Prior	to	the	2024-2025	award	year,	the	HEA	allowed	schools	to	use	alternate	expected	family	contributions	(EFCs)	when
packaging	aid	for	periods	other	than	nine	months.	The	FAFSA	Simplification	Act	eliminated	this	provision.	Beginning	with
the	2024-2025	award	year,	when	packaging	aid	for	any	period	that	is	not	nine	months,	schools	must	use	a	student9s
calculated	9-month	SAI	in	the	formula	to	determine	eligibility	for	need-based	aid,	as	described	above	(that	is,	COA	3	SAI	3
OFA	=	need).	As	a	result	of	this	change,	students	who	are	enrolled	for	periods	shorter	than	nine	months	will	have	less
financial	need	than	would	have	been	the	case	in	the	past	when	using	an	alternate	(smaller)	EFC	for	such	periods.	See
Volume	8,	Chapter	3	for	more	information	on	how	this	change	may	affect	Direct	Subsidized	Loan	eligibility	for	students
receiving	loans	for	periods	of	enrollment	(loan	periods)	shorter	than	nine	months.
Treatment	of	Negative	SAIs
A	student	may	have	a	calculated	SAI	that	is	a	negative	number	as	low	as	-1,500.	Also,	as	explained	in	Chapter	3	of	the
Application	and	Verification	Guide,	certain	students	will	automatically	receive	a	-1,500	SAI.	When	packaging	need-based
aid	for	students	with	negative	SAIs,	schools	must	convert	any	negative	SAIs	to	zero	for	awarding	purposes.	This	means
that	a	negative	SAI	will	not	increase	the	amount	of	need-based	aid	a	student	can	receive.	Note	that	a	negative	SAI	also
does	not	increase	the	amount	of	non-need-based	aid	that	a	student	may	receive	because	the	SAI	is	not	a	factor	in
determining	eligibility	for	aid	that	isn9t	based	on	financial	need.
Packaging	Rules
Pell	Grants	as	the	First	Source	of	Aid
Pell	Grants	are	the	first	source	of	aid	for	a	student,	and	packaging	
Title	IV	funds	begins	with	determining	a	student9s	Pell
Grant	eligibility,	as	described	in	Volume	7.	A	correctly	determined	Pell	Grant	is	never	adjusted	to	take	into	account	other
forms	of	aid.	When	awarding	aid	from	the	other	Title	IV	programs,	you	must	ensure	that	the	student9s	need	or	COA	is	not
exceeded.
In	some	cases,	a	student9s	aid	package	may	include	a	Pell	Grant	and	non-
Title	IV	aid	(for	example,	institutional	aid	or
private	education	loans),	but	no	other	types	of	Title	IV	aid,	and	the	combination	of	the	Pell	Grant	and	the	other	aid	may	be
large	enough	to	exceed	the	student9s	COA.	For	instance,	the	National	Collegiate	Athletic	Association9s	(NCAA's)	rules	for
athletic	aid	may	permit	a	school	to	award	athletic	aid	that	covers	a	student9s	full	COA	(see	<NCAA	Considerations=	in
Chapter	2	of	this	volume	for	more	information).	In	this	case,	the	student	is	still	eligible	for	the	full	amount	of	the	Pell
Grant.	However,	you	can9t	award	any	Title	IV	funds	other	than	the	Pell	Grant.
Note	that	in	some	cases	a	student9s	SAI	may	be	higher	than	the	COA,	resulting	in	no	financial	need,	but	the	student	may
still	qualify	for	a	calculated	Pell	Grant	or	a	minimum	Pell	Grant	(see	Volume	7,	Chapter	2	for	more	information	on	Pell
Grant	eligibility	criteria).	As	an	example,	consider	a	student	with	an	SAI	of	6,650,	a	COA	of	$5,500,	and	a	calculated	Pell
Grant	amount	of	$745.	In	this	circumstance	the	student	is	still	eligible	for	the	full	Pell	Grant	amount	(as	long	as	it	doesn9t
exceed	the	COA),	but	you	may	not	award	any	other	types	of	need-based	Title	IV	aid.
If	a	student9s	aid	package	includes	a	Pell	Grant,	other	types	of	Title	IV	aid,	and	non-Title	IV	aid,	and	the	total	aid	amount
exceeds	the	student9s	COA,	the	student	still	qualifies	for	the	full	Pell	Grant	amount,	but	you	must	adjust	the	other	Title	IV
aid	to	ensure	that	the	COA	is	not	exceeded.
In	the	circumstances	described	above	you	may	(but	are	not	required	to)	adjust	non-
Title	IV	aid	over	which	you	have
control	in	accordance	with	your	school9s	policies.
No	Alternate	SAIs	and	Treatment	of	Negative	SAIs
DCL	GEN-23-11
DCL	GEN-24-05
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