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Compliance
Issues: Cooperative Communication on Campus When an eligible school enters into a Program Participation Agreement (PPA) with the U.S. Department of Education to participate in the Title IV program, it agrees to comply with the laws, regulations and policies governing the Federal Student Aid (FSA) programs. While a school’s financial aid office assumes most of the responsibility for administering Title IV, HEA programs, it doesn’t function without sharing information and tasks performed by a school’s education department, business/bursar office, admissions office, records office and others. [34 CFR 668.14] Many times an institution’s eligibility documents, compliance reports and other critical information are addressed to the president’s office or other administrative departments. The school’s responsibility extends to administering Title IV programs in a manner that ensures all the information received by any institutional office that might affect a student’s FSA eligibility is communicated to the financial aid office. Therefore, it’s critical that schools have a process in place that assures effective communication throughout the campus. [34 CFR 668.16(b)(3)] Look at your school’s informational structure to see where it’s necessary to have staff cooperation and set procedures for coordinating and sharing information. A few examples include: Normally, the admissions/evaluations office has information on accepted transfer units, which is necessary to determine a student’s grade level and monitor the maximum time frame needed to complete their educational objective. The admissions office also determines whether a student is required to pay out-of-state tuition, which in turn would affect his or her cost of attendance calculation. A student’s current enrollment status is generally provided by the records office, which is also responsible for reporting changes to the National Student Loan Data System (NSLDS). If the records office is designated by the institution to process withdrawals or leaves of absence, that information should be reported to the financial aid office for any necessary refund or “Return of Title IV Funds” calculation. The financial aid office usually confirms that a student is meeting the school’s satisfactory academic progress (SAP) requirements. If a student isn’t meeting SAP, the business/bursar’s office needs to be advised not to release funds to the student. Therefore, it’s important that the financial aid office have access to the student’s most current enrollment information. The business/bursar’s office is often responsible for delivering financial aid funds. Prior to delivering funds, the business office staff needs confirmation that the student is still enrolled, enrolled in enough units to be eligible for the funds and is meeting the school’s SAP policy. Cooperatively sharing information means that the financial aid office provides necessary data to other campus offices, as well. For example, when the office has determined that a refund is due after completing a “Return of Title IV Funds” calculation for a student who has withdrawn from the school, it’s important to share the time frame required for the business office to meet the federal timeliness requirement. [34 CFR 668.173(b)] Furthermore, it’s important that the financial aid office develop and apply an adequate system to identify and resolve any discrepancies in information received from different sources with respect to a student’s eligibility for financial aid under Title IV, HEA programs. For example, sometimes in the admissions process, student information conflicts with data on the Free Application for Federal Student Aid (FAFSA); the school needs to resolve the conflict. [34 CFR 668.16(f)] In meeting its obligations to participate in the FSA programs, a school must demonstrate that it’s administratively capable of properly managing them. Key to a school’s success is effective communication between campus offices, strong internal controls and sound business and financial management practices. ©2005 EDFUND VALERIE GONZALEZ, SENIOR CLIENT RELATIONS MANAGER AT 1150 N. LOOP, 1604 W, SUITE 108-417, SAN ANTONIO TX 78248 – TELEPHONE: TOLL FREE 1.866.353.4950 – VGONZALEZ@EDFUND.ORG – WWW.EDFUND.ORG.
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