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In an effort to increase efficiency and improve funds control, Federal Student Aid is moving away from processing paper checks. Beginning January 1, 2015, FSA will no longer accept Direct Loan refunds of cash sent manually via paper check. The COD School Relations Center will not process paper checks for Direct Loan refunds of cash and will return them to the sender.


Schools now need to refund cash electronically via the G5 Web site. This method is faster and more secure than manual/paper processing, and is less likely to result in errors.


As noted in an April 2, 2013 Electronic Announcement, schools can refund cash manually via paper check in some cases; however, paper checks should only be used as an exception when a school is unable to process electronically or is instructed to refund cash via paper check in an audit or program review. If a school must refund cash via paper check, it must:

–        Make the check payable to the U.S. Department of Education and include the Direct Loan School Code or OPE ID and the award year to which the funds apply on the check. Note: If there is not enough information to allow the check to be processed, it will be returned to the school.

–        Include a completed Direct Loan Refunds of Cash transmittal sheet with the check. You will find the form at the following link:

–        Note: Funds should not be combined for multiple award years or multiple school codes. A separate check and transmittal sheet should be used for each award year and school.

–        Mail the check to the COD School Relations Center at:


Regular Mail/No Signature Required U.S. Department of Education Attention: Direct Loan Refunds of Cash P.O. Box 9001 Niagara Falls, NY 14302


Overnight Address/Requiring Signature U.S. Department of Education Attention: Direct Loan Refunds of Cash 2429 Military Rd, Suite 200 Niagara Falls, NY 14304 (Phone number for tracking form only: 716/284-2225)


Note: If a school is required to refund cash as part of a liability assessed in an audit or program review, it must follow the instructions provided by the issuing office.


If a school is returning cash as a result of refunds made to a borrower’s account, a corresponding downward disbursement adjustment must also be reported to the COD System. Also, remember that Direct Loan disbursements, disbursement adjustments, and refunds of cash, should be reported or submitted in whole dollar amounts only. The use of pennies in Direct Loan processing will impact a school’s ability to successfully complete its monthly reconciliation because its Net Drawdowns may not match the Net Disbursements reported to the COD System. For further information, refer to the following electronic announcements.




In an Electronic Announcement posted to the IFAP website on December 23, USDE informed institutions that NSLDS will, as of February 1, 2015, no longer accept enrollment reporting files in file layout formats that are older than those posted to the Information for Financial Aid Professionals (IFAP) Web site on February 27, 2014. An enrollment reporting file sent in an older format on or after February 1, 2015 will be rejected. Schools have been required to report enrollment, including program-level student enrollment information, to NSLDS in one of the new formats since responding to the first enrollment reporting roster generated on or after October 1, 2014. More information about these requirements is available in Dear Colleague Letters GEN-14-07, GEN-14-17, the NSLDS Enrollment Reporting Webinars held on July 15 and 16 and 30 and 31, and in the Electronic Announcement titled “Reminder of Program-Level Reporting Requirement” posted to the IFAP Web site on September 26, 2014.


IMPORTANT: USDE continues to monitor schools’ compliance with NSLDS enrollment reporting requirements. Within the next few weeks notices will be sent to the Chief Executive Officer (e.g., president, chancellor, owner) of any school that remains out of compliance with these enrollment reporting requirements. Schools that fail to comply with NSLDS enrollment reporting requirements will be referred to the Program Compliance office for action.


Accurate Program-Level Enrollment Reporting

It is critically important for schools to completely and accurately report students’ program-level enrollment information to NSLDS. This information is used to determine the subsidy status of loans under the 150% Direct Subsidized Loan Limit.

Schools must pay particular attention to correctly reporting Published Program Length. After reviewing early submissions of program-level enrollment reporting information, USDE has discovered Published Program Lengths that appear to be reported incorrectly and are unreasonably short. This could harm the student and cause loss of subsidy in circumstances when the student should not lose interest subsidy. The Published Program Length field is a six-digit number with an implied decimal after the third digit.


For example, to report 2 years, the school would enter “002000”. To report 1.5 years the school would enter “001500”.


If a school is reporting program length in weeks or months, it is also essential that the school correctly report the number of weeks of instructional time that the school has defined for its Title IV Academic Year. This number is used by NSLDS to convert the weeks or months value to a value in years to establish the student’s Maximum Eligibility Period for Direct Subsidized Loans.


If you determine that you have incorrectly reported any of a student’s key program-level enrollment information which is used by NSLDS to identify a unique program (CIP Code, Credential Level, and Published Program Length), you must report the student as never having attended (status X) the program that was associated with the inaccurate reporting, and then re-establish the student’s program-level enrollment information by reporting the accurate program-level information.


Student Permanent Address

Schools are now required to report Student Permanent Address along with the campus-level enrollment reporting information. Schools may not have a valid postal address for every student, therefore changes will be implemented regarding the collection of address information early in 2015. Communications to schools on how to handle address information going forward, including how to report if there is no valid address available for a student will also be issued.


NSLDS is not currently rejecting enrollment reporting records if an address is not contained in the school’s submission. For now, schools that do not have a valid address for a student should leave all the address fields on that record blank. If a partial or invalid address is given, it could cause the record to reject.


NSLDS Enrollment Reporting Resources

For more information about NSLDS enrollment reporting requirements, refer to the July 2014 version of the NSLDS Enrollment Reporting Guide, available on the IFAP Web site. Additional information is available in the NSLDS Reference Materials section of the IFAP Web site.


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


Final Reconciliation

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.


Your school MUST use the USDE recently released Disclosure Template to provide all of the required GE disclosures for the 13/14 award year no later than JANUARY 31, 2015. The following steps and frequently asked questions will help you get this accomplished on time and keep your school compliant with the GE regulations.

1. Before accessing the template, click on the links below to view the Quick Start Guide for use with either Internet Explorer or Mozilla Firefox in printable, PDF format. It is critical that you print and read before you start! This will answer most of your questions. IMPORTANT: The template does not save any data as input by the user. For your convenience, use the screenshots in this Quick Start Guide to view the screens and prepare the necessary data before completing the GEDT data entry form.

  • Quick Start Guide for use with Internet Explorer 7.0 and above
  • Quick Start Guide for use with Mozilla Firefox 3.0 and above

2. Access the disclosure template application:

3. For each GE program you will enter:

  • your six-digit OPEID
  • the six-digit CIP code for the GE Program
  • the credential level of the GE Program

4. You will then complete the template with specific information about the GE Program, consistent with GE Electronic Announcement #25

This includes:

  • program length
  • selecting the appropriate SOC codes for the program (based on the program’s CIP code)
  • the cost of the program
  • information needed for the template to calculate an on-time completion rate
    • median debt information
    • the job placement rate, if applicable

5. Once the form is complete, the template application will generate a zip file containing the GE Program’s disclosure page, which you will host on your website.

In making the required disclosures using the GE Disclosure Template, you must prominently provide a direct link from the home page of the GE Program website to the program’s disclosure page that was generated by the disclosure template application.

Any other web page containing general, academic, or admissions information about the GE Program must also contain a prominent and direct link to the program’s web home page or to the GE Program disclosure page generated by the application.

NOTE: The information above differs slightly from earlier guidance specifying that the required GE disclosures must be displayed on the actual GE Program home page and may not be linked to another site or document. For this current disclosure process, the functionality of the required disclosure template is such that an institution must provide a link to the generated GE disclosure page for the program instead of having the disclosures appear on the program home page itself.

Please note that a unique output file must be generated for each program at the institution that is subject to the gainful employment regulations.


  • Gainful Employment Electronic Announcement #46
  • Additional information and resources related to the gainful employment regulations—including the published regulations and Federal Register Notices, answers to frequently asked questions, and guidelines for determining which educational programs are subject to the gainful employment regulations—are available on the Department of Education’s Gainful Employment Information Page
  • Send questions about the gainful employment disclosure requirements to
  • For additional assistance with the Gainful Employment Disclosure Template, contact:

The Gainful Employment Disclosure Template Help Desk
Call (855) 359-3697 or (855) 359-3697 (toll-free) or email


Availability of 2015-2016 Web Demo System

In order to assist you with the 2015-2016 FAFSA processing cycle, FSA has provided a Microsoft PowerPoint presentation containing information and screen shots pertaining to the 2015-2016 FAFSA on the Web site. To view the presentation just click on the following link: 2015-2016 FAFSA on the Web Preview Presentation in MS PowerPoint, 22MB, 102 Pages


The 2015-2016 Web Demonstration site is available at The demonstration site can be used as a training tool for your staff and for students and parents. You can access the demonstration site using eddemo as the User name and fafsatest as the Password.


2015-2016 SAR Comment Codes and Text Guide

This reference guide includes a description of changes to the SAR comments for 2015-2016, and also provides the complete text for all 2015-2016 comments.

The guide is also available from the Federal Student Aid Download (FSAdownload) Web site, located at


2015-2016 Summary of Changes for the Application Processing System Guide

This guide provides information about changes and enhancements made to the application processing system for 2015-2016, including the following topics:

–        Major changes to the 2015-2016 application processing system

–        Application processing system schedule for 2015-2016

–        2015-2016 Free Application for Federal Student Aid (FAFSA), including information about ordering and distribution of FAFSA on the Web Worksheets

–        2015-2016 FAFSA on the Web

–        2015-2016 FAA Access to CPS Online

–        2015-2016 Central Processing System (CPS), including database matches, edits, need analysis, communications sent to students, and Student Aid Report (SAR) comments


2015-2016 FAFSA on the Web Worksheet

The final version of the 2015-2016 FAFSA on the Web Worksheet is now available in English and Spanish.

The FAFSA on the Web Worksheet provides a preview of the questions that an applicant may be asked while completing FAFSA on the Web at This Worksheet is optional and should only be completed by applicants who plan to use FAFSA on the Web. It does not include all questions from the FAFSA; the questions that are included are ordered as they appear on FAFSA on the Web.


In an electronic announcement posted to the IFAP website on November 24, 2014, USDE provides suggested text for each of the required 2015-2016 verification items. While use by an institution of the suggested text fulfills the regulatory verification requirements, institutions are not required to use the U.S. Department of Education’s suggested text and formats, except as noted below. Instead, institutions may develop and use their own text, forms, documents, statements, and certifications that are specific to the items required to be verified for a particular student or group of students. The one exception is that institutions must use the exact language provided in the “Statement of Educational Purpose” in APPENDIX A for students who are placed in Verification Tracking Groups V4 or V5.

This electronic announcement includes attachments and enclosures as follows:

APPENDIX A provides suggested text for each of the required 2015-2016 verification items.

APPENDIX B provides an example of how institutions may use the suggested text to develop an institutional verification document.

APPENDIX C and APPENDIX D provide important information about each of the Verification Tracking Groups.
Information on how tax filers may request an IRS Tax Return Transcript and an IRS Record of Account is provided in APPENDIX E. Institutions may have difficulty matching a parent’s IRS Tax Return Transcript or IRS Record of Account with the student because the last names may be different. USDE recommends that institutions explain to the student how to match the student to his or her parent’s transcript prior to submitting it to the institution.

A chart of the availability of 2014 IRS tax information is provided in APPENDIX F.

You will find this information in its entirety at

DJA Clients: Verification forms will be developed by DJA and provided for your use.

2015–2016 Verification Tracking Groups

As with 2014–2015 award year verification, the Department will continue to use data-based statistical analysis to select applicants for verification. A Verification Tracking Flag will be set on the applicant’s Institutional Student Information Record (ISIR) to indicate placement into one of the 2015–2016 Verification Tracking Groups. An applicant will remain in the original 2015–2016 Verification Tracking Group for the entire 2015–2016 award year regardless of subsequent corrections to the applicant’s record.

Although 2015–2016 applicants will not be assigned to Verification Tracking Group V2 (formerly Supplemental Nutrition Assistance Program (SNAP) Verification Group), SNAP must be verified for applicants placed in Verification Tracking Groups V1, V4, V5, and V6, if the receipt of SNAP is indicated on the ISIR.

The individual verification items from the 2015–2016 Federal Register notice that an applicant must verify are based upon the Verification Tracking Group to which the applicant is assigned. See the following chart of the 2015–2016 Verification Tracking Group:


Consistent with the USDE regulations, the 2015–2016 FASFA data items that may require verification for an applicant selected for verification and the acceptable documentation for those items were announced in the federal register released June 25, 2014. This Federal Register notice did not include any changes to the FAFSA items that may need to be verified. However, based on suggestions from the financial aid community, USDE provided clarification and additional guidance for some of the verification items and acceptable documentation for the 2015–2016 award year.


Obtaining a Duplicate Internal Revenue Service (IRS) Form W-2

In instances where an applicant or parent is required to provide copies of IRS Form W-2, and the applicant or parent did not save their copy, the applicant or parent should request a replacement copy from the employer who issued the original W-2.


Determining Adequacy of Income – Verification Tracking Group V6

Institutions should use reasonable judgment when evaluating the validity of the income information provided by students and parents who are placed in Verification Tracking Group V6, and are therefore asked to provide information on how they financially supported themselves or their families. The term “reasonable” may differ among institutions, and may depend on student demographics and experiences. Just as institutions are given the option to accept a statement from students and parents as acceptable documentation for household size, number in college, untaxed income, etc., institutions may choose to accept a signed low-income statement, an income-to-expenses comparison, or other documentation as determined by the institution. Such documentation will allow students or parents to clarify how they supported themselves and, if applicable, their families. This support may include: receipt of public assistance, veteran’s educational benefits, or other income that is not included on the FAFSA; shared-living arrangements that drastically reduce living costs; instances of poverty or homelessness; or documentation of low-living costs.


Other Untaxed Income and W-2s


Tax Filers

All applicants placed in Verification Tracking Group V6 must provide a copy of their IRS Form W-2 for each source of employment income received for tax year 2014 to verify other untaxed income that was not transferred using the IRS Data Retrieval Tool or that did not appear on an IRS Tax Return Transcript. The IRS Form W-2 is used to verify whether there was any such income that should have been reported on the FAFSA or if it was reported correctly.


Nontax Filers

If an institution questions a claim that an applicant or parent has not, will not, and is not required to file a 2014 IRS income tax return, the institution must require the applicant to submit a “Verification of Nonfiling Letter” from the IRS indicating that the tax filer did not file a 2014 IRS income tax return. A request to the IRS for a Verification of Nonfiling Letter can be made using the IRS “Get Transcript Online” tool at or by submitting IRS Form 4506-T and checking box 7.


IMPORTANT NOTE: A response to a request for a Verification of Nonfiling Letter for the 2014 tax year generally will not be issued until after June 15, 2015. However, because there are limited circumstances when the IRS will provide a Verification of Nonfiling Letter before June 15, 2015, for purposes of verification, the Verification of Nonfiling Letter for the 2014 tax year must be dated on or after June 15, 2015. Finally, receipt of a Verification of Nonfiling Letter does not address whether or not the tax filer was required to have filed a tax return.


Dependency Status and Number of Household Members

Institutions are reminded that the FAFSA reported household size may need to be coordinated with one of the dependency questions on the FAFSA and any necessary corrections should be reported to the CPS. An example is when an applicant who answers “yes” to the dependency question about having “dependents other than a spouse” reported a household size of one. Should such an applicant verify that the household size is actually one, the answer to the “dependents other than a spouse” question on the FAFSA should be changed to “no.” It is important that these elements be accurate and corrected with the CPS since they have a direct effect on dependency status and the Expected Family Contribution (EFC) calculation.


FAFSA Parental Information

As with the 2014–2015 FAFSA, parental information for the unmarried parents of a dependent student must include both of the student’s legal (biological or adoptive) parents if those parents live together, regardless of the gender of the parents (see Dear Colleague Letter GEN-13-12). This includes not only the reporting of income and other financial information, but also nonfinancial information such as number of household members.


The Defense of Marriage Act

In Dear Colleague Letter GEN-13-25 USDE provided guidance on the implications of the Supreme Court’s decision on the Defense of Marriage Act (DOMA), as it applies to completion of a FAFSA and the calculation of a student’s EFC. As noted in Dear Colleague Letter GEN-13-25, for purposes of the Title IV Higher Education Act programs, a student or parent is considered married if the student or parent was legally married in any domestic or foreign jurisdiction that recognizes the relationship as a valid marriage. This applies to all parents or students, regardless of the couple’s gender, where the couple resides, or where the student will be attending school.


High School Completion Status

Applicants placed in Verification Tracking Groups V4 and V5 must provide documentation verifying their reported high school completion status. Institutions have asked USDE for additional guidance for applicants who have taken State-authorized examinations (e.g., the GED test, HiSET, TASC, or other State-authorized high school equivalency examinations). Test transcripts submitted by an applicant are acceptable documentation of high school completion only if:

–         The official test transcript specifically indicates that a State has determined that the test results are considered by the State to meet its requirements of high school equivalency; or

–        The official test transcript includes language that the final score is a passing score.


Institutions are required to have written policies and procedures for administering the Federal Supplemental Opportunity Grant (FSEOG). The guidance below should assist you in developing a policy and procedure for your institution. Take the time to read and develop one now if you do not already have one in place. Don’t get caught in a program review or audit without one!

The Federal Supplemental Educational Opportunity Grant (FSEOG) provides assistance to exceptionally needy undergraduate students. Students are exceptionally needy if they have the lowest EFCs. A priority must be given to Pell Grant recipients.

Schools have more latitude in selecting and awarding recipients of FSEOG funds than you do when awarding Pell or Direct Loans. However, there is certain criteria that must be considered, and in order to receive FSEOG, students must meet the general eligibility requirements that apply to all federal student aid recipients.

In general, if any part of the school’s allocation is directly or indirectly based on the financial need of independent students or students who are attending part-time, then you must offer a reasonable proportion of the FSEOG allocation. This requirement includes part-time students at eligible additional locations, as well as part-time students on the main campus. A policy that excludes part-time or independent students is not acceptable.

The maximum FSEOG for a full academic year is usually $4,000. The minimum FSEOG amount is $100, but you may prorate this amount if the student is enrolled for less than an academic year.

The FSEOG maximum award for a student applies to both the federal share and the required non-federal share. The FSEOG federal dollars awarded to a student are considered to be 75 percent of that student’s total FSEOG award, and the school must account for the remaining 25 percent non-federal share, regardless of the type of school resources used and the method used to match.

When awarding FSEOG funds for an award year, you must first select students with the lowest expected family contributions (EFC) who will also receive Pell Grants in that award year. This group is known as the FSEOG first selection group.

If you have remaining FSEOG funds after making awards to all Pell Grant recipients for that award year, you must next select students with the lowest EFCs who are not receiving Pell Grants. This group of students is known as the FSEOG second selection group.

A school would not be in compliance if it awards FSEOGs on a first-come, first-served basis or were it to arbitrarily set expected EFC benchmarks (cutoffs) from which it would select FSEOG recipients. Such a practice might exclude otherwise eligible students from the selection process.

Your selection procedures may specify categories of students to ensure that the students in each category have an opportunity to be awarded FSEOG funds. Categories may be based on class standing, enrollment status, program, date of application, or a combination of factors. You may choose to assign a percentage or dollar amount of FSEOG funds to each category; there is no requirement to make the percentage or dollar amount proportional to the need of students in a particular category or even to the number of students in the category. However, categorization may not be used to exclude certain students or groups of students from consideration. If you know that your school’s funds are so limited as to effectively exclude year after year categories that come later in the sequence, your school may not be in compliance with the “reasonably available” provision.

Your school’s written selection procedures must ensure that FSEOG recipients are selected on the basis of the lowest EFC and Pell Grant priority requirements over the entire award year. If your school enrolls students as often as monthly or weekly, FSEOG funds can be reserved for use throughout that award year (on the basis of your school’s experiences from previous periods), and selection practices can be applied in a manner that would assure a reasonable consistency over the entire award year.

FAFSA On Web Available Jan. 1, IRS Data Retrieval Tool Available Feb. 1.

As we say farewell to 2014, processing for the 2014-2015 award year continues, as we also prepare for the 2015-2016 award year processing. The 2015-2016 FAFSA on the Web was available to applicants on January 1 and CPS began processing on January 2.

The IRS Data Retrieval Tool will be available on February 1. This issue of the DJA Newsletter covers resources that will assist you in getting off to a great start! In addition, please join me on February 25th for a special DJA webinar to go over 2015-2016 updates.

Best wishes for a prosperous and healthy new year. We look forward to working with you in 2015!