02 Jan Changes to the Unusual Enrollment History Review Process

by Stacey Musulin, Assistant Director, ConnSCU BOR (CT Community Colleges)

Attendees at the 2014 Federal Student Aid (FSA) conference in Atlanta may have heard about upcoming changes to the Unusual Enrollment History (UEH) review process for the 2015-2016 year.

As you recall, beginning in the 2013-14 award year, the Department of Education (ED) announced its intention to combat fraud in the Pell Grant program by identifying students whose enrollment patterns appeared unusual (i.e., Pell disbursements at multiple schools within certain timeframes). Via the use of certain UEH codes and communication codes (C-codes), institutions would be able to find students selected for review and perform an analysis of Pell disbursement for the prior three award years.  (see Dear Colleague Letter GEN-13-09 dated 3/8/2013)

In the NSLDS Update session at the FSA conference, attendees were given a sneak peek of the upcoming changes (see slide below with correction), with official guidance from ED to be forthcoming at a future date.

What will stay the same for 2015-16:

• UEH Codes (2/3) and values
• C Flags (359/360) for UEH
• The procedure for resolving UEH C Flags

What will be different for 2015-16:

• Four (instead of 3) prior award years will need to be reviewed
• Both Loan and Pell histories will need to be reviewed (versus Pell alone)

As of this writing, no Dear Colleague Letter or Electronic Announcement as arrived, but Financial Aid Administrators should monitor their email and the Information for Financial Aid Professionals (IFAP) site for this topic. Also as of this writing, the SAR Comment Codes and Text document for 2015-2016 has not yet been amended to include the four-year lookback.