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General TRIO Questions

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Award Aid - Why do some think it needs to be part of the COA and go though FA?

I've asked this question in multiple budget trainings and COE priority trainings, PLUS I asked the FSAtraining help desk about Award Aid as "Other Aid" in the FAFSA/Federal Aid regulations. No one can answer me!

Scenario: The Financial Aid office is 1- using SSS Award Aid to pay off balances owed in student accounts before deployment. 2 - saying SSS Award Aid is part of the Max Cost of Attendance and refusing to distribute it to students who've reached that threshold.

(Our FA director was formerly at a big city college and we like to think she's very knowledgeable on SSS Award aid since that college has several TRIO programs.)


Our COE trainers believe that Award Aid is separate from Financial Aid and should not go through that office and should be issued as a separate check, much like I've done for Upward Bound stipends in the past. However, m…


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Great question — this one gets misinterpreted often.


The governing citation is 34 CFR §646.30(e) under the Student Support Services (SSS) Program regulations. It authorizes SSS projects to provide grant aid only to current participants who are also receiving a Federal Pell Grant during that same academic year. The funds are meant to supplement, not replace other sources of financial aid.


In practice, the Financial Aid Office must be directly involved in determining who receives SSS grant aid and the amount of each award. This isn’t just best practice, it’s a federal assurance requirement under 34 CFR §646.11(d), which states that “the institution’s financial aid office will consult with the SSS project with respect to which SSS participants should receive grant aid and the amount of the grant aid awards.”


This coordination ensures compliance with Title IV rules regarding Cost of Attendance (COA) and prevents overawards, which occur when total aid exceeds allowable limits. The Business Office typically processes SSS grant aid through the student’s account so that it appears on the official aid record, and any remaining balance can be refunded to the student.


It’s important not to confuse SSS grant aid with Upward Bound stipends.

• Upward Bound stipends (regulated under 34 CFR §645.30(f)) are considered participant support payments, not financial aid. They can be issued directly to students as compensation for participation or performance.

• SSS grant aid, however, is a form of federal student financial assistance, tied to Pell eligibility, and therefore must be coordinated through the Financial Aid Office and reflected in the student’s aid package.


There isn’t a prescribed federal deployment method, but ED requires that whatever process is used must be documented, consistent, and compliant with both TRIO regulations and the Uniform Guidance at 2 CFR Part 200.


For reference:

34 CFR §646.30 – Student Support Services Program

34 CFR §646.11 – Assurances

34 CFR §645.30(f) – Upward Bound Participant Stipends

Low-income documentation

Can we use Federal or State tax form to cross reference with the low-income levels posted in the ED to documentate low-income ?https://www.ed.gov/about/ed-offices/ope/trio/federal-trio-programs-current-year-low-income-levels

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Hello -


Federal - not State - tax forms can be used to document low income due to the taxable income listed on the federal form that is to be compared to the TRiO low income levels. See the regulations below:


Regulation / Statute Requiring Documentation of Low-Income Status


20 U.S.C. § 1070a-11(e) (part of the statutory TRIO umbrella authority) spells out how a student’s status as a “low-income individual” must be documented. 

The text states:


“Except in the case of an independent student … documentation of an individual’s status … shall be made by providing the Secretary with—

(A) a signed statement from the individual’s parent or legal guardian;

(B) verification from another governmental source;

(C) a signed financial aid application; or

(D) a signed U.S. or Puerto Rico income tax return.” 


And for independent students, the same kinds of documents apply (but from the student instead of the parent). 


Also, the statute includes a special rule that homeless youth or foster care youth are eligible without needing the usual income documentation. 



Regulatory Definition of “Low-Income Individual” in TRIO Regulations


In addition to the statute, the TRIO program regulations define “low-income individual” consistently across programs. For example, in 34 CFR Part 646 (SSS program):


“Low-income individual means an individual whose family’s taxable income did not exceed 150 percent of the poverty level amount in the calendar year preceding the year in which the individual initially participated in the project.” 


So, combining the statute and regulation gives you both how low-income is defined, and how it must be documented.

Moderator

TRIO Umbrella Regulations - Free Course

Umbrella Regs Course

Dear Lisa

ree

Have a TRIO question for Lisa? Ask at https://www.nosotrosedu.org/group/general-trio-questions/discussion. Follow for more #DearLisaQA

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