General Provisions
Certification
SMWC is certified to participate in Title IV aid programs for up to six years. At the end of the six-year period, SMWC must apply for recertification. The Department will notify the school six months prior to the expiration date on the PPA. SMWC must submit its materials and completed application to the Department no later than 90 calendar days before our PPA expires.
The Department may permit a participating school to participate under a provisional certification for up to three years if the school is not financially responsible because it does not satisfy one or more of the general standards, has an unacceptable audit opinion, or has a past performance problem that has not been resolved.
The Vice President for Finance is responsible for the fiducial process associated with a provisional certification. The Associate Vice President for Financial Aid is responsible for all reporting and approvals required on the PPA during the provisional certification period.
Withdrawals and Return to Title IV Funds -
The Dept. of Education is currently updating this regulation. Updates coming soon.
Attendance
Federal funds are awarded to students under the assumption they will complete the payment period or period of enrollment. When a student withdraws or ceases to attend classes or submit required assignments the institution must determine if the student is eligible for the aid they received or was scheduled to receive.
SMWC does not take attendance however; we monitor student’s interaction by their physical presence in class, interaction with their instructor and submission of required assignments. The faculty documents the date(s) of the above activities and that date is used when completing the Return to Title IV calculation.
34 CFR §668.22(c)(1)(iii) an institution that does not require attendance to be taken should use the midpoint of the payment period or period of enrollment when a student is determined to have unofficially withdrawn. However, under 34 CFR §668.22(c)(3)(i) an institution may us a student’s last date of attendance at an academically-related activity that documents the student’s attendance at the activity.
Leave of Absence
A leave of absence (LOA) is a temporary interruption in a student’s program of study. LOA refers to the specific time period during a program when a student is not in attendance.
An LOA may be requested only in cases of documented circumstances beyond the student’s control, and will not be approved for a failure to maintain satisfactory academic progress. A student may request an LOA from their Program Director or the Vice President for Academic Affairs. The length of an LOA may vary given the student’s specific circumstances, but the student must resume classes within one full year from the start of the LOA or he/she will be required to reapply for admission to the College.
A student who requests to take an LOA will be responsible for dropping his/her courses prior to the last date to drop for the term. If the LOA is requested after the drop deadline, the student will be responsible for completing those courses.
A student approved for an LOA will be expected to fulfill all current financial obligations to the College, in accordance with the published refund policies.
PLEASE NOTE: SMWC’s Leave of Absence policy does not conform to the federal Title IV student aid requirements. Therefore, an LOA will be treated as a federal withdrawal and is subject to Title IV Return of Funds calculations. In addition, a student on LOA will be reported as withdrawn to the National Student Clearinghouse, triggering the start of the grace period or repayment of student loans.
Withdrawals
Official
The official withdraw process begins when the student provides official notification to the school of his or her intent to withdraw. The forms are completed by the Registrar’s office and distributed to offices related to the student’s program and the Financial Aid office.
Unofficial
An unofficial withdraw occurs when the school determines the student has ceased attendance or interaction.
Administrative
Prior to disbursing Federal, State or Institutional funds to a student, SMWC must confirm that the student has begun attendance in a payment period by submitting required assignments. Students that have not triggered attendance or submitted the required assignments within the first 5 days of the period of enrollment for 8 week modules or 10 days for 16 week semesters will be “Administratively Withdrawn”.
Modules
Students who are enrolled in a Credit Hour Program offered in Modules that do not complete all modules during a payment period will be considered a “withdrawal” if:
The student ceased to attend before completing or fail to begin attendance in a scheduled course.
Was not attending other courses
Is not planning on attending other modules in the payment period.
Withdrawal Date
A withdrawal date is the date in which the student notifies the college of his/her intent to withdrawal. An unofficial withdraw occurs when the institution realizes the student has ceased attendance or interaction.
SMWC does not take attendance; however, at the faculties discretion some classes may require attendance. The financial aid office will use the dates provided by the registrar’s office for official withdrawals and academic attendance for unofficial withdrawals.
Post-withdrawal Disbursements
If a recipient of Title IV grant or loan funds withdraws from a school after beginning attendance, the amount of Title IV grant or loan assistance earned by the student must be determined. If the amount disbursed to the student is less than the amount the student earned, and for which the student is otherwise eligible, he or she is eligible to receive a post-withdrawal disbursement of the earned aid that was not received.
If a student or parent is eligible for a post-withdrawal disbursement they will be notified by the Financial Aid Office. If a refund is applicable, then one will be issued by the Business Office after all tuition and fees on the account have been paid in full.
Priorities for disbursement includes from grants disbursing first, then loan funds. They will be paid to outstanding institutional charges. The Financial Aid office must receive approval from the student to disburse post-withdrawal loan funds, the student must send the confirmation within 14 days of the date of receipt. We must also have written permission to apply those funds to charges from prior years (up to $200). The Business Office has 14 days to return any post-withdrawal funds to the student or parent.
Returning unearned aid:
If a recipient of Title IV grant or loan funds withdraws from school after beginning attendance, the school must perform an R2Tr calculation to determine the amount of Title IV assistance earned by the student. If the amount disbursed to the student is greater than the amount the student earned, the unearned funds must be returned.
After the Return to Title IV (R2T4) calculation is completed, any aid that was not earned by the student will be return to the aid program by SMWC. Title IV aid not earned will be returned as follows:
- Unsubsidized Direct Loans (other than Direct PLUS loans)
- Subsidized Direct Loans
- Direct PLUS loans
- Federal Pell grants
- Iraq and Afghanistan Service Grant
- Federal Supplemental Educational Opportunity Grant (FSEOG) for which a return of funds is required
- TEACH Grants for which a return is required
Federal regulation states, the institution has 30 days from the date of the withdrawal or the end of the payment period or period of enrollment to complete the calculation. The school must return the amount of Title IV funds no later than 45 days after the date of determination.
NOTE: returning funds could result in the student owing SMWC a balance and/or the Department of Education.
The Financial Aid Office (along with the Registrar and Online Director) determine institutional and student shares of unearned aid. For campus students the amounts are prorated however, if a student has attended 60% or more during the enrollment period they are charged all tuition and fees for that period. For Online students, if they withdraw within the first week they may be eligible for a 100% refund if it’s approved by the Director of Online. After 2/3’s of the semester has passed the student may receive up to a 30% refund.
Students are notified if they owe a Title IV grant repayment by the Business Office via an invoice or billing statement.
Compliance Audits
In order to show administrative capability, Saint Mary-of-the-Woods College must show no evidence of significant problems that affect the institution’s ability to administer a Title IV program as identified in:
Program reviews conducted by ED, an accrediting agency (HLC), or a state agency (Indiana CHE)
Audits conducted by ED, an accrediting agency, or a state agency
Internal/third party audits
Findings made in any criminal, civil, or administrative proceeding
Saint Mary of the Woods College undergoes an annual audit (A-133) each summer which is conducted by an individual who is sufficiently independent of the school. All audits, along with an audited financial statement, must be submitted to the Department of Education in a timely manner in accordance with Department of Education requirements. All financial statements that are submitted must cover the last complete fiscal year.
Accordingly, audits are submitted on-line via ED’s eZAudit Web site at www.ezaudit.ed.gov.
The Financial Aid Office receives notices of requested records via e-mail and the Business Office and the Financial Aid Office are responsible for coordinating with the auditor and providing those records. The records are assessed and provided to the auditor by manually retrieving paper and/or electronic files.
Consumer information
Please refer to the Consumer Information portion of this catalog.
Verification - The Dept. of Education is currently updating this regulation. Updates coming soon.
Saint Mary-of-the-Woods College verifies all the Institutional Student Information Reports (ISIR) that are selected for verification by the Department of Education. The Financial Aid Office may review any student aid report that may or may not be selected for verification to clarify any conflicting information or document the information provided on the report. The Financial Aid Office may request certain tax documents, information pertaining to household size or any other required documents to resolve verification or conflicting information.
Students are responsible for supplying the documents required to clear their status. There are deadlines and consequences for not providing documents in a timely manner.
To ensure fair and accurate awarding of Title IV funds, federal financial aid regulations require that SMWC complete the verification process on all selected applicants who have been chosen by the Central Processing System (CPS) unless we discover conflicting information. The “census” (cut-off) date for verification is the last day of the current academic year or 120 days after the students last day of enrollment.
If a student is in the verification process, they will receive notification from the Financial Aid Office and are required to respond within 30 days. Failure to comply will result in another request being sent to the applicant, followed by a final request.
Students and/or parents are initially notified of required documentation by email and their student portal. Once documents are received they are verified and uploaded in the student’s electronic file in CampusNexus. If, for any reason, documentation is not received within two weeks the students and/or parents are notified with a second notice and then a final notice. The total allotted time is between four to six weeks.
Conflicting & Inaccurate Information
If there are no changes the verification process is complete. However, if there are discrepancies, the Financial Aid Office will make the necessary corrections electronically to the FAFSA. Once the corrections are made, the counselor can complete the verification process and award the student as aid per their eligibility.
If the verification or file review process result in a change in an applicant’s EFC, and if that EFC change results in an award change, the student is sent an email indicating the change and the revised award in posted on the student portal.
| Verification Exclusion |
There are times when we don’t need to verify a student’s application or certain data elements of the ISIR. All exclusions must be documented. Listed below are situations for verification exclusions:
Death of the student.
Not a Title IV aid recipient.
The applicant is eligible to receive only unsubsidized student financial assistance.
Applicant is verified by another school. The student completed verification at another school for the same academic year before transferring. A letter from the school stating that it verified the student application and provides the transaction number.
Post enrollment – the student was selected after ceasing to be enrolled at SMWC.
Both of the parents (or spouse) are mentally incapacitated.
Both parents or the custodial parent (spouse) has died.
The parents (spouse) are residing in a country other than the US and cannot be contacted by normal means.
The parents (spouse) can’t be located because the student does not have and cannot get their contact information.
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Professional Judgment & Dependency Override
The Director and FA staff have the authority to exercise professional judgment. Professional judgment can be exercised on a case by case basis after verification and any conflicting/inconsistent information has been resolved. All Professional Judgments must be approved by the Director of Financial aid.
The reason for the adjustment must be documented and it must relate to the special circumstances that differentiate the student – not to conditions that exist for ta whole class of students.
Professional judgment would not be used in circumstances where an independent student cannot be made a dependent student, a change cannot be made to the Federal Methodology need analysis formula, post-enrollment costs cannot be added to a student’s budget, etc.
The Director and FA staff have the authority to exercise dependency override. A dependency override will be considered on a case-by-case basis for students with unusual circumstances. Unusual circumstances do include abandonment by parents, an abusive family environment that threatens the student’s health or safety or the student being unable to locate his parents.
The situations that do not qualify for a dependency override:
Parents refuse to contribute to the student’s education.
Parents are unwilling to provide information on the FAFSA on or for verification.
Parents do not claim the student as a dependent for income tax purposes.
Student demonstrates total self-sufficiency.
Misrepresentation
If a Financial Aid staff member suspect misreported information or altered documents was received to fraudulently obtain federal funds, the student will be reported to the Office of Inspector General.
If a student is suspected of Title IV or State of Indiana fraud (e.g., falsified documents or forged signatures on an institutional application, documents submitted for verification of information on the application, or loan promissory note) an investigation will be initiated.
Title IV Fraud:
To report an issues, suggestion or leave positive feedback you can submit your case online or call the FSA Feedback System.
https://Feedback.studentaid.ed.gov
1-844-651-0077
Monday – Friday - 8:00 a.m. – 8:00 p.m.
State (Indiana):
To file a complaint or appeal regarding your Indiana grants you can submit your case online or call the Indiana Commission for Higher Education:
www.in.gov/CHE/
1-888-528-4719
Monday – Friday - 8:00 a.m. – 5:00 p.m.
Student Complaints
Documentation
Citizenship – a student must be one of the following to be eligible to receive federal student aid:
A U.S. citizen or national
A citizen of the Freely Associated States: the Federated States of Micronesia and the Republics of Palau and the Marshall Islands.
A U.S. permanent resident or other eligible noncitizen.
If a citizen must prove his status as a U.S. citizen or national, only certain types of documents are acceptable. The Department doesn’t specify all of the acceptable documents, but here are some documents that can be used to prove citizenship:
A Certificate of Naturalization (N-550 or N-570)
A Certificate of Citizenship (N-560 or N-561)
A copy of the student’s birth certificate
A U.S. Passport
A wallet-size passport card
A copy of Form FS-240 (Consular Report of Birth Abroad), FS-545 (Certificate of birth issued by a foreign service post) or DS-1350 (Certification of Report of Birth).
NOTE: other documents may be required by our ESL department.
The DHS assigns to all legal aliens an Alien Registration Number (ARN), which FSA uses to identify the student records that must be sent to DHS for immigration status verification.
If this data is match, the student may receive Title IV aid. If the record has data errors or the student’s noncitizen status has not yet been confirmed; DHS will continue to check its records in a process called secondary confirmation. Within three to five days, CPS should generate a SAR and ISIR indicating the results of the secondary confirmation. SMWC should wait at least 10 but no more than 15 days for the result of the automated secondary confirmation.
If the student did not pass secondary confirmation or we have conflicting information, a third step verification is required via the SAVE system.
Ability to Benefit
SMWC does not use Ability to Benefit testing to admit students or determine Title IV eligibility.