Federal Student Aid Policies & Procedures

Verification Process and Procedures

CSU must check the accuracy of all applications the Central Processing System (CPS) selects for verification, up to 30 percent of our total number of federal aid applicants. The CPS will select applicants for verification due to edit checks which identify inconsistencies or potential errors, as well as randomly select applicants for verification. CSU must also verify any application information that it has reason to believe is incorrect or discrepant. If the CPS selects an application for verification, it is required that CSU verifies five major data elements:

  • Household size
  • Number enrolled in college
  • Adjusted gross income (AGI)
  • U.S. income tax paid
  • Certain untaxed income and benefits
    • Social Security Benefits
    • Child Support Received
    • IRA/Keogh deductions
    • Foreign income exclusion
    • Earned income credit
    • Interest on tax free bonds
    • Welfare benefits including TANF

Students selected for verification are sent a letter including instructions regarding the documents that should be submitted to CSU within ten days.  The file is held on a pending status and no award will be made until the requested documentation has been received and reviewed.  Exceptions are granted for students that are only eligible for unsubsidized Stafford loans, and PLUS loans as these applications do not have to be verified.

The data reported on the verification worksheet, federal tax returns, and other supporting documentation provided is checked against the appropriate data elements on the Institutional Student Information Record (ISIR).

Generally speaking, when the new information conflicts with the original information presented on the FAFSA, corrections, updates, and adjustments may need to be made and a new expected family contribution (EFC) calculated.  The new EFC can be calculated by the school and only needs to be submitted to CPS for students eligible for Federal Pell Grants. 

Global Financial Aid Services (GFAS) assists CSU with verification and their staff will also contact students with instructions for submitting the necessary documentation

Undergraduate Grade Level Determination

Any student pursuing an undergraduate degree must be classified by grade level, as well as meet grade level progression in order to comply with the requirements of FSA and the Federal Family Education Loan (FFEL).  Graduate students do not have grade level requirements.

Please refer to the table below to determine the grade level or the progression rate of an undergraduate student.

Number of Credits Completed Student’s Grade Level
0 to 24 credits

 Freshman
25 to 48 credits

 Sophomore
49 to 72 credits

 Junior
73 or more credits

 Senior

Grade level progression occurs after 24 semester hours are successfully completed.  This is based off of the federal requirement that an academic year must meet minimum requirements.  At CSU, this means a minimum of 24 semester hours and a minimum of 30 weeks of instruction.

Any new student entering CSU wishing to use FSA must first be fully accepted into an approved program.  The results of the evaluation will determine what credit will transfer into CSU, which will also determine the student’s current grade level.  While attending CSU, the student will need to submit a course transfer request form if subsequent coursework is completed outside of CSU.  Then the student’s grade level would be recalculated using the additional transfer credit to ensure that the student’s account and grade level will be accurate.

Regarding loan limits associated with a student’s grade level, a student will only progress to a higher grade level once he/she begins a new academic year.

Loan Counseling

Loan Entrance/Exit Counseling (Required)

The U.S. Department of Education requires that any student receiving a FFEL complete loan entrance and exit counseling. Loan entrance counseling provides information to students concerning how to manage student loans, both during and after college. Exit Counseling is generally required once a student drops below half-time enrollment status, withdraws or graduates. The student must notify the CSU Office of Financial Aid prior to withdrawal or graduation for loan counseling.  The purpose of loan exit counseling is to inform the student of their tentative total loans received while in attendance at CSU and to provide the student with an estimated payment schedule.

Borrower Rights & Responsibilities

When a student takes on a student loan he/she has certain rights and responsibilities.
The borrower has the right to receive the following information before the first loan disbursement.

  • The full amount of the loan
  • The interest rate
  • When the student must start repaying the loan
  • The effect borrowing will have on the student's eligibility for other types of financial aid
  • A complete list of any charges the student must pay (loan fees) and information on how those charges are collected
  • The yearly and total amounts the student can borrow
  • The maximum repayment periods and the minimum repayment amount
  • An explanation of default and its consequences
  • An explanation of available options for consolidating or refinancing the student loan
  • A statement that the student can prepay the loan at any time without penalty

The borrower has the right to receive the following information before leaving school.

  • The amount of the student's total debt (principal and estimated interest), what the student's interest late is, and the total interest charges on the loan(s)
  • A loan repayment schedule that lets the student know when his/her first payment is due, the number and frequency of payments, and the amount of each payment
  • If the student has FFEL Program Loans, the name of the lender or agency that holds the student's loan(s), where to send the student's payments, and where to write or call if the student has questions
  • The fees the student should expect during the repayment period, such as late charges and collection or litigation costs if delinquent or in default
  • An explanation of available options for consolidating or refinancing the student's loan
  • A statement that the student can repay his/her loan without penalty at any time

The borrower has a responsibility to do the following.

  • Understand that by signing the promissory note, the student is agreeing to repay the loan according to the terms of the note
  • Make payments on the student loan even if the student does not receive a bill or repayment notice
  • If the student applies for a deferment or forbearance, he/she must still continue to make payments until notification that the request has been granted
  • Notify the appropriate representative (institution, agency, or lender) that manages the student's loan when the student graduates, withdraws from school, or drops below half-time status; changes his/her name, address, or Social Security Number, or transfers to another institution
  • Receive entrance counseling before being given the first loan disbursement, and to receive exit counseling before leaving school

FSA Disbursements

When a student applies for financial aid, the package awarded is based on an academic year. The academic year consist of 4 terms (32 weeks).  FSA awarded for the academic year will be divided into four payment periods that will cover each term.

Pell Grant disbursements will not post to a student’s account until after day 14 of the term.  Excess Pell funds will be refunded to the student no sooner than 21 days after the term starts. After the first week of the term has ended, CSU will verify that first week of assignments have been completed in all courses enrolled for that term.  It is very important that a student completes the first week of instructional requirements; otherwise it will result in the student being institutionally dropped from the course(s).  Any Pell eligible student institutionally dropped from a course(s) will have an adjustment to their award. 

Federal loans for students will also not be disbursed to CSU until attendance has been confirmed.   Excess loan funds will be refunded to the student (or lender if designated by the student) within 14 days of receipt by CSU or no sooner than 21 days after the term starts.

Once federal funds have been disbursed, students will receive a disbursement notice via email from the CSU Office of Financial Aid.

Loss of Financial Aid Eligibility

Federal regulations require CSU to establish and apply reasonable standards of Satisfactory Academic Progress (SAP) for eligible students to receive financial assistance under the programs authorized by Title IV of the Higher Education Act.  CSU students who wish to be considered for financial aid must: 

  1. be in good standing at the university and
  2. maintain satisfactory academic progress in their program of study as set forth in this policy. 

SAP is a FSA eligibility requirement and is administered by the university in addition to the academic standards of performance required under the CSU Academic Progress Policy.  The SAP policy is reviewed annually by the CSU Financial Aid Committee.

For more information, please visit the Term Enrollment System Policies page.

Transfer Credits

Transfer credits accepted toward the student’s degree program will be included when calculating the SAP Credit Hour Completion Ratio (Quantitative Measure).  This includes credit for English as a Second Language (ESL) and remedial courses, if accepted toward the degree program.

Repeated Courses

Students receiving Title IV Aid may repeat a course, as allowed under CSU academic policy.  Repeated courses will count toward the quantitative progress requirement of SAP.  They will also count towards the maximum time frame for eligibility.

Incomplete Grades
Students receiving Title IV Aid may receive incomplete grades, as allowed under CSU academic policy.  Incomplete grades will count toward the quantitative and maximum time frame elements of SAP.  Students who do not complete course requirements after an incomplete grade is assigned will receive a course grade based on the assignments completed with zeros being assigned for non-completed assignments.

Second Bachelor’s Degree
Students who are pursuing a second CSU bachelor’s degree will have a maximum financial aid eligibility of 100 percent of the second-degree requirements.  The timeframe limitation in a second CSU bachelor’s degree is 90 credit hours, including transfer credits. 

Financial Aid Probation
Students who do not maintain SAP under this policy will initially be placed on Financial Aid Probation and notified of their probationary status.  While on Financial Aid Probation, they will be eligible to receive financial aid for their next 12 semester hours.  Students on Financial Aid Probation will be reviewed at the end of each period of enrollment.  If they do not meet all conditions of SAP at the end of their Financial Aid Probation period, they will have their financial aid eligibility suspended. 

Suspension of Federal Student Aid
By statute, students on Financial Aid Probation who do not meet SAP requirements after the probationary period are ineligible for Title IV Federal Student Aid programs.  Students who do not maintain SAP or fail to meet the conditions of their Financial Aid Probation will be notified by CSU and suspended from receiving Title IV Federal financial aid.  Students may appeal suspensions by completing the SAP Appeal Petition.  Requests for reinstatement of eligibility must be made to the CSU Office of Financial Aid no later than one month prior to the term in which the student desires to enroll.  Reinstatement following suspension is not automatic.

Financial Aid Appeal Procedure

Students may appeal their suspension of financial aid if the student were unable to meet SAP requirements as a direct result of undue hardship or special circumstances, as stated in the federal regulations. Situations such as the death of a student’s relative, personal injury or illness sustained by the student, or other unusual circumstances may prevent a student from achieving SAP. As a result, students have the right to appeal their financial aid suspension by completing the SAP Appeal Form. The appeal will be reviewed by a committee and, if approved, the student will be notified in writing and granted an additional probationary period of 12 semester hours (attempted hours) in which they will receive financial aid and reestablish eligibility under SAP.

Reestablishing Financial Aid Eligibility

A student not making SAP may re-establish eligibility on his or her own, either because an appeal was denied or because he or she did not submit an appeal. A student can re-establish SAP on his or her own by completing enough hours with an acceptable GPA to bring their statistics back to an acceptable level.

Return of Title IV Funds

The CSU Business Office is notified by the CSU Student Services Department or by the student of the student’s withdrawal.  Based on this notification, the student file is pulled, the withdrawal information is reviewed, and an R2T4 calculation is performed if appropriate. 

All Leave of Absence (LOA) requests should be submitted no later than the student’s last day of attendance for consideration.  If they are approved for an LOA then no R2T4 calculation is performed (unless the student fails to return.) 

All withdrawal files must be reviewed within 30 days to comply with Federal Post Withdrawal Disbursement calculation regulations.

If a student has received Federal Stafford/PLUS loan funds or Federal Grant funds during their current period of enrollment, and there is a break in their attendance that is considered a withdrawal, an R2T4 calculation is required to be performed.  If a student has not yet been awarded, but has a valid ISIR for the current award year, and is Federal Grant eligible based on their ISIR, an R2T4 calculation is needed to discover potential Post Withdrawal Disbursements for the Federal Grant.

When a student withdraws from CSU or is withdrawn by the institution where the break in attendance is greater than seven days, and the student did not receive approval for an LOA, this is considered a withdrawal. These withdrawals require an R2T4 calculation if Federal funds have been disbursed for the current payment period, or if the student is eligible for a post withdrawal disbursement of federal funds.

For current financial aid recipients, a tuition percentage will be determined based on the return of Title IV funds regulations.  The CSU Office of Financial Aid determines the return of Title IV funds percentage and informs the Business Office.  Institutions are required to determine the percentage of Title IV aid “earned” by the student and to return the unearned portion to the appropriate aid program.  This percentage is determined by the percentage of the enrollment period completed by the student, as outlined below.

The return of funds policy follows these steps.

  • Determine the percentage of the enrollment period completed by the student.

Days Attended ÷ Days in Enrollment Period = Percentage Completed
If the calculated percentage exceeds 60 percent, then the student has “earned” all Title IV aid for the enrollment period.

  • Apply the percentage completed to the Title IV aid awarded to determine the student's eligibility for aid prior to the withdrawal.

Total Aid Disbursed   x   Percentage Completed   =   Earned Aid

  • Determine the amount of unearned aid to be returned to the appropriate Title IV aid program.

Total Disbursed Aid - Earned Aid = Unearned Aid to be Returned
If the aid already disbursed equals the earned aid, no further action is required.  If the aid already disbursed is less than the earned aid, a late disbursement will be made to the student.  If the aid already disbursed is greater than the earned aid, the difference must be returned to the appropriate Title IV aid program.

  • Distribute the responsibility to return funds between the institution and the student.

CSU and the student are both responsible for returning unearned funds to the appropriate programs in specific loan/grant order.  The institution must return the lesser of:

  1. The total amount of unearned aid; OR
  2. Institutional charges multiplied by the unearned percentage.

Amounts that must be returned will first be applied to federal loans and then to grants.  Loan borrowers will be permitted to repay loans based on the terms of the promissory note.

The student will also be billed for any amount due to CSU resulting from the universities return of federal aid funds.  For example, if CSU is required to return federal aid, which was used to pay a portion of the student’s charges for the enrollment period, the student is required to pay CSU for the unpaid portion of the charges.

If a student owes any money to the school resulting from the return of federal aid funds, the student will receive a bill from the accounting office.

Any refund or repayment obligation will be clearly outlined for the student in writing and will also appear on their CSU bill.

  • Return the Title IV aid, based on the type of aid disbursed, in the following order:
  1. Federal Unsubsidized Stafford Loan
  2. Federal (Subsidized) Stafford Loan
  3. Federal PLUS (Parent) Loan
  4. Federal Pell Grant

If the contracted charges are adjusted downward by the Business Office after the withdrawal was finalized, any credit balance will be refunded to the funding source in the order outlined above.

The student's grace period for loan repayments for Federal Unsubsidized and Subsidized Stafford Loans will begin on the day of the withdrawal from CSU.  The student should contact the lender if they have questions regarding their grace period or repayment status.

The student's eligibility for future financial aid may change based on their withdrawal from CSU and SAP standards.

Post-Withdrawal Disbursements

The requirements for a post-withdrawal disbursement are similar in many ways to the requirements under Subpart K – Cash Management of the Student Assistance General Provisions regulations. However, in some cases, the post-withdrawal disbursement requirements differ from the cash management requirements. Any post-withdrawal disbursement due must meet the current required conditions for late disbursements. For example, The U.S. Department of Education must have processed a Student Aid Report (SAR) or Institutional Student Information Record (ISIR) with an official EFC prior to the student’s loss of eligibility. These conditions are listed in a chart on Late Disbursements in Volume 4 – Processing Aid and Managing Federal Student Aid Funds. A school is required to make (or offer as appropriate) post-withdrawal disbursements. A post withdrawal disbursement must be made within 180 days of the date the institution determines that the student withdrew. The amount of a post-withdrawal disbursement is determined by following the requirements for calculating earned FSA, and has no relationship to incurred educational costs.  Global Financial Services (GFS) is responsible for notifying the student of the post withdrawal disbursement.  They will also track this process and make any disbursements.  This will be done on behalf of CSU. 

Procedures

  • If a student is eligible for a post withdrawal of a federal grant, it will be disbursed within 45 days of the date of determination of withdrawal. 
  • A student/parent is notified of eligibility for a post-withdrawal disbursement of a Federal loan within 30 days of the withdrawal date by email and must respond within fourteen days.
  • If student/parent accepts the post withdrawal disbursement of a federal loan, it must be made as soon as possible but no later than 180 days of the withdrawal date.
  • GFS will track this notification and make appropriate updates in the system as necessary. 
  • When the student/ parent’s response is received by GFS it will be updated in the system. 
  • The priorities for disbursement are grants first; paid to outstanding institutional charges before being paid directly to student.

Returning Unearned Funds

CSU and the student could both be responsible for returning unearned funds to the appropriate programs in specific loan/grant order, depending on the result of the R2T4 calculation. CSU must return the lesser of:

  1. The total amount of unearned aid; OR
  2. Institutional charges multiplied by the unearned percentage.

Amounts that must be returned will first be applied to federal loans and then to grants.  Loan borrowers will be permitted to repay loans based on the terms of the promissory note.

The student will also be billed for any amount due to CSU resulting from CSU return of federal aid funds.  For example, if CSU is required to return federal aid, which was used to pay a portion of the student’s charges for the enrollment period, the student is required to pay CSU for the unpaid portion of the charges.

If a student owes any money to CSU resulting from the return of federal funds, the student will receive a bill from the Business Office.

Disclosure of Preferred Lender List

CSU acknowledges and explicitly states that borrowers always have a choice in selecting a FFELP lender.  We cannot and will not deny borrowers of that choice.  Our goal is to provide students with the best service available, so by developing a preferred lender list we feel that we have eliminated some of the student’s homework.  Each of the lenders that CSU has chosen to be listed on the preferred lender list has been presented with a standard questionnaire that explains why they should be listed as a preferred lender for CSU.  Below are some of the questions that each lender was required to answer.

  • What is the mission and vision statement of your company?
  • How many years has your company been in business?
  • Where does your company rank in comparison to your competitors?
  • Can the borrower access and manage their account online 24/7?
  • How convenient are the call center hours of your company?
  • What are your borrower benefit offerings?
  • Does your company advise borrowers on debt management/default prevention?
  • What are your value-added services or additional benefits that would provide service above and beyond to the borrower and CSU?

These are just a few of the questions presented to each of the lenders on our preferred lender list.  CSU prides itself on providing customer service at the highest level.  The customer service these lenders provide to our students and school will greatly impact the success of our students achieving their educational goals.  One of the most important things for a student to remember about getting loans to help pay for school, is that the student has the choice to select any lender they wish to use. 

Summer 2010 Crossover Policy

CSU will assign the summer 2010 crossover period to the 2009-10 award year for all students who have completed a 2009-10 FAFSA with no comparison to the 2010-11 FAFSA.

For new students with a 2010-11 FAFSA only, the financial aid award will be based off the students 2010-11 EFC and Pell eligibility. However, if a student becomes eligible for 2009-10 Pell Grant in excess of their 2010-11 Pell Grant eligibility, the financial aid award will be revised so the student receives the greatest benefit.

Satisfactory Academic Progress Policy (SAP)

Federal regulations require CSU to establish and apply reasonable standards of Satisfactory Academic Progress (SAP) for eligible students to receive financial assistance under the programs authorized by Title IV of the Higher Education Act. CSU students who wish to be considered for financial aid must:

  1. be in good standing at the university and
  2. maintain satisfactory academic progress in their program of study as set forth in this policy.

SAP is a FSA eligibility requirement and is administered by the university in addition to the academic standards of performance required under the CSU Academic Progress Policy. The SAP policy is reviewed annually by the CSU Financial Aid Committee.

The CSU Office of Financial Aid measures progress on the basis of credit hours. Students are evaluated at the end of every term for SAP once they have completed 12 hours. All students are evaluated on three standards: grade point average (qualitative measure), semester hours completion ratio (quantitative measure), and maximum timeframe. To maintain eligibility under SAP, students must meet all three standards.

Standard 1: Grade Point Average (Qualitative Measure)

Students must maintain a minimum qualitative measure of progress defined as the cumulative GPA. The requirements are listed below:

  • Students in undergraduate programs must maintain a 2.0 cumulative GPA.
  • Students in graduate programs must maintain a 3.0 cumulative GPA.

Standard 2: Semester Hour Completion Ratio (Quantitative Measure)

Students (either full-time or part-time) must maintain a minimum incremental progress by completing a percentage of all semester hours attempted. Progress is evaluated at the end of each term. Hours attempted include courses as well as repeated courses, withdrawals, and incompletes. All students must successfully complete 67 percent of all cumulative credits attempted.

Standard 3: Maximum Timeframe

Students must complete their degree program within 150 percent of the semester hour requirements for the degree. Students must complete an associate's degree within 90 semester hours, a bachelor's degree within 181 semester hours, and a master's degree within 55 semester hours. Students who are unable to complete their degree program within the timeframe limitation will be suspended from FSA programs. The maximum timeframe limit may be reevaluated by the CSU Director of Financial Aid if there are program changes that can eliminate prior courses that do not apply toward the current degree program.

SAP Notification

Students are notified of the SAP policy in the CSU catalogue and website. All periods of enrollment at CSU are calculated in SAP, including periods of enrollment during which a student did not receive financial aid. Cumulative GPAs are calculated using grades earned at CSU.

Transfer Credits

Transfer credits accepted toward the student's degree program will be included when calculating the SAP Maximum Timeframe. This includes credit for English as a Second Language (ESL) and remedial courses, if accepted toward the degree program.

Repeated Courses

Students receiving Title IV Aid may repeat a course, as allowed under CSU academic policy. Repeated courses will count toward the quantitative progress requirement of SAP. They will also count towards the maximum time frame for eligibility.

Incomplete Grades

Students receiving Title IV Aid may receive incomplete grades, as allowed under CSU academic policy. Incomplete grades will count toward the quantitative and maximum time frame elements of SAP. Students who do not complete course requirements after an incomplete grade is assigned will receive a course grade based on the assignments completed with zeros being assigned for non-completed assignments.

Second Bachelor's Degree

Students who are pursuing a second CSU bachelor's degree will have a maximum financial aid eligibility of 100 percent of the second-degree requirements. The timeframe limitation in a second CSU bachelor's degree is 90 semester hours, including transfer credits.

Financial Aid Probation

Students who do not maintain SAP under this policy will initially be placed on Financial Aid Probation and notified of their probationary status. While on Financial Aid Probation, they will be eligible to receive financial aid for their next 12 semester hours. Students on Financial Aid Probation will be reviewed at the end of each period of enrollment. If they do not meet all conditions of SAP at the end of their Financial Aid Probation period, they will have their financial aid eligibility suspended.

Suspension of Federal Student Aid

By statute, students on Financial Aid Probation who do not meet SAP requirements after the probationary period are ineligible for Title IV Federal Student Aid programs. Students who do not maintain SAP or fail to meet the conditions of their Financial Aid Probation will be notified by CSU and suspended from receiving Title IV Federal financial aid. Students may appeal suspensions by completing the SAP Appeal Petition. Requests for reinstatement of eligibility must be made to the CSU Office of the Registrar no later than one month prior to the term in which the student desires to enroll. Reinstatement following suspension is not automatic.

Undue Hardship

Students may appeal their suspension under SAP if they were unable to maintain SAP as a direct result of hardship or special circumstances, as provided by federal regulations. Personal situations such as the death of a student's relative, an injury or illness of the student, or other special circumstance may prevent a student from achieving satisfactory academic progress. As a result, a student may appeal his or her suspension of Federal Student Aid by completing the SAP Appeal Petition and submitting the Petition to the Registrar's Office. If the Appeal is approved, a student will have a probationary period of 12 semester hours (attempted hours) during which he or she will receive financial aid and reestablish eligibility under SAP.

The Office of the Registrar will submit completed SAP Appeal Petitions to the Office of the Registrar for review. The Appeal Board will make the final determination on all Appeal Petitions and forward all decisions to the committee for action. The Office of the Registrar will notify students of their appeal results.


Columbia Southern University - 800.977.8449 - FERPA - Privacy - Office of Disability Services