All post-secondary education expenses must be itemized on the IPE and appropriate comparable benefits applied to these costs. These benefits include PELL or other grants and non-merit scholarships. Any other funds the student receives for the cost of training, which do not have to be repaid, are to be counted. Loans, merit awards/scholarships, and work-study income are not to be considered as comparable benefits. (Further information may be found in the Comparable Benefits section of this Resource Guide.)
Every client seeking support for training in a post-secondary education program must apply for all grants available, including the PELL Grant. The counselor must be provided documented proof of grant application prior to agreeing to sponsor a client in training. The counselor should advise clients in high school, who plan to enter a post-secondary education program, to apply for financial aid early in their senior year. Even if a client has applied for and been denied a grant previously, the client must reapply each year.
There have been instances when the institution's Financial Aid Office only considered the PELL Grant because the Agency was paying the balance. Denying the client access to other financial aid for which they may be eligible is a violation of the Rehabilitation Act. The individual being an Agency client has no bearing on the amount of assistance for which he/she is entitled. In order
to prevent this from happening and to determine all available comparable benefits the following procedures are to be followed:
* The counselor is to submit to the Financial Aid Office the Financial Aid Transmittal Document (VR-35) form with Part I completed and signed by the client.
* Part II of the VR-35 is to be completed by the Financial Aid Officer and returned to the counselor.
* The counselor is to complete Part III of the VR-35, send the original copy to the Financial Aid Office, and keep a copy in the clients case file.
* The counselor is to consult with the Financial Aid Officer regarding any other available grants that the client may be entitled.
The colleges and universities have different grant application deadlines. The counselor is responsible for contacting the individual school for and advising the client of the appropriate grant application deadline.
The counselor should not supplement grants, scholarships, and/or other comparable benefits in excess of the actual costs for tuition, room, and books. If the amount of the client's financial aid exceeds these costs, the excess is to be applied toward remaining training expenses.
The counselor is to authorize to the institution for payment of tuition, dorm, books, and other expenses identified in the IPE well in advance of the registration date. If the enrollment deadline requires authorization prior to the client receiving notification of grant award, the counselor may do so as long as the client's file contains evidence of grant application. Once the grant(s) is received, the school/client must reimburse the Agency for any costs covered by the grant award or cancel the authorization, if appropriate. Expenses for the following semester will not be authorized until this reimbursement has been made.
If a client is in default of a Title IV loan and denied a PELL Grant, then they are not able to access a comparable benefit. Clients who are in default should be advised to proceed to clear their default status by making arrangements to repay the loan. The client is required to provide the counselor documentation of his/her efforts to remove the default status. A determination to provide the Agency assistance can only be made on an individual basis after careful examination of all the circumstances involving the default status and the individual's financial situation. Default status can be cleared if the holder of the loan certifies, for the purpose of reinstating Title IV eligibility, the borrower has made satisfactory arrangements to repay the defaulted loan, or the loan is discharged in bankruptcy. (This is in accordance with RSA Policy Directive 92-02.)
32 Miss. Code. R. 22-3.14.6.1