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© 2013 Cooley LLP, Five Palo Alto Square, 3000 El Camino Real, Palo Alto, CA 94306 The content of this packet is an introduction to Cooley LLP’s capabilities and is not intended, by itself, to provide legal advice or create an attorney-client relationship. Prior results do not guarantee future outcome. Implementing Academic Innovation – Non-Traditional Calendars Presented by: Rebecca Flake WASFAA Conference April 14, 2014

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Implementing Academic Innovation – Non-Traditional Calendars. Presented by: Rebecca Flake W ASFAA Conference April 14, 2014 . Agenda. Definitions Academic Calendars Modules and Intersessions Standard Term with Modules and Non-standard Term, Substantially Equal - PowerPoint PPT Presentation

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Page 1: Implementing Academic Innovation –  Non-Traditional Calendars

© 2013 Cooley LLP, Five Palo Alto Square, 3000 El Camino Real, Palo Alto, CA 94306 The content of this packet is an introduction to Cooley LLP’s capabilities and is not intended, by itself, to provide legal advice or create an attorney-client relationship. Prior results do not guarantee future outcome.

Implementing Academic Innovation –

Non-Traditional Calendars

Presented by:Rebecca Flake

WASFAA Conference

April 14, 2014

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Agenda

Definitions Academic Calendars Modules and Intersessions Standard Term with Modules and Non-standard Term,

Substantially Equal Awarding, Disbursing, and R2T4

Non-Standard Term, Not Substantially Equal and Non-Term

Awarding, Disbursing, and R2T4 Things to Consider

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Definitions

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Definitions

Term a period in which all classes are scheduled to begin and end

within a set time frame; generally a semester or quarter

Academic Year the number of instructional weeks and credits or clock hours

a full-time student must attempt in a school year

Instructional Week any period of 7 consecutive days in which at least 1 day of

regularly scheduled instruction, examination, or (after the last day of classes) at least 1 scheduled day of study for exams occurs

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Definitions

What is an academic calendar?

How an institution defines the calendar in which instruction is offered to students

Must be defined for each program of study

Can vary by program

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Academic Calendars

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Academic Calendars

Standard Term –

Quarter ranging between 10 and 12 weeks; but at least 9 weeks

Semesters ranging between 14 and 17 weeks Offered on set calendar Term lengths do not vary by more than 2

weeks (intersession exception) If quarters, award quarter credits; if semester,

award semester credits

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Academic Calendars

Standard term, continued-

Combine modules to make a term

Can attach an intersession

The payment period is the term and not the individual module (if module changes to non-standard term)

May award Title IV for some repeat coursework, if otherwise eligible

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Academic Calendars

Non-Standard Term, Substantially Equal –

Quarter or semester which are longer or shorter than standard length; term lengths do not vary by more than 2 weeks

Offer quarter credits in a semester or semester credits in a quarter

At least 9 weeks Generally administered the same as standard

term

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Academic Calendars

Non-Standard Term, Not Substantially Equal

Quarter or semester which are longer or shorter than standard length; term lengths vary by more than 2 weeks

Offer quarter credits in a semester or semester credits in a quarter

Administered as non-term

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Academic Calendars

Non-Term

Programs offered in clock hour

Overlapping terms or courses

Self-paced programs

Floating start and end dates

Most difficult to administer

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Academic Calendars

A program is required to be clock hours when -

Clock hours are required in the Federal or State approval or licensure process required to offer the program

Exception for limited program component

Completing clock hours is a requirement for graduates to apply for licensure or the authorization to practice the occupation that the student intends to pursue

The credit hours awarded for the program are not in compliance with the definition of a credit hour in 34 CFR 600.2

The institution does not provide the clock hours that are the basis for the credit hours awarded for the program or each course

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Modules and Intersessions

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Modules and Intersessions

What is a module?

A course that does not span the entire length of the term

Compressed course that is offered over a shorter timeframe than the traditional course offering

Must not overlap semesters to remain standard term

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Modules and Intersessions

Modules continued:

Generally the same amount of academic work in a shorter instructional period

Modules can work in a standard term calendar

Student may start modular course after term begins

The student may skip a module and not be withdrawn

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Modules and Intersessions

What is an intersession?

A period of time in which short optional courses are offered between longer standard terms

May only be attached to a standard term and make it longer than 15 weeks

Should not start or end during the standard term

Does not change a standard term into a non-standard term unless the intersession courses are required and not optional

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Modules and Intersessions

Intersessions continued –

Must attach to the same term for all students in the same program

Changes the end date of the loan period and R2T4 payment period, if the student enrolls

Credits for the intersession course are included in the enrollment status for the attached longer term – must include the intersession when awarding, if enrolled

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Modules and Intersessions

House with a Shed or Addition Analogy

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Standard Term with Modules and

Non-Standard Term, Substantially Equal

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Awarding - Standard Term with Modules and Non-Standard Term, Substantially Equal

Generally similar awarding with the exception of intersessions attachment to the standard term

Enrollment status for courses enrolled in the term – modular, full term, and intersession

Enrollment status may include limited repeat coursework – even within the term if needed

Cost of attendance is adjusted for periods of non-attendance – indirect costs and tuition and fees may differ from student to student

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Awarding - Standard Term with Modules and Non-Standard Term, Substantially Equal

Student may attend only the intersession and receive Title IV if they have sufficient enrollment status and COA

Pell Formula 1 or 3

Must recalculate Pell and CB for courses the student does not start – during the term, at the end of the term, or upon withdrawal

Modular schedule may increase number of recalculations

Enrollment changes late in the term must be considered

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Awarding - Standard Term with Modules and Non-Standard Term, Substantially Equal

May award loans for single term

The minimum loan period is the entire term even if the student only attends a single module

Loan Period: Scheduled Academic Year (SAY), Borrower-Based Academic Year 1(BBAY-1), Borrower-Based Academic Year 2 (BBAY-2)

Loan period end date will include the intersession as part of the term, if enrolled

Prorate loan awards only for final period of study

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Disbursement - Standard Term with Modules and Non-Standard Term, Substantially Equal

One disbursement of each fund type by term

Multiple disbursements within the term- if a single payment period loan and the school does not have a low

default rate; if it is in the best interest of student (by module) or; the non-standard term is longer than 4 months

Up to 10 days prior to the start of the term or later module

Disbursement for registered coursework if paid early and actual coursework if paid after class start

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Disbursement - Standard Term with Modules and Non-Standard Term, Substantially Equal

Delay disbursement until student begins their first module within term

Should not delay disbursements until student begins all courses or at least half-time

Clearly communicate disbursement policy to students enrolled in modules who will not receive disbursement at the start of the term

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R2T4 - Standard Term with Modules and Non-Standard Term, Substantially Equal

Perform R2T4 calculation when a student stops attending all courses at any point in the term

Official and unofficial withdrawals – all unearned grades

Calculation not required if student provides notification of intent to attend a module later in term unless they do not return

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R2T4 - Standard Term with Modules and Non-Standard Term, Substantially Equal

Review enrollment status for Pell recalculation

No recalculation required for loans unless not disbursed – consider revised enrollment status for loan PWD

If attendance taking or academic engagement monitoring - use the last day of attendance or last day of academic related activity as withdrawal date

May use midpoint if non-attendance taking or academic engagement monitoring

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R2T4 - Standard Term with Modules and Non-Standard Term, Substantially Equal

Use modules enrolled at point of withdrawal to calculate total days; excluding days on scheduled break and LOA

If only enrolled in modules 1 and 3, exclude days in module 2 when calculating total days

If enrolled in both term courses and module courses, use the longer period to calculate total days

Calculate tuition liability for enrolled modules based on institutional policy

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Non-Standard Term, Not Substantially Equal

and Non-Term

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Awarding- Non-Standard Term, Not Substantially Equal and Non-Term

Awards based on the lesser of a full academic year, program length or remaining period of study

Academic year awards are usually full-time

Pell Formula 4; Formula 5A for Correspondence

Must prorate all awards for periods less than a full academic year

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Awarding- Non-Standard Term, Not Substantially Equal and Non-Term

Payment period for loans only in final period of study

May not award funds for repeat coursework

BBAY 3

Advance grade level after successful completion of prior academic year

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Disbursement - Non-Standard Term, Not Substantially Equal and Non-Term

Pell may be disbursed by payment period

Loans limited to two disbursements at start and midpoint

Student must successfully complete the prior payment period in weeks and credit/clock hours

Failing grades delay disbursement

Disbursement up to 10 days before payment period if prior period is successfully completed

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R2T4 - Non-Standard Term, Not Substantially Equal

Perform R2T4 calculation when a student stops attending at any point during the payment period

If unequal disbursement schedule, use longer loan payment period and project the remaining Pell disbursement for the same period

Calculation not required if student provides notification of intent to return within 45 days unless they do not return

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R2T4 - Non-Term

Intent to return to a later module within 45 days

The payment period end date must be modified for additional coursework required due to failure

For clock hour programs, the numerator includes the scheduled clock hours to have been completed through the last day of attendance in the payment period; denominator is all clock hours in payment period

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Things to Consider

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Things to Consider

System programming considerations to accommodate non-traditional calendars:

Alternate course start and end dates within the term

Varying COA/need calculations

SAP calculations to consider all courses within the term

Transcript consistency

R2T4 considers alternative start and end dates

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Things to Consider

Drop and add periods for modules and intersession

Tracking initial attendance in all modules and intersession

Varying disbursement dates

Varying processing schedules

Crossover award tracking

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Things to Consider

Operational Considerations: Alternative billing processes and impact on institutional refund

policy

Impact on state-funded programs

New policies and procedures

Communication with impacted offices/departments

Communication with students

Implementation and compliance monitoring

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Things to Consider

Communication with students:

The possible availability of Title IV funds from the earlier award year if they start classes in a cross over period and the required application process; may need to complete two FAFSAs

The delay of disbursement of funds until their module begins

The SAP evaluation process is not impacted by modular courses – no early evaluations

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Questions?

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Thank You!Rebecca Flake

Senior Advisor Higher Education Services

Cooley, LLC202-776-2343

[email protected]