Experimental Sites

Experimental Sites Initiative - Questions and Answers
Below is a set of questions and answers regarding the ending of the existing experiments as of June 30, 2012. It also includes links to the relevant regulations.

General questions are listed first followed by questions for each individual experiment.

General Questions

Q1: With the ending of the current experiments as of June 30, 2012, will schools be required to submit reports for AY 11-12?
A1:  With the ending of the experiments, schools need not report information to the Department on the experiments that end as of June 30, 2012.  However, schools must maintain documentation of 2011-2012 data related to the experiments.

Q2: Is it necessary for a school to include in their policies and procedures when the experiments in which they participated ended?
A2:  Yes.  An auditor or program reviewer would need to know when a school’s regulatory exemptions were applicable and when the school had to follow the regular statutory and regulatory requirements.

Loan Proration for Graduating Borrowers
Section 425(a)(1)(A)(ii)(II) and (iii)(II); Section 428(b)(I)(A)(ii)(II); 34 CFR 685.203(a)(3)(ii)

Q1: If a school certified a summer loan prior to July 1, 2012, does the loan need to be prorated?
A1: Under the experiment, if the loan was certified by the school prior to July 1, 2012,for a loan period that began before July 1, 2012, no proration is required even if all or a portion of that loan is for summer of 2012.  This applies to all students, not just graduating borrowers. Otherwise loan proration would apply, when applicable, for loan periods that begin on or after July 1, 2012.

Q2: Since the experiment is ending, is there any discussion on making changes to the existing regulations so that the student is not subject to proration?
A2: No.The loan proration requirements are statutory not regulatory. 

Credit Title IV Aid to Prior Term Charges 34 CFR 668.165(b)(i)
Credit Title IV Aid to Institutional Charges 34 CFR 668.164(b)

Q1: The regulations provide that Title IV student aid can be used to pay institutional charges other than tuition, fees, room and board if the school obtains a written authorization from the student (or parent) to do so. Can the authorization be submitted to the school by email from a university-assigned and secured email account?  Or may we build a secured interactive web site similar to e-consent?
A1: Yes, an e-mail or other secure electronic process is sufficient, as long as the process can reasonably ensure that the person providing the authorization is who he or she says they are.  The use of an electronic PIN or similar process would be acceptable. 

Q2: What are the requirements for using Title IV aid to pay prior year charges?
A2: Under the regulations, the amount of prior year charges, of any type, that can be paid with current year Title IV aid is limited to a total of $200.  If those charges are for something other than prior year tuition and fees, the student's authorization is required.

Q3: Can students who were enrolled at a school in the experiment to Credit Aid to Institutional Charges through the 2011-2012 award year be grandfathered in so that schools do not have to obtain the student's authorization to credit Title IV aid going forward? 
A3: Yes, for any student who participated in this experiment and is continuously enrolled, the school does not have to obtain the student’s authorization to credit Title IV aid going forward as long as the student did not opt out of this crediting option.  Students who begin attendance at the institution for the 2012-2013 or subsequent award years will be required to provide authorization.  

Entrance Loan Counseling
34 CFR 674.16(a) (1) (iv), (vii), (xi) and (xii) (Perkins); and 34 CFR 685.304(a) (Direct Loans)

Q1: Can students that borrowed prior to the 2012-2013 award year be grandfathered and therefore not subject to entrance counseling for the 2012-2013 and subsequent award years? 
A1: Yes, any student who borrowed a Direct or FFEL loan for a loan period that began on or before July 1, 2012 is not required to participate in entrance counseling.

Exit Loan Counseling
485(b) of the Act and the following regulations: 34 CFR 674.42(a) (Perkins); and 34 CFR 685.304(b) (Direct Loans)

Q1: Since the experiment ends on June 30, 2012, will students who graduate before July 1, 2012 be required to complete an exit interview?
A1: No.  Students will be required to have exit counseling only upon leaving school on or after July 1, 2012.

Loan Fees in Cost of Attendance
Section 472(12) of the Act

Q1: Do schools have to begin adding loans fees to students' budgets starting with: 1) loans that are disbursed after June 30, 2012; OR, 2) can schools begin adding loan fees to students' budgets starting with loan periods that begin in the 2012-2013 academic year?
A1: The school must add loan fees for loans that have loan periods that begin after June 30, 2012.