Title IV Reconciliation Tools and Tips

1. 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

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

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

4. 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

5. 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.”

6. Disbursement Reporting Time Frame • 15 day reporting requirement for disbursements and disbursement adjustments • Federal Register published June 27, 2017 • 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

7. 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) • Tentative allocations published January; finals published in April • PELL and TEACH Grant funding is initiated by the reporting of accepted actual disbursements • Records First, i.e., submit the records first and the funds will be available to draw in G5 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

8. 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?

9. Funds Drawn/Returned - G5.gov • G5 Award Numbers (and Drawdowns and Refunds) are school, program, and award year specific • Example for 2017-18 Award Year

10. When to Draw/Return • Cash Management Regulations: • 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.” • Key Concepts: • Immediate need – three business days • Excess/Idle Cash – up to seven days • Schools may NOT hold additional funds while reconciling accounts

11. Returning Funds • Return of funds through G5 should be made electronically • Set up a bank account through G5 for refunds (888-336-8930) • If funds are being returned for R2T4, 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

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

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

14. 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 G5 • 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

15. 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 • Don’t assume they match because they exchange data

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

17. 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 New for Pell 2017-18

18. 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

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

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

21. 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 • Contains complete year to date student/disbursement level data and can be used to help rebuild lost school data either by student or school

22. 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

23. 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

24. 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

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

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

27. 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 = 17,937recipients / $77,851,424 • Rutgers is a traditional term school

28. 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

29. 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

30. External Reconciliation What Tools Do You Use for External Reconciliation? • SAS • EDconnect • DL Tools • COD • G5 • YTD-Pell • MS Access • SQL

31. 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

32. DePaul University • DePaul uses both Peoplesoft and Excel in the business and financial aid offices • 2016-17 data • 20,000+ enrollment • Pell 5494 recipients totaling $20,426,229.00 • DL 4624 recipients totaling $234,696,052.00 • Traditional quarter school

33. 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 • Controller’s Office process cash transaction through G5

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

35. 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 • G5 report

36. 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

37. Thomas Jefferson University • 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

38. 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

39. 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

40. 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

41. 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

42. QUESTIONS? Barbara.davis@ed.gov 202-821-3953

43. Pell Reports

44. Direct Loan Reports

45. Direct Loan Reports

46. TEACH Reports

47. Non Program Specific Reports

48. FSA Conference Presentations • #2 New COD Reporting • #8 Administering Disbursements • #17 Cash Management Regulations Overview • HO3 Hands-on COD Advanced

49. Resources • COD implementation for 2017-18 processing year • https://ifap.ed.gov/eannouncements/031617CODSystemImplementationfor20172018AY.html (see attachment for Pell SAS information) • Federal Register 2017-18 Award Year Deadline Dates • https://ifap.ed.gov/fregisters/attachments/FR062717AwardYearDeadlineDates1718.pdf

50. Resources, Continued • Federal Pell Grant Reconciliation • https://ifap.ed.gov/eannouncements/020717FederalPellGrantProgramReconciliation.html • Federal Direct Loan Reconciliation • https://ifap.ed.gov/eannouncements/121416WilliamDFordFedDirectLoanPrgmReconciliation.html