Pat Stephenson and Tamy Garofano | Dec. 2014 U.S. Department of Education 2014 FSA Training Conference for Financial Aid Professionals FISAP/Campus-Based

Pat Stephenson and Tamy Garofano | Dec. 2014

U.S. Department of Education

2014 FSA Training Conference for Financial Aid Professionals

FISAP/Campus-Based Update

Session 45

Topics• Overview of Campus-Based Programs and FISAP• FISAP Part II• eCB Self-Service Features• Title III/V Designation• Underuse of Funds• FWS Community Service Requirement• Reallocation of Funds• Supplemental Funding• Annual Closeout• FISAP Change Requests• Perkins Loan Program• Work Colleges Program• Comprehensive Transition and Postsecondary Programs (CTP)

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Campus-Based Programs

•Federal Supplemental Opportunity Grant – (FSEOG) – Funding Authorization•Federal Work-Study (FWS) – Funding Authorization•Federal Perkins Loan – School revolving fund

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FISAP

• The Fiscal Operations Report and Application to Participate (FISAP)

• Schools must complete the FISAP to:Request Campus-Based funding for the upcoming year (Application

to Participate)Report Campus-Based expenditures for the prior year (Fiscal

Operations Report)

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FISAP Part II

• Impact on Funding Authorizations• Amount Requested• Total Enrollment• Total Tuition and Fees• Total Pell Expenditures• Calendar Type

• Traditional• Non-Traditional

• Eligible Aid Applicants

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FISAP Part II

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FISAP Part II

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FISAP Part II

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FISAP Part II

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FISAP Part II – Impact on Funding

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CB Final Funding Worksheet

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Statement of Account (SOA)

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Title III and Title V Designation• Annual application process for eligibility designation of the

Title III and Title V programs and application for the waiver of non-Federal share includes:

• Notice Inviting Application for Designation as an Eligible Institution for Fiscal Year 2015 published November 3. Deadline: December 18, 2014 http://www2.ed.gov/about/offices/list/ope/idues/eligibility.html

• A requirement that the institution enroll needy students as outlined in the Federal Register Notice published November 3, 2014

• Use of the “Core Expenses” as reported to the National Center for Educational Statistics (NCES) Integrated Postsecondary Education Data System (IPEDS) for Academic Year 2012-13

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Title III and Title V Designation• Designation of Eligible Institution – Programs under Parts A and F

of Title III and Title V of the HEA:

• Strengthening Institutions Program (SIP)• Alaska Native and Native Hawaiian-Serving Institutions (ANNH)• Predominantly Black Institutions (PBI)• Native American-Serving Nontribal Institutions (NASNTI)• Native American and Native American Pacific Islander-Serving Institutions

(ANNAPISI)• Hispanic-Serving Institutions STEM and Articulation (HSI STEM and

Articulation)• Promoting Post-Baccalaureate Opportunities for Hispanic Americans (PPOHA)• Developing Hispanic-Serving Institutions (HSI)

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Title III and Title V Designation• An institution that submits an “Application to Request

Designation as an Eligible Title III and Title V Institution” and is approved:

• Receives the institutional match for FWS and FSEOG waiver

• May also apply for a Title III or Title V Grant Award

• An institution that is denied designation as an eligible institution can:

• Apply to the Secretary of Education for a waiver of the requirements of needy student enrollment or Core Expenses as detailed in the instructions for completing the application

See the Federal Register Notice published November 3, 2014 for details

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Annual Process Flow

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Waiver Length for Non-Federal Match• Institutions that have been designated as an eligible

institution receive the waiver for one year

• The application process must be completed each year

• Institutions that have applied and received a Title III or V Grant award receive the waiver for duration of the grant award

• If grant is terminated or cancelled, the institution must complete the application process to receive the waiver in subsequent years

• HBCU and TCCU institutions are exempt from annual application process

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Underuse of Funds

• Schools with an underutilization of Campus-Based funds that exceeds 10% of their annual authorization are penalized. The annual authorization for the following year will be reduced by the dollar amount of the underutilization

• Schools that do not exceed the 10% threshold are not penalized

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Example - FSEOG Underuse

• 2013-14 Underuse Reported on 2015-16 FISAP:

• Annual FSEOG Authorization: $100,000• Amount of FSEOG Expended: $ 50,000• Amount of FSEOG Unexpended: $ 50,000

Amount of Penalty to 2015-16 FSEOG: $50,000

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Determine Underuse Percentage

• For FSEOG:Unexpended FSEOG Authorization (IV/E/18) / Final adjusted FSEOG authorization (IV/A/1) x 100 = % unexpended FSEOG authorization

• For FWS:Unexpended FWS authorization (V/E/19) / Final adjusted FWS authorization (V/A/1) x 100 = % unexpended FWS authorization

If either result is more than 10%, your 2015-16 authorization for the program will be reduced by the dollar amount unexpended in 2013-14

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Underuse of Funds

• Can schools avoid the underuse penalty to their annual authorization?

• Schools are sent a notification after the October 1 FISAP filing deadline if they reported unexpended FWS or FSEOG funds on the FISAP

• Schools have until December 15 to review, reconcile, and revise FISAP entries

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Underuse of Funds

• Schools with more than 10% remaining underused/unexpended in either FWS or FSEOG or both, may submit an Underuse Waiver request

• Waiver approvals are provided to schools with rare, extenuating circumstances beyond the school’s control for not utilizing their funds, such as: • Death of FAA• Catastrophic weather

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Underuse of Funds

• Waiver Process

• Common Denials:• The school had difficulty making necessary Campus-Based awards

to students• Awarded students did not return the second semester• New Financial Aid Administrator• Staff did not realize the funds had not been expended until too late

in the year

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Underuse of Funds

• Waiver Process• To Apply:

• Access your submitted 2015-16 FISAP and select “Yes” in Part II, Section C, Item 6

• Click “submit” at the bottom of the menu, then select ‘Submit Waiver” from the drop down list

• On the “Additional Information” screen explain the circumstances that caused the underuse of the authorization

• Click the “Submit” button under the justification, then click “Continue to Submit”

• A confirmation message will display• The deadline to request this waiver is February 9, 2015

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FWS Community Service

• Requirement

• Each school that participates in the FWS program is required to expend at least seven percent (7%) of its total FWS federal authorization to compensate students employed in community service activities

• In meeting that seven percent (7%) community service expenditure requirement, one or more of the school’s FWS students must be employed as a reading tutor for children in a reading tutoring project or performing family literacy activities in a family literacy project. [34 CFR 675.18(g)(1)]

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• Failure to Meet the Requirement

• A school that fails to meet one or both of the FWS community service requirement may be required to return FWS federal funds in an amount that represents the difference between the amount a school should have spent for community service and the amount it actually spent

• A school that is not compliant with the FWS community service requirements may be subject to a Limitation, Suspension, and Termination (L, S, & T) proceeding, through which the school could be denied future participation in the FWS Program, and possibly other Title IV, HEA programs, and/or subject to a substantial fine

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• Waiver Process

• The Secretary may waive one or both of the community service requirements for a school if the school has demonstrated that enforcing the requirement(s) would cause a hardship for the students at that school

• The fact that it may be difficult for the school to comply with the requirement(s) is not in and of itself a basis for granting a waiver. [34 CFR 675.18(g)(2)]

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• Waiver Process

• In the past, the Secretary has approved a limited number of waivers when schools were able to demonstrate an exceptional circumstance. For example:

• Small FWS Annual Authorization• Rural Area• Specialized Program of Study

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• Waiver Process• Common Denials:

• The school was unable to generate sufficient FWS positions to utilize the funds

• The school had difficulty making necessary FWS awards to students

• Awarded students did not return the second semester• New Financial Aid Administrator• Staff did not realize the funds had not been expended until too late

in the year

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• Submission Requirements

• A school must submit its waiver request to the Department of Education (the Department) electronically via the eCampus-Based (eCB) Website at the “Community Service Waiver” link at the top of the “Setup – Change Years/Schools” page

• The school’s waiver request must specify whether the school is requesting a waiver of the seven percent (7%) community service requirement, the reading tutor or children or family literacy project requirement, or both. It must also include detailed information to demonstrate that complying with the requirement(s) would cause hardship for the school’s students

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•Waiver Process

• The deadline for electronic submission of a school’s waiver request is 11:59 p.m. (ET) on Monday, April 27, 2015

• Transmissions must be completed and accepted by 12:00 midnight

• A waiver request that is received after April 27, 2015 will not be considered

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Reallocation of Funds

• The Campus-Based Reallocation form must be completed if:

• A school does not intend to spend its entire 2014-15 FWS or FSEOG authorization; or

• A school wants to request supplemental 2015-16 FWS funds that will be used to employ students in community service jobs (not for any other purpose), and the school had a FWS fair share shortfall as shown on line 28 of the school’s 2015-16 final funding worksheet, provided with its final authorization letter

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• Annual Electronic Announcement provides detailed information and Worksheet

• Deadline for submission is mid August

• Campus-Based Reallocation Form OMB No.1845-0030

• Do not send this worksheet to the U.S. Department of Education. Enter data in the reallocation module of the FISAP on the Web at http://cbfisap.ed.gov/

.

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Reallocation Form

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• To access the Campus-Based Reallocation Form, log into the eCB website and select the “Setup” link on the top navigation bar. Select the “Reallocation Form” link on the top right side of this page. From that point, follow the instructions for completing the form

• After completing the Campus-Based Reallocation Form, click on the “Submit” button. You can verify submission by viewing the Submission Log on your eCB Self-Service page

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• FWS federal funds released on the Campus-Based Reallocation Form by the deadline date will not be included in the calculation of the institutional requirement to spend at least seven percent (7%) of its FWS federal authorization to pay the federal share of compensation to students employed in community service positions

• Unexpended amounts of the federal authorization reported on the FISAP that is due by October 1, 2015, will not reduce the institutions FWS federal allocation for purposes of determining compliance with the seven percent (7%) community service requirement

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Supplemental Funding• Each year prior to September 30th, the Department of

Education uses information collected on the Campus-Based Reallocation Forms returned by schools, to reallocate unexpended Federal Supplemental Educational Opportunity Grant (FSEOG) and Federal Work-Study (FWS) program funds from the previous award year as supplemental allocations for the current award year

• Note: Because there were no new Perkins Loan funds appropriated for the 2014-15 Award Year, there will be no Perkins Loan funds available to be awarded for the 2015-16 Award Year through the supplemental award process

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Supplemental Funding

• Supplemental Campus-Based funds will be distributed in accordance with section 413D(d) for FSEOG and section 442(d) for FWS of the Higher Education Act of 1965, as amended, and the regulations at 34 CFR 673.4

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• The Department will award100 percent of the available FWS funds to schools with a 2015-16 fair share shortfall (final funding worksheet for FWS, line 28) that:Requested a supplemental 2015-16 FWS allocation on line 5 of the

Campus-Based Reallocation Form to compensate students employed in community service jobs during the 2015-16 Award Year; and

Indicated on line 4 of the Campus-Based Reallocation Form that they spent at least five percent (5%) of their total 2014-15 FWS funds to compensate students employed as reading tutors of children or in family literacy activities as part of their community service activities

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• FSA will verify that a school spent at least five percent (5%) of its total 2014-15 FWS allocation to compensate students employed as reading tutors of children in family literacy activities as part of its community service activities when the school submits its Fiscal Operations Report and Application to Participate (FISAP) due October 1, 2015

• If a school received supplemental FWS funds for which it was not entitled, those funds will be de-obligated from G5

• Note: All (100%) of the supplemental FWS funds must be used to compensate students employed in community service activities

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• By the end of September schools are notified by e-mail if they received supplemental Campus-Based funds • This e-mail is sent to the Financial Aid Administrator identified

on the most recently submitted FISAP, or as updated via the “Contact Info” page on the eCB Website

• In the e-mail, schools will be referred to the school’s Statement of Account (SOA) on the eCB Website which will reflect the supplemental award amount for each program

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• To access the Statement of Account (SOA), schools should:

• Log into the eCB Website;• Select the “Self-Service” link from the top navigation bar;• Scroll to the “Campus-Based Notifications for All Available Award

Years” section;• Scroll to the “Statement of Account” bullet; and, • Click on the appropriate year link next to it

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Annual Closeout

• Campus-Based awards are closed out each year in early/mid Spring

• This process involves reconciling a school’s authorized award for each program with the amounts reported as expended on the FISAP

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Annual Closeout

• For example: FWS Authorized Amount: $ 50,000

Amount reported as expended

on FISAP: $ 40,000

Amount of authorized amount

not spent: $ 10,000

Amount de-obligated from G5

at Closeout: $ 10,000

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Annual Closeout

• The closeout amount will appear in G5 as the authorized amount for the 2013-14 award year

• If a school drew down more than what was reported as expended on its FISAP, a negative amount will appear in the “available balance” line in G5 after the closeout process occurs

• The school must repay the negative balance back to G5 in order to reconcile the account

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Annual Closeout

• FWS G5 Award ID: P033A14XXXX

• FWS Authorization: $ 50,000• Total amount drawn from G5: $ 50,000• Amount de-obligated at Closeout: $10,000• Current G5 Balance: -$ 10,000

• School must repay negative balance back to G5

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FISAP Change Requests

• Schools must submit their initial FISAP no later than October 1, 2014

• Revisions may be made to the FISAP data through December 15, 2014

• After December 15, a FISAP Change Request must be submitted and approved by the Department before a school is able to make any further revisions

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• FISAP changes must only be made to correct verified and documented errors in reporting

• FISAP changes requested after funds are de-obligated during Closeout may be approved, but funds will not be reinstated to G5 for any changes made after December 15

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• Many schools attempt to adjust the FISAP data to compensate for de-obligations due to Closeout

• In most cases the requested changes will not be approved

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Example Reported on 2015-16 FISAP:

•Annual FSEOG Authorization: $ 100,000•Amount of FSEOG Expended: $ 50,000•Amount of FSEOG Unexpended: $ 50,000

•Amount of FSEOG de-obligated during Closeout: $ 50,000

• Change request submitted reducing the Final Adjusted Authorized amount to $50,000 and unexpended funds to $0

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• School requests to reduce the amount in Part IV, Section A, #1, Final Adjusted FSEOG Amount to $50,000, and Part IV, Section E, #18 to $0, eliminating an unexpended amount

• Part IV, Section A, #1, Final Adjusted FSEOG Amount should only be reduced if FSEOG funds were returned through the reallocation process

• The Closeout process looks at the Statement of Account to determine Final Adjusted FSEOG Amount, not the FISAP

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• Part IV, Section A, #1, Final Adjusted FSEOG Authorization should only be increased if FSEOG funds were received through the Supplemental Funding process

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• Common Reasons for Corrections/Revisions:

• Due to A-133 Audit or Program Review findings• Late R2T4 calculations• School is late reconciling accounts and discovers errors in reporting

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• Campus-Based staff review all requests and make a determination of whether a request is valid

• Schools may be contacted to clarify or revise their requested changes

• Campus-Based staff will approve/deny requests and notify the FAA listed on the FISAP

• Once approved, the school has five days to submit the Working Copy of the FISAP to the official submission

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• Impact of Changes on G5 Funding after December 15:

• Funding Increases• FISAP will be opened to allow for accurate reporting, but funding

increases to G5 will not be approved

• Funding Decreases• Funding de-obligations will be processed in G5

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• As a general rule, funding reinstatements after December 15 of the reporting year are only approved in rare, extenuating circumstances, such as:• Death of the FAA• Catastrophic weather conditions

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Perkins Loan Program

• Cohort Default Rate

• Perkins Loan Program cohort default rate is separate from FFEL/DL default rate calculations

• Schools with a Perkins Loan Program cohort default rate at 50% or higher for three consecutive years are notified of the appeal process and requirement to liquidate their school Perkins portfolio

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• Cohort Default Rate – Appeals

• Valid reason to appeal a Perkins Loan Program cohort default rate of 50% or higher for three consecutive years:• Inaccurate calculation of the cohort default rate reported on the FISAP• Small number of borrowers entering repayment (on average fewer than 10)

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• Cohort Default Rate – Appeals

• School President is notified via registered mail of the status of the Perkins portfolio (FAA is copied)

• If appeal is not received, school President is notified via registered mail to begin liquidating the Perkins portfolio and is provided contact information and links to the procedures

• If appeal is received, the school is notified of the decision by registered mail. Those denied must begin liquidating their Perkins portfolio

• Schools in this group are referred to the Compliance Area

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• Reminders of Key Perkins Program Requirements• Use of Funds—

• Making loans to students;• Administrative expenses (if it makes loans to students);• Capital distributions (liquidation or return of excess liquid capital);• Litigation costs• Other collection costs, agreed to by the Secretary in connection with the collection

of principal, interest, and late charges on a loan made from its fund (see §674.47); and

• Repayment of any short-term, no-interest loans made to its Fund by the institution in anticipation of collections

• Reporting to NSLDS—• It is the school’s responsibility to ensure that its required reporting to NSLDS

(which includes Perkins loan account detail) is completed on time and accurately

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Perkins Loan Program• Reporting to NSLDS (continued)—

• Schools that use a third party servicer must communicate these requirements to its third party servicer and ensure that its servicer complies with timely and accurate reporting requirements. It is important for schools to understand that they will be responsible for any non-compliance by the servicer

• For the purposes of Perkins liquidation and closeout, schools must ensure that NSLDS reflects that all borrower loan accounts are fully retired, accepted for assignment by the Department or purchased by the school

• In some cases, a school may need to request a reconciliation report from NSLDS to ensure its records are consistent with NSLDS, reconcile any discrepancies and update NSLDS accordingly. It is recommended that all schools complete this reconciliation with NSLDS at least every six months

• Until the Department accepts a loan and is able to successfully report on the loan to NSLDS, the loan is still the responsibility of the school and the school must report the loan to NSLDS as transferred for assignment using the code “AE” and the “certification date” as the loan status date

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• Liquidation of Perkins

• A schools Perkins Loan portfolio and its Perkins Loan Revolving Fund must both be liquidated when it ends its participation in the Perkins Loan Program

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• Liquidation of Perkins

• A school must liquidate its Perkins Loan portfolio and program fund, when it:Voluntarily withdraws from the program;has had its eligibility to participate in the Perkins Loan Program

terminated by the Department;has not been approved by the Department for continued

participation during the school's recertification process; oris closing

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Perkins Loan Program• The process of liquidating includes a review of the

outstanding Perkins Loans to determine if the loans have been maintained and administered properly so they can be assigned to the Department

• All loans must be properly accounted for and updated in the NSLDS

• This process also includes liquidating the funds in the Perkins Loan portfolio and accounting for any Perkins Loans that could not be assigned to the Department

• A school's Perkins Loan portfolio and program Fund is not considered liquidated and closed out until an official letter of completion has been received from the Department

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• Check IFAP for updated Assignment and Liquidation procedures posted November, 2014

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• DRAP – Default Reduction Assistance Program

• DRAP assists schools in bringing defaulted Perkins Loan borrowers back into repayment before their accounts are sent to collection agencies

• A letter is sent from the Department on official letterhead to defaulted Perkins Loan borrowers that explains the serious consequences of default, including:• The inability to obtain other federally supported financial assistance• Withholding of federal and state income tax refunds• Salary garnishment• Damage to credit history

The letter encourages borrowers to contact the school to initiate repayment arrangements

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• DRAP

• Participation in the DRAP program is voluntary

• There is no cost to the school

• It is most effective when used during the 30-day period when the school is waiting for the defaulted borrower to respond to the final demand letter

• Do not request default reduction assistance once the account has been referred to a collection agency

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• DRAP

• Through the DRAP process, a school or its third party servicer will need to:Submit borrower name and address information for letters to be printed and

mailed by the Department;Maintain/Update borrower name and address information;Edit school’s DRAP contact information;Run a report that assists in monitoring the letters mailed to borrowers

:

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• DRAP

• Accessing and Initiating the DRAP process:• Information related to accessing and initiating the DRAP process is

posted to IFAP each year in October:• http://ifap.ed.gov/eannouncements/100314CB2014DRAPProcess.html

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Work Colleges Program

• Application to participate located on the eCB Self-Service page:

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• Only schools that meet the criteria to participate should submit an application

• This is not an application to participate in the Federal Work-Study Program

• 34 CFR 675.41 provides information on the Work Colleges Program

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• The purpose of the program is to:

• Recognize comprehensive work-learning-service programs that are an integral and valuable part of the institutions’ educational approach

• promote an institutional financial plan that decreases reliance on grants and loans

• encourage student engagement in community service activities

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• Currently, only seven colleges/universities meet the criteria• Every student in every academic program on campus must

participate in a work program in order for the school to meet the requirement

• For more information on the Work Colleges Program, contact:• Robin Tafler, Executive Director, Work Colleges Consortium• [email protected]• www.workcolleges.org

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Students With Intellectual Disabilities• A Comprehensive Transition and Postsecondary (CTP)

program must be approved by the Department of Education in order for students to receive federal student aid

• To be approved, an institution must submit an updated Electronic Application for Approval to Participate in the Title IV Federal Student Aid Programs (E-App) to the Department for CTP programs

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Students With Intellectual Disabilities

• Federal Student Aid Programs available for approved CTP programs:

• Federal Pell Grant (Pell Grant)• FSEOG • FWS• Parent Loan for Undergraduate Student (only for dependent

students attending an institution that is participating in the Experimental Site)

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Federal Student Aid for CTP Programs

• Students with intellectual disabilities are eligible to receive Federal Pell, FSEOG, and FWS assistance as long as they meet general Title IV eligibility requirements, with the following exceptions:

• Students:

• Do not have to be enrolled as regular students, or have been accepted for enrollment, in an eligible program at an eligible institution

• Do not have to have a high school diploma or its recognized equivalent

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Federal Student Aid for CTP Programs

Students must maintain satisfactory academic progress as determined by the school for this program.

However, the institution has additional flexibility in creating a satisfactory academic policy that does not have to meet all of requirements in 668.34.

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Additional FISAP Reporting for CTP • Federal student aid received by students with intellectual

disabilities for CTP Programs must be included on the FISAP

• Institutions should:

• Complete the Financial Assistance for Students with Intellectual Disabilities Expenditure Report regardless of expenditures and submit by October 1, 2015,

AND

• Include, in the appropriate FISAP fields, the federal student aid received by students enrolled in approved CTP programs

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Campus-Based Programs

• For additional information about any Campus-Based program or process, contact the Campus-Based Call Center at 877-801-7168

• Customer Service representatives are available Monday through Friday from 8:00 a.m. through 8:00 p.m. (ET). You may also e-mail [email protected]

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QUESTIONS?

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Documents

Pat Stephenson and Tamy Garofano | Dec. 2014 U.S. Department of Education 2014 FSA Training Conference for Financial Aid Professionals FISAP/Campus-Based