Financial Aid Policies

Financial Aid Department Code of Conduct

Highland Community College Financial Aid Department employees are expected to maintain the highest standards of conduct in all aspects of the administration of their duties, including all duties conducted in dealing with any entity involved in any way with financial assistance. This expectation applies regardless of whether the entity is involved in a government-sponsored, subsidized, or regulated activity.

Any Highland Community College employee who is either directly or indirectly involved with financial assistance should adhere to the following standards.

Employees must never take any action for personal gain or benefit.

Employees must never take any action that they believe is, or might be, contrary to law, regulation, or the best interests of the students and parents served.

Employees must ensure in every circumstance that information provided to students and parents is accurate, unbiased, and does not reflect any preference arising from actual or potential personal or institutional gain.

Employees must remain objective in all decisions and when advising the College regarding any institution involved in any aspect of student financial assistance.

Employees must never solicit or accept anything of value from an entity involved in the making, holding, consolidating, or processing of student loans, including reimbursement of expenses for serving on an advisory board or participating in a training activity sponsored by such an entity.

Employees must always disclose to the College any involvement with or interest in any entity involved in any aspect of financial aid.

Statement of Ethical Principles

Highland Community College adheres to the National Association of Student Financial Aid Administrators (NASFAA) Statement of Ethical Principles.

Financial aid professionals are committed to removing financial barriers for those who wish to pursue postsecondary education.

They make every effort to assist students with financial need.

They remain aware of issues affecting students and advocate for student interests at the institutional, state, and federal levels.

They support efforts to encourage students, beginning as early as elementary school, to aspire to and plan for education beyond high school.

They educate students and families through clear, accurate, and high-quality consumer information.

They respect the dignity of students, protect student privacy, and ensure the confidentiality of student records and personal circumstances.

They ensure equity by applying all need analysis formulas consistently across the institution’s full population of financial aid applicants.

They provide services that do not discriminate on the basis of race, gender, ethnicity, sexual orientation, religion, disability, age, or economic status.

They recognize the importance of professional development and continuing education.

They promote the free expression of ideas and opinions and foster respect for diverse viewpoints within the profession.

They commit to the highest level of ethical behavior and avoid conflicts of interest or the appearance of conflicts of interest.

They maintain the highest level of professionalism in support of the goals of the National Association of Student Financial Aid Administrators.

Student Loan Code of Conduct

Prohibition Against Remuneration to Highland Community College

Highland Community College will not solicit, accept, or agree to accept anything of value from any lending institution, guarantee agency, or loan servicer in exchange for any advantage or consideration related to student loan activity.

This prohibition includes, but is not limited to, revenue-sharing agreements, computer hardware provided below market value, computer software used to manage loans unless it can manage disbursements from all lenders, and printing costs, postage, or related services.

This prohibition does not prevent the College from accepting favorable terms or conditions that directly benefit student borrowers.

Prohibition Against Remuneration to College Employees

Highland Community College requires that no trustee or employee accept anything of more than nominal value, on their own behalf or on behalf of another, during any twelve-month period from any lending institution, guarantee agency, or loan servicer.

This includes a prohibition on payment or reimbursement for lodging, meals, or travel to conferences or training seminars provided by such entities.

This does not prohibit a trustee or employee from receiving compensation for conducting non-college business with a lending institution, guarantee agency, or loan servicer, nor does it prohibit compensation offered to the general public.

This prohibition does not prevent the College from holding membership in nonprofit professional associations.

Ban on Gifts

No Highland Community College employee or agent involved in the financial aid office, or with responsibility for education loans, may solicit or accept any gift from a lender, guarantor, or loan servicer.

Gifts include any gratuity, favor, discount, entertainment, hospitality, loan, or item of more than nominal value, including services, transportation, lodging, or meals, whether provided directly, prepaid, or reimbursed.

The following items are not considered gifts.

Standard materials, programs, or activities related to loans, default prevention, or financial literacy, such as brochures, workshops, or training sessions.

Food, refreshments, training, or informational materials provided as an integral part of a training session designed to improve lender services to the institution, when the training contributes to professional development.

Favorable loan terms or borrower benefits provided to student employees, when those benefits are comparable to those offered to all students.

Entrance and exit counseling services provided to meet institutional requirements, provided the institution controls the counseling and the counseling does not promote specific lender products or services.

Philanthropic contributions unrelated to education loans or not exchanged for loan-related advantages.

State-administered education grants, scholarships, or financial aid funds.

Ban on Gifts to Family Members

Gifts to family members of a college officer, employee, or agent involved in student loans are considered gifts to the officer, employee, or agent if the gift is given with their knowledge and acquiescence and if there is reason to believe the gift was given because of the individual’s official position.

Limits on Participation in Lender Advisory Boards

Any College employee involved in financial aid or student loans who serves on a lender or guarantor advisory board may not receive anything of value from the entity, except reimbursement for reasonable expenses incurred while serving.

Prohibition on Contracting Arrangements

No employee may accept payment from a lender in exchange for consulting services related to educational loans.

This does not prohibit employees with no involvement in student loans from entering such agreements.

This does not prohibit service on a board of directors or trusteeship if the individual recuses themselves from decisions related to educational loans.

Prohibition on Revenue Sharing Agreements

Highland Community College will not enter into revenue-sharing agreements in which a lender provides loans to students or families and, in exchange, pays fees or provides material benefits to the institution for recommending the lender.

Prohibition on Offers of Funds for Private Loans

Highland Community College will not request or accept offers of loan funds in exchange for promises related to loan volume, number of loans, or preferred lender arrangements.

Ban on Staffing Assistance

Highland Community College will not accept assistance from lenders for financial aid office or call center staffing.

This does not prohibit professional development training, educational or financial literacy materials that disclose lender involvement, or short-term staffing assistance during declared emergencies.

Interaction With Borrowers

Highland Community College participates in the William D. Ford Federal Direct Loan Program. All eligible student and parent borrowers are packaged exclusively through this program.

Repeated Coursework Policy

Effective July 1, 2011, federal financial aid regulations limit the number of times a student may repeat a course and receive federal financial aid for that course.

Federal regulations state that a student may receive federal financial aid when repeating a course that was previously failed, regardless of the number of times the course was attempted and failed. Once a passing grade is received, the student may receive federal financial aid for only one additional repeat of that course.

Failing grades include F, U, I, or W. Passing grades include A, B, C, D, R, P, or S.

An exception to this regulation applies to repetitions of previously passed courses that are mandated by institutional policy due to the student failing other coursework. An institution may not pay a student for retaking previously passed courses if the student is required to retake those courses because the student failed a different course in a prior term.

These federal regulations do not affect Highland Community College’s policies governing whether a student may retake coursework, including repeating courses to achieve a higher grade. The regulations apply only to determining enrollment status for Title IV, Higher Education Act program purposes.

Students enrolled in a program that requires enrollment in a course on a continuing basis using the same course number are not considered to be retaking coursework, provided the course content is different for each term. Simply changing the syllabus for a course that is offered every term does not qualify the course for repeated financial aid eligibility.

Examples of Repeated Coursework That May Be Counted Toward Enrollment Status

A student who receives a failing grade may repeat a failed course until it is passed.

A student who receives a grade of D in a course that requires a grade of C for their major may repeat the course one time.

Examples of Repeated Coursework That May Not Be Counted Toward Enrollment Status

A student who receives a grade of D, repeats the course, and receives another grade of D may not count the course toward enrollment status if the student chooses to repeat the course a second time.

All coursework, including repeated coursework, is included in financial aid standards of satisfactory academic progress calculations. All repeated coursework counts as attempted credits regardless of whether federal financial aid was received.

13.1 Return of Title IV Funds

Title IV funds are awarded to students under the assumption that the student will attend school for the entire payment period or period of enrollment for which the assistance was awarded. When a student fails to complete the payment period or period of enrollment, he or she may no longer be eligible for the full amount of Title IV funds the student was scheduled to receive.

It is the policy of Highland Community College to determine the amount of earned and unearned portions of Title IV aid as of the date the student ceases attendance in accordance with federal regulations and the Return of Title IV funds as dictated in Volume 5 of the Student Aid Handbook.

In general, a student earns federal financial aid in direct proportion to the percentage of the payment period or period of enrollment they complete. For example, if the student completes 25% of the payment period or period of enrollment, the student earns 25% of the federal financial aid scheduled to be received.

Students completing 60% of the payment period or period of enrollment are considered to have earned 100% of the federal financial aid he or she was scheduled to receive.

R2T4 Withdrawal Exemptions

Students are not considered withdrawn if the student successfully completes, effective January 19, 2021, any of the following conditions.

The student completes all requirements for graduation from his or her program before completing the days or hours in the period that the student was scheduled to complete.

The student completes one module that includes 49% or more of the number of days in the payment period.

The student completes a combination of modules that, when combined, contain 49% or more of the number of days in the payment period.

The student completes coursework equal to or greater than the coursework required for the institution’s definition of a half-time student, which is six credits.

Students who have received more aid than what has been earned are notified in writing of the amount of unearned aid he or she must repay. In the event the student has received less aid than the amount he or she has earned, the student is eligible to receive those funds. Students are notified in writing of any action needed to accept the funds.

Title IV Funds to Be Returned

In accordance with federal regulations, unearned Title IV financial aid is returned by Highland Community College in the following order: Direct Unsubsidized Stafford Loans, Direct Subsidized Stafford Loans, PLUS Loans, Pell Grants, Federal Supplemental Educational Opportunity Grants (FSEOG), Iraq and Afghanistan Service Grants, and other Title IV assistance.

Withdrawal Date

The last date of attendance as reported by the instructor is the withdrawal date used in the Return of Title IV funds calculation.

Timeframe for Return of Title IV Aid

The College must return the amount of Title IV funds for which it is responsible as soon as possible, but not later than 30 days after the date of the College’s determination that the student withdrew.

The College must determine the withdrawal date for a student who withdraws without providing notification to the College no later than 30 days after the end of the payment period.

R2T4 Freeze

Highland Community College does not use a R2T4 Freeze date.

This policy is a Department of Education Title IV financial aid policy and does not replace the official Tuition Refund Policy of Highland Community College.