Transfer students could have their FAFSA flagged by the Dept. of Education as having an unusual enrollment history. The financial aid office could then require academic transcripts from all institutions the student has attended the previous four years in which they also received federal aid.
The financial aid office will then determine whether academic credit was earned at each of those institutions during the award year the student received a Pell Grant or Direct Loan. Based on those determinations the student would then be awarded federal aid for the upcoming academic year if credit hours were completed. If no credit hours were earned at the previous institutions where the student received federal aid, the student would not be eligible for federal aid but could appeal.
Appeals must include the reasons no credit hours were earned, and an explanation of what the student would do in the future to ensure they can complete the hours they register for. If the appeal is approved, the student would be on financial aid probation for one semester. The student would have to meet federal SAP criteria in the probation semester for federal aid to be awarded the next semester.
If the appeal is denied, the student could pay out of pocket, then request a review at the end of the first semester of enrollment to determine whether federal aid could then be awarded the next semester they choose to enroll.