Currently one son is a junior in a 4-year college. The next one is
a high school senior and will attend the same 4-year college in the
fall. Last, I have twins that are sophomores in high school. This fall
the twins will have "dual enrollment." Our school district allows
juniors and seniors to take one or two classes per semester at the
local 2-year technical college. The courses will count for high school
credit as well as college transfer credit. Can I count all four
children on FAFSA as college students even though the twins will only
be part time?
— Lisa B.
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You cannot count the twins as college students on the FAFSA. Only
children who will attend an eligible college or university on at least
a half-time basis for the purpose of obtaining a degree or certificate
are eligible for federal student aid and may be counted as part of the
number in college on the FAFSA. Such students are referred to as
Students who are enrolled in "dual enrollment" programs are not
considered regular students because completion of the program does not
lead to a degree or certificate and because the students are
ineligible as they do not yet have a high school diploma or its
equivalent. Likewise, students taking
Advanced Placement (AP)
International Baccalaureate (IB)
classes are not considered to be college students.
Dual enrollment programs are discussed on page 1-5 of the 2010-11
Federal Student Aid Handbook, which states: "A student enrolled in
elementary or secondary school is not eligible for aid from the FSA
programs, even if she is simultaneously enrolled in an eligible
college program. A student is considered to be enrolled in secondary
school if she is pursuing a high school diploma or if she has
completed the requirements for a diploma, has not yet received it, and
either she is taking college coursework for which her high school
gives credit or her high school still considers her to be enrolled
there." The Federal Student Aid Handbook is published by the US
Department of Education to provide guidance to college financial aid
administrators in interpreting federal laws and regulations concerning
federal student financial aid.
The FAFSA requirements are based on sections 484(a)(1), 484(b)(3),
484(b)(4), 475(b)(3), 476(a)(2) and 477(a)(3) of the Higher Education
Act of 1965 and the regulations at 34 CFR 600.2 "Regular Student" and
34 CFR 668.32(a)(1). For example, the following is an excerpt from
section 475(b)(3) of the Higher Education Act of 1965, which discusses
the calculation of the parent contribution part of the expected family
contribution (EFC): "dividing the assessment resulting under paragraph
(2) by the number of the family members, excluding the student’s
parents, who are enrolled or accepted for enrollment, on at least a
half-time basis, in a degree, certificate, or other program leading to
a recognized educational credential at an institution of higher
education that is an eligible institution in accordance with the
provisions of section 487 during the award period for which assistance
under this title is requested". This section of the Higher Education
Act of 1965 clearly limits which family members are counted as college
students in calculating the EFC.
These restrictions remain in effect even though sections 101(a)(1) and
102(d)(1) of the Higher Education Opportunity Act of 2008 amended
sections 101(b) and 102(b) and (c) of the Higher Education
Act of 1965 to permit eligible institutions of higher education to
dually enroll secondary students as regular students effective July 1,
2010. The amendments made by the Higher Education Opportunity Act of
2008 relate to the definition of an institution of higher education
and not to student eligibility for federal student aid.