ES4323 - Institutional Selection for UEH Review

1. Institutional Regulations
   1. There may be instances where DMACC suspects that a student for whom the Department of Education did not assign an UEH Flag may be one whose past enrollment suggests that the student’s prior academic history should be reviewed. The Financial Aid Department will develop a procedure for identifying students with an UEH based on the following criteria:
      1. The student has not been previously flagged as having an UEH by the federal processor as identified by the student’s Institutional Student Information Record (ISIR).
      2. The student has accessed federal student loans at no less than two institutions as indicated on the student’s ISIR prior to attending DMACC and had an aggregate outstanding federal student loan balance equal to or greater than $10,500, or the student has accessed federal student loans at the graduate level prior to attending DMACC.
      3. Students who have previously borrowed at DMACC will be exempt from this policy and procedure.
      4. Students who have previously earned credit at DMACC will be exempt from this policy and procedure.
      5. DMACC may further select a student for UEH at its discretion should the student’s educational purpose be in question or if the student is suspected of an attempt to commit fraud during the application process.
   2. The Financial Aid Department will evaluate an applicant’s prior receipt of a Federal Pell Grant or Federal Direct Loan (not including a Direct Consolidation Loan or parent PLUS Loan) during the current and prior three academic years (four-year review period). On a case-by-case basis, the Financial Aid Department will evaluate an applicant’s prior receipt of a Federal Pell Grant or Federal Direct Loan during each award period such aid was disbursed. Such cases include suspected fraud, an attempt to attend only long enough to receive a financial aid disbursement, or a student’s failure to maintain satisfactory academic progress.
   3. The student will be required to provide official transcripts from each institution attended for which a disbursement of Federal Pell Grant or Federal Direct Loan had occurred during the four-year review period. On a case-by-case basis, the Financial Aid Department will require the student to provide official transcripts from each institution attended for which a disbursement of a Federal Pell Grant or Federal Direct Loan occurred. Such cases include suspected fraud, an attempt to attend only long enough to receive a financial aid disbursement, or a student’s failure to maintain satisfactory academic progress.
   4. The Financial Aid Department will be required to follow all Department of Education requirements for UEH resolution as outlined in Dear Colleague Letters GEN-15-05 and GEN-13-09.
   5. The authority for DMACC to deny Title IV, HEA program assistance under the circumstances described in this policy is section 484(a)(4)(A) of the Higher Education Act of 1965, as amended, which requires the student to sign a Statement of Educational Purpose. By signing the Statement of Educational Purpose as part of the student’s submission of the FAFSA, the student certified that he or she would use the Title IV, HEA program assistance received only to meet educational costs. (See also 34 CFR 668.32(h) and GEN 13-09).
2. Procedure
   1. DMACC students must complete the Free Application for Federal Student Aid (FAFSA) prior to June 30th of each award year.
   2. Upon receipt of the student’s ISIR, an evaluation will be conducted to determine a selection for institutional UEH review.
   3. If selected for institutional UEH review, tracking requirement will be added to the student’s record and the student will be notified of the requirement to complete an Institutional Enrollment History Review form. The student will be as though the Department of Education had assigned the student a UEH value of ‘3.’
   4. The student will be provided access to an Institutional Enrollment History Review form.
   5. Upon completion, the student will provide the form to the Financial Aid Office for review. A review will only be conducted if the UEH form is completed in its entirety. The initial review of the UEH form will be conducted by a designated Financial Aid Specialist. The Specialist will determine that the form is complete and all required official transcripts have been provided. Students will have 30 days from the time of submission of the UEH form to provide all required transcripts to the Financial Aid Office. If official transcripts are not provided, the review process will not continue. The Enrollment History Review will be denied and communication to the student will be sent notifying them of the official transcript requirement. If all official transcripts have been provided, the Specialist will continue with the review process as outlined below.
   6. Using information from the National Student Loan Data System (NSLDS), the DMACC Financial Aid Department will identify the institutions where the student received Pell Grant and/or Federal Direct Loan funding.
   7. The DMACC Financial Aid Department will determine, for each of the previously attended institutions during the four-year review period whether academic credit was earned during the award year in which the student received Pell Grant and/or Federal Direct Loan funds. Academic credit is considered to have been earned if the academic records show that the student completed any credit hours or clock hours.
      1. Academic Credit Earned: If DMACC determines that the student earned any academic credit at each of the previously-attended institutions, no further action will be required unless the institution has other reasons to believe that the student is one who enrolls just to receive the credit balance (as determined by the Financial Aid Director or Advisor) or the student is not maintaining satisfactory academic progress (as defined by ES4300 ). In such instances, DMACC will require the student to provide the additional information discussed below under “Academic Credit Not Earned.” If it is determined that academic credit was not earned at one or more of the previously-attended institutions, DMACC will follow the “Academic Credit Not Earned” guidance below.
      2. Academic Credit Not Earned: If the student did not earn academic credit at a previously attended institution DMACC will request documentation from the student explaining why the student failed to earn academic credit, and the circumstances that required the student to attend multiple institutions. This documentation will be requested and collected via the Enrollment History Review form. The DMACC Financial Aid Department will determine whether the documentation supports (1) the reasons given by the student for the student’s failure to earn academic credit or did not maintain satisfactory academic progress; (2) the reasons given by the student for the student’s need to attend multiple institutions; and (3) that the student did not enroll only to receive credit balance funds.
   8. When further action is required, a review of the requested explanation and documentation as outlined under paragraphs G(1) and G(2) will be conducted by a Financial Aid Advisor.
   9. The Financial Aid Advisor will determine the existence of an extenuating circumstance that prevented a student from earning credit or maintaining satisfactory academic progress at each institution attended and required that the student attend multiple institutions prior to enrolling at DMACC. The Advisor will approve or deny Title IV aid. The decision will be communicated to the student via US Mail or student email. The decision to deny will also outline how a student may regain eligibility for financial aid at DMACC.
   10. The decision to deny access to Title IV aid may be further appealed to the Director of Financial Aid at the request of the student. The Financial Aid Director will only review the Enrollment History Review Form in the event additional documentation or explanation of material significance not included in the original review is provided by the student. Failure to provide such additional documentation or explanation will result in an immediate denial.