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09 Sep 08
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Developing an appropriate institutional policy is challenging, as it requires that academic leadership play a role in defining standards that are the same as or stricter than those applicable for students enrolled in the same educational programs who are not receiving Title IV assistance. The policy must also be consistent with other similar institutional policies, such as NCAA guidelines imposed on student athletes. Since SAP regulations are two-pronged- qualitative and quantitative-IHEs often make the mistake of strictly monitoring one element at the expense of the other.
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During the Title IV recertification process, there are certain changes that require written approval from the U.S. Department of Education before the disbursement of Title IV aid.
These include changes to the state authorizing agency or accrediting agency; changes to program offerings (including the addition of non-degree programs); and changes to institutional structure (nonprofit versus for-profit). These must be submitted, along with supporting documentation, to receive approval.
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Failure to reconcile Title IV accounts is a common compliance issue. Both the financial aid and business offices must work together to compare records of disbursed amounts for each federal program.
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These amounts must also be reconciled to the amounts drawn down and reported to the Grants Administration and Payment System (GAPS) for campus-based aid, and the Common Origination and Disbursement (COD) system for Pell Grants and Direct Loans.
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To help schools comply, the U.S. Department of Education Federal Student Aid program provides monthly reconciliation worksheets for each program.
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Instead of dictating an institutional policy, federal regulations require the institution to determine the earned and unearned Title IV aid as of the date enrollment ceases, up to the 60 percent point in each payment period.
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The most common compliance issue related to Title IV refunds involves late refunds made to FFEL lenders. Generally, schools must complete the refund calculation and return any unearned funds within 30 days of the student's official withdrawl.
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