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Session 11 Title IV Reconciliation Tools and Tips Barbara Davis | Nov. -Dec. 2017 Session 11 Title IV Reconciliation Tools and Tips Barbara Davis | Nov. -Dec. 2017 U. S. Department of Education 2017 FSA Training Conference for Financial Aid Professionals

Agenda • Reconciliation - The Basics • • Definition Disbursing Drawing Returning Reconciliation tools Agenda • Reconciliation - The Basics • • Definition Disbursing Drawing Returning Reconciliation tools • Reconciliation panel discussion • 2

What is reconciliation ? Ensuring that school records (financial aid and business office) match What is reconciliation ? Ensuring that school records (financial aid and business office) match exactlyamount and disbursement date AND • Ensuring that the Department’s systems exactly reflect the school’s data And • Drawdowns = Disbursements • • 3 (no funds are held beyond regulatory timelines and $0 balance by end of program year processing)

Reconciliation is REQUIRED • Monthly reconciliation is REQUIRED for Direct Loans, Perkins, Federal Work. Reconciliation is REQUIRED • Monthly reconciliation is REQUIRED for Direct Loans, Perkins, Federal Work. Study (FWS), and SEOG (Supplemental Education Opportunity Grant (SEOG) • • • Direct Loan - 34 CFR 685. 300(b) (5) Perkins - 34 CFR 674. 19 (d) (1) FWS - 34 CFR 675. 19 (b)(2)(iv) SEOG - 34 CFR 676. 19 (b)(2) Regular reconciliation recommended for all programs • • • Identifies issues with meeting other cash management and disbursement reporting requirements Demonstrates administrative capability FSA Handbook Volume 4 Chapters 5 and 6 4

Disbursement Definition 34 CFR 668. 164(a), “an institution makes a disbursement of Title IV, Disbursement Definition 34 CFR 668. 164(a), “an institution makes a disbursement of Title IV, HEA program funds on the date that the institution credits a student’s account at the institution or pays a student or parent directly with (i) Funds received from the Secretary, or (iii) Institutional funds used in advance of receiving Title IV, HEA program funds. ” 5

Disbursement Reporting Time Frame • 15 day reporting requirement for disbursements and disbursement adjustments Disbursement Reporting Time Frame • 15 day reporting requirement for disbursements and disbursement adjustments • Federal Register published June 27, 2017 • 6 An institution must submit Pell Grant, Iraq and Afghanistan Service Grant, Direct Loan, and TEACH Grant disbursement records, as applicable, no later than 15 days after making the disbursement or becoming aware of the need to adjust a student's previously reported disbursement

Pell, CB, and IASG Annual Funding Each award year a new current funding level Pell, CB, and IASG Annual Funding Each award year a new current funding level (CFL) or authorization is established • Campus-Based (CB) funding is based on data reported on the Fiscal Operations Report and Application to Participate (FISAP) • • • PELL and TEACH Grant funding is initiated by the reporting of accepted actual disbursements • • Tentative allocations published January; finals published in April Records First, i. e. , submit the records first and the funds will be available to draw in G 5 either later that day or the following day Iraq and Afghanistan Service Grant (IASG) funding is a case-by-case manual increase based on anticipated disbursements 7

Direct Loan Annual Funding Advance Funding • • • Initial authorization – Spring/Summer Subsequent Direct Loan Annual Funding Advance Funding • • • Initial authorization – Spring/Summer Subsequent increase late November and additionally as needed Foreign Schools/Heightened Cash Monitoring 1 • • • No initial authorization Records First - Accepted actual disbursements increase funding Heightened Cash Monitoring 2/Reimbursement • • Records First - Funds requested by FSA Did you know you can request to be a records first school for Direct Loans? 8

Funds Drawn/Returned - G 5. gov • G 5 Award Numbers (and Drawdowns and Funds Drawn/Returned - G 5. gov • G 5 Award Numbers (and Drawdowns and Refunds) are school, program, and award year specific • Example for 2017 -18 Award Year Program Award Year Direct Loan P 268 K 18#### Trailing Year TEACH Grant P 379 T 18#### Trailing Year Pell Grant P 063 P 17#### Leading Year Pell Grant Administrative Cost Allowance P 063 Q 17#### Leading Year IASG P 408 A 17#### Leading Year Campus-Based 9 G 5 Award Number FWS: P 033 A 17#### SEOG: P 007 A 17#### Leading Year

When to Draw/Return • Cash Management Regulations: • • • Key Concepts: • • When to Draw/Return • Cash Management Regulations: • • • Key Concepts: • • • 10 34 CFR 668. 161 -166 “The institution, as a trustee of Federal funds, may not use or hypothecate (i. e. , use as collateral) Title IV, HEA program funds for any other purpose. ” Immediate need – three business days Excess/Idle Cash – up to seven days Schools may NOT hold additional funds while reconciling accounts

Returning Funds • Return of funds through G 5 should be made electronically • Returning Funds • Return of funds through G 5 should be made electronically • • Set up a bank account through G 5 for refunds (888 -336 -8930) If funds are being returned for R 2 T 4, schools MUST send downward disbursement adjustments for Grant/Direct Loan Programs For Grant Programs, disbursement changes cannot be submitted after funding for the award year has been canceled (five years after the end of the award year) • TEACH is an exception and changes can be back submitted back to 2008 -09 • • Reminders: • If returning funds from an audit or program review, follow repayment instructions per the Final Audit or Program Review Determination letter 11

Internal Reconciliation Players: All Title IV Aid Programs Financial Aid Office Business Office Reconcile Internal Reconciliation Players: All Title IV Aid Programs Financial Aid Office Business Office Reconcile Internally 12 12

What Needs to Agree? • Cash • Disbursements • Net draws = net disbursements What Needs to Agree? • Cash • Disbursements • Net draws = net disbursements by program and award year 13

Bursar Tips for Internal Reconciliation • • • Ensure bursar/business office and financial aid Bursar Tips for Internal Reconciliation • • • Ensure bursar/business office and financial aid records agree with the amount the student wants and is eligible to receive Regularly compare bank statements to G 5 Return funds to the correct program and award year Refunds of Cash should be made electronically • Drawdown adjustments should only be used to correct drawdown errors • 14

FAO Tips for Internal Reconciliation • Daily/weekly check-in between Business Office and Financial Aid FAO Tips for Internal Reconciliation • Daily/weekly check-in between Business Office and Financial Aid Office (FAO) • • • Do disbursements reported match disbursements posted? Do draws and refunds of cash match disbursements? Run comparison reports between your Business Office and Financial Aid Office software • 15 Don’t assume they match because they exchange data

External Reconciliation Players: Campus. Based/Pell/DL/TEACH Financial Aid Office Business Office G 5 (Resource) Reconcile External Reconciliation Players: Campus. Based/Pell/DL/TEACH Financial Aid Office Business Office G 5 (Resource) Reconcile Campus-Based Aid via FISAP 16 Reconcile all other Title IV aid with COD 16

Pell, DL, and TEACH Reports for Reconciliation • School • Account Statement (SAS) Delivered Pell, DL, and TEACH Reports for Reconciliation • School • Account Statement (SAS) Delivered monthly to school’s Student Aid Internet Gateway (SAIG) mailbox • SAS Disbursement Detail on Demand Request via batch menu, Report Requests • Parameter driven - date range, monthly, YTD • 17

SAS Provides the Department’s official monthly Ending Cash Balance and detailed cash and disbursements SAS Provides the Department’s official monthly Ending Cash Balance and detailed cash and disbursements • Generated the first full weekend of the month and reflects data up to the end of the previous month (YTD or month to date depending on your settings) • You MUST reconcile monthly to the balances reflected on the DL SAS and must document that you have done so (recommended for all programs) • DL SAS now available in two formats only - fixed length and comma delimited with headers • 18

Reconciliation to the SAS School Receives SAS Compare Cash Summary Match ? YES NO Reconciliation to the SAS School Receives SAS Compare Cash Summary Match ? YES NO Compare Cash Detail Compare Loan Detail NO Resolve Issues Resolved ? YES DONE (Documentation) 19 19

Additional Reports for Reconciliation • Actual Disbursement List (DL only) • • School Funding Additional Reports for Reconciliation • Actual Disbursement List (DL only) • • School Funding History • • 20 SAIG mailbox and COD reporting website School menu/funding info Details all CFL changes, cash draws, refunds, and adjustments by program and award year

Additional Pell Reports for Reconciliation • Electronic Statement of Account (SAIG) - cash transactions Additional Pell Reports for Reconciliation • Electronic Statement of Account (SAIG) - cash transactions Initial Obligation/Authorization, changes to obligation/authorization both by date and amount • Number of unduplicated YTD recipients • • Reconciliation Report (SAIG) - summary disbursement Summary Pell Grant received YTD by each student • Includes verification and POP status as well as Life-Time Eligibility used (LEU) • • Year to Date (YTD) file (SAIG) - detail disbursement level • 21 Contains complete year to date student/disbursement level data and can be used to help rebuild lost school data either by student or school

Final Reconciliation and Closeout The process by which schools complete processing at the end Final Reconciliation and Closeout The process by which schools complete processing at the end of an award year. This process should: Be an extension of regular reconciliation cycle (i. e. , one final monthly reconciliation) • Result in a $0 ending cash balance (Net Drawdowns = Net Accepted and Posted Disbursements) in ALL systems • Occur shortly after final disbursements are made for a program and award year (or reported for CB Programs) • Ensure that all cash management and disbursement reporting requirements have been met • 22

New for Closeout - Aligning the Programs New and revised closeout correspondence • Balance New for Closeout - Aligning the Programs New and revised closeout correspondence • Balance confirmation process for all programs • • • DL available from 2011 -12 forward Pell Grant and TEACH available from 2016 -17 forward No Zero Balance Letter needed but make sure SAS reflects a $0 ending cash balance • Balance confirmation = tighter processing controls, reports no longer sent and Program Year Closeout Letter generated • 23

Closeout - continued • Request Reopen/Extended Processing through COD Website (all programs) • • Closeout - continued • Request Reopen/Extended Processing through COD Website (all programs) • • Reopen functionality allows self service reopen if confirmed closed prior to submission deadline Approval still needed to reopen for extended processing after data submission deadlines Change in balance will result in the school no longer being confirmed closed • Downward disbursement adjustments or adjustments due to POP still allowed for Pell without extended processing • 24

Panel Discussion Introduce Participants • Discussion topics • • 25 How do you coordinate Panel Discussion Introduce Participants • Discussion topics • • 25 How do you coordinate internal reconciliation What tools do you use for external reconciliation Tips and Tools of the Trade

Panel Participants Rob Fahy - Rutgers University • Sherry Cwirko - De. Paul University Panel Participants Rob Fahy - Rutgers University • Sherry Cwirko - De. Paul University • Thomas Stewart - Thomas Jefferson University • 26

Rutgers University Rutgers uses a Home Grown System(FAMS), EDExpress, and Banner 2016 -17 • Rutgers University Rutgers uses a Home Grown System(FAMS), EDExpress, and Banner 2016 -17 • Student Enrollment = 68, 942 • Direct Loans = 41, 545 recipients/ $436, 846, 952 • Pell Grant Program = 17, 937 recipients / $77, 851, 424 • Rutgers is a traditional term school • 27

What is Your School’s Process? • • • Receive the SAS files-Format them with What is Your School’s Process? • • • Receive the SAS files-Format them with DL Tools for DL Receive the Year to Date file for Pell Run a listing of Pell/ DL students from both FAMS and Banner. Then obtain a list of students disbursements from Student Accounts Run a comparison of above lists against the SAS and YTD Correct/document any discrepancies Reconcile to the balances on SAS and YTD

Internal Reconciliation How do you coordinate internal reconciliation? • Step 1 - The Office Internal Reconciliation How do you coordinate internal reconciliation? • Step 1 - The Office of Financial Aid (OFA) does a monthly comparison of the OFA disbursement data to the Student Accounts disbursement data • Step 2 - Communicate a discrepancy list via email to Student Accounts with a reason as to what the issue is for them to resolve • Step 3 - Fix any issues on the OFA side

External Reconciliation What Tools Do You Use for External Reconciliation? • • SAS EDconnect External Reconciliation What Tools Do You Use for External Reconciliation? • • SAS EDconnect DL Tools COD G 5 YTD-Pell MS Access SQL

Tips and Tools of the Trade Make sure you are aware of all the Tips and Tools of the Trade Make sure you are aware of all the reports that are available to you on COD for reconciliation • Make sure to have a good relationship with your Student Accounts Office • Excel and MS Access are your friend • Don’t be afraid if you have an issue to call COD and ask for help •

De. Paul University De. Paul uses both Peoplesoft and Excel in the business and De. Paul University De. Paul uses both Peoplesoft and Excel in the business and financial aid offices • 2016 -17 data • • • 32 20, 000+ enrollment Pell 5494 recipients totaling $20, 426, 229. 00 DL 4624 recipients totaling $234, 696, 052. 00 Traditional quarter school

What is Your School’s Process? • • • Daily transmission of files Weekly reports What is Your School’s Process? • • • Daily transmission of files Weekly reports Financial Aid disbursed weekly Student Accounts Office reports disbursements to Controller’s Office process cash transaction through G 5

Internal Reconciliation How do you coordinate internal reconciliation? • System generated reports • • Internal Reconciliation How do you coordinate internal reconciliation? • System generated reports • • COD Technical Reference • • Rejected records Loan period/academic year dates Comparison of YTD program totals to Controllers cash transactions Assists with how to resolve issues COD Website & Reports

External Reconciliation What Tools Do You Use for External Reconciliation? • • • SAS External Reconciliation What Tools Do You Use for External Reconciliation? • • • SAS on Demand-YTD Report School Funding Information School Summary Financial Information Refund of Cash & Cash Activity Yearly Totals Anticipated Disbursement Queue Pell POP Report Pell Grant Year-to-Date Record G 5 report

Tips and Tools of the Trade • • • Know the team players Communication Tips and Tools of the Trade • • • Know the team players Communication Weekly reviews- systems issues are identified and resolved in a timely manner COD Technical Reference- your best friend Undisbursed Loan Records- clean these up sooner rather than later

Thomas Jefferson University • • • 37 Thomas Jefferson University, Philadelphia, PA Banner Software Thomas Jefferson University • • • 37 Thomas Jefferson University, Philadelphia, PA Banner Software 3881 Undergraduate and Graduate Students $69 Million in Direct Loans and $723, 000 in Pell Majority Programs are Fall/Spring, semester based with a few exceptions

What is Your School’s Process? • • • We are advanced funding school We What is Your School’s Process? • • • We are advanced funding school We report the loans first and draw only on accepted loans Send daily reports of loans/grants to the Bursar Office, so they know what students need their funds fed to their account Work Flow is used between FA and Registrar with regards to students who withdraw before or after semester starts Banner communicates with each Department but we still run reports to ensure all students are being captured

Internal Reconciliation I reconcile on weekly basis by running an ARGOS report out of Internal Reconciliation I reconcile on weekly basis by running an ARGOS report out of Banner for disbursed and undisbursed loans/grants • Communicate once or twice a week with Bursar with regards to drawdowns, paid loans/grants, etc. • We rectify any errors that appear amiss between my award screen and general ledger • Run a reject report for loans/grants and make necessary corrections to retransmit those files •

External Reconciliation Receive the monthly SAS reports from COD and convert them into an External Reconciliation Receive the monthly SAS reports from COD and convert them into an excel file • Use the SAS along with an end of the month ARGOS report out of Banner and then combine the two • Built an in-house Excel file with Macros, Pivot tables that matches what is on the SAS against the Banner report • Rectify any discrepancies between Banner and COD •

Tips and Tools of the Trade Run weekly reports of rejected files and ensure Tips and Tools of the Trade Run weekly reports of rejected files and ensure corrections go through with COD • Run weekly reports on disbursed loans/grants and ensure amounts match COD • Communicate with Bursar weekly to ensure drawdowns are being made and align with what you believed was paid out • Communicate daily with Registrar with respect to WD, LOA’S, dropped credits, etc. to adjust loans accordingly •

QUESTIONS? Barbara. davis@ed. gov 202 -821 -3953 42 QUESTIONS? Barbara. [email protected] gov 202 -821 -3953 42

Pell Reports Report Name Frequency SAIG Mailbox COD Reporting Web Site Multiple Reporting Records Pell Reports Report Name Frequency SAIG Mailbox COD Reporting Web Site Multiple Reporting Records (MRR) Daily Fixed Length No Pending Disbursement List Weekly Comma-Delimited Pell POP Report Weekly Comma-Delimited Pell Lifetime Eligibility Used Report Weekly Comma-Delimited Verification Status Report Monthly Comma-Delimited Reconciliation Report By Request (also generated by FSA just prior to processing deadline) Fixed Length No Year-to-Date (YTD) File By Request Fixed Length No Electronic Statement of Account (ESOA) System generated if trigged by change or by request Fixed Length No Pell Grant School Account Statement (SAS) Monthly Comma-Delimited No Pell Grant School Account Statement Disbursement Detail on Demand By Request Comma-Delimited No 43

Direct Loan Reports Report Name SAIG Mailbox COD Reporting Web Site Direct Loan Rebuild Direct Loan Reports Report Name SAIG Mailbox COD Reporting Web Site Direct Loan Rebuild File By Request Fixed Length No Direct Loan School Account Statement (SAS) Monthly Comma-Delimited with headers Fixed Length No Direct Loan School Account Statement (SAS) Disbursement Detail on Demand On Demand Comma-Delimited Fixed Length No Duplicate Student Borrower Report Monthly Comma-Delimited Do not distribute Comma-Delimited Pending Disbursement Listing Report Weekly Comma-Delimited Do not distribute Comma-Delimited Direct Loan Actual Disbursement Report 44 Frequency Weekly Comma-Delimited Do Not Distribute Comma-Delimited

Direct Loan Reports Report Name Frequency SAIG Mailbox COD Reporting Web Site Direct Loan Direct Loan Reports Report Name Frequency SAIG Mailbox COD Reporting Web Site Direct Loan Counseling Report *Student. Loans. gov information Weekly No Comma-Delimited Completed PLUS Application Report Weekly No Comma-Delimited Weekly Credit Status Report Weekly No Comma-Delimited Direct Loan Completed MPN Report Weekly No Comma-Delimited MPN Status Report Weekly Comma-Delimited Direct Loan Subsidized Loan Usage Change Weekly Comma-Delimited SULA Adjustments Needed Report Monthly (prior to closeout) 45 Comma-Delimited

TEACH Reports Report Name Frequency SAIG Mailbox COD Reporting Web Site TEACH Grant School TEACH Reports Report Name Frequency SAIG Mailbox COD Reporting Web Site TEACH Grant School Account Summary (SAS) Monthly Comma-Delimited with header No TEACH Grant School Account Summary (SAS) Disbursement Detail on Demand On Demand Comma-Delimited with header No Multiple Reporting Records (MRR) Daily Fixed Length Comma-Delimited Pending Disbursement List Weekly Comma-Delimited ATS Discharge Report Weekly Fixed Length Comma-Delimited Rebuild File By request Fixed Length No 46

Non Program Specific Reports Report Name Frequency SAIG Mailbox COD Reporting Web Site COD Non Program Specific Reports Report Name Frequency SAIG Mailbox COD Reporting Web Site COD School Monitoring Report Weekly Preformatted Text PDF COD School Funding History Report Adhoc 47 Comma-Delimited (available from the School/funding information menu for authorized school users)

FSA Conference Presentations #2 New COD Reporting • #8 Administering Disbursements • #17 Cash FSA Conference Presentations #2 New COD Reporting • #8 Administering Disbursements • #17 Cash Management Regulations Overview • HO 3 Hands-on COD Advanced • 48

Resources • COD implementation for 2017 -18 processing year • • Federal Register 2017 Resources • COD implementation for 2017 -18 processing year • • Federal Register 2017 -18 Award Year Deadline Dates • 49 https: //ifap. ed. gov/eannouncements/031617 CODSystem. Implement ationfor 20172018 AY. html (see attachment for Pell SAS information) https: //ifap. ed. gov/fregisters/attachments/FR 062717 Award. Year. Dea dline. Dates 1718. pdf

Resources, Continued • Federal Pell Grant Reconciliation • • Federal Direct Loan Reconciliation • Resources, Continued • Federal Pell Grant Reconciliation • • Federal Direct Loan Reconciliation • 50 https: //ifap. ed. gov/eannouncements/020717 Federal. Pell. Grant. Progra m. Reconciliation. html https: //ifap. ed. gov/eannouncements/121416 William. DFord. Fed. Direct Loan. Prgm. Reconciliation. html

Closeout Guidance • Recent system updates (all programs) • • TEACH • 51 https: Closeout Guidance • Recent system updates (all programs) • • TEACH • 51 https: //ifap. ed. gov/eannouncements/attachments/062917 Additional CODSys. Implement. Plannedfor. July 14 thru 162017. pdf https: //ifap. ed. gov/eannouncements/090817 Additional. TEACHGrant Closeout. Infofor 20162017 AY. html

Closeout Guidance, Continued • Direct Loan • • Pell Grant • 52 https: //ifap. Closeout Guidance, Continued • Direct Loan • • Pell Grant • 52 https: //ifap. ed. gov/eannouncements/070617 Additional 20152016 DL Program. Year. Closeout. Info. html https: //ifap. ed. gov/eannouncements/090817 IASGPell 1617 AYProc. D eadline. html

Campus Based References https: //ifap. ed. gov/eannouncements/042517 FISAPForm. In stru. Ref. Tech. Ref. Due Campus Based References https: //ifap. ed. gov/eannouncements/042517 FISAPForm. In stru. Ref. Tech. Ref. Due 092917. html • https: //ifap. ed. gov/eannouncements/071717 e. Campus. Bas ed. App. Fiscal. Op. Rprt 1617 and 1819 FISAPAvail. html • 53

Customer Service Centers • COD school relations center (Pell Grant, Direct Loan, and TEACH Customer Service Centers • COD school relations center (Pell Grant, Direct Loan, and TEACH reconciliation assistance) • • Campus-Based call center (FISAP, Perkins default. and campus-based program assistance) • • • 54 8 a. m. to 11 p. m. (ET) Monday through Friday 1 -800 -848 -0978 (Direct Loan), 1 -800 -474 -7268 (Pell Grant) [email protected] gov 8 a. m. to 8 p. m. (ET) Monday through Friday 1 -866 -441 -2175 [email protected] gov