managing title iv funds - fasfaa.memberclicks.net · 3 managing title iv funds: follow the money...

Managing Title IV Funds Or…

Follow the Money

2

Wood Mason U.S. Department of Education

Federal Student Aid

Atlanta, GA

[email protected]

770.383.9662

Direct Loan Reconciliation

mailto:[email protected]

3 Managing Title IV Funds: Follow the Money

Agenda • Guides & Resources

• G5

• Annual Funding

• Drawing Funds

• Refunding Funds

• Adjusting Funds

• Completing Annual Reconciliation

4

Guides & Resources • Blue Book

http://ifap.ed.gov/ifap/BlueBook.jsp

• FSA Handbook – Volume IV

http://ifap.ed.gov/fsahandbook/1415FSAHbkVol4.html

Managing Title IV Funds: Follow the Money

5

Guides & Resources • COD Help Desk (8AM – 8PM Eastern Time)

Grant Programs: 800.474.7268

Direct Loan Program: 800.848.0978

Foreign Schools: 571.392.3737

Email: [email protected]

• G5 Help Desk (8AM – 6PM Eastern Time)

Phone: 888.336.8930


• eCampus-Based Help Desk (8AM – 8PM Eastern Time)

Phone: 877.801.7168


Managing Title IV Funds: Follow the Money

Follow the Money Payment

Data

Disbursement

Records / FISAP

Payment

COD eCB

G5


www.g5.gov


To access G5 • Your school must have a DUNS number

• The Data Universal Numbering System (or D-U-N-S Number) is a unique nine-digit identification code that is assigned to a school. G5 grantees and payees must register their D-U-N-S number and TIN with the System for Award Management (SAM)

8 8 Managing Title IV Funds: Follow the Money

Establish a user ID • Each user establishes their own access • Click on “Not Registered?” Sign up • Read only available for FAAs

Establish a bank account for deposit of funds • May be one or multiple federal funds bank accounts If one bank account must be able to identify different

types of Title IV funds

• Maintaining and accounting for Funds 34 CFR 668.163 • Blue Book, Volume 5 page 22

Designate a bank account for the return of funds • May be the same as the one used for deposit of funds


Drawn funds are electronically transmitted to your school’s bank account

• ACH

Direct Deposit sign-up form SF 1199a

Funds requested prior to 3:00PM (Eastern Time) generally are deposited in your bank account the next business day

• FEDWIRE

Your bank may charge a fee

Funds requested prior to 2:00PM (Eastern Time) generally are deposited in your bank account the same day

Instructions are found on the G5 Website under “FAQs/Banking”


G5 award ID numbers are school, program, and award year specific

• Funds are drawn from, and returned to, G5 by program and award year


Title IV Financial Aid processing systems… • Common Origination & Disbursement System

Pell Grant Program

Direct Loan Program

TEACH Grant Program

Iraq & Afghanistan Service Grant

Actual disbursement data drives funding

In COD by 10:00AM transmitted to G5 the same day

In COD by 10:00PM transmitted to G5 the next day

• eCB

Supplemental Education Opportunity Grant (SEOG)

Federal Work Study (FWS)


Each award year a new Current Funding Level (CFL), or initial authorization, is established

• Campus-Based funding is calculated from the data you report on your Fiscal Operations Report & Application to Participate (FISAP) Tentative allocations are published in January Final notice of allocations are published in April

• Pell Grant and TEACH Grant program are “Records First” Submitted and accepted actual disbursement data

establishes, and increases, your CFL and corresponding G5 available balance

• Iraq & Afghanistan Service Grant Manually funded on a case-by-case basis Funding based on submitted anticipated disbursements

and manually processed on a case-by-case basis


Direct Loan schools on the Advance Cash Funding Method receive an initial CFL in Spring

• Approximately 60%-65% of previous year disbursement activity

Increase in late November and as needed thereafter

Submitted and accepted actual disbursement data will increase your CFL

Submit actual disbursements up to seven days in advance

A “bump” can be requested via COD Customer Service

You must NOT have any unsubstantiated funds

Direct Loan schools on a heightened cash management funding control method (HCM1, HCM2, Reimbursement) are “Records First”

No initial CFL


Direct Loan schools can be funded at the location level as well as at the Main Campus level

• A Main Campus can fund for itself and its additional locations A G-code school can fund for an E-code school An E-code location cannot fund for another E-code

location

• The Direct Loan Award ID in G5 is specific to the Direct Loan School Code (G or E) that originated the award A Main Campus (G-code) and Additional Location (E-

code) will each have its own Direct Loan Award ID differentiated by a unique 4-digit G5 (GAPS) ID for each school in advance


FSA pays an Administrative Cost Allowance (ACA) to Pell Grant and Campus-Based participant schools

• The Pell Grant ACA is $5 for each unduplicated Pell Grant recipient

• The Pell Grant ACA is calculated by the Department and automatically deposited in the school’s account

• The Pell Grant ACA is paid three (3) times during the award year cycle


FSA pays an ACA to Campus-Bases participant schools

• The ACA is taken from the Federal Allocation • The maximum if 5% of the sum of… The advanced loans in the Perkins Loan Program The total earned compensation in the FWS Program The total awards to recipients in the FSEOG Program


Schools have a fiduciary responsibility to… • Safeguard FSA funds • Ensure FSA funds are used for the intended purpose • Maintain records of the eligibility of each Title IV

recipient Amount and date of each posting of funds Amount and date of each return of financial aid

• Return funds on a student’s behalf to the Direct Loan Program

• Return to the U.S. Department of Education funds that cannot be used as intended


Drawing Funds: Authorization/CFL vs. Available Funds

• Authorization refers to the total amount of aid made available to date for the entire award year for that award May include funds already drawn

• Available funds refer to the authorization minus funds already drawn

• Funds may only be drawn based on immediate need Funds that will be disbursed within three (3) business

days OR Funds that have already been disbursed


Drawing Title IV Funds


NOTE: Training on G5 functionality is available from the Main page after log in

Cash Management • 15-day reporting requirement for disbursement data

and adjustments to disbursement data An institution must submit Pell Grant, Iraq and

Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement data to COD no later than 15 days after making the disbursement or becoming aware of the need to adjust a student’s previously made disbursement 34 CFR 668.164(a), “Title IV funds are disbursed on the

date that the institution: (a) Credits those funds to a student's account in the institution's general ledger or any sub ledger of the general ledger, or (b) pays those funds to a student directly. Title IV funds are disbursed even if an institution uses its own funds in advance of receiving program funds from the Secretary”


Title IV Excess Cash • A school must disburse Title IV funds to a student within

3 business days of receiving the Title IV funds in its Federal Bank Account

• Title IV funds that are not disbursed before this deadline are Title IV excess cash and must be returned immediately In rare instances funds MAY be held for an additional 7

calendar days Blue Book Volume 5, Pg 24

NOTE: A school man NOT hold additional funds while reconciling accounts


Adjusting Title IV Drawdowns • Adjusting a drawdown for a Campus-Based Program is

not allowed in G5 Adjust via the FISAP Adjustments and corrections can be made for up to 5

years Contact the eCB Help Desk for assistance

• Adjustment to a Title IV drawdown for the Pell Grant, TEACH Program, and Direct Loan Program Only allowed to correct either a drawdown or return of

funds to an incorrect award year or program Should be made as soon as possible after the necessary

correction is identified NEVER allowed for reconciliation


FSA Initiated Reductions • Campus-Based Reduction of Title IV funds to expenditures reported for

award year 2012 – 2013 occurred in February, 2015 • Pell Grant Program COD will generate and transmit a system-generated

Negative Disbursement (ND) Response for Unresolved POPs (Potential Overaward Process) Verification W not updated

Both result in an Unprocessed De-obligation (UD)


FSA Initiated Reductions • TEACH Grant Program Program Year Closeout Reduction of the CFL to net drawdowns (ND) Reduces G5 available to net drawdowns

• Direct Loan Program Placement on Heightened Cash Management (HCM1) OR Program Year Closeout Both result in the CFL reduced to the greater of Net

Accepted and Posted Disbursements (NAPD) or Net Draws (ND) Corresponding reduction to G5 available balance


Returning Title IV Funds • What are reasons Title IV funds would need to be returned Unable to disburse all that was drawn (excess cash)

Funds drawn by mistake from incorrect award or award year

Returning unclaimed funds

R2T4 calculation requires a return of funds after a disbursement adjustment


Returning Title IV Funds • What are reasons Title IV funds would need to be returned Receipt of a COD Negative Disbursement Response

Owing funds after an audit or program review

A student no longer needs/wants funds

Within 120 days a school can return funds to G5 reduce the disbursement

If more than 120 days since the disbursement the BORROWER should return funds via his or her Servicer


Recovery of unclaimed Title IV funds • Your student’s credit balance check was mailed but

comes back or the EFT failed You have 45 days to attempt a subsequent disbursement OR You must return the funds to ED You may continue trying to disburse so long as unclaimed

funds are returned to ED within 240 days of when the credit balance check or EFT was issued

• If a credit balance check is mailed but not cashed You must return the funds to ED no later than 240 days

after the credit balance check was issued NOTE: Reference 2015-2016 FSA Handbook, Volume 4, Pg 48


Two more reminders when returning funds… • If you are returning funds as the result of an audit or

Program Review liability follow the directions in the final audit or Program Review Determination Letter

• If you are returning Direct Loan funds to comply with statutory or regulatory requirements, the 120-day rule does NOT apply

Send the funds back via G5 and take a corresponding downward adjustment to the appropriate disbursement(s)


How to return Title IV funds • Title IV funds should be returned electronically via G5 2015-2016 FSA Handbook Volume 4, Chapter 4 Blue Book Volume 5, Chapter 5

• If exceptional circumstances require you to return Grant funds via paper check Make the Make check payable to U.S. Department of

Education Use a separate check for each award/award year Note the school’s DUNS # and award number (i.e.,

P063P15####) on the front of the check U. S. Department of Education, PO Box 979053, St.

Louis, Missouri, 63197-9000


Setting up a refund bank account in G5


Creating a Refund of Title IV Funds via G5


Electronic refunds post to G5 within three (3) business days

• Electronic processing of refunds significantly reduces human error and delays

• Updates in COD within 5 – 7 days

• Schools setup the bank account from which refunded funds are drawn

• You can create multiple refunds on one screen and at one time on G5


Monthly reconciliation is a required task for the Direct Loan, TEACH Grant, FWS and SEOG Programs

• Regular reconciliation is suggested for ALL Title IV Programs Identifies issues with meeting cash management and

disbursement reporting requirements Demonstrates administrative capability Electronic processing of refunds significantly reduces

human error and delays • What are the regulatory citations/requirements? Direct Loan Program – 34 CFR 685.300(b)(5) TEACH Grant Program – 34 CFR 686.37 FWS – 34 CFR 675.19(b)(2)(iv) SEOG – 34 CFR 676.19(b)(2)


Reconciliation resources • COD Customer Service Representatives and

Reconciliation Specialists

TEACH Grant Program

Direct Loan Program

• eCB

FWS

SEOG

• G5 Help Desk

• G5 reports


G5 External Award Activity


Note available FWS/SEOG funds for AY 13/14



Note last date to

draw funds



Note one Payee for two Grantees and User Defined

Defined Recipient Reference Numbers for each

G5 External Award Activity Detail


COD reports and COD Web screens • School Account Statement (SAS)

• Cash and disbursement data

• Direct Loan and TEACH Grant Programs

• COD Web screens

• School Summary Information

• School Funding Information

• School Summary Financial Information

• Cash Activity



Daryl Dixon (555) 555-

5555


5555


5555

Wood’s School of Holistic and Metaphorical Communication

Keep contacts

updated Check all programs

and award years for

cash concerns



Note Pell Unduplicated recipients

And Total ACA paid

Remember…actual disbursements drive funding!



Note how the submission of actual disbursement data

on 11/13/2014 increased the CFL

Remember…actual disbursements drive funding!



This drawdown

was

substantiated in

5 days

Completing Reconciliation • Closeout Deadline Date September 30

TEACH Grant, Pell Grant, Campus-Based Programs

Cash and disbursement data

Direct Loan and TEACH Grant Programs

• Direct Loan Program Year Closeout

• Last business day of July of the year following award year processed

Direct Loan Program Year Closeout deadline date for award year 2013-2014 will be July 31, 2015

Direct Loan School MUST have a SAS with a $0 ending cash balance and have received the “Zero Balance” letter


Completing Reconciliation • Adjustments to your FISAP for reconciliation purposes

may be requested until December 15th on a “timely” filed document

• Extended processing is sometimes necessary Last business day of July of the year following award

year processed Requested via the COD Web for Pell Grant, TEACH

Grant, and Direct Loan Program Required for any Direct Loan Program processing after

the Program Year Closeout Deadline Date has lapsed Required for Pell Grant increases only Pell Grant Program award reductions can be taken without

extended processing


Help Desk Contact Information • G5 Help Desk – 8:00am-6:00pm (Eastern Time)

Monday thru Friday • 888.336.8930 (no cost per call) • 866.697.2696 (TDD) • Email: edcaps.user.ed.gov • Website: https://www.G5.gov

• eCampus-Based Help Desk 8:00am-8:00pm (Eastern Time) Monday thru Friday FWS and SEOG 877.801.7168 (no cost per call) Email: [email protected] Website: https://cbfisap.ed.gov


Help Desk Contact Information • COD School Relations Center – 8:00am-8:00pm

(Eastern Time) Monday thru Friday

800.848.0978 (Direct Loan Program)

800.474.7268 (Grants Programs)

571.392.3737 (Foreign Schools)

FAX: 877.623.5082


Website: https://www.cod.ed.gov


Wood Mason U.S. Department of Education

Federal Student Aid Atlanta, GA

770.383.9662 [email protected]

52 Title IV Funding: Follow the Money

mailto:[email protected]

managing title iv funds - fasfaa.memberclicks.net · 3 managing title iv funds: follow the money...

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