Tuesday, May 24, 2016
The most it's possible to spend at our school in one semester in tuition and fees is about $1600. Add in books, and you might get a bit over $2000, but it depends on the program of study. Usually semester balances are under $2000.
While we were in the direct loan program, though, students were eligible for $9500 in their first year, and $10,500 in their second year. Students are able to borrow as much as they'd like up to that limit, AND, it is their choice on how to allocate that. They can opt to take the whole amount in a single term.
We had many students take a maximum loan amount in one term. Many of these students were also Pell eligible and able to get about another 1900 - 2000 per term from Pell.
Students with credit balances in the $7,000 - $10000 range became common.
The college was only able to hold the credit balance until the 28th day of the term, after which it is required to be release. The problem, though, is that if the student stops attending before the 60% mark, the school is forced to return a prorated amount of the Title IV funds (Pell & Direct loans).
After the second year of the program, the school ended up needing to return over $500,000 due to students coming in and disappearing after getting the credit balance check. This was a direct loss to the school, as it's not as if the money was still on campus paying for services such as housing or dining. It was mostly returned credit balances.
Had we been able to limit the amount of the loan to smaller amounts, it would have reduced the amount of R2T4 payments. Additionally, it would have made us a much less attractive option for people to get a quick check.
I know it sounds like some sort of troll-y conservative doom speak to focus on fraud and abuse, but this really did represent the substantial majority of our R2T4 payment situation. It took about 2 or 3 terms for word to get around, and after that the 28 day walk offs began to go way up.
For low cost access institutions, limiting loan amounts makes a boat load of sense. Or, at minimum, allowing schools to hold the balance until the 60% mark passes would just be common sense.
So yes, theoretically, a student can show up for two weeks, get paid, and then disappear leaving us on the hook for some of the funding. I don't know how often this happens, but probably much more than I am aware of.
And if I recall correctly, we used to verify attendance a little later (third or fourth week), but it was moved up for some reason or another -- I think it was either to help the financial aid office get a head start on all the paperwork or to accommodate the students (since having that one or two thousand dollars available makes a big difference for many of them).
If your school is holding refunds from Title IV funds past the 28th day of the term, they are in violation. The practice will not survive a Title IV audit. Some of the other schools in our system found this out the hard way, and were placed on heightened cash flow monitoring - that's not fun.
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And if there's one thing I've learned from working in this area for 14 years, it's that you'd be amazed at what the various financial aid offices at schools, both large and small, don't know about the actual rules.
One of the issues is that Federal audits are super slow to happen. Our last one was over 10 years ago. We learned some hard lessons though, as a few schools in our state system had their audits 2 years back. The 20 some odd schools in our system are separate and individually accredited, but we standardize a whole lot between us. After those 3 schools had negative audits, we learned we were doing some things wrong system wide.
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