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!


In January, the U.S. Department of Education’ s (ED) Office of Postsecondary Education (OPE) released a new beta-version of the 2019-2020 Financial Aid Shopping Sheet that was first introduced in 2012. According to the OPE announcement, the Financial Aid Shopping Sheet was redubbed the “College Financing Plan” to “more accurately reflect that loans may be a significant part of the student’s investment, and to emphasize to students that they are making a financial transaction when enrolling in an institution.” Although the beta-version of the College Financing Plan looks very similar to the Financial Aid Shopping Sheet institutions have been using, some data elements have changed, some have been expanded and some section headings have been restructured to better illustrate a rather simple formula its predecessor didn’t do so well; Total Cost of Attendance – Grants and Scholarships = Net Cost.
For the 2019-2020 award year, schools may continue using the current FA shopping sheet if they wish to do so, however ED is asking schools to voluntarily adopt the College Financing Plan. Schools that plan to begin using the new sheet for the 2019-2020 award year or wish to provide feedback should contact ED by April 1, 2019.
Schools that signed the Memorandum of Understanding (MOU) to comply with the Principles of Excellence (POE) in Executive Order 13607 will be required to begin using the new format for the 2020-2021 award year once it is released however ED has not provided clarification as to when, and whether or not schools currently using the FA Shopping sheet need to adopt the College Financing Plan.


In the final days of the 115th Congress, legislators passed the Veterans Benefits and Transition Act of 2018. The new law which was signed by President Trump contains several provisions to assist and protect student veterans. Under the new law, institutions that accept GI Bill benefits could face losing participation in Veteran’s educational benefits for programs if an institution prevents a veteran student from attending or participating in their courses because of delays in Chapter 31 or 33 benefits.
If a student veteran provides certification of eligibility to the school, it can’t impose any penalties on the student including the assessment of late fees, the denial of access to classes, libraries, or other institutional facilities, or the requirement that a covered individual borrow additional funds. State approving agencies which grant approval to programs at institutions of higher education may terminate a program’s approval if an institution violates these provisions.
Additionally, the law requires the Veterans Affairs to provide timely payment of VE Educational Benefits. Under the “Prompt Payments” provisions, the Secretary of Veterans Affairs must ensure that payment is made to institutions on behalf of eligible students within 60 days after the institution certifies a student’s eligibility.
The Forever GI Bill Housing Payment Fulfillment Act of 2018 was also signed into law at the end of 2018. The law addressed problems with the Harry W. Colmery Veterans Educational Assistance Act of 2017, also known as the Forever GI Bill. Under the Forever GI Bill, monthly housing stipends were supposed to be based on the location of the campus of the institution where a veteran student attends classes, a change from the previous direction that the calculation was to be based on the location of the institution, but outdated information technology systems at the Veteran’s Administration “stymied efforts to update necessary information that enable proper housing payments, resulting in a months long backlog. The Forever GI Bill Housing Payment Fulfillment Act of 2018 the VA is expected to begin reimbursing student veterans who did not receive their full housing benefits.



The 2019-2020 Federal Pell Grant Payment and Disbursement Schedules are here. On September 28, 2018, the President signed the 2019 HELP appropriations act, Public Law (P.L.) 115-245 which included an increase to the maximum Pell Grant award. For the 2019-2020 award year, the maximum Pell Grant award is $6195.00 for students with a zero EFC. The minimum Pell Grant award also increased to $650.00 for students with an expected family contribution (EFC) of 5576.
Although $6195.00 is the maximum Pell Grant scheduled award for the 2019-2020 award year, beginning with the 2017-2018 award year, a student may be eligible to receive Pell Grant funds for up to 150 percent of the student’s Pell Grant scheduled award for an award year. To be eligible for the additional Pell Grant funds, the student must be otherwise eligible to receive Pell Grant funds for the payment period and must be enrolled at least as a half-time student, as defined in 34 CFR 668.2(b), in the payment period(s) for which the student receives the additional Pell Grant funds in excess of 100 percent of the student’s Pell Grant scheduled award. For additional information see Dear Colleague Letter GEN-19-01.


The Office of Management and Budget recently released an updated Perkins Loan Assignment Form. Schools that wish to assign Perkins Loans to the Department must begin using the new form by June 30, 2019 unless they complete assignments electronically via the Perkins Loan Assignment System online. The revised form replaces the one that recently expired on December 31, 2018. The new Expiration Date is December 31, 2021 and the form itself has a few other minor changes. According to the electronic announcement from Federal Student Aid, the Date of First Disbursement was moved from the required manifest portion (Section C) of the Institutional Certification page to the historical loan information portion (Section C) of the Borrower and Loan Information page. As a result, some of the data fields on the Borrower and Loan Information page have been shifted and renumbered. The Date of First Disbursement is the new field 20, followed by the Date of Last Disbursement as new field 21, and so on.
This change places the historical loan information together and should help ensure schools and third-party servicers provide all required data on the form.
With the change in field numbers, we also made corresponding updates to the Perkins. The revised form and the instructions have been posted to the Campus-Based Processing Information Page on the IFAP Website.


Last month, FSA released an announcement informing the Financial Aid community that the Central Processing System was skipping the database match with Selective Service System during the government shutdown.
According to the electronic announcement FSA states that “during this match bypass, Student Aid Reports (SARs) and Institutional Student Information Records (ISIRs) will display Comment Code 390: “We were unable to verify your eligibility for federal student aid with one or more other federal agencies through computer matching programs. Your school will contact you if additional information is needed.”  The CPS will assign a blank value to the Selective Service Match Flag on SARs and ISIRs unless the corrected transaction already has a valid SSS match flag value that the CPS can pull forward to the new transaction.
You can read all about it here in this electronic announcement from FSA.
Now that the shutdown is over, CPS will reprocess ISIR records for impacted students. In an announcement posted on January 31, 2019 FSA announced that CPS will begin reprocessing over 600, 000 ISIR records. Given immense volume of records requiring correction, CPS will only reprocess up to 50,000 record per day. At that rate it will take at least until February 12, 2019 for CPS to get caught up.


Federal Student Aid will be contacting TEACH Grant recipients whose TEACH Grants were converted into Direct Unsubsidized Loans to redetermine if they met or are meeting the TEACH Grant Service Requirements, but had their grants converted into loans because they did not comply with the annual certification requirements. According to an announcement from FSA, individuals may qualify to have their loans converted back to TEACH Grants if they can demonstrate that they completed at least four years of qualifying teaching or are expecting to or are in the process of doing so.


The Department of Education is asking schools with Perkins Loans that were awarded or disbursed to students after the expiration of the Perkins Loan Program to review all its Perkins Loan data on NSLDS. The ask follows an announcement last month that ED has identified many Perkins Loans on NSLDS with errors. The most common errors are loan dates reported after 9/30/16 for graduate borrowers, 9/30/17 for undergraduate borrowers and loans with a disbursement date after 6/30/18 for all borrowers.

According to ED, the issue typically occurs when a school or its third-party servicer reports updated batch information that overwrites the information that was previously reported to NSLDS correctly. Schools using third party servicers can work directly with their servicer to resolve any errors. Schools can request a Perkins Loan Reconciliation Report (REC005) from NSLDS which will help ensure that all Perkins Loan information is reported accurately.

If your school awarded a loan or disbursement in error, your school must reimburse the Perkins Loan Revolving Fund for the amount of the loans, correct the FISAP, notify the borrower, and update NSLDS accordingly.


Borrowers with questions about qualifying for Public Service Loan Forgiveness have a new tool to help them understand their options and how to qualify to have their loans forgiven. Now, when a student calls with questions, you can direct them to the website at Borrowers will be able to:

  • assess whether their employer qualifies for PSLF;
  • assess whether their loans qualify for PSLF;
  • decide which PSLF form to submit; and
  • learn about other actions borrowers should or must take if they want to receive PSLF.

For more information and PSLF resources, check out this electronic announcement from FSA.


Last month the Department of Education was ordered to begin granting closed school discharges for borrowers affected by the closure of their institution. The Department reported that they’ve identified more than 15,000 borrowers who are eligible to have their loans automatically discharged and they’ve begun emailing notifications to borrowers. Most discharges will be completed within 90 days.

Since the 2016 borrower defense to repayment regulations are now in effect, there are new conditions for schools when they close. According to a recent electronic announcement schools must provide all enrolled students with a closed school discharge application and a written disclosure, describing the benefits and consequences of a closed school discharge as an alternative to completing their educational program through a teach-out agreement, immediately upon submitting a teach-out plan after the occurrence of any of the following events:

  • The Department initiates a limitation, suspension, or termination of the participation of a school in any Title IV, HEA program under 34 CFR 600.41 or subpart G of 34 CFR Part 668 or initiates an emergency action under 34 CFR 668.83;
  • The school’s accrediting agency acts to withdraw, terminate, or suspend the accreditation or preaccreditation of the school;
  • The school’s State licensing or authorizing agency revokes the school’s license or legal authorization to provide an educational program;
  • The school intends to close a location that provides 100 percent of at least one program; or
  • The school otherwise intends to cease operations.


Federal Student Aid just announced that the Department of Homeland Security’s SAVE system instructions for school users have been released. Version 2.0 of the instruction guide replaces version 1.0 which was released in May 2018 and includes updates and changes through September 4, 2018.

According to the recent electronic announcement from FSA, Version 2.0 addresses system processes and procedures for:

  • How to resolve a “No cases found” error message;
  • What action is necessary for each of the five SAVE response messages;
  • How to proceed if a SAVE response is not received within 15 business days of submission;
  • How and when to resolve a “closed case” and request a new DHS verification number;
  • How to check the Institutional Student Information Record (ISIR) DHS Match Flags for a confirmed eligible noncitizen status after FSA’s Application Processing Division has resent a DHS verification number to SAVE;
  • How to enter “Cuban/Haitian Entrant review requested” in the SAVE “Special comments” box;
  • How to determine whether unusual immigration statuses are eligible for Title IV Aid, and;
  • How to find help for SAVE system issues.