Introduction - ed
A Guide to Creating a Policies and Procedures Manual
(Updated for 2016-2017 Award Year requirements)
The guide is designed to assist institutions in documenting policies and procedures related to the Title IV programs as required by federal regulations. It has been designed to help a school understand the minimum general statutory and regulatory requirements.
Federal regulations require schools to have written policies and procedures for the administration of the Title IV student assistance programs; however a manual is not required. Experience shows that having a manual will assist schools in implementing and adhering to established procedures, as well as routinely reviewing and updating them. A manual may also streamline audit and program review experiences. It is a tool to assist schools in being good stewards in the administration of the Title IV programs and the delivery of dollars and services to students.
To assist your school with revising or creating a policies and procedures manual, we recommend that you begin with these sections first. These areas are typically requested prior to a program review:
Satisfactory Academic Progress (SAP) (Section 1.3)
Admissions (Sections 2.3 and 3.10)
Refunds (Section 8.3)
Return of Title IV Funds (Section 3.2)
Consumer Information (Section 3.4)
Verification (Section 3.5)
Perkins Loan Selection and Awarding of Students (Section 4.1)
FWS Selection and Awarding of Students (Section 5.1)
FSEOG Selection and Awarding of Students (Section 6.1)
When using this guide, consider the following:
• Start creating a policies and procedures manual or cross-reference your answers to a manual that you already have developed.
• Use the icons provided in this guide or establish your own to assist in developing your own style.
• Establish a team with members from all appropriate offices to assist in the writing and review of procedures.
• Include a comprehensive calendar of activities related to student aid delivery, including dates and deadlines for students.
• Develop a schedule to test, review and update your manual. Remember to inform staff of this schedule.
• Train your staff on the procedures – existing ones as well as those revised or newly developed.
Disclaimer: This document has been prepared to provide schools with basic guidance to develop policies and procedures. However, it should not be assumed that this document is all-inclusive. For a more complete explanation of specific program requirements, your school should refer to the applicable statutes, regulations, and the Federal Student Aid Handbook. It is the school’s responsibility to ensure that all Title IV requirements outlined in the Law and regulations are met.
Table of Contents
Institutional Overview
Section 1: Administrative Capability
1.1 Adequate number of qualified person(s) to administer
the Title IV Programs
1.2 Adequate Checks and Balances
1.3 Satisfactory Academic Progress
1.4 Conflicting Data
1.5 Fiscal & Cash Management
1.6 Financial Aid Counseling
Section 2: Institutional Eligibility
1. General Requirements
2. Updating Application Information
3. Admission Policy for Public or Private Nonprofit educational
institution, Proprietary Institution of higher education, and
Postsecondary Vocational Institution
4. State Authorization
Section 3: General Provisions
1. Certification
2. Title IV Refunds
3. Compliance Audits and Audited Financial Statements
4. Consumer Information
5. Verification
a. Schools not participating in the Quality Assurance Program
b. Schools participating in the Quality Assurance Program
6. Professional Judgment & Dependency Overrides
7. Misrepresentation
8. Documentation
9. Secondary Confirmation
10. Ability to Benefit
Section 4: Federal Perkins Loan Program
1. Selection and Awarding of Students
2. Master Promissory Note (MPN)
3. Loan Disclosure
4. Fiscal Procedures and Records
5. Forbearance and Deferment
6. Contact with Borrowers
7. Billing
8. Collection
9. Litigation
10. Cancellation
Section 5: Federal Work-Study Program and Job Location
and Development Program
1. Selection and Awarding of Students
2. Assigning FWS Jobs
3. FWS Fiscal Procedures and Records
4. Job Location and Development (JLD) Procedures
and Records
5. Work Colleges Program Procedures and Records
Section 6: Federal Supplemental Educational Opportunity Grant (FSEOG) Program
1. Selection and Awarding of Students
2. FSEOG Fiscal Procedures and Records
Section 7: Federal Pell Grant Program
1. Calculating Federal Pell Grant Awards
2. Federal Pell Grant required and optional recalculations
3. Fiscal records and disbursement requirements for Pell Grants
4. Disbursement For Books & Supplies
5. Iraq and Afghanistan Service Grant Program
Section 8: Federal Direct Loan Program
1. Borrower Eligibility for Federal Direct Loan/PLUS
2. Counseling Borrowers
3. Payment of a Refund or Return of Title IV
4. Administrative and Fiscal Control
Section 9: TEACH Grant
1. Eligibility Determination
2. Counseling
3. Recalculation of TEACH Grant award amounts
4. Fiscal Control and fund accounting
5. Institutional reporting requirements
Appendix A: Acronyms and Common Terms
Appendix B: Example of a completed policy and procedure
Appendix C: Policies and Procedures At A Glance
Helpful hints for using this guide:
• How to add information or use the check boxes – in order to add information or to use the check boxes, you must right-click on the blank box or the check box and then click properties. From there you can check the boxes or fill in the information you would like. This process may be different depending upon the version of Microsoft Word you use, but right-clicking will allow you to use these functions.
Icon Definition
Icons are a useful way of designating categories of information.
The following icons have been developed for use with your policies and procedures.
|[pic] |Good Practice |
| |Good Practice suggestion. However, if you commit to a good practice you must ensure it is |
| |followed. |
|[pic] |Tip |
| |Suggestions for handling a form or procedures efficiently |
|[pic] |Help |
| |Points the reader to helpful information |
|[pic] |Policy |
| |Briefly states or refers reader to specific policy |
| |documents available in other offices |
|[pic] |Important |
| |A critical piece of information that, if overlooked, |
| |could result in an error |
|[pic] |Exception |
| |A way of doing something that is an exception to |
| |the general rule and why it is an exception |
|[pic] |Definition |
| |Explain terms |
|[pic] |Checklist |
| |A checklist that the user can follow to complete |
| |a task |
|[pic] |Example |
| |A specific example of an activity, a document, etc. |
|[pic] |New |
| |Highlights something new |
Institutional Overview
(Good Practice Suggestion)
An institutional overview provides information specific to your institution that provides colleagues with an understanding of your financial aid operations.
Name of Institution:
OPE ID:
Suggested information:
1. School and its mission, number of students receiving Financial Aid, and its philosophies.
2. Information pertaining to your school that is unique and may
require explanation.
Calendar of Activities
Suggested information:
• Include a calendar of all financial aid activities. The calendar should include an explanation of activities for each month of the year. Be sure to include activities that may involve other offices and list those offices.
Sample of all Forms and Materials used by the school
Suggested information:
• Include copies of all application forms used by the school. Some examples of forms that could be included are: Admissions Applications, FAFSAs, Applications for institutional scholarships or grants, ISIR Records, Loan Applications, Verification Documents (Verification Worksheets, etc), SAP Appeals Forms, Professional Judgment Forms, and any other forms the school uses in determining a student’s eligibility.
• Include an explanation of where to locate Handbooks, Catalogs etc …
|Section 1 |
Policy: Administrative Capability
Regulation: 668.16; 668.34
Purpose: Document the responsibilities of the various offices with respect to the approval, disbursement, and delivery of Title IV, HEA program assistance, and the preparation and submission of reports to the Secretary.
Scope: Specifically Address
1.1 Adequate number of qualified person(s) to administer
the Title IV Programs
1.2 Adequate Checks and Balances
1.3 Satisfactory Academic Progress
1.4 Conflicting Data
1.5 Fiscal Reports and Financial Statements
1.6 Financial Aid Counseling
Responsibilities:
(Identify individuals and/or offices responsible for developing and updating this section)
Definitions:
(Identify acronymns or definitions that will be used in this section)
Resources available to assist in the development of a manual:
• Conflicting Data Activity #1 in the FSA Verification Assessment.
• Satisfactory Academic Progress (SAP) Assessment http:/ifap.qahome/qaassessments/sap.html
• Program Integrity Questions & Answers - Satisfactory Academic Progress
• Default Prevention Resource Information Webpage
• Review the 2016-2017 FSA Handbook (Application and Verification Guide, Volumes 1, 2 and 4) for guidance related to the topics in this section
|Part 1.1 |Adequate Staffing Procedure |This section is required 668.16(b) |
1. List the offices involved in approving and disbursing Title IV Aid. Provide a short description of each office as indicated (If other offices are involved at your school and are not listed below, include descriptions of those offices as well):
Academic or Education Personnel/Registrar:
Employee job duties and staff functions
Institutional communication (how the Registrar communicates with other institutional offices)
Admissions Personnel:
Employee job duties and staff functions
Institutional Communication (how the Admissions Office communicates with other institutional offices)
Financial Aid Personnel:
Employee job duties and staff functions
Institutional Communication (how the Financial Aid Office communicates with other institutional offices)
Fiscal Office Personnel:
Employee job duties and staff functions
Institutional Communication (how the Fiscal Office communicates with other institutional offices)
Placement Officer Personnel:
Employee job duties and staff functions
Institutional Communication (how the Placement Office communicates with other institutional offices)
Campus Security Personnel:
Employee job duties and staff functions
Institutional Communication (how the Campus Security Office communicates with other institutional offices)
2. Number and distribution of financial aid staff:
3. If applicable, document the use of third-party servicers to aid in the administration of Title IV Aid (e.g., ATB independent test administrator (prior to July 1, 2012), Perkins Loan servicer):
4. Select types of program(s) in which the institution participates:
Federal Work Study Federal SEOG
Federal Perkins Federal Pell
National SMART ACG
TEACH Grant FFEL
Direct Loan Grad PLUS
Other Other
Other Other
5. Number of Financial Aid applications evaluated:
6. Number of students who receive Title IV assistance and the amount
of funds administered:
7. Type of financial aid delivery system used by the institution:
8. The degree of the office automation used in the administration of Title IV aid:
Suggested information:
• Description of the type of software application used by the financial aid office and business office. Is the system homegrown or an off the shelf product?
• Process for how ISIR records are received through FAA Access to CPS online and how that data is entered into your own computer system.
• Process for any automatic systems such as packaging, SAP determinations, budget construction, reviewing files, requesting verification documents.
• If financial aid documents are kept in electronic format, explain process.
• Explain how computer systems are backed up.
• Explain security measures in place to protect private information, e.g., the use of passwords, etc.
|Part 1.2 |Adequate Checks and Balances Procedure |This section is required 668.16 (c) |
Include documentation to show clear and separate division of responsibility for the administration of financial aid programs that are divided between the Financial Aid Office and the Fiscal Office.
Complete the information below to indicate individuals who are responsible for the Financial Aid and Fiscal Office as applicable at your institution. You must ensure that there is a separation of function as outlined in 668.16:
Financial Aid Office
Fiscal or Business Office
Good Practices
(Good Practice Suggestion)
Providing specific detail of your organizational structure assists in an understanding of how your Title IV aid operation is structured.
• Describe the organizational structures of the business office and the financial aid office.
• Include the general office hours for the offices and how appointments are made to assist students.
• Include a flow chart or organizational chart that shows the structure and interfaces of both offices.
• Include copies of Job Descriptions for key positions in both offices.
• Include the structure of other offices that work closely with the Financial Aid Office.
• Include Audit & Program Review and Self-Evaluation Processes
Financial Aid Office:
Fiscal or Business Office:
Identify:
Where fiscal records are maintained:
|Part 1.3 |Satisfactory Academic Progress Procedure |This section is required 668.16 (e); |
| | |668.34 |
Documentation to show that Satisfactory Academic Progress standards are published and are reasonably applied for measuring whether an otherwise eligible student is making SAP in his/her educational program.
Please note there are new requirements for SAP that became effective beginning with the 2011-12 academic year. This section provides the requirements for 2011-12 and prior and beyond.
SAP Policy
The school must establish, publish and apply reasonable standards for measuring whether an otherwise eligible student is making SAP in their educational program.
Academic Standards:
SAP Standard for Title IV students:
Standard for student enrolled in same educational program who is not receiving
Title IV assistance:
Are standards for Title IV students the same or stricter than non Title IV students enrolled in the same educational program? Y N
Required Information to be addressed in the school’s SAP Policy:
❑ The policy provides for consistent application of standards to all students within categories of students, e.g., full-time, part-time, undergraduate, and graduate students, and educational programs established by the school.
❑ The policy provides that a student’s academic progress is evaluated at the end of each payment period if the educational program is either one academic year in length or shorter than an academic year; or for all other educational programs, at the end of each payment period or a least annually to correspond with the end of a payment period.
❑ The policy specifies the grade point average (GPA) that a student must achieve at each evaluation, or if a GPA is not an appropriate qualitative measure, a comparable assessment measured against a norm.
❑ If a student is enrolled in an educational program of more than two academic years, the policy specifies that at the end of the second academic year, the student must have a GPA of at least a “C” or its equivalent, or have academic standing consistent with the school’s requirements for graduation.
❑ The policy must include a maximum timeframe in which the student must complete his or her educational program. For an undergraduate program measured in credit hours, the maximum timeframe cannot be longer than 150 percent of the published length of the educational program, as measured in credit hours. For an undergraduate program measured in clock hours, the maximum timeframe cannot be longer than 150 percent of the published length of the educational program, as measured by the cumulative number of clock hours the student is required to complete and expressed in calendar time. For a graduate program, the maximum timeframe must be defined by the school and must be based on the length of the educational program.
❑ The policy must specify the pace at which a student must progress through his or her educational program to ensure that the student will complete the program within the maximum timeframe and must provide for measurement of the student’s progress at each evaluation.
❑ The school must calculate the pace at which the student is progressing by dividing the cumulative number of hours the student has successfully completed by the cumulative number of hours the student has attempted. In making this calculation, the school is not required to include remedial courses.
❑ The policy must describe how a student’s GPA and pace of completion are affected by course incompletes, withdrawals, or repetitions (see definition of full-time student in 34 CFR 668.2(b)), or transfers of credit from other institutions. Credit hours from another institution that are accepted toward the student’s educational program must count as both attempted and completed hours.
❑ The policy must provide that, at the time of each evaluation, a student who has not achieved the required GPA, or who is not successfully completing his or her educational program at the required pace, is no longer eligible to receive assistance under the Title IV, HEA programs unless: For schools that evaluate SAP at the end of each payment period, the student is placed on financial aid warning or the student has appealed and has been placed on financial aid probation. For schools that evaluate SAP annually or less frequently than at the end of each payment period, the student has appealed and has been placed on financial aid probation.
Financial Aid Warning and Financial Aid Probation:
❑ If the school places students on financial aid warning, or on financial aid probation, the policy must describe these statuses and that a student on financial aid warning may continue to receive assistance under the Title IV, HEA programs for one payment period despite a determination that the student is not making SAP. Financial Aid Warning Status may be assigned without an appeal or other action by the student. The policy may also include, for a student on Financial Aid Probation, that they may receive Title IV, HEA program funds for one payment period. Further, while a student is on financial aid probation, the school may choose to require the student to fulfill specific terms and conditions such as taking a reduced course load or enrolling in specific courses. At the end of one payment period on financial aid probation, the policy must require that the student meet the school’s SAP standards or meet the requirements of the academic plan developed by the school to qualify for further Title IV, HEA program funds.
Appeal Process:
❑ If the school’s policy permits a student to appeal a determination by the school that he or she is not making SAP, the policy must describe how the student may reestablish his or her eligibility to receive assistance under the Title IV, HEA Programs; the basis on which a student may file an appeal: The death of a relative, an injury or illness of the student, or other special circumstances and information the student must submit regarding why the student failed to make SAP, and what has changed in the student’s situation that will allow the student to demonstrate SAP at the next evaluation.
❑ If the school’s policy does not permit a student to appeal a determination by the school that he or she is not making SAP, the policy must describe how the student may reestablish his or her eligibility to receive assistance under the Title IV, HEA programs.
Notification:
❑ The school’s policy must provide for notification to students of the results of an evaluation that impacts the student’s eligibility for Title IV, HEA program funds.
For schools that evaluate SAP at the end of each payment period the policy must specifically address the following:
❑ If a student is not making SAP according to the school’s policy at the end of each payment period, the school’s policy may (for the payment period following the payment period in which the student did not make SAP) – place the student on financial aid warning, and disburse Title IV HEA program funds to the student; or place the student directly on financial aid probation.
❑ For the payment period following a payment period during which a student was on financial aid warning, the school’s procedures may include placing the student on financial aid probation and disbursing Title IV HEA program funds to the student if – a) the school evaluates the student’s progress and determines the student did not make SAP during the payment period the student was on financial aid warning; b) the student appeals the determination; and c) the school determines that the student should be able to meet the school’s SAP standards by the end of the subsequent payment period or the school develops an academic plan for the student that, if followed, will ensure that the student is able to meet the school’s SAP standards by a specific point in time.
❑ The school’s policy must not allow a student on financial aid probation for a payment period to receive Title IV, HEA program funds for the subsequent payment period unless the student makes SAP or the school determines that the student met the requirements specified by the school in the academic plan for the student.
For schools that evaluate SAP annually or less frequently than the end of each payment period, the policy must specifically address the following:
❑ If a student is not making SAP according to the school’s policy, the school may place the student on financial aid probation and may disburse Title IV, HEA program funds to the student for the subsequent payment period if –a) the school evaluates that the student is not making satisfactory academic progress; b) the student appeals the determination; and c) the school determines that the student should be able to make satisfactory academic progress during the subsequent payment period and meet the school’s satisfactory academic progress standards at the end of that payment period, or the school develops an academic plan for the student that, if followed, will ensure that the student is able to meet the school’s satisfactory academic progress standards by a specific point in time.
❑ The school’s policy must not allow a student on financial aid probation for a payment period to receive Title IV, HEA program funds for the subsequent payment period unless the student makes SAP or the school determines that the student met the requirements specified by the school on the academic plan for the student.
[pic] Important A critical piece of information that, if overlooked, could result in an error
Academic Year Definition (668.3):
Schools must define the Title IV academic year for each eligible program. A school may have different definitions of the academic year for different programs. Schools must properly define and understand the academic year definition in order to accurately award and disburse Title IV funds. The academic year definition is also used for monitoring SAP and tracking loan usage periods for the subsidized Direct Loan limitation.
Schools are required to define their academic year. It is essential to include the definition in this section in order to understand your SAP standards.
1. Include whether the school offers programs in credit hours with terms, clock hours, or credit hours without terms.
2. Include the minimum academic year definition for all programs.
3. Include whether your school’s academic year is more than the minimum requirement.
4. Include whether the school has one definition for all programs. If not, include
an explanation of those programs that need a different definition.
5. Include whether the payment periods are determined by terms or by hours
and weeks.
|Part 1.4 |Conflicting Data |This section is required 668.16 (f); |
| | |668.54(a)(3) |
Schools must have an adequate system to identify and resolve discrepancies in the information that the school receives from different sources with respect to a student’s application for financial aid under the Title IV, HEA programs. Use the information in this section to help you develop your procedures for resolving conflicting data.
Resolving Conflicting Data:
Your school’s procedures must ensure that you resolve conflicting data for your applicants as follows:
• Applicants selected for verification – If the school has reason to believe that any information on the application used to calculate the EFC is discrepant or inaccurate (or if any supporting documentation is discrepant or inaccurate), you must require the applicant to provide adequate documentation to resolve the conflict.
• Applicants not selected for verification – the school must resolve conflicting information regardless of whether or not the applicant was selected for verification. The financial aid office must review all tax returns provided to the school even if they were not requested. All C Codes on the ISIR must be reviewed and resolved by the financial aid office.
• Other applicant information received by the school – The school must have an adequate internal system to identify conflicting information that it may have regardless of the source. The office lead for each office is required to provide information that could impact the financial aid status of each student applicant e.g. (Admissions Office: High School Diploma, Fiscal Office: Report outside awards, Graduate Aid Office: Report outside awards, Registrar: Report changes in enrollment, FWS Office: Report FWS earning in a calendar year, NSLDS: Review financial aid history, (e.g. review aid received from prior colleges attended).
Your procedures should also address the following:
Implementation of the 2017-2018 Early FAFSA. The 2017-2018 FAFSA has been commonly referred to as the Early FAFSA because the 2017-2018 FAFSA becomes available for students to complete on October 1 of the preceding year, instead of January 1, as was the case for FAFSAs before 2017-2018. For example, the 2016-2017 FAFSA became available on January 1, 2016. With the implementation of the Early FAFSA, the 2017-2018 FAFSA is available beginning on October 1, 2016. In addition to the earlier FAFSA filing date, the 2017-2018 FAFSA introduces the use of prior-prior year income and tax information. This means that the same 2015 income and tax information that was reported on the 2016-2017 FAFSA, should be reported on the 2017-2018 FAFSA. To help schools address possible conflicting information between the 2016-2017 and the 2017-2018 FAFSA, the U.S. Department of Education created special edit codes that the Central Processing System (CPS) uses to alert institutions if there is possible conflicting information between the 2016-2017 and the 2017-2018 FAFSAs. These special edit codes were designed to take into account logical income and tax information difference that may occur because of marital status changes, and dependency status changes. The Department of Education released a Dear Colleague Letter providing institutions with guidance on how to resolve conflicting information identified by these edit codes, and what remaining responsibility schools have to identify and resolve any conflicting information not identified by the edit codes. Please be sure your procedures address the resolution of conflicting data according to the DCL referenced above.
In addition, the following charts provide examples of conflicting data to assist you in the development of your own procedures.
The charts below are available by selecting the link:
Good practices vs. what is required
Chart A provides examples of issues that are considered Conflicting Data. Although the chart is designed to be extensive, it is not to be construed as an all-inclusive list. The chart is provided for information only and has been developed to help you review your policies and procedures.
(Important) A critical piece of information that, if overlooked, could result in an error.
Chart B provides examples of issues not considered Conflicting Data, but would be a good practice to consider. The chart is provided for information only and has been developed to help you review your policies and procedures.
(Good Practice Suggestion)
Chart A: Examples of issues considered Conflicting Data
| |
|A student is not selected for verification, the tax return or IRS transcript is on file and information conflicts with items on the FAFSA. |
| |
|An IRS 1040 Tax Return shows single head of household and on the FAFSA/ISIR shows the same person as married. |
| |
|A Parent or student reports on their FAFSA and signed a verification worksheet that they will not file an IRS 1040 Tax Return. You have reason to believe that |
|they would have been required to file a U.S. Income Tax Return, as the amount of reported income is greater than or equal to the minimum amount required to |
|file as indicated in the instructions provided by the IRS. |
| |
|A school receive statements or information that suggests that the copy of the IRS Income Tax Return you received is not the Income Tax Return actually filed |
|with the IRS. |
| |
|A school receives a “Profile” from CSS where the student reports a specific amount of untaxed income; FAFSA reports a different amount. (If the school receives|
|the CSS Profile, it must ensure that information contained there does not conflict with other documents received by the school). The information on the FAFSA |
|must not conflict with what is collected on the CSS Profile if the school chooses to use it. |
| |
|Veterans Affairs (VA) benefits verified by the certifying official in the Registrar don’t match the FAFSA. (To resolve conflicting information, the school can |
|rely on the certifying official). |
| |
|Admissions information received impacts student eligibility (i.e., student accepted into a non degree program, student received scholarship from high school, |
|etc.) |
| |
|The Student Academic Progress or Enrollment Status on file in the Financial Aid Office doesn’t agree with the information from the Registrar Office. |
This is a good practice. However, if you choose to include these examples, you must follow them consistently.
(Good Practice Suggestion)
Chart B: Examples of issues not considered Conflicting Data, but would be a good practice to consider for review
| |
|Review assets reported on the FAFSA to determine, if applicable, that the information report matches the provided |
|U.S. Income Tax Return. For example, if the assets on the FAFSA are $0 or low but significant interest and |
|dividend income or capital gains are reported on the U.S. Income Tax Return. |
|If $0 income is reported (Your institution may want to consider developing a method to review $0 to low income |
|reporting). |
|Review the address reported by the student/parent |
|Review to determine if the student or parents reported business/farm net worth but didn’t file a schedule C or |
|Form 1120 or just didn’t supply it to the school (Your institution may want to consider requesting additional |
|documentation from the student or parent). |
|If the school collects a W-2, review Box 14 information from W-2 (Determine if the dollars represented are untaxed|
|income not previously reported). |
Identify person(s) responsible for coordinating both Federal and non-federal aid at your institution.
• Provide procedure as to how Federal and non-Federal aid is identified and processed through the financial aid office.
Provide procedure to identify and resolve discrepancies in the information that the institution receives from different sources with respect to a student’s application for Title IV aid.
• Identify all student aid applications, need analysis documents, Statements of Registration Status, and eligibility notification documents presented by or on behalf of each aid applicant. Provide a description of all documents, including any copies of State and Federal income tax returns that are normally collected.
• Include a description of how the institution verifies information received from the student or other sources.
• Include procedures concerning the coordination of any other information normally available to the institution regarding a student’s citizenship, previous educational experience (NSLDS), documentation of the student’s social security number, or other factors relating to the student’s eligibility for Title IV Aid (e.g. coordinating outside aid received by various offices on campus).
• Include procedures to refer to the Office of the Inspector General of the Department of Education for investigation any credible information indicating that an applicant for Title IV may have engaged in fraud or other criminal conduct.
• Include any credible information indicating that any employee, third-party servicer, or other agent of the school , who acts in a capacity involving the administration of Title IV, HEA programs, or the receipt of funds under those programs may have engaged in fraud, misrepresentation, conversion or breach of fiduciary responsibility or other illegal conduct involving the Title IV, HEA programs.
|Part 1.5 |Fiscal & Cash Management |This section is required 668.16 (d); |
| | |668.24 (b); 668.164; 668.165; 668.166 |
Additional fiscal requirements are found throughout most sections of this manual. The fiscal requirements here are also part of the fiscal requirements in Sections 4-11 of this manual. You may choose to repeat the information contained in this section (in sections 4-11) or you can refer to this section as appropriate. However, you must still include the specific information required in addition to this general fiscal information as applicable in each section.
Maintaining records required under the individual Title IV HEA program regulations. Specifically,
Fiscal reports and financial statements
• Identify the process used to obtain information for required fiscal reports and financial statements. Include bank account and internal ledger reconciliation procedures.
Develop and follow procedures for record retention and examinations as outlined in 34 CFR 668.24. Use the following information to ensure your procedures are adequately developed:
Record retention and examinations 34 CFR 668.24 (b)
← Your school’s procedures must include the following:
Program records 34 CFR 668.24(a)
← Your school must establish and maintain, on a current basis, any application for Title IV, HEA program funds and program records that document:
← Your school’s eligibility to participate in the title IV, HEA programs
← The eligibility of its educational program for title IV, HEA program funds
← Your school’s administration of the title IV, HEA programs in accordance with all applicable requirements
← Your school’s financial responsibility
← Information included in any application for title IV, HEA program funds
← Your school’s disbursement and delivery of title IV, HEA program funds
Describe the school’s procedures to ensure compliance with the Program records requirements:
Fiscal records 34 CFR 668.24(b)
← Your school must account for the receipt and expenditure of title IV, HEA program funds in accordance with generally accepted accounting principles.
← Your school must establish and maintain on a current basis:
← Financial records that reflect each HEA, title IV program transaction
← General ledger control accounts that identify each title IV, HEA program transaction and separate those transactions from all other institutional financial activity
Describe the school’s procedures to ensure compliance with the Fiscal records requirements:
Required Records 34 CFR 668.24(c)
← The records your school must maintain must include (but are not limited to):
← The Student Aid Report (SAR) or Institutional Student Information Record (ISIR) used to determine eligibility for title IV, HEA program funds
← Application data submitted to the Secretary, lender, or guaranty agency by the school on behalf of the student or parent
← Documentation of each student’s or parent borrower’s eligibility for title IV, HEA program funds
← Documentation relating to each student’s or parent borrower’s receipt of title IV, HEA program funds, including but not limited to documentation of:
← The amount of grant, loan or FWS award; its payment period; its loan period, if appropriate; and the calculations used to determine the amount of the grant, loan, or FWS award
← The date and amount of each disbursement or delivery of grant or loan funds, and the date and amount of each payment of FWS wages
← The amount, date, and basis of the school’s calculation of any refunds or overpayments due to or on behalf of the student, or the treatment of title IV, HEA program funds when a student withdraws
← The payment of any overpayment or the return of any title IV, HEA program funds to the title IV, HEA program fund, a lender, or the Secretary, as appropriate
← Documentation of and any information collected at any initial or exit counseling required by applicable program regulations
← Reports and forms used by the school in its participation in a title IV HEA program, and any records needed to verify data that appear in those reports and forms
← Documentation supporting the school’s calculations of its completion or graduation rates under 34 CFR 668.47 and 34 CFR 668.48
Describe the school’s procedures to ensure compliance with the records requirements:
General requirements 34 CFR 668.24(d)
← Your school must maintain required records in a systematically organized manner
← Your school must make its records readily available for review by the Secretary or the Secretary’s authorized representative at a school location designated by the Secretary or the Secretary’s authorized representative
← Your school may keep required records in hard copy or in microform, computer file, optical disk, CD-ROM, or other media formats, provided that:
← Except for the Student Aid Report (SAR) or Institutional Student Information Record (ISIR) that has special instructions outlined in 34 CFR 668.24(d)(3)(ii), all records must be retrievable in a coherent hard copy format or in other media formats acceptable to the Secretary
← Your school shall maintain the SAR or ISIR used to determine eligibility for title IV, HEA program funds in the format in which it was received by the school, except that the SAR may be maintained in an imaged media format
← Any imaged media format used to maintain required records must be capable of reproducing an accurate, legible, and complete copy of the original document, and when printed, this copy must be maintained in its original hard copy or in an imaged media format
← Any document that contains a signature, seal, certification, or any other image or mark required to validate the authenticity of its information must be maintained in its original hard copy or in an imaged media format
← If your school participates in the Federal Perkins Loan Program, your procedures must address the requirements outlined in 34 CFR 674.19
← If your school closes, stops providing educational programs, is terminated or suspended from the title IV, HEA programs, or undergoes a change in ownership that results in a change of control as described in 34 CFR 600.31, it shall provide for:
← The retention of required records
← Access to those records, for inspection and copying, by the Secretary or the Secretary’s authorized representative
Describe the school’s procedures to ensure compliance with the general records requirements:
Record retention 34 CFR 668.24(e)
← Unless otherwise directed by the Secretary:
← Your school shall keep records relating to its administration of the Federal Perkins loan, FWS, FSEOG, Federal Pell Grant, ACG, National SMART Grant, or TEACH Grant Program for three years after the end of the award year for which the aid was awarded and disbursed under those programs, provided that your school shall keep:
← The Fiscal Operations Report and Application to Participate in the Federal Perkins Loan, FSEOG, and FWS Programs (FISAP), and any records necessary to support the data contained in the FISAP, including “income grid information,” for three years after the end of the award year in which the FISAP is submitted
← Repayment records for a Federal Perkins Loan, including records related to cancellation and deferment requests, in accordance with the provisions of 34 CFR 674.19 (see Section 4.4 of this Guide)
← Your school shall keep records relating to a student or parent borrower’s eligibility and participation in the Direct Loan Program for three years after the end of the award year in which the student last attended the school
← Your school shall keep all other records relating to its participation in the Direct Loan Program, including records of any other reports or forms, for three years after the end of the award year in which records are submitted
← Your school shall keep all records involved in any loan, claim, or expenditure questioned by a title IV, HEA program audit, program review, investigation, or other review until the later of:
← The resolution of that questioned loan, claim, or expenditure; or
← The end of the retention period applicable to the record
Describe the school’s procedures to ensure compliance with the record retention requirements:
Examination of records 34 CFR 668.24(f)
← Your school, and third-part servicer, if any, cooperates with an independent auditor, the Secretary, the Department of Education’s Inspector General, the Comptroller General of the United States, or their authorized representatives, and the school’s accrediting agency, in the conduct of audits, investigations, program reviews, or other reviews authorized by law
← Your school and servicer must cooperate by:
← Providing timely access, for examination and copying, to requested records, including but not limited to computerized records and records reflecting transactions with any financial institution with which the school or servicer deposits or has deposited any title IV, HEA program funds, and to any pertinent books, documents, papers, or computer programs
← Providing reasonable access to personnel associated with the school’s or servicer’s administration of the title IV programs for the purpose of obtaining relevant information
← The Secretary considers that a school or servicer has failed to provide reasonable access to personnel if the school or servicer:
← Refuses to allow those personnel to supply all relevant information
← Permits interviews with those personnel only if the school’s or servicer’s management is present; or
← Permits interviews with those personnel only if the interviews are tape recorded by the school or servicer
← Upon request of the Secretary, your school or servicer promptly shall provide any information the school or servicer has respecting the last known address, full name, telephone number, enrollment information, employer, and employer address of a recipient of title IV funds who attends or attended the school
Describe the school’s procedures to ensure compliance with the examination of records requirements:
Disbursing Title IV Funds 34 CFR 668.164
Include procedures to show how your school maintains Title IV funds received in accordance with the disbursement requirements outlined in 34 CFR 668.164.
Disbursement 34 CFR 668.164(a):
← Except as provided under 34 CFR 668.164 (a)(2) include procedures to ensure that the institution considers that a disbursement of title V, HEA program funds occurs on the date that the institution credits the student’s ledger account or pays the student or parent directly with funds received from the Secretary; or institutional funds used in advance of receiving title IV, HEA program funds.
← For a Direct Loan for which the student is subject to the delayed disbursement requirements under 34 CFR 685.303(b)(5):
← If the institution credits a student’s ledger account with institutional funds earlier than 30 days, the institution considers that the disbursement is made on the 30th day after the beginning of the payment period.
← If the institution credits a student’s ledger account with institutional funds earlier than 10 days before the first day of classes of a payment period, the institution considers that the disbursement is made on the 10th day before the first day of classes of a payment period.
Describe the school’s disbursement procedures:
Disbursements by payment period 34 CFR 668.164(b):
Include procedures to address the following:
← Except for paying a student under the FWS program or unless 34 CFR 685.303(d)(4)(i) applies, the institution disburses during the current payment period the amount of title IV, HEA program funds that a student enrolled at the institution, or the student’s parent, is eligible to receive for that payment period.
← If the institution makes a prior year, late, or retroactive disbursement as provided under 34 CFR 668.164(c)(3), (j), or (k), it ensures that the student was enrolled and eligible during the payment period covered by that prior year, late, or retroactive disbursement.
← At the time a disbursement is made to a student for a payment period, the institution confirms that the student is eligible for the type and amount of title IV, HEA program funds identified by the disbursement. If the institution engages a servicer to perform activities or transactions that lead to or support that disbursement, the institution must ensure that the third party servicer confirms the student’s eligibility. Those activities and transactions include but are not limited to:
← Determining the type and amount of title IV, HEA program funds that a student is eligible to receive;
← Requesting funds under a payment method described in 34 CFR 668.162; or
← Accounting for funds that are originated, requested, or disbursed, in reports or data submissions to the Secretary.
Describe the school’s procedures to ensure disbursement by payment period:
Crediting a student’s ledger account 34 CFR 668.164(c):
← If the institution credits a student’s ledger account with title IV, HEA program funds to pay for allowable charges associated with the current payment period, the allowable charges are:
← The amount of tuition, fees, and institutionally provided room and board assessed the student for the payment period, or as provided in 34 CFR 668.164(c)(5), the prorated amount of those charges if the institution debits the student’s ledger account for more than the charges associated with the payment period; and
← The amount incurred by the student for the payment period for purchasing books, supplies, and other educationally related goods and services provided by the institution for which the institution obtains the student’s or parent’s authorization under 34 CFR 668.165(b).
← The institution ensures that it only includes the costs of books and supplies as part of tuition and fees under 34 CFR 668.164(c)(1)(i) if the institution:
← Has an arrangement with a book publisher or other entity that enables it to make those books or supplies available to students below competitive market rates;
← Provides a way for a student to obtain those books and supplies by the seventh day of a payment period; and
← Has a policy under which the student may opt out of the way the institution provides for the student to obtain books and supplies under 34 CFR 668.164(c)(2). A student who opts out under 34 CFR 668.164(c)(2) is considered to also opt out under 34 CFR 668.164(m)(3).
← The institution documents on a current basis that the books or supplies, including digital or electronic course materials, are not available elsewhere or accessible by students enrolled in the program from sources other than those provided or authorized by the institution; or
← The institution demonstrates that there is a compelling health or safety reason
← If the institution includes in one or more payment periods for the current year, prior year charges of not more than $200, it ensures that those charges are for:
← Tuition, fees, and institutionally provided room and board, as provided under 34 CFR 668.164(c)(1)(i), without obtaining the student’s or parent’s authorization; and
← Educationally related goods and services, provided by the institution, as described in 34 CFR 668.164(c)(1)(ii), if the institution obtains the student’s or parent’s authorization under 34 CFR 668.165(b).
← If the institution chooses, it may include in the current payment period unpaid allowable charges from any previous payment period in the current award year or current loan period for which the student was eligible for title IV, HEA program funds.
← The institution ensures that it determines the prorated amount of charges associated with the current payment period by:
← For a program with substantially equal payment periods, dividing the total institutional charges for the program by the number of payment period in the program; or
← For other programs, dividing the number of credit or clock hours in the current payment period by the total number of credit or clock hours in the program, and multiplying that result by the total institutional charges for the program.
Describe the school’s procedures to when crediting a student’s ledger account:
Direct Payments 34 CFR 668.164(d):
← Except as provided under 34 CFR 668.164(d)(3), the institution ensures that it makes any direct payment:
← To a student, for the amount of title IV, HEA program funds that a student is eligible to receive, including Direct PLUS Loan funds that the student’s parent authorized the student to receive, by:
← Initiating an EFT of that amount to the student’s financial account;
← Issuing a check for that amount payable to, and requiring the endorsement of, the student; or
← Dispensing cash for which the institution obtains a receipt signed by the student
← To a parent, for the amount of the Direct PLUS Loan funds that a parent does not authorize the student to receive, by
← Initiating an EFT of that amount to the parent’s financial account;
← Issuing a check for that amount payable to and requiring the endorsement of the parent; or
← Dispensing cash for which the institution obtains a receipt signed by the parent
← Issuing a check. The institution ensures that it considers a check issued on the date that it:
← Mails the check to the student or parent; or
← Notifies that student or parent that the check is available for immediate pick-up at a specified location at the institution. The institution ensures that is holds the check for no longer than 21 days after the date it notifies the student or parent. If the student or parent does not pick up the check, the institution immediately mails the check to the student or parent, pays the student or parent directly by other means, or returns the funds to the appropriate title IV, HEA program
← Student choice. If the institution is located in a State that makes direct payments to a student by EFT and that enters into an arrangement described in 34 CFR 668.164(e) or (f), including if the institution uses a third-party servicer to make those payments, it has established a selection process under which the student chooses one of several options for receiving those payments.
In implementing its selection process, the institution ensures that:
← It informs the student in writing that he or she is not required to open or obtain a financial account or access device offered by or through a specific financial institution;
← The student's options for receiving direct payments are described and presented in a clear, fact-based, and neutral manner;
← Initiating direct payments by EFT to a student's existing financial account is as timely and no more onerous to the student as initiating an EFT to an account provided under an arrangement described in 34 CFR 668.164 (e) or (f);
← It allows the student to change, at any time, his or her previously selected payment option, as long as the student provides the institution with written notice of the change within a reasonable time;
← No account option is preselected; and
← A student who does not make an affirmative selection is paid the full amount of the credit balance within the appropriate time-period specified in 34 CFR 668.164 (h)(2), using a method specified in 34 CFR 668.164(d)(1).
Direct Payments 34 CFR 668.164(d) (continued):
In describing the options under its selection process, the institution ensures that it:
← Prominently presents as the first option, the financial account belonging to the student;
← Lists and identifies the major features and commonly assessed fees associated with each financial account offered under the arrangements described in 34 CFR 668.164 (e) and (f), as well as a URL for the terms and conditions of each account. For each account, if an institution by July 1, 2017 follows the format, content, and update requirements specified by the Secretary in a notice published in the Federal Register following consultation with the Bureau of Consumer Financial Protection, it will be in compliance with the requirements of this section with respect to the major features and assessed fees associated with the account; and
← Although not required, the institution may provide, for the benefit of the student, information about available financial accounts other than those described in 34 CFR 668.164 (e) and (f) that have deposit insurance under 12 CFR part 330, or share insurance in accordance with 12 CFR part 745.
← If your institution does not offer or use any financial accounts offered under 34 CFR 668.164 (e) or (f) it may make direct payments to a student's or parent's existing financial account, or issue a check or disburse cash to the student or parent without establishing the selection process described in 34 CFR 668.164(d)(4)(i).
Describe the school’s procedures Direct Payments:
Tier one arrangement 34 CFR 668.164(e):
If your institution is under a Tier one (T1) arrangement (as described in 34 CFR 668.164(e)(1) the institution ensures that:
← The student's consent to open the financial account is obtained before an access device, or any representation of an access device, is sent to the student, except that an institution may send the student an access device that is a card provided to the student for institutional purposes, such as a student ID card, so long as the institution or financial institution obtains the student's consent before validating the device to enable the student to access the financial account;
← Any personally identifiable information about a student that is shared with the third-party servicer before the student makes a selection under paragraph 34 CFR 668.164(d)(4)(i):
← Does not include information about the student, other than directory information under 34 CFR 99.3 that is disclosed pursuant to 34 CFR 99.31(a)(11) and 99.37, beyond:
← A unique student identifier generated by the institution that does not include a Social Security number, in whole or in part;
← The disbursement amount;
← A password, PIN code, or other shared secret provided by the institution that is used to identify the student; or
← Any additional items specified by the Secretary in a notice published in the Federal Register;
Tier one arrangement 34 CFR 668.164(e) (continued):
← Is used solely for activities that support making direct payments to the student and not for any other purpose
← Is not shared with any other affiliate or entity except for the purpose described in 34 CFR 668.164(e)(2)(ii)(B)
← Informs the student of the terms and conditions of the financial account, as required under 34 CFR 668.164(d)(4)(i)(B)(2), before the financial account is opened
← Ensures that the student:
← Has convenient access to the funds in the financial account through a surcharge-free national or regional Automated Teller Machine (ATM) network that has ATMs sufficient in number and housed and serviced such that title IV funds are reasonably available to students, including at the times the institution or its third-party servicer makes direct payments into the financial accounts of those students;
← Does not incur any cost:
← For opening the financial account or initially receiving an access device;
← Assessed by the institution, third-party servicer, or a financial institution associated with the third-party servicer, when the student conducts point-of-sale transactions in a State; and
← For conducting a balance inquiry or withdrawal of funds at an ATM in a State that belongs to the surcharge-free regional or national network;
← Ensures that:
← The financial account or access device is not marketed or portrayed as, or converted into, a credit card;
← No credit is extended or associated with the financial account, and no fee is charged to the student for any transaction or withdrawal that exceeds the balance in the financial account or on the access device, except that a transaction or withdrawal that exceeds the balance may be permitted only for an inadvertently authorized overdraft, so long as no fee is charged to the student for such inadvertently authorized overdraft; and
← The institution, third-party servicer, or third-party servicer's associated financial institution provides a student accountholder convenient access to title IV, HEA program funds in part and in full up to the account balance via domestic withdrawals and transfers without charge, during the student's entire period of enrollment following the date that such title IV, HEA program funds are deposited or transferred to the financial account;
← No later than September 1, 2016, and then no later than 60 days following the most recently completed award year thereafter, discloses conspicuously on the institution's Web site the contract(s) establishing the T1 arrangement between the institution and third-party servicer or financial institution acting on behalf of the third-party servicer, as applicable, except for any portions that, if disclosed, would compromise personal privacy, proprietary information technology, or the security of information technology or of physical facilities;
← No later than September 1, 2017, and then no later than 60 days following the most recently completed award year thereafter, discloses conspicuously on the institution's Web site and in a format established by the Secretary:
← The total consideration for the most recently completed award year, monetary and non-monetary, paid or received by the parties under the terms of the contract; and
← For any year in which the institution's enrolled students open 30 or more financial accounts under the T1 arrangement, the number of students who had financial accounts under the contract at any time during the most recently completed award year, and the mean and median of the actual costs incurred by those account holders;
Tier one arrangement 34 CFR 668.164(e) (continued):
← Provides to the Secretary an up-to-date URL for the contract and contract data as described in paragraph 34 CFR 668.164(e)(2)(vii) for publication in a centralized database accessible to the public;
← Ensures that the terms of the accounts offered pursuant to a T1 arrangement are not inconsistent with the best financial interests of the students opening them. The Secretary considers this requirement to be met if:
← The institution documents that it conducts reasonable due diligence reviews at least every two years to ascertain whether the fees imposed under the T1 arrangement are, considered as a whole, consistent with or below prevailing market rates; and
← All contracts for the marketing or offering of accounts pursuant to T1 arrangements to the institution's students make provision for termination of the arrangement by the institution based on complaints received from students or a determination by the institution under 34 CFR 668.164(e)(2)(ix)(A) that the fees assessed under the T1 arrangement are not consistent with or are higher than prevailing market rates
← Takes affirmative steps, by way of contractual arrangements with the third-party servicer as necessary, to ensure that requirements of this section are met with respect to all accounts offered pursuant to T1 arrangements.
← Except for 34 CFR 668.164(e)(2)(ii)(B) and (C), the requirements of 34 CFR 668.164(e)(2) no longer apply to a student who has an account described under 34 CFR 668.164(e)(1) when the student is no longer enrolled at the institution and there are no pending title IV disbursements for that student, except that nothing in 34 CFR 668.164(e)(3) should be construed to limit the institution's responsibility to comply with 34 CFR 668.164(e)(2)(vii) with respect to students enrolled during the award year for which the institution is reporting. To effectuate this provision, an institution may share information related to students' enrollment status with the servicer or entity that is party to the arrangement.
Describe the school’s procedures for Tier one arrangement:
Tier two arrangement 34 CFR 668.164 (f):
If your institution is under a Tier two (T2) arrangement (as described in 34 CFR 668.164(f)(1) the institution ensures that it:
← Complies with the requirements described in 34 CFR 668.164(d)(4)(i), 34 CFR 668.164(f)(4)(i) through (iii), (vii), and (ix) through (xi), and (f)(5) if it has at least one student with a title IV credit balance in each of the three most recently completed award years, but has less than the number and percentage of students with credit balances as described in 34 CFR 668.164 (f)(2)(ii)(A) and (B); and
← Complies with the requirements specified in 34 CFR 668.164(d)(4)(i), 34 CFR 668.164(f)(4), and (f)(5) if, for the three most recently completed award years:
← An average of 500 or more of its students had a title IV credit balance; or
← An average of five percent or more of the students enrolled at the institution had a title IV credit balance. The institution calculates this percentage as follows:
← The average number of students with credit balances for the three most recently completed award years
← The average number of students enrolled at the institution at any time during the three most recently completed award years.
Tier two arrangement 34 CFR 668.164 (f) (continued):
The Secretary considers that a financial account is marketed directly if:
← The institution communicates information directly to its students about the financial account and how it may be opened;
← The financial account or access device is cobranded with the institution's name, logo, mascot, or other affiliation and is marketed principally to students at the institution; or
← A card or tool that is provided to the student for institutional purposes, such as a student ID card, is validated, enabling the student to use the device to access a financial account.
Under a T2 arrangement, the institution must:
← Ensure that the student's consent to open the financial account has been obtained before:
← The institution provides, or permits a third-party servicer to provide, any personally identifiable information about the student to the financial institution or its agents, other than directory information under 34 CFR 99.3 that is disclosed pursuant to 34 CFR 99.31(a)(11) and 99.37;
← An access device, or any representation of an access device, is sent to the student, except that an institution may send the student an access device that is a card provided to the student for institutional purposes, such as a student ID card, so long as the institution or financial institution obtains the student's consent before validating the device to enable the student to access the financial account;
← Inform the student of the terms and conditions of the financial account as required under 34 CFR 668.164(d)(4)(i)(B)(2), before the financial account is opened;
← No later than September 1, 2016, and then no later than 60 days following the most recently completed award year thereafter:
← Disclose conspicuously on the institution's Web site the contract(s) establishing the T2 arrangement between the institution and financial institution in its entirety, except for any portions that, if disclosed, would compromise personal privacy, proprietary information technology, or the security of information technology or of physical facilities; and
← Provide to the Secretary an up-to-date URL for the contract for publication in a centralized database accessible to the public;
← No later than September 1, 2017, and then no later than 60 days following the most recently completed award year thereafter, disclose conspicuously on the institution's Web site and in a format established by the Secretary:
← The total consideration for the most recently completed award year, monetary and non-monetary, paid or received by the parties under the terms of the contract; and
← For any year in which the institution's enrolled students open 30 or more financial accounts marketed under the T2 arrangement, the number of students who had financial accounts under the contract at any time during the most recently completed award year, and the mean and median of the actual costs incurred by those account holders
← Ensure that the items under 34 CFR 668.164 (f)(4)(iv) are posted at the URL that is sent to the Secretary under 34 CFR 668.164f)(4)(iii)(B) for publication in a centralized database accessible to the public;
Tier two arrangement 34 CFR 668.164 (f) (continued):
← Ensure that the student accountholder can execute balance inquiries and access funds deposited in the financial accounts through surcharge-free in-network ATMs sufficient in number and housed and serviced such that the funds are reasonably available to the accountholder, including at the times the institution or its third-party servicer makes direct payments into them;
← Ensure that the financial accounts are not marketed or portrayed as, or converted into, credit cards;
← Ensure that the terms of the accounts offered pursuant to a T2 arrangement are not inconsistent with the best financial interests of the students opening them. The Secretary considers this requirement to be met if:
← The institution documents that it conducts reasonable due diligence reviews at least every two years to ascertain whether the fees imposed under the T2 arrangement are, considered as a whole, consistent with or below prevailing market rates; and
← All contracts for the marketing or offering of accounts pursuant to T2 arrangements to the institution's students make provision for termination of the arrangement by the institution based on complaints received from students or a determination by the institution under 34 CFR 668.164 (f)(4)(viii)(A) that the fees assessed under the T2 arrangement are not consistent with or are above prevailing market rates;
← Take affirmative steps, by way of contractual arrangements with the financial institution as necessary, to ensure that requirements of this section are met with respect to all accounts offered pursuant to T2 arrangements; and
← Ensure students incur no cost for opening the account or initially receiving or validating an access device.
← If the institution enters into an agreement for the cobranding of a financial account with the institution's name, logo, mascot, or other affiliation but maintains that the account is not marketed principally to its enrolled students and is not otherwise marketed directly within the meaning of 34 CFR 668.164(f)(3), the institution must retain the cobranding contract and other documentation it believes establishes that the account is not marketed directly to its enrolled students, including documentation that the cobranded financial account or access device is offered generally to the public.
← Institutions falling below the thresholds described in 34 CFR 668.164(f)(2) are encouraged to comply voluntarily with the applicable provisions of 34 CFR 668.164 (f)(4) and (f)(5) of this section.
← The requirements of 34 CFR 668.164(f)(4) no longer apply with respect to a student who has an account described under 34 CFR 668.164(f)(1) when the student is no longer enrolled at the institution and there are no pending title IV disbursements, except that nothing in this paragraph should be construed to limit the institution's responsibility to comply with 34 CFR 668.164(f)(4)(iv) with respect to students enrolled during the award year for which the institution is reporting. To effectuate this provision, an institution may share information related to students' enrollment status with the financial institution or entity that is party to the arrangement.
Describe the school’s procedures for Tier two arrangements:
Ownership of financial accounts opened through outreach to the institution’s students 34 CFR 668.164 (g):
← The institution ensures that any financial account offered or marketed pursuant to an arrangement described in 34 CFR 668.164 (e) or (f) meets the requirements of 31 CFR 210.5(a) or (b)(5), as applicable.
Describe the school’s procedures for ownership of financial accounts opened through outreach to the institution’s students:
Title IV HEA credit balances 34 CFR 668.164(h):
← The institution ensures that a title IV, HEA credit balance is paid directly to the student or parent as soon as possible, but no later than:
← Fourteen (14) days after the balance occurred if the credit balance occurred after the first day of class of a payment period; or
← Fourteen (14) days after the first day of class of a payment period if the credit balance occurred on or before the first day of class of that payment period.
Describe the school’s procedures for Title IV HEA credit balances:
Early disbursements 34 CFR 668.164 (i):
← Except as provided in 34 CFR 668.164 (i)(2), the institution ensures that the earliest it may disburse title IV, HEA funds to an eligible student or parent is:
← If the student is enrolled in a credit-hour program offered in terms that are substantially equal in length, 10 days before the first day of classes of a payment period; or
← If the student is enrolled in a credit-hour program offered in terms that are not substantially equal in length, a non-term credit-hour program, or a clock-hour program, the later of:
← Ten days before the first day of classes of a payment period; or
← The date the student completed the previous payment period for which he or she received title IV, HEA program funds.
← Your institution ensures that it does not:
← Make an early disbursement of a Direct Loan to a first-year, first-time borrower who is subject to the 30-day delayed disbursement requirements in 34 CFR 685.303(b)(5). This restriction does not apply if the institution is exempt from the 30-day delayed disbursement requirements under 34 CFR 685.303(b)(5)(i)(A) or (B); or
← Compensate a student employed under the FWS program until the student earns that compensation by performing work, as provided in 34 CFR 675.16(a)(5).
Describe the school’s procedures for Early disbursements:
Late disbursements 34 CFR 668.164 (j)
← For purposes of 34 CFR 668.164(j), the institution ensures that an otherwise eligible student becomes ineligible to receive title IV, HEA program funds on the date that:
← For a Direct Loan, the student is no longer enrolled at the institution as at least a half-time student for the period of enrollment for which the loan was intended; or
← For an award under the Federal Pell Grant, FSEOG, Federal Perkins Loan, Iraq-Afghanistan Service Grant, and TEACH Grant programs, the student is no longer enrolled at the institution for the award year.
← Except as limited under 34 CFR 668.164(j)(4), the institution ensures that a student who becomes ineligible, as described in paragraph 34 CFR 668.164(j)(1), qualifies for a late disbursement (and the parent qualifies for a parent Direct PLUS Loan disbursement) if, before the date the student became ineligible:
← The Secretary processed a SAR or ISIR with an official expected family contribution for the student for the relevant award year; and
← For a loan made under the Direct Loan program or for an award made under the TEACH Grant program, the institution originated the loan or award; or for an award under the Federal Perkins Loan or FSEOG programs, the institution made that award to the student.
← Provided that the conditions described in 34 CFR 668.164(j)(2) of this are satisfied the institution only makes a late disbursement if:
← The student withdrew from the institution during a payment period or period of enrollment, the institution must make any post-withdrawal disbursement required under 34 CFR 668.22(a)(4) in accordance with the provisions of 34 CFR 668.22(a)(5);
← The student completed the payment period or period of enrollment, the institution must provide the student or parent the choice to receive the amount of title IV, HEA program funds that the student or parent was eligible to receive while the student was enrolled at the institution. For a late disbursement in this circumstance, the institution may credit the student's ledger account as provided in 34 CFR 668.164(c), but must pay or offer any remaining amount to the student or parent; or
← The student did not withdraw but ceased to be enrolled as at least a half-time student, the institution may make the late disbursement of a loan under the Direct Loan program to pay for educational costs that the institution determines the student incurred for the period in which the student or parent was eligible.
← The institution ensures that it does not make a late disbursement later than 180 days after the date the institution determines that the student withdrew, as provided in 34 CFR 668.22, or for a student who did not withdraw, 180 days after the date the student otherwise became ineligible, pursuant to 34 CFR 668.164(j)(1)
← The institution ensures that it does not make a late second or subsequent disbursement of a loan under the Direct Loan program unless the student successfully completed the period of enrollment for which the loan was intended.
← The institution ensures that it does not make a late disbursement of a Direct Loan if the student was a first-year, first-time borrower as described in 34 CFR 685.303(b)(5) unless the student completed the first 30 days of his or her program of study. This limitation does not apply if the institution is exempt from the 30-day delayed disbursement requirements under 34 CFR 685.303(b)(5)(i)(A) or (B).
← The institution ensures that it does not make a late disbursement of any title IV, HEA program assistance unless it received a valid SAR or a valid ISIR for the student by the deadline date established by the Secretary in a notice published in the Federal Register.
Describe the school’s procedures for Late disbursements:
Retroactive payments 34 CFR 668.164 (k):
← If the institution chooses to make a retroactive payment for a student to an enrolled student for a payment period the student completed (for example, because of an administrative delay or because the student's ISIR was not available until a subsequent payment period), the institution may pay the student for all prior payment periods in the current award year or loan period for which the student was eligible. For Pell Grant payments under 34 CFR 668.164(k), the student's enrollment status must be determined according to work already completed, as required by 34 CFR 690.76(b).
Describe the school’s procedures for Retroactive payments:
Returning funds 34 CFR 668.164 (l):
← Notwithstanding any State law (such as a law that allows funds to escheat to the State), the institution ensures that it returns to the Secretary any title IV, HEA program funds, except FWS program funds, that it attempts to disburse directly to a student or parent that are not received by the student or parent. For FWS program funds, the institution is required to return only the Federal portion of the payroll disbursement.
← If an EFT to a student's or parent's financial account is rejected, or a check to a student or parent is returned, the institution may make additional attempts to disburse the funds, provided that those attempts are made not later than 45 days after the EFT was rejected or the check returned. In cases where the institution does not make another attempt, the funds must be returned to the Secretary before the end of this 45-day period.
← If a check sent to a student or parent is not returned to the institution but is not cashed, the institution must return the funds to the Secretary no later than 240 days after the date it issued the check.
Describe the school’s procedures for Returning funds:
Provisions for books and supplies 34 CFR 668.164 (m):
← The institution must provide a way for a student who is eligible for title IV, HEA program funds to obtain or purchase, by the seventh day of a payment period, the books and supplies applicable to the payment period if, 10 days before the beginning of the payment period:
← The institution could disburse the title IV, HEA program funds for which the student is eligible; and
← Presuming the funds were disbursed, the student would have a credit balance under 34 CFR 668.164(h).
← The institution must ensure that the amount it provides to the student to obtain or purchase books and supplies is the lesser of the presumed credit balance under this paragraph or the amount needed by the student, as determined by the institution.
← The institution must have a policy under which the student may opt out of the way the institution provides for the student to obtain or purchase books and supplies under this paragraph 34 CFR 668.164(m). A student who opts out is considered to also opt out under 34 CFR 668.164 (c)(2)(i)(C);
← If a student uses the method provided by the institution to obtain or purchase books and supplies, the student is considered to have authorized the use of title IV, HEA funds and the institution does not need to obtain a written authorization under paragraph 34 CFR 668.164(c)(1)(ii) and 34 CFR 668.165(b) for this purpose.
Describe the school’s procedures for Provisions for books and supplies:
Notices and authorizations 34 CFR 668.165
← Include your school’s procedures for notifying a student or parent of the amount of funds that the student or his or her parent can received under each title IV, HEA program, and how those funds will be disbursed
← Include your school’s procedures for obtaining student or parent authorizations to pay for allowable charges
Note: It would be helpful to include copies of any notices or authorizations used by your school to comply with this part.
Describe the school’s procedures for notices and authorizations:
Excess Cash 34 CFR 668.166
Describe the school’s procedures for ensuring excess cash is returned as required in 34 CFR 668.166:
[pic] Help
The Fiscal Year-End reconciliation worksheet is designed as a comprehensive exercise for all programs for year-end reconciliation. It is also important for schools to ensure that they reconcile all accounts on a monthly basis. Monthly reconciliation also makes year-end reconciliation an easier process. There are separate worksheets for each program. Instructions are included with each worksheet.
These forms can be accessed from the Fiscal Management Assessment
Or, select any specific worksheet listed below:
Fiscal Year-End Reconciliation Worksheet
Federal Pell Grant Monthly Reconciliation
TEACH Grant Monthly Reconciliation
FWS Monthly Reconciliation
Federal Perkins Monthly Reconciliation
FSEOG Monthly Reconciliation
Direct Loan Monthly Reconciliation
|Part 1.6 |Financial Aid Counseling |This section is required,; 668.16 (h) |
The following topics need to be addressed for Financial Aid counseling of students:
• Identify the sources and the amount of each type of aid awarded.
• Provide a method by which aid is determined and disbursed, delivered or applied to a student’s account.
• Make available the rights and responsibilities of the student with the respect to enrollment at the institution and receipt of financial aid.
• Provide information regarding the institution’s refund policy, the requirements for the treatment of Title IV funds when a student withdraws under 668.22, its standards of SAP and other conditions that may alter the student’s aid package.
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2016-2017 Introduction and Section 1, Administrative Capability, Page 3 of 37
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