March 8, 2011

Do You Know?

Final Rules

Each month, we provide information about a specific Final Rules topic. This month, we’ll continue the discussion with an explanation of the Program Integrity (PI) Rules that will go into effect on July 1, 2011; specifically, the topic of repeating coursework. (Check out last month’s Online News to read about the impact of several verification process changes.)

Repeating Coursework

The PI Rules published on Oct. 29 changed the definition of “full-time student” in regard to the repetition of course work. The PI Rules amend the definition of full-time student by:

• Adding the phrasing, “… including for a term-based program, repeating any coursework previously taken in the program.”
• Establishing that a student in a term-based program may be paid for repeating coursework one time only by conditionally counting it in the student’s enrollment status.

The revised rule also applies to three-quarter, half-time and less-than-half-time enrollment statuses. The one-year academic limitation on non-credit and reduced-credit remedial coursework is not affected.

Though ED's intent is to prevent students from using federal funds to repeat courses they have already successfully completed, it could also have negative consequences for financial aid eligibility for courses that have evolving content but retain the same course number from semester to semester (e.g. dissertation or thesis courses). Schools that use duplicate course numbers for courses with varied content should review their course numbering systems to see if modifications are required to avoid any negative impact from this new rule.

ED’s goal was to limit the provision so that it would not include more than one repetition of a previously-passed course or any repetition of previously-passed coursework that would be taken due to the student’s failure of other coursework. The provision applies to non-standard terms, but not to non-term programs, since the student must successfully complete the credit or clock hours in a payment period before advancing to the next. If a school permits repeated coursework in term-based programs, it will need to monitor repeated coursework to ensure that the one-time-only rule is followed.

If you have questions about the final rules, check out our session at the OASFAA conference or contact our Policy Analyst, Matt McCreary, at 405.234.4296 or mmccreary@ogslp.org.