Federal Student Aid FACTS

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Policies & Procedures for Award of FSA

Verification Policies and Procedures

  • All selected applicants will be verified.
  • Selected applicants must submit required verification documents within twenty-eight (28) days of notification.
  • If the student fails to provide the required documentation within the established time frame, then the student will be treated as a cash-paying student until the documents are provided.
  • If the student does not meet the deadline and is not capable of making cash payment at the end of the deadline he/she will not be granted access to their classes.
  • The Financial Aid Office reserves the right to make exceptions to the above stated policies due to mitigating circumstances, on a case-by-case basis.
  • Students will be given a clear explanation of the documentation needed to satisfy the verification requirements and the process for document submission.
  • APUS will inform students in a timely manner of the consequences of failing to complete verification requirements.  This may include the notification that their courses were dropped for non-payment or that the student’s Statement of Intent form was cancelled due to inactivity or failure to complete the verification process.
  • Students will be informed of their responsibilities regarding the verification of application information, including the college's deadline for completion of any actions required.
  • Students will be notified if the results of verification change the student's scheduled award. 
  • The college will assist the student in correcting erroneous information.
  • Any suspected case of fraud will be reported to the Regional Office of the Inspector General, or, if more appropriate, to a State or local law enforcement agency having jurisdiction to investigate the matter.  Referrals to local or state agencies will be reported on an annual basis to the Inspector General.
  • No interim disbursements.

Students with questions about their verification status may email finaid@apus.edu for assistance.

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Undergraduate Grade Level Determination

In order to meet the grade level progression requirements for FSA and the FFEL (Federal Family Education Loan), the following policy is established to explain how undergraduate grade level progression is made and to explain how transfer credits are used to determine grade level advancement.  (There are no grade level requirements for graduate students.)

Our university system uses the table below to determine the grade level of an undergraduate student for FSA purposes.

Number of Credits Completed

Student's Grade Level

0 to 24 credits

Grade Level 1, or Freshman

25 to 48 credits

Grade Level 2, or Sophomore

49 to 72 credits

Grade Level 3, or Junior

72+ credits

Grade Level 4, or Senior

Financial Aid is required to be based on a minimum of 24 semester credits and a minimum of 30 instructional weeks.

The Finance Department will evaluate the student’s grades and total credits completed at the end of each semester.  Based on the academic standards of the school, a student can only progress to a higher grade level at the same time that a student begins a new academic year (for loan limit purposes.)

Transfer Credit Award

Upon completion of an official Transfer Credit Evaluation, our Finance Department is notified of the number of transfer credits that the student has been awarded.  Based on the chart above, the Financial Aid Office will determine the student's appropriate grade level, and will calculate the annual loan limit for the student based on the student’s grade level. 

If an existing student completes subsequent coursework outside of our university system and submits a TCE Update, the Financial Aid Office will recalculate the grade level for a student and a revised award letter will be done for the student so that the student’s account and grade level will be accurate.

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Loan Counseling

Entrance and Exit Interview/Loan Counseling

The Department of Education requires that any student receiving a Federal Family Education Loan be notified concerning their loan and obligations.  The university counsels each student regarding loan indebtedness and gives each student an entrance test and e-mails or mails an exit interview regarding the loan to make sure the student understands the total amount borrowed and the Borrower Rights and Responsibilities regarding repayment.

The student must contact the Financial Aid Office prior to withdrawal or graduation for loan counseling.  The purpose of this session is to inform the student of their tentative total loans received while in attendance at the college, refunds that may be made, and to provide the student with an estimated payment schedule.  If the student is unable to contact the Financial Aid Office, an exit interview will be provided. 

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:

  • 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.

If you want additional information about your rights and responsibilities, the terms of loan repayment (including loan repayment schedules), the necessity of loan repayment and required loan exit counseling can use the links for the Department of Education at the bottom of this page.

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FSA Disbursements

When a student applies for financial aid, the package is generally awarded based on an academic year. The academic year is generally two semesters.  Federal Student Aid is generally paid in two disbursements, once each semester.

Pell Grant disbursements will occur after the first week of class in the semester for those students who are eligible (once entrance into the classroom can be confirmed).  The disbursement of funds to the University will usually take a minimum of 14 days from the beginning of the semester.  Pell fund eligibility may be impacted for students who are dropped from a course or courses due to non-attendance.  To prevent adjustments due to non-attendance drops, students must log into all classrooms during the first week of class. 

Federal loans for students will not be disbursed to the University until classroom enrollments have been confirmed.  This will be no sooner than 30 days after the semester starts.   Excess loan funds will be refunded to the student (or lender if designated by the student) within 14 days of receipt by the University.  Students may also elect to have the Finance Department manage their credit balance for them as long as the student provides a written statement.

Once federal funds have been disbursed, students will receive a disbursement notice via email from the University’s Financial Aid Office.   Once the financial aid package is approved and accepted by the student, access to the classroom will be given.  (Please note that the classroom does not open until the first day of class.)

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Loss of Financial Aid Eligibility

Students failing to meet or maintain SAP during any period of evaluation will lose eligibility for Federal Student Aid, in accordance with Title IV of the Higher Education Act.  These students will be placed in a Financial Aid Denial status and will be e-mailed of their status by a Financial Services team member.  Once in “Denial” status students are no longer eligible for Federal Student Aid.  To regain FSA eligibility, students must satisfy all SAP requirements.

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Financial Aid Appeal Procedure

Any student placed on “Financial Aid Denial” status may appeal their denial due to mitigating circumstances (situations that have had a negative effect on the student’s ability to successfully meet the normal SAP standards).   The request for an exception to the policy must be a written petition submitted via email to our university’s Financial Services Office within 3 days of the notification of “Financial Aid Denial.”  Students who fail any SAP requirements have the ability to appeal their SAP denial status. An Appeals Committee will consider all appeals. Students will be notified in writing of the committee’s decision within 3 business days of receipt of their emailed request.  All decisions made by the committee are final.

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Reestablishing Financial Aid Eligibility

Students placed on “Financial Aid Denial Status” may reestablish their eligibility for FSA by registering for courses at their own expense and demonstrating their ability to meet SAP.  Once students demonstrate their ability to meet SAP, they may reapply for Federal Student Aid for future courses.  For example, a student who is in violation of SAP requirements completes 12 credits in a semester with good grades and has now completed 48 credits.  They raise their cumulative GPA above the 1.75 cumulative GPA threshold.  If their quantitative measure remains at least 67% or higher, then they are no longer in FSA Denial status and they can reapply for Federal Student Aid.”

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Returning FSA Funds

All institutions participating in the FSA Programs are required to use a statutory schedule to determine the amount of FSA Program funds a student has earned or qualified for when he or she ceases attendance based on the period the student was in attendance. 

Our Financial Aid Office must calculate the amount of FSA Program assistance the student did not earn and those funds must be returned back to the lender or Federal Government.  Up through the 60% point in each payment period or period of enrollment, a pro rata schedule is used to determine how much FSA Program funds the student has earned at the time of withdrawal.  After the 60% point in the payment period or period of enrollment, a student has earned 100% of the FSA Program funds.

The percentage of the payment period or period of enrollment completed is determined by the total number of calendar days in the payment period or period of enrollment for which the assistance is awarded divided into the number of calendar days completed in that period as of the day the student withdrew. Scheduled breaks of at least five consecutive days are excluded from the total number of calendar days in a payment period or period of enrollment (denominator) and the number of calendar days completed in that period (numerator). 

Title IV funds credited to outstanding loan balances for the payment period or period of enrollment for which a return of funds is required must be returned in the following order:

  • Unsubsidized Stafford Loan Program
  • Subsidized Stafford Loan Program
  • Unsubsidized Direct Stafford loans (other than PLUS loans)
  • Subsidized Direct Stafford loans
  • Federal Perkins Loan Program
  • Graduate PLUS loans
  • Federal PLUS loans
  • Federal Direct PLUS loans

If funds remain after repaying all loan amounts, those remaining funds must be credited in the following order:

  • Federal Pell Grants for the payment period for which a return of funds is required
  • Academic Competitiveness Grant & National SMART Grant
  • Federal Supplemental Educational Opportunity Grant (FSEOG) for which a return of funds is required
  • Other assistance under this Title for which a return of funds is required.

Students will be notified of any refunds due to a lender on their behalf through the mailed exit interview material.  Refunds to any of the Title IV or State programs will be paid within 45 days from the date of determination.

Return of Unearned FSA Funds
The school must return the lesser of the following:

  • The amount of FSA Program funds that the student does not earn;
  • OR The amount of institutional costs that the student incurred for the payment period or period of enrollment multiplied by the percentage of funds that was not earned.  When we mean earned, this means the percentage of funds that was earned over time (during the semester) by the student.

The student (or parent, if a Federal PLUS loan) must return or repay, as appropriate:

  • Any FSA loan funds in accordance with the terms of the loan
  • The remaining unearned FSA Program grant (not to exceed 50% of the grant) as an overpayment of the grant.

If a student earned more aid than was disbursed to him/her, the institution would owe the student a post-withdrawal disbursement which must be paid within 120 days of the student's withdrawal.

The institution is required to return the amount of Title IV funds for which it is responsible no later than 45 days after the date of the determination of the date of the student's withdrawal.

Students who officially withdraw during a semester
Students who elect to withdraw from the university during a semester must do so by dropping or withdrawing from all of their courses in the semester and then completing the Disenrollment Request Form. When this occurs the institution will review the official date of withdrawal and compare the total number of calendar days in a payment period or period of enrollment (denominator) and the number of calendar days completed in that period (numerator).

Once the lesser of the amount of FSA Program funds that the student does not earn or the amount of institutional costs that the student incurred for the payment period or period of enrollment multiplied by the percentage of funds that was not earned is completed, the amount (if any) unearned funds are returned to the lender or back to COD.  Students who as the result of officially withdrawing have Federal funds returned and now owe money to the institution are notified by e-mail and a ‘Balance Hold’ is placed on the account. 

Students who fail to pass any of their courses in a semester
Federal guidelines require APUS to review the grades for all students who complete their semester.  The institution must not only check students for Satisfactory Academic Progress in their program of study but must also have a mechanism in place to determine if a student failed to complete any courses in a semester. 

Students who failed at least one course in a semester and have drops or withdrawals as the remainder of their grades is considered to have not passed any courses within the semester.  These students are considered as ‘unofficial withdrawals’ and are no longer considered as enrolled at the institution and are subject to Federal Return of Title IV Funds rules.  The only exception to this rule occurs if the student has future registrations in their next semester.

The following procedures are followed:  Approximately 21 to 24 days after the end of a semester (to allow for initial grade posting and any grade revisions due to student appeal) a report is run to determine those students who failed to pass any courses in their semester.  This report will identify any students who meet the involuntary withdrawal criteria.  Once identified, the institution will follow all procedures listed above in Returning FSA Funds and Return of Unearned FSA Funds.

Effective Tuesday, October 23, 2007 the university changed its policy regarding how students will be calculated for earned and unearned Federal Student Aid when they involuntarily withdraw from the institution.  A student is considered an involuntary withdrawal from the university when at the end of a semester the student has failed to pass any of their courses from that semester, has at least one failing grade and the student is not registered for future classes.  In this situation where a student has involuntarily withdrawn and they received Federal Student Aid for the semester, the university is required by law to perform a Return of Title IV Aid calculation to determine the percentage and amount of aid that the student earned for the semester.

Prior to the above date the institution chose to use a straightforward 50% earned policy allowed in the Federal Regulations.  Effective October 23rd, the policy will be as follows:

For students identified as having not passed any of their courses in a semester, the institution will determine the last date that they participated in an academically-related activity (such as entering the classroom, participating in a discussion group, taking an exam, turning in homework, etc.)  Once the last date of an academically-related activity has been determined, the Financial Aid Office will determine if the mid-point date will be used for the calculation or if the date is after the midpoint of the semester, then the last attendance date will be used for the calculation.  This date will be considered as their Withdrawal Date for the purposes of determining the percentage of the payment period that a student was actively participating over the whole semester and subsequently the amount of unearned Title IV aid that must be returned to the Federal Government. The institution will review each student on the All Fail report on a case-by-case basis.

Any questions regarding the Return of Title IV Aid calculation process should be addressed to Financial Services.

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Institutional Tuition Refund Policy

The Tuition Refund Policy of our university system can be viewed in our online Student Handbook by clicking here

A student must officially notify APUS when he/she intends to withdraw from the school.  The official withdrawal date is the date that the student notified the school by completing the withdrawal request form.  Detailed information about the Drop/Withdrawal Policy at our universities can be viewed in our online Student Handbook by clicking here.

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Graduation/Completion Rates

APUS definition of Completion Rates
APUS has a specifically defined definition of completion rates that it uses to evaluate a cohort of students progress towards graduation. Included in this cohort are ALL part time, full time, first time, continuing and transfer students.

The APUS calculated completion rate for each group is as follows:

Associate Degree   
Bachelor’s Degree 
Master’s Degree
Undergraduate Certificate 
Graduate Certificate 

86%
84%
70%
64%
83%

Student Right-to-Know Act
Although American Public University System has developed the above cohort to determine the completion rates on our students, Federal Regulations require us to disclose completion rates based on a specifically defined cohort.

U.S. Department of Education regulations require that we must make available, to current and prospective students, no later than July 1, 2008, the rates for the cohort for which the 150% of the normal time for completion elapsed between September 1, 2006 and August 31, 2007.  Based on the required calculation rate, 2% of our students meet the criteria of certificate- or degree-seeking, full-time, first-time undergraduate students. 

American Public University System has a student population that is military or service-related. The vast majority transfer into either American Military University or American Public University and attend on a part-time basis; their completion rates are not reflected in the cohort as specified by the U.S. Department of Education.

American Public University System, has computed graduation rates for our entire student population.

The data for these calculations and the cohort year calculations are available from the university should you wish to review them.  You may contact Chip Woodward, Director of Financial Aid Regulations & Compliance at cwoodward@apus.edu for this information.

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Preferred Lender List Discloser

APUS firmly acknowledges and explicitly states that borrowers always have a choice in selecting a FFELP lender. APUS cannot deny borrowers that choice.  It is also our belief that it is our goal to provide choice to students and parents in selecting lenders that have been carefully evaluated on an objective set of quality and price criteria.  Therefore, our list of preferred lenders meets high standards of quality, customer service and generous benefits to help not only our student borrowers but parents who borrow on the behalf of undergraduate students.

The following criteria were the basis of determining the lenders chosen for our preferred lender list:

1.  Experience & longevity  

  • Is the lender a well-known, reputable company?
  • What is the lender’s track record in the industry?
  • Is the company’s focus on student loans?
  • How many customers have loans with this lender?
  • Is the lender financially sound and strong?

2.  Best value & benefits 

  • Does the lender offer to pay fees on the student’s behalf?
  • Does the lender offer interest rate reductions and rebates?
  • How easy is it for borrowers to earn and keep rate reductions and rebates?
  • Does the lender offer borrowers the opportunity to re-earn rate reductions?

3.  Customer service investment     

  • Does the lender recommend that students maximize their use of free aid and federal loans before taking a private loan?
  • Will the loan be sold?
  • If so, will servicing remain with the originating lender?
  • How convenient are the lender’s call center hours?
  • Are the lender’s customer service representatives experienced, friendly and knowledgeable?

4. Flexible repayment options             

  • Does the lender offer combined billing of their federal and private loans?
  • Does the lender offer deferment and forbearance counseling?
  • Does the lender offer flexible repayment options?
  • Does the lender provide tools and resources to help borrowers determine the best repayment solutions for them?
  • Does the lender offer loan consolidation options?
  • Does the lender advise borrowers on debt management/default prevention?

5. Technology investments                 

  • Can students and parents apply for loans online at any time?
  • Can borrowers access and manage their account online 24/7?
  • Does the lender offer support for technology and online services?

If you have any questions on why a specific lender is on our preferred lender list, please feel free to send your question to the Financial Services office at finaid@apus.edu.

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For information on Non-Federal Financial Aid, click here to enter online Student Handbook.

More detailed FSA information is available via the Department of Education at the following links:
Department of Education – Start Here, Go Further, Federal Student Aid
The Student Guide: Financial Aid from the US Department of Education
or click here for PDF file in English (4MB)

Most of the information dissemination activities required by the Higher Education Act of 1965, as amended, have been satisfied within these pages. Students who need additional assistance with Federal Student Aid may contact our Financial Services Office at finaid@apus.edu.