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A financial aid consultant can help your college identify risks and prevent program review findings

What are the most frequently reported program review findings according to ED?

ED recently released an updated program review guide packed with lot’s of great info to help schools and colleges understand the in’s and out’s of a program review. The new guide covers everything from general program review processes to procedures and guidelines for following up. According to the guide, these are the most frequently cited program review findings. 

These are the top ten most frequently cited program review findings at colleges and universities.

  • Crime Awareness Requirements Not Met
  • Verification Violations
  • Return to Title IV Calculation Errors
  • Student Credit Balance Deficiencies
  • Drug Abuse Prevention Requirements Not Met
  • Student Status – Inaccurate/Untimely Reporting
  • Entrance/Exit Counseling Deficiencies
  • Consumer Information Requirements Not Met
  • SAP Policy Not Adequately Developed and/or Monitored
  • Inaccurate Record keeping

How does your institution assess it’s risk and preparedness for audits and program reviews?

To learn more about how your institution can adjust its processes and reporting to minimize its risk of these federal student aid compliance issues, please contact us.

Get your 2018-2019 IRS Tax Return Transcript Matrix for ISIR Verification here!


Colleges aren’t the only ones with questions about the Higher Education Emergency Relief Fund, students have questions too. Last month, ED released a (very) brief Frequently Asked Questions (FAQ) with questions from students about Emergency Relief Student Grants.

  1. Do I have to repay the emergency financial aid grant I received from my university through the CARES Act?

No.  The funds provided by the CARES Act are grants, so they do not need to be repaid.

  1. I am a student who received an emergency financial aid grant from my university through the CARES Act. Is this grant includible in my gross income?

No. According to the Internal Revenue Service, “Emergency financial aid grants under the CARES Act for unexpected expenses, unmet financial need, or expenses related to the disruption of campus operations on account of the COVID-19 pandemic, such as unexpected expenses for food, housing, course materials, technology, health care, or childcare, are qualified disaster relief payments under section 139.”   For more information please visit:

  1. What can emergency financial aid grants provided by the CARES Act be used for?

Emergency financial aid grants to students can be used for expenses related to the disruption of campus operations due to coronavirus (including eligible expenses under a student’s cost of attendance, such as food, housing, course materials, technology, health care, and child care). Please click here for more information about what is included in a student’s cost of attendance. 



In an update to the OCOVID-19 Title IV Frequently Asked Questions page on the Department’s Office of Postsecondary Education website, ED provided three new FAQs related to Student Eligibility and the effect of Pass/Fail grades on Satisfactory Academic Progress and Recordkeeping and Data Security elated to telework.

  1. How do courses graded as “Pass/Fail” affect Satisfactory Academic Progress (SAP)?

Students may be permitted to take some or all classes on a pass/fail basis. It is also permissible for an institution to administratively determine that all coursework in a term will be evaluated on a pass/fail basis. An institution may modify its policies restricting the number of courses students may take on a pass/fail basis to accommodate the national emergency due to the coronavirus. Where an institution has no existing policy allowing pass/fail grades, it may adopt one, even if only temporarily. Courses taken on a pass/fail basis count as attempts for SAP purposes. Generally, pass/fail grades are not factored into a student’s GPA. However, an institution may follow its own policy with respect to the effect of pass/fail grades on GPA. (Published May 14, 2020)

  1. How can an institution resolve a C Code for Selective Service registration if the Selective Service System (SSS) is unable to provide Status Information Letters during this national emergency?

We are aware that requests for a Status Information Letter from the SSS are not currently being considered. Therefore, to resolve a Selective Service C code for applicants who do not pass the database match, we recommend that applicants use the online system at to register or to verify prior registration. A financial aid administrator (FAA) may perform this task if he or she chooses or if the applicant cannot complete this task.

If the online process does not confirm the applicant’s registration, the FAA has the authority to determine whether the applicant knowingly and willfully failed to register as required by Section 462(f) of the Military Selective Service Act. An FAA may consider special circumstances that may have prevented registration, and if the FAA determines the student – for example – did not knowingly and willfully fail to register for the selective service, the student may meet this eligibility requirement. The FAA should follow the process outlined in Volume 1 of the 2019-2020 Federal Student Aid Handbook and may do so in lieu of using the status information letter. (Published May 14, 2020)

Recordkeeping and Data Security

  1. Is the Department providing any flexibilities during this national emergency for record retention and data security requirements given the rapid change to telework for many institutional employees.

The Department cannot exempt an institution from record retention or data security requirements.  An institution must use its judgment to determine whether it can securely use email or other electronic methods to exchange information with applicants and students.  For example, an institution may determine that during the COVID-19 national emergency, they will accept documents (as permitted by the Office of Postsecondary Education’s Updated Guidance for interruptions of study related to Coronavirus (COVID-19), posted April 3, 2020) by photograph via smartphone or as a scanned document, as opposed to notarized or certified paper copies of documents that may be required under normal circumstances.  In such instances, the institution must continue to properly preserve those documents for their records, which may include preserving text messages for the formal record or requiring students to provide hard copies, notarized copies or official copies of documents through the institution’s normal process when normal campus operations resume.  We are providing flexibility to institutions regarding how they can collect documents during the national emergency, but institutions are still required to maintain the requisite documents in their records during and after the national emergency. (Published May 14, 2020)


Last month ED published new Final Rules for addressing sexual harassment, assault, and other forms of sex discrimination on college campuses. Among other changes, the new rules bring due process to campus for investigating and adjudicating cases.
Colleges will have to comply with the new rules by August 14, 2020 and that means, it’s time to update your campus crime and security policies and procedures as they relate to Title IX sexual harassment. Additionally, it is important to note – the Final Rules taking effect in August require institutions to post contact information for their designated Title IX coordinator on their website and in a number of other school publications such as school catalogs, handbooks, and employee publications along with information about how to report sexual harassment and file a formal complaint. The U.S. Department of Education and the Office of Civil Rights (OCR) released the following guidance to assist schools in understanding their obligations and making policy and procedural changes.
U.S. Department of Education Releases Final Title IX Rule
Title IX: Fact Sheet: Final Title IX Regulations
Title IX: U.S. Department of Education Title IX Final Rule Overview
Title IX: Summary of Major Provisions of the Department of Education’s Title IX Final Rule
Title IX: Summary of Major Provisions of the Department of Education’s Title IX Final Rule and Comparison to the NPRM
The New Title Ix Rule: Excluding Reliance On A Party’s “Statements” When The Sexual Harassment At Issue Consists Of Verbal Conduct
OCR Webinar: Title IX Regulations Addressing Sexual Harassment



The closeout deadline for the 2018-2019 Direct Loan Program Year is Friday, July 31, 2020. This is the last processing day before the end of the program year. According to a recent reminder from Federal Student Aid, all school data must be received and accepted by this date to be included in a school’s final Ending Cash Balance for the year.

There are several basic steps that a school must undertake to successfully close out their Direct Loan program at the end of each award year.

First, schools should be sure to reconcile to an Ending Cash Balance of $0 and Total Net Unbooked Disbursements of $0, as reflected on your monthly School Account Statement (SAS) Report and in your school’s internal records. Once everything is in harmony and you have no more disbursements or returns to process, complete the School Balance Confirmation form on the Common Origination and Disbursement (COD) Web Site.

The Balance Confirmation form can be completed after the school has reconciled to a $0 balance both internally and externally. Once the school has completed their final reconciliation, the school should log in to the COD Web Site. From the School options menu click on the Balance Confirmation link on the left-hand side of the page and follow the instructions on the School Balance Confirmation screen.

To meet the closeout deadline, all records must be submitted to the COD System no later than 8:00 p.m. Eastern time (ET) on Friday, July 31, 2020 . After this deadline, Direct Loan records will not be accepted by the COD System and schools will no longer have Direct Loan funds available to draw down for the 2018-2019 Award Year. In other words, the Department of Education (the Department) will reduce the school’s Current Funding Level (CFL) to the greater of Net Drawdowns or Net Accepted & Posted Disbursements.

For more information check out the electronic announcement from FSA.


ED just released guidance for institutions to report how they are using CARES Act Emergency Grants distributed to students under the HEERF. Schools must submit an initial report to ED within 30 days of the institution’s Certification and Agreement and 45 days thereafter. Instructions on the reporting process will be forthcoming in addition to other announcements.
In the meantime, the Department is instructing institutions to post information publicly on their school’s website. To be in compliance schools must post the following information on their website within 30 days after the date when the institution received its allocation of Emergency Grants for students under 18004(a), and update it every 45 days thereafter until such time as the Department provides other guidance.

1. An acknowledgment that the institution signed and returned to the Department the Certification and Agreement and the assurance that the institution has used, or intends to use, no less than 50 percent of the funds received under Section 18004(a)(1) of the CARES Act to provide Emergency Financial Aid Grants to students.

2. The total amount of funds that the institution will receive or has received from the Department pursuant to the institution’s Certification and Agreement [for] Emergency Financial Aid Grants to Students.

3. The total amount of Emergency Financial Aid Grants distributed to students under Section 18004(a)(1) of the CARES Act as of the date of submission (i.e., as of the 30-day Report and every 45 days thereafter).

4. The estimated total number of students at the institution eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 and thus eligible to receive Emergency Financial Aid Grants to students under Section 18004(a)(1) of the CARES Act.

5. The total number of students who have received an Emergency Financial Aid Grant to students under Section 18004(a)(1) of the CARES Act.

6. The method(s) used by the institution to determine which students receive Emergency Financial Aid Grants and how much they would receive under Section 18004(a)(1) of the CARES Act.

7. Any instructions, directions, or guidance provided by the institution to students concerning the Emergency Financial Aid Grants.

ED’s Office of Postsecondary Education noted in their recent announcement that institutions must be sure to protect the confidentiality of student data such as student Personally Identifiable Information (PII), adhere with FERPA requirements and use appropriate data suppression methods to do so. Read the May 6, 2020 announcement for more details.