted Usually the TIV defined by AY. The length of the program if less than AY. Student’s loan limit is for the first loan period at LMN College which is whatever remains in the annual loan limit less what was borrowed at ABC College. If the student used 100% of DL at ABC College there may be no funds available at LMN College.

Examples: � ABC College disbursed $1800 in subsidized and $1000 unsubsidized loan. At LMN College the student is a grade level 1/dependent so the remaining eligibility would be: Subsidized: Unsubsidized: $3500 - $1800 = $1700 $2000 - $1000 = $1000 � ABC College disbursed $3500 in subsidized and $2000 unsubsidized loan. At LMN College the student is a grade level 1/dependent so the remaining eligibility would be: Subsidized: Unsubsidized: $3500 - $3500 = $0 $2000 - $2000 = $0 � The available DL for LMN College’s loan period may include no loans due to 100% used at ABC College. If the program is longer than one academic year the student will regain eligibility in the second academic year.

QUESTIONS

Steve Winters Global Financial Aid Services 228. 523. 1057 swinters@globalfas. com