Basics of Campus-Based Programs

1. Session 6 Basics of Campus-Based Programs Ashley Higgins and Zachary Goodwin| Dec. 2014 U.S. Department of Education 2014 FSA Training Conference for Financial Aid Professionals

2. What are the Campus-Based Programs? • Three separate need-based CBP programs: • Perkins Loan • Federal Supplementary Educational Opportunity Grant (FSEOG) • Federal Work-Study (FWS) • Recipients and amounts selected by schools, not ED, with high-need students a priority

3. Perkins Loan • Created as the National Direct Student Loan (NDSL) Program • National Defense Education Act of 1958 • Renamed in 1986 • Subsidized interest at a rate of 5% • 9-month grace period • Annual maximums • $5,500 for undergraduate students • $8,000 for graduate students

4. FSEOG • Authorized as part of the Higher Education Act of 1965 as the Educational Opportunity Grant • Precursor to the Pell Grant • Renamed in 1972 • Grant now serves as a supplement to the Pell Grant • Annual maximum of $4,000

5. Federal Work-Study • Authorized in 1964 • Economic Opportunity Act • Community service requirement added in 1992 • Used to fund payroll for student jobs • No annual maximum as long as financial need is not exceeded

6. Who Receives CBP Funds? • Students with exceptional financial need • FWS is an exception • Funds must be “reasonably available” • Students may be placed into categories

7. The Application Process • Fiscal Operations Report and Application to Participate (FISAP) • October 1 submission deadline • December 15 update • Filed via the eCampus-Based system atwww.cbfisap.ed.gov • Links to training, blank forms, and instructions

8. Common FISAP Errors • School does not validate FISAP information provided by 3rd party servicers • Schools request more than what they can reasonably expend • Schools with unexpended funds do not request a waiver for underuse of funds • Funding penalty in the following year results • FSEOG and FWS authorized amounts are adjusted downward to eliminate unexpended funds

9. CBP Allocations • Subject to Congressional budget process • Base guarantee • $5,000 • 90% of per-student amount in school sector • 90% of first-year allocation • Fair share • Institutional need as a portion of national need • Published in early spring

10. Awarding

11. Awarding FSEOG • Available only to undergraduates • Award amount must remain between: • Minimum - $100 • Maximum - $4,000 • Up to $4,400 in a study abroad program

12. Awarding FSEOG • Pell Grant recipients, with lowest EFCs • Known as FSEOG first selection group • Not necessary to receive a Pell Grant in the same payment period as FSEOG • Not receiving Pell Grant, with lowest EFCs • Known as FSEOG second selection group • May be selected after all Pell recipients have been awarded • Includes students who exceed Pell LEU for entire award year

13. Awarding FSEOG • Establishing categories of students • Selection procedures may establish categories of students • Class standing, enrollment status, program, etcetera • May assign proportional funds to each category • May not be used to exclude certain groups, within each category must first award to Pell recipients, lowest EFCs • Funds must be made reasonably available for all class starts in an award year

14. Awarding FSEOG • Selection Prohibitions • Awarding on a first-come, first-served basis • Arbitrary EFC cut-offs • Exclusion of students from certain states • Use of professional judgment in awarding • Applicable only to making adjustment(s) to a data element(s) in the EFC or COA • May not be used to circumvent selection priority • Awarding to offset loss of Pell Grant eligibility due to LEU

15. Awarding FWS • Must be made reasonably available to all eligible students • No award limits but may not exceed need • Student’s academic workload should be considered • Net earnings should be used for awarding and packaging • Gross amount minus job-related expenses and non-refundable taxes

16. FWS: Periods of Non-Attendance • Student may be employed during periods of non-attendance • Summer, vacation, period of co-op education, or term of non-attendance • Student must be planning to enroll for the next period of enrollment • Financial need must exist for that period • Net earnings must be used to cover expenses related to financial need for that period

17. Matching Requirements

18. Federal Share Limitation • FSEOG Limits • The federal share of FSEOGs made by a school may not exceed 75% of the total FSEOGs • The 25% nonfederal share of FSEOGs made from the school’s own resources (unless received a waiver) may include: • institutional scholarships, grants, and waivers; • state scholarships and grants; and • funds from foundations or other organizations

19. FSEOG and FWS Matching • Three accounting methods • Individual recipient basis • Aggregate basis • Fund-specific basis • 100% of funds considered for R2T4 purposes • ED may waive the nonfederal share requirement for FSEOG and FWS for an eligible school • Under FWS, the institutional share requirements for employment provided by a private for-profit organization or the administration of the JLD Program are never waived

20. Administrative Cost Allowance (ACA) • School is entitled to ACA for an award year IF for that award year: • Provides FWS employment; • Advances funds under the Perkins Loan Program; or • Awards grants under the FSEOG Program • Shall be used to offset administrative costs in the Campus-Based and Pell Grant programs • Including consumer information requirements

21. Transfers & Carry Forward/Back

22. Fund Transfers Flexibility to transfer funds between programs under certain circumstances • FWS • May transfer up to a total of 25% of its FWS allocation (initial plus supplemental) for an award year to its revolving Perkins fund or FSEOG allocation, or both • Does not need to receive Perkins FCC but must have a Perkins Level of Expenditure (LOE) • FSEOG

23. Fund Transfers: General Rules • Award transferred funds according to the requirements of the program to which they are transferred • Report the transfer of funds on the Fiscal Operations Report portion of the FISAP • Any transferred funds that are unexpended must be transferred back to the original program at the end of the award year • The program that the school wants to transfer funds to must also have an allocation for that same award year

24. Carry Forward/Carry Back • May spend up to 10% of its current year’s FWS or FSEOG allocation (initial and supplemental) in the following award year (carryforward) • Before a school may spend its current year’s allocation, it must spend any funds carried forward from the previous year • Your school is also permitted to spend up to 10% of its current year’s FWS or FSEOG allocation (initial and supplemental) for expenses incurred in the previous award year (carry back)

25. Carry Forward/Carry Back • Must match FWS or FSEOG funds carried forward or carried back in the award year that they are spent • Report funds carried forward/back on the FISAP • May not carry forward or carry back any funds to any award year in which there is no specific program allocation • Not permitted to add funds carried forward or back to the total FWS or FSEOG allocation for an award year when determining the maximum percentage of available funds that may transfer

26. Carry Forward/Carry Back • FWS Limitations • Not permitted to add funds that are carried forward or back to the total FWS allocation for an award year when determining the maximum percentage of available funds that may be used in that award year for: • Transferring FWS funds to FSEOG • Providing the federal share of wages in private for-profit sector jobs; • The Job Location and Development (JLD) Program

27. Carry Back for Summer • May use any portion of initial/supplemental FWS allocations for the current award year to pay student wages earned on or after May 1 of the previous award year but prior to the beginning of the current award year • May spend any portion of its current award year’s initial/supplemental FSEOG allocations to make FSEOG awards to students for payment periods that begin on or after May 1st of the prior award year but end prior to the start of the current award year

28. Disbursing Campus-Based Funds

29. Disbursing CBP Awards • $200 limit on prior award year charges that may be paid from current year Campus-Based funds • EFT may be made without student authorization • If student refuses, must still be paid in therequired time frame • Payment may be issued to stored-value card • School must obtain student authorization to credit FWS to student’s account at institution

30. Disbursing CBP Awards • FSEOG and Perkins • Award amount divided by the number of payment periods expected to attend in the academic year • May receive uneven amounts each payment period to cover uneven costs or EFA • FWS • Students must be paid at least monthly • Earned when students perform work • Wages earned while attending may be paid after the last day of attendance

31. Returning Unused Funds • If school returns more than 10% of its allocated funds for any Campus-Based program, ED will reduce allocation for second succeeding year by the amount returned • ED may waive upon request • Waiver is requested when FISAP is filed by submitting an explanation per FISAP Instruction Booklet • Must be a circumstance beyond the school’s control

32. Reallocation • Reallocation form (www.cbfisap.ed.gov) must be completed in the following situations • School will not spend entire 2014-15 FWS allocation • School is requesting supplemental 2015-16 FWS funds to pay students in community service jobs • Must have spent at least 5% of 2014-15 allocation to pay students employed as reading tutors of children or in family literacy activities as part of community service • Must have an FWS fair share shortfall as shown on line 28 of the 2014-15 final allocation letter • August 17, 2015 deadline

33. FWS: General & Community Service Requirements

34. Assigning FWS Jobs • A school should establish and maintain job descriptions • Jobs may be on or off-campus • Things to consider when assigning jobs: • Financial need • Number of hours student can work • Period of employment • Anticipated wage rate • Amount of other assistance available to student

35. Federal Share Limitation • In general, the federal share of FWS wages paid to a student may not exceed 75% of the student’s total wages • Example: if a school has $45,000 in FWS federal funds, it would be required to provide at least $15,000 in nonfederal funds. Then, a total of $60,000 would be available to pay students under the FWS program • If student working for a private for-profit organization, the federal share of the student’s wages may not exceed 50%. 35

36. Federal Share Limitation • In some cases, schools can use the federal share to pay up to 100% of the FWS wages paid to a student • In other cases, where a student is employed at a private nonprofit organization or a federal, state, or local public agency, a school may use the federal share of FWS wages to pay up to 90% of a student’s wages 36

37. FWS Conditions/Limitations • FWS employers are required to pay at least the federal minimum wage and may pay for overtime • If the state or local minimum wage is higher, the employer must pay at least that amount • FWS students may not displace employees • Students are not to be permitted to work in FWS positions during scheduled class times • FWS jobs may not involve constructing, operating, or maintaining religious facilities

38. On-Campus Employment • FWS students may be employed on campus at any type of school • FWS students may be assigned to assist a professor • FWS students may earn academic credit and FWS compensation at the same time with some restrictions

39. Work for Proprietary School • If an FWS student is not working in a community service position, the position must be on campus and must provide student services • Jobs primarily benefiting the proprietary school are not considered to be student services • Non-community service jobs must also be directly related to the student’s training or education

40. Work Off-Campus • For FWS students working at a non-profit or government agency, the work performed must be in public interest • Work is not considered to be in the public interest if it: • Primarily benefits the members of an organization that has membership limits • Involves political activity • Is for an elected official unless that official is responsible for regular administration of federal, state, or local government • Is as a political aide to an elected official • Takes into account party affiliation • Involves lobbying

41. Work Off-Campus Examples of Work in the Public Interest: • A student works for a private, non-profit membership organization, such as a golf club or swimming pool • If the general public may use the organization’s facilities on the same basis as its members, the work is considered to be in the public interest • If only members may use the facilities, FWS employment is not considered to be in the public interest 41

42. Work Off-Campus If a student is working off-campus for a private, for- profit employer: • The job must be academically relevant • It will not qualify as community service • The employer may not replace employees with FWS students

43. Off-Campus Agreements • A written agreement with the organization is required for off-campus employment • The agreement must specify what share of student compensation/other costs will be paid by the off-campus organization • It is the school’s responsibility to make sure that payment for work performed is properly documented and that each student’s work is properly supervised

44. Community Service • Community service is defined in Section 441(2) of the HEOA and 34 CFR 675.2 (b) • Community services must be open and accessible to the community • Exception: Support services for students with disabilities • Direct service is not required • Private, for-profit organizations do not qualify

45. Community Service • Schools must inform students of FWS community service opportunities available in the local community • Schools are also required to use at least 7% of their FWS allocation for community service jobs • In fulfilling the community service requirement, schools must employ at least one student as a literacy tutor for young children or in a literacy project for families with preschool or elementary school children

46. Community Service Waiver Schools may request a waiver of one or both of the community service expenditure requirements by the annual deadline. • This year’s deadline is Monday, April 27, 2015 The school should include detailed information that demonstrates that the requirement would cause a hardship for students at the school. 46

47. Employing FWS Students as Tutors • An FWS tutoring job may qualify 100% federal share but not qualify as part of the 7% requirement • To qualify as community service and for the 100% federal share, the job must meet the requirements for both FWS tutors and community service

48. Training for Tutors • ED recommends that tutors be trained • With some restrictions, an FWS tutor may receive wages while training • Training must be for a limited and reasonable time • No wages may be paid for taking an academic course developed to provide tutoring training • FWS tutor may receive wages for preparation and evaluation time • This must also be for a reasonable amount of time

49. Job Location & Development Program

50. JLD Program • The JLD program is part of the FWS program • The JLD program locates and develops off-campus job opportunities for students regardless of financial need • Jobs may be located and developed for both FWS and non-FWS eligible students • Jobs must, to extent practicable, complement the student’s program or vocational goals