In an Electronic Announcement dated December 18, 2014, USDE reminds schools of the general disbursement reporting, excess cash, and reconciliation requirements for all Title IV programs. Because these requirements apply to disbursement and financial data, both the Financial Aid Office and Business Office should review the information provided below.
Disbursement Reporting Requirements
The disbursement and disbursement adjustment reporting requirements for all Title IV aid are announced in an annual Federal Register Notice. The most recent Federal Register Notice, published on July 11, 2014, specifies that a school must submit disbursement records no later than 15 days after making the disbursement or becoming aware of the need to adjust a student’s previously reported disbursement.
Excess Cash Requirements
USDE considers excess cash to be any amount of Title IV funds (other than Federal Perkins Loan Program funds) that a school does not disburse to students or parents by the end of the third business day after the date the school: (1) received the funds from the Department, or (2) deposited or transferred to its federal account previously disbursed Title IV funds received from the Department. In some circumstances, cash may be held for up to an additional 7 calendar days if a school meets the excess cash tolerance and can disburse the aid to students within that time frame. In no circumstance should cash balances remain beyond the additional 7-day period.
Reconciliation is the process by which a school reviews and compares Title IV aid (grants, loans, and campus-based aid) recorded on the Department’s systems with the information in the school’s internal records. Schools should reconcile both internally (between Business Office and Financial Aid Office data) and externally (between school data and the COD System/G5). Through reconciliation, disbursement and cash discrepancies are identified and resolved in a timely manner to ensure the school meets all regulatory requirements. Schools must document their reconciliation efforts and retain this documentation for auditing purposes.
If completed on a regular basis, reconciliation can assist schools in determining whether the disbursement reporting and excess cash deadlines noted above are being met, and also whether any additional data needs to be submitted to ensure all school data is reflected correctly in the Department’s records. For the Direct Loan, Teacher Education Assistance for College and Higher Education (TEACH) Grant, and Campus-Based programs (including Federal Perkins Loan, Federal Supplemental Educational Opportunity Grant, and Federal Work-Study), schools must reconcile at least monthly to meet regulatory requirements. For all other Title IV programs (including Federal Pell Grant) it is highly suggested that schools also reconcile at least monthly or as frequently as necessary to identify issues and maintain compliance with the cash management and disbursement reporting requirements outlined above.
Additional information on reconciliation can be found on the IFAP Web site in the following publications:
– Electronic Announcements (published annually by program)
– Federal Student Aid Handbook
– Blue Book
– FSA Training Conference Presentations
If a school is meeting all disbursement/adjustment reporting, excess cash, and reconciliation requirements, a final reconciliation should begin no later than the last award or payment period end date at the school for a given program and year. A school should be able to reconcile to a zero ending cash balance soon after its final disbursements and should not carry an ending cash balance (positive or negative) for an extended period.
DJA not only reconciles Direct Loan accounts for our clients on a monthly basis, we also reconcile Pell, SEOG and FWS accounts each month to ensure they are balanced. The final reconciliation for these programs is done by our team as well. Although DJA reconciles the DL SAS reports; Pell Grant Year to Date reports; SEOG and FWS to our accounting records, institutions must do an internal reconciliation to these reports as well. Please reconcile that all disbursements have been credited to the student’s accounts and any credit balance was returned within the required 14 days.