The U.S. Department of Education (ED) confirmed to NASFAA the following information: “We recently obtained guidance from ED ---- …the consortium doesn’t impact the student’s eligibility for Title IV aid and the program’s academic year is not affected if the coursework taken at the host school overlaps/does not take place in same timeframe as the home school’s standard term. The school that awards Title IV aid should do so based on its own academic calendar and using a Direct Loan period that encompasses the beginning and ending dates of actual enrollment.”
Consortium Agreement: A consortium agreement is between two or more Title IV-eligible institutions. Under a consortium agreement, the Home Institution is the school at which the student is enrolled as a regular student under 34 CFR 600.2 and that will award the student's degree.The Teaching Institution is not awarding the degree.
Cost of Attendance (COA): It is important to ensure that the COA accurately reflects the period in which the student will be enrolled, particularly related to room and board or transportation expenses.Normal COA allowances used for those items may not reflect the estimated expenses the student would incur when enrolled for a longer period or in a different locale.
Academic Year: The academic year format is not affected if the coursework taken at a Teaching Institution overlaps or does not take place within the same timeframe as the Home Institution’s normal terms. If the Home Institution is the school awarding aid, it must include credits taken at the Teaching Institution in the student’s enrollment status for a term that occurs at a time reasonably like the timeframe for the Teaching Institution’s coursework.
Enrollment Status: The Home Institution must agree to treat all the coursework taken at the Teaching Institution the same as if those courses were taken at the Home Institution, and that the courses taken at the Teaching Institution will transfer and count toward degree completion at the Home Institution.
Awards and Disbursements: Federal Pell Grants, TEACH Grants, and campus-based aid will continue to be awarded based on the Home Institution’s academic calendar and disbursed based on the Teaching Institution’s calendar. Direct Loans must be awarded and disbursed based on the Teaching Instituiton’s academic calendar and the student’s actual dates of enrollment.Under the 150% subsidized loan limitation and associated Common Origination and Disbursement (COD) reporting requirements, the academic year and loan period reported to COD should reflect the actual period for which the loan is being originated.
Satisfactory Academic Progress (SAP): SAP must be evaluated by the Home Institution using its own standards. If a student is in a consortium agreement, a different timeframe for review may be established. The Home Institution must publish clear information about the intervals for students studying under a consortium agreement. Note that if a student is still engaged in coursework at the Teaching Institution when the Home Institution evaluates SAP, the coursework must be treated per the Home Institution’s policies for incomplete coursework.
Return of Title IV Funds (R2T4): If the student withdraws during the payment period or period of enrollment covered by the consortium agreement, the institution awarding, and disbursing aid must complete the R2T4 calculation. In the R2T4 calculation, the denominator would consist of all the days the student was scheduled to attend at both the Home and Teaching Institution. The numerator would include all the days attended at either institution.
COD Reporting Requirements: Since the student’s Home Institution awards the Title IV aid, it is responsible for reporting to COD.The academic year, loan period, and disbursement dates reported should be those of the Home Institution.
NSLDS Reporting Requirements: The student’s enrollment status is always reported to NSLDS by the Home Institution. The Home Institution is responsible for accurate and timely reporting to NSLDS of a student’s withdrawal or graduation dates, as well as any changes in the student’s enrollment status.
Reference 34 CFR 668.5 of the Student Assistance General Provisions regulations and Volume 2, Chapter 2 of the FSA Handbook.