RS 00205.350 Determining Full-Time Attendance (FTA)

The student must meet both State and Federal requirements to establish FTA. Verify FTA preadjudicatively in every case. For instructions about State and Federal FTA requirements, see RS 00205.300.

B. Procedure for verifying FTA

Contact the school official and the student to resolve any discrepancies;

Document the information the school official and student provide (for instructions, see Documenting the Adjudicative Decision in GN 01010.053); and

Process the claim (for instructions, see Processing Claims and Conversion Cases for Student Benefits in RS 00205.400D.4. and RS 00205.400F.6.).

Instead of the Form SSA-1372, we can accept a statement the school provides on its own form or letterhead stationery if it gives the same information as the SSA-1372.

Accept a rubber-stamped or mechanical facsimile signature.

Accept other types of evidence worked out by agreement with a particular school if the Assistant Regional Commissioner (ARC), Management Operations and Support, in whose jurisdiction the school is located approves the local procedure.

NOTE: If using other types of evidence (e.g., a letter from the school or a school record), document the nature and acceptability of the evidence.

C. Procedure when a school considers the student in FTA/not in FTA

1. School considers student to be in FTA

Accept the school official's statement that the school considers the student to be in FTA according to its standards and practices for day students.

2. School does not consider student to be in FTA

Inform the student that the school indicates that they are not in FTA. Afford the student an opportunity to rebut the accuracy of the report.

Document the file with the student's response and any contacts with the school when reconciling the issue.

Use the school's report to terminate or deny entitlement if the student does not reply.

Verify attendance at each school if the student is simultaneously attending more than one school. See RS 00205.350D.3. in this section.

D. Procedure for determining full-time attendance

1. Enrolled for 20 hours weekly attendance

a. General

Consider the student to be in FTA for the month that 20 hours of weekly attendance begins or ends.

Christopher began attending school at least 20 hours weekly on August 30 and continued through June 1. Consider them in FTA for August through June.

Consider graduation ceremonies an integral part of school attendance, even though the student may not be scheduled for at least 20 hours of weekly attendance for the month of graduation. If the graduation ceremony is held the month following the month 20 hours of weekly attendance ends, consider the student to be in FTA for the month of graduation, even if the ceremony occurs in or after the month of attainment of age 19.

If, however, there is an interval of one or more months between the cessation of 20 hours of weekly attendance and the graduation ceremony, do not consider the student in FTA after the month the 20-hour weekly attendance ceased.

b. Exceptional situations

Document the file with a statement from a school official if, because of special circumstances, the student is unable to schedule attendance of at least 20 hours per week; the school considers the student to be in FTA under its standards and practices; and either:

The school does not schedule at least 20 hours per week and attending that school is the student's only reasonable alternative; or

The student's medical condition prevents them from scheduled attendance of at least 20 hours per week. Obtain appropriate medical evidence from the student.

John stopped attending school at age 16. At age 18, they enrolled for 16 1/2 hours of scheduled classroom attendance in an evening high school program. John explained that they had stopped attending school at age 16 because of illness and now, at age 18, are too old to attend a conventional high school. They added that they had enrolled for the maximum number of hours available at the evening high school and that the school considers the evening program equivalent to the day program.

Consider John to be in FTA if the school verifies them to be full time according to its standards and practices. This is an exceptional situation and John has provided a reasonable explanation for their scheduled classroom attendance of less than 20 hours weekly.

Patty stopped attending Central High School at age 17. After attaining age 18, they enrolled for 16 1/2 hours scheduled classroom attendance in an evening high school program. Patty explained that they were pregnant and were embarrassed to return to Central High. They added that they had considered enrolling for 20 hours of weekly classroom attendance at the evening high school but did not because the school considered 16 1/2 hours to be full time and they could then have more time to pursue their other interests.

Do not consider Patty to be in FTA. This is not an exceptional situation and they did not provide a reasonable explanation for their scheduled classroom attendance of less than 20 hours weekly.

If, however, Patty enrolls for less than 20 hours of scheduled attendance for medical reasons based on their physician's advice, consider this an exceptional situation. Document the file accordingly.

2. Deemed FTA during a period of nonattendance

a. Period of nonattendance

A student can be in deemed FTA during a period of nonattendance if certain conditions are met. For complete instructions, see Deemed Full-Time Attendance During a Period of Nonattendance in RS 00205.320.

A period of nonattendance begins on the first day of the month following the last month in which the student was in FTA.

A period of nonattendance ends on the last day of the month preceding the month in which the student resumes FTA.

If the student is in FTA and reduces their subject load to less than full-time or to less than 20 hours of scheduled attendance, ordinarily do not consider the student to be in FTA. For instructions about exceptional situations, see RS 00205.350D.1.b. in this section.

Do not deem a student to be in FTA for the period of nonattendance if the student does not plan to resume FTA at an educational institution (EI).

IMPORTANT: A student who attains age 19 during a period of nonattendance is not deemed to be in FTA. If a student attains age 19 during a period of nonattendance, benefits terminate the month the student attains age 19. For an example of how to terminate benefits to a student who attains age 19 during a period of nonattendance, see When Student Benefits Terminate in RS 00205.325F.4.

b. Intent to return to school

Entitle a student for a period of nonattendance of four calendar months or less if they intend to attend or to return to a secondary-level-school program immediately following the period of nonattendance, and the school is an educational institution (EI).

Deem a student who intended to resume FTA timely at an EI, but did not do so, to be in FTA throughout the month in which they changed their intent. Do not, however, entitle the student for more than four calendar months following the last month they were in actual FTA.

Jeff was last in FTA in high school on May 7. They intend to resume FTA at high school on October 25. Jeff’s entitlement can continue uninterrupted since they were a full-time student in May, and they can be deemed to be a full-time student (if all other requirements are met) for the 4-month period from June through September.

c. Establishing intent to return to the same school

Establish intent to resume FTA if the student states that they plan to continue FTA at the same school. Consider the student to be in deemed FTA for the period of nonattendance.

d. Establishing intent to attend a different school

Deem the student to be in FTA for the period of nonattendance if the student states that they plan to resume FTA at a different school that is an EI. In addition to the SSA-1372 for the period of attendance at the first school, give the student a Form SSA-1372 to complete and take to their new school for certification. Inform the student when their benefits will end if they do not return the completed and certified form timely.

Code the STUD screen (MSOM COMMON 005.029) to terminate the student's benefits the month after the first month of intended FTA at the new school.

If the student returns the new form timely, update the STUD screen.

If the student does not return the form timely, benefits will terminate the month after the first month of intended FTA at the new school.

If the student returns the form after benefits have terminated, treat the SSA-1372 as new and material evidence; do not require a new application unless the period of nonattendance exceeded 4 months.

NOTE: Intent is not established if the student does not specify the name of the new school. Terminate benefits the month after the last month of actual FTA.

If you don’t know whether the new school named by the student is an EI, develop per Determining the EI Status of a School in RS 00205.250.

Entitlement continues, pending an EI determination.

If you determine the school is not an EI, terminate the student benefits the later of either: