The new Subscription-Based Programming Enrollment Model published in the September 2, 2020, Federal Register is an exciting new awarding and disbursement model for self-paced programs that bills tuition by Subscription Period. The new Subscription Period provides for much more flexible programming within a term-based structure while also holding the student accountable for sustaining academic progress to remain eligible for disbursement of Title IV funding.
The new program structure was the result of a lot of arduous work by members of many facets of the higher education community. In 2019, representatives of diverse types of institutions, student advocacy groups, and other affected parties met with Department of Education officials over a period of months to discuss regulatory improvements on an ambitious agenda of topics including innovation in higher education. One of the results of their work is the formalization of this new academic structure as an alternative to the existing standard term, nonstandard term, and nonterm options.
10 KEY POINTS ABOUT THE NEW SUBSCRIPTION PERIODS ENROLLMENT MODEL
1. The Subscription Periods Enrollment Model is a new program option for flexible, self-paced programming.
The new Distance Education and Innovation regulations published on September 2, 2020, provide an exciting new opportunity for postsecondary institutions offering self-paced programming. While initially intended only for programs approved by the Department of Education as Direct Assessment, the Final Rule expanded the new financial aid option to any self-paced program that bills students by Subscription Period (i.e., a flat amount of tuition for a specific period during which a student can take as much or as little coursework as desired).
Students are billed an ‘all-you-can-eat’ flat tuition rate based on enrollment-level commitment for a Subscription Period or term, which allows them to enjoy tremendous flexibility with course load and rate of progress. The new model uses the term-based packaging models that have broad adoption, but the timing of disbursements is based on the expectation that students will complete work commensurate with their enrollment-level commitments. The model allows for some fluctuation in student progress without affecting disbursements.
A Subscription-Period model may be just what you have been wishing for if you have been trying to manage self-paced programming with nonterm financial aid and term-based billing or if you are using a term structure and found it too rigid when required to keep self-paced coursework contained within single terms.
2. Courses may overlap terms with Subscription Periods.
Subscription-Period programming is offered using either standard or nonstandard terms. One of the biggest changes is that, while still term-based programming, courses or coursework for Subscription-Period programming can overlap from one term to another without causing the program to become nonterm for financial aid purposes. This only applies if implementing the full Subscription-Period functionality. The current stipulation that a program becomes a nonterm program if a course overlaps from one term to another will continue to apply to non-subscription-period term-based programming.
3. Students elect their enrollment levels.
While students may take as much or as little coursework as they want during a Subscription Period (term), each student will commit to a specific enrollment level (such as full-time or half-time). Institutions determine how the Subscription-Period fees are set for each of the different enrollment levels, which enrollment levels will be offered for each program, and how often a student may change a commitment to a specific enrollment level. Note, however, that a change in enrollment levels is allowed no more often than once each academic year. The Department of Education envisioned separate program versions for each offered enrollment level, and institutions will manage changes from one to another for a student to adjust his/her enrollment level. Such a change must occur at the beginning of a Subscription Period, as a single period cannot support more than one enrollment status. Since the enrollment level is stipulated, there is no longer any need for ‘census’ or ‘Pell recalculation dates.’ However, Pell must be adjusted for attended credits (or other units of measure) at the end of the Subscription Period.
4. Title IV is packaged for the elected enrollment level regardless of actual registration.
The student is packaged using existing eligibility and awarding rules at the selected enrollment level, with no adjustment in financial aid offers based on actual registration (other than the previously mentioned period-end Pell recalculation for attended credits).
5. Subscription Period Enrollment Model disbursements are tied to successful completion of credits/units for the elected enrollment level.
The payment period is the Subscription Period or term. Financial aid for a Subscription Period may be disbursed no sooner than the later of:
- Ten days before the start of that period, or
- The date on which the student has completed the minimum number of required credits (or other units) successfully for that term’s disbursements.
How do you determine the minimum number of required credits for a term? It is a 2-step process:
- Determine the minimum number of units needed for each Subscription Period. For example, if in a half-time program where the institution’s definition of ‘half-time study’ is six to eight credits, the minimum number of units for a Subscription Period would be six credits.
- Add the total number of minimum units for each previously attended Subscription Period except for the most recently attended Subscription Period.
Using this approach for a student committed to full-time study (12 credits per Subscription Period), disbursements for the first 2 periods have no credit completion requirement, as follows:
- Period 1 has no previous terms of attendance, so 0 credits are needed for Title IV disbursements.
- Period 2 has only one previously attended term, and we do not count the most recently completed term, so 0 credits are needed for Title IV disbursements.
However, when the student starts the third period, he/she must have completed 12 credits successfully to receive Title IV disbursements. Disbursements for the fourth period will require a total of 24 credits, and each successive period will require an additional 12 credits for disbursements. If a student is progressing slowly, disbursements for one Subscription Period may be delayed until the student has completed enough credits satisfactorily.
A student who transfers from one Subscription-Period program to another must complete any credits (or other units) that were needed for the next disbursement in the original program. This applies whether the student is entering an entirely new program or if the student is switching to an updated version of the same program with a different enrollment-level expectation (e.g., switching from a full-time to a part-time version of the same program).
6. Students transferring into a Subscription Period program are treated as if they are at the beginning of the Subscription Period program.
Students transferring into a Subscription-Period program from another non-Subscription-Period program will start as if the students were at the beginning of the Subscription-Period program. Zero credits (or other units) are required for disbursements from the first two periods, and then the count will increase incrementally, reflecting the minimum enrollment status credits for each previous period the student has attended (except for the most recently attended period).
7. Satisfactory Academic Progress (SAP) has just a qualitative measure with Subscription Periods.
There is no ‘pace’ or ‘quantitative’ component for Subscription-Period SAP, but an institution’s SAP policy for a Subscription-Period program still must include a qualitative measurement, and a Maximum Timeframe still applies. All other current SAP timing and status rules continue to apply.
8. Subscription Periods are not ‘Programs with Modules’ for R2T4 purposes
A Subscription-Period student is assumed to be enrolled for the full Subscription Period or term, so R2T4s for Subscription Periods are much more streamlined than they are for terms with modules. Regardless of a student’s enrollment and participation patterns, the entire Subscription Period is the denominator for R2T4 periods, and the numerator runs from the Term Start Date to the R2T4 Withdrawal Date, which is determined by existing rules for withdrawal dates. No R2T4 is required if a student graduates before the end of a Subscription Period.
9. Financial aid processing for Subscription Period Enrollment Model programming is complex. Don’t initiate it without considering the financial aid disbursement process.
This new option provides great flexibility to students for their academic course loads and paces, and there is hope that the new option will support enhanced academic innovation and increased nontraditional student participation throughout our higher education community. When considering Subscription-Period programming and anticipating significant growth for that programming, management of the financial aid disbursement process must be a key discussion item.
While incredibly flexible for students, the Subscription-Based Programming Enrollment Model features complex regulatory requirements and nuances, including that it:
- Anticipates a specific enrollment level throughout a standard or nonstandard term program rather than packaging per the student’s actual enrollment;
- Has a flat tuition amount each term, which may vary by program/enrollment level;
- Allows courses to overlap more than one term;
- Does not have ‘census dates’ but does require Pell recalculation to confirm sufficient attendance;
- Calculates a target number of cumulative, successfully completed credits or units needed for disbursement;
- Clears Title IV disbursements only when a student has sufficient cumulative, successfully completed units; and
- Has specific Satisfactory Academic Progress (SAP) and Return to Title IV (R2T4) requirements.
Completion targets and successfully completed units can be tracked on spreadsheets for an initial cohort or a few students, but an automated financial aid solution is necessary to ensure a streamlined student experience and disbursements for a growing student population. By way of example, see the typical approaches and potential automation for activities associated with the top enrollment models, including Subscription Period.
10. There are implementation considerations for the Subscription Periods Enrollment Model.
There are two critical implementation considerations for Subscription Periods:
- Institutions may either ‘teach out’ their current students in existing nonterm or other programs and only start new students in the Subscription-Period programming, or they may withdraw students from their current program structures (with R2T4s as appropriate) and enroll them in Subscription-Period-based versions of the programs.
- Since the disbursement requirements are something new, pay special attention to finding a way to display to both students and staff student disbursement credit targets and progress against those targets.
As the leading provider of SaaS solutions that automate financial aid traditional and non-traditional enrollment models, Regent Education is committed to expanded packaging and disbursement automation in support of the new Subscription–Based-Programming Enrollment Model. See our Press Release for details.
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