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!


The Children of Fallen Heroes Scholarship (CFH) is a new Federal Grant (Scholarship). It was established by Congress as part of the 2018 Omnibus Spending Bill passed last march. Beginning with the 2018-2019 award year, children whose parent or guardian died in the line of duty while serving as a public service officer are eligible for maximum Pell Grants, Direct Loans and Campus-Based funds based on a zero Expected Family Contribution. Schools are responsible for determining eligibility for CFH and documenting students’ eligibility.

According to a recent electronic announcement from Federal Student Aid, to qualify for CFH, there are several conditions that a student must meet.

First, a student must be Pell-eligible. In addition to having a Valid EFC between 0 and 5486, the student must meet all other eligibility requirements (i.e. resolved all C-Codes, completed Verification, etc.). CFH is only available to students who are 24 years old and under or enrolled at an institution of higher time of his or her parent’s or guardian’s death.

To determine if a student qualifies, it is important to understand what a public safety officer is. For purposes of the Children of Fallen Heroes Scholarship, a public safety officer is defined on one of two ways. Since this is a Federal Law, a public safety officer is primarily defined by Federal Statutes but the CFH rules include in its definition of a public safety officers certain state and local fire police.

The Federal definitions are found in section 1204 of title I of the Omnibus Crime Control and Safe Streets Act of 1968 (42 U.S.C. 3796b). It includes a variety of individuals serving public agencies in various capacities such as chaplains, firefighters and law enforcement officers, including unpaid volunteers such as volunteer firefighters (who aren’t compensated) as long as they are serving in an official capacity. Law enforcement officers can also be police, corrections, probation, parole, and judicial officers. Public Service Officers may also be members of certain public or non-profit rescue squads and ambulance crews that provide rescue services or emergency medical services as part of an emergency response system. Finally, Section 1204 includes in its definition of public safety officers, FEMA employees who performed duties hazardous duties related to a major disaster or emergency.

A state or local fire police officer, is defined for CFH purposes as an individual who is a fire police officer who was serving in accordance with State or local law as an officially recognized or designated member of a legally organized public safety agency and provides scene security or directs traffic in response to any fire drill, fire call, or other fire, rescue, or police emergency, or at a planned special event.

Recent guidance from FSA notes that a single, national data source of individuals who died in the line of duty while serving as a public safety officer doesn’t exist, so school Financial Aid offices will have to make a determination of eligibility on a case by case basis in conjunction with each student. Students who meet the criteria for CFH must provide supporting documentation to the Financial Aid Office in order to determine a student’s eligibility for CHF. The Financial Aid office must gather certain supporting documentation and maintain it on file as supporting documentation along with documentation of their eligibility determination. That documentation should include evidence that the student was less than 24 years of age or enrolled at an institution of higher education at the time of his or her parent’s or guardian’s death. FSA provided some examples of acceptable documentation that may be used to determine eligibility for this scholarship:

• A determination letter acknowledging eligibility for certain federal benefits under the Public Safety Officers Benefit (PSOB) program administered by the Department of Justice;
• A written letter of attestation or determination made by a state or local government official with supervisory or other relevant oversight authority of an individual who died in the line of duty while serving as a public safety officer as defined above;
• Documentation of the student qualifying for a state tuition or other state benefit accorded to the children or other family members of a public safety officer consistent with the definition in 42 U.S.C. 3796b, or as a fire police officer as noted above; or
• Other documentation the school determines to be from a credible source that describes or reports the circumstances of the death and the occupation of the parent or guardian.
• Institutions must maintain all evidentiary documentation related to the determination of the student’s eligibility for the Children of Fallen Heroes Scholarship.

Once a student’s eligibility has been determined a student will continue to be eligible in future award years, as long as the student remains Pell eligible and continues to be enrolled.


The Consolidated Appropriations Act of 2018, which was signed into law last spring included a new federal grant program called the Children of Fallen Heroes Scholarship, or CFH for short. Although its name would lead you to believe otherwise, it’s not really a scholarship in the traditional sense and it’s not quite a grant either. The CFH Scholarship simply makes students eligible for full Pell grant awards, Direct Loans and Campus-Based funding by treating eligible students like zero EFC students.
Under CFH, a Pell-eligible student whose parent or guardian died in the line of duty while performing as a “public safety officer” is eligible to receive a maximum Pell Grant, beginning with the 2018-2019 award year. Students who qualify for CFH will also be awarded Direct Loans and Campus-Based programs based on a zero EFC. To accomplish this, Financial Aid Administrators will be required to determine and document a student’s eligibility and report information about each eligible student to Common Origination and Disbursement (COD) and Central Processing System (CPS).
COD system changes are scheduled for December 9, 2018 and will include the implementation of a new CFH indicator as part of the Pell award record which institutions will use to report eligible students. Unfortunately, eligibility information entered into the COD system will not be carried on the ISIR, nor visible in NSLDS. As a result, CPS will not recalculate a student’s EFC when an institution makes the determination that a student qualifies for a Children of Fallen Heroes Scholarship.
Additional system modification are reportedly in the works to add additional functionality to CPS which would allow schools to certify students’ eligibility on CPS. Look for more guidance from FSA next month about processing these awards.


The IPEDS Winter Data Collection for the 2018-2019 year opens on December 12, 2018. The deadline for the Winter IPEDS is February 13, 2019. The Winter Collection includes: Student Financial Aid, Graduation Rates, 200% Graduation Rates, Admissions, and Outcome Measures. To login to the 2018-2019 data collection system, please go to the following link:
All institutions that participate in the Title IV Federal Financial Assistance programs are required to complete all IPEDS surveys.



The Session Titles, Descriptions, and Agenda have been posted for this year’s Federal Student Aid Training Conference for Financial Aid Professionals.

On the FSA Conferences website, you can now access updated session titles and descriptions, as well as an agenda and updated resource center descriptions.

The FSA Training Conference will be held Nov. 27-Nov. 30, 2018

Conference sessions will be held at the Georgia World Congress Center (GWCC)

285 Andrew Young International Blvd

Atlanta, GA 30313


If your school participates in the Federal Perkins Loan Program you need to update your 2017-2018 FISAP. Beginning on October 26, 2018, all schools that participate in the Federal Perkins Loan Program must update their “Cash on hand and in depository” as of October 31, 2018. This information is reported on Part III, section A, Line 1.2 on the FISAP for 2017-18. This information must be submitted to the Department of Education by December 14, 2018.


To assist schools, FSA offers several tips:

  1. Remember to submit the updated FISAP – Simply validating and/or saving the new data entry does not result in submission to the Department. After updating and validating Line 1.2, it is imperative that schools complete the process by using the “Submit” button.
  2. Verify that changes/corrections have been received by the Department – Schools should log in to the Common Origination and Disbursement (COD) Web Site, and from the School tab, select the link for Campus-Based. Once directed to Campus-Based, select “Self-Service” then “Submission Log” to view the log and verify submission of the update.
  3. Signature not required for FISAP changes – Currently, schools are not required to re-send signature pages when changes are made to a previously submitted FISAP.


Although the Federal Perkins Loan Program ended a year ago, schools who haven’t exited the program and liquidated their Perkins Loan portfolio are still permitted to service them and must do so according to the instructions provided in an October 6, 2017, Dear Colleague Letter. As part of those instructions, schools still must meet several obligations under the Perkins Loan Program to ensure that certain administrative responsibilities and reporting requirements are met.

According to a recent reminder from Federal Student Aid (FSA), there are several important requirements schools must follow to ensure they are accurately reporting loans in the National Student Loan Data System and managing their Perkins Loan portfolio properly.

Administrative Requirements

Due Diligence
• Keep borrowers informed, of any and all changes that affect the borrowers’ rights or responsibilities;
• Respond to any and all inquiries from borrowers;
• Ensure that information available is provided to those offices (admissions, business, alumni, placement, financial aid, and registrar’s offices) responsible for billing and collecting loans (including third-party servicers), as needed to determine the—
• Enrollment status of borrower;
• Expected graduation or termination date of borrower;
• Date the borrower withdraws, is expelled, or ceases enrollment on at least a half-time basis; and
• Borrower’s current name, address, telephone number, and social security number.

Use of Contractors for Billing and Collection
Schools must ensure servicers and collection firms comply with the program rules in performing its duties as outlined by any contractual agreement with the school. Schools that contract with third-party servicers to perform billing, collection, or other program activities remain responsible for compliance with program requirements in performing these duties. This includes decisions regarding cancellation, postponement, or deferment of repayment, extension of the repayment period, other billing and collection matters, as well as the safeguarding of all funds collected by its employees and contractors.
Servicers should provide:
• Statements to the school detailing activity associated with each borrower account in the portfolio;
• Changes in the borrower’s name, address, telephone number, or the borrower’s Social Security number; and
• Amounts collected from the borrower

Collection Procedures
When borrowers do not respond to routine billing methods, more intensive collection procedures are required, potentially including litigation with the borrower.
If the school, or the firm it engages, pursues collection activity for up to 12 months and does not succeed in converting the account to regular repayment status, or the borrower does not qualify for deferment, postponement, or cancellation on the loan, the school shall –
• Litigate in accordance with the procedures in § 674.46;
• Make a second effort to collect the account as follows:
• If the school first attempted to collect the account using its own personnel, it shall refer the account to a collection firm.
•If the school first attempted to collect the account by using a collection firm, it shall either attempt to collect the account using school personnel, or place the account with a different collection firm; or
• Submit the account for assignment to the Secretary in accordance with the procedures set forth in § 674.50.

After twelve months of collection efforts, if the collection firm retained by the school is unsuccessful in placing an account into a successful repayment status, the school must require the collection firm to return the account to the institution for one of the actions described above.
If a school is unsuccessful in its efforts to place a loan in repayment after extensive collection efforts, it must continue to service the loan by making yearly attempts to collect from the borrower until the loan is:
• recovered through litigation;
• assigned to the Department; or
• written off only if the outstanding principle, accrued interest, collection costs and late charges are within the allowable thresholds as prescribed under § 674.47(h) (loans with a balance of less than $25; or loans with a balance of less than $50 if the borrower has been billed for this balance for at least 2 years).

The Department recognizes that a school may have exhausted all of its collection options on some of its defaulted Perkins Loans and strongly encourages schools to assign these loans to the Department so additional steps can be taken to recover the loan funds. The Department has collection tools that are not available to schools, such as administrative wage garnishment, Treasury offset, and litigation by the Department of Justice.
Schools should also evaluate their portfolio, assess in particular the older defaulted loans, and ensure that collection procedures under 34 CFR 674.45 (including the assignment of defaulted loans) are being followed.

Ceasing Collections
A school may cease collection activity on defaulted accounts with balances of less than $200 (including outstanding principal, accrued interest, collection costs, and late charges) if the school performed the required due diligence and the account has had no activity for four years. Although interest will continue to accrue and may put the account over $200, the school will not have to resume collection activity if it documents that it ceased collection activity when the account was under $200. The borrower is responsible for repaying the account, including any accrued interest. The account will be included in the school’s cohort default rate, if applicable, and the borrower will still be in default and ineligible for federal student aid funds. Schools are encouraged to assign these loans to the Department.

Reporting Requirements

Schools, themselves or through their third-party servicers, are required to report enrollment and loan status information on all Perkins loans to NSLDS. Please be reminded of the following:
It is the school’s responsibility to ensure that the required reporting to NSLDS, including Perkins Loan account detail, is completed timely and accurately. Schools that use a third-party servicer must communicate the reporting requirements to their third-party servicer and ensure that the servicer complies with timely and accurate reporting. It is important for schools to understand that they are responsible for any non-compliance by the servicer.
Perkins Loan reporting includes enrollment data for each loan. It is important to report the actual location where the student is attending classes in the Code for Current School (NSLDS Perkins Data Provide Instructions (DPI), Field Code #286) for each loan record in the data extract file submitted to NSLDS. This ensures that the student is placed on the correct enrollment reporting roster and eliminates misreporting when the student is not attending classes at the main location.

For purposes of Perkins Loan assignment, it is very important that borrower loan information is accurate and kept current through the assignment process and until the loan has been officially accepted for assignment to the Department and the school is notified of the acceptance.

Schools should request a reconciliation report from NSLDS to ensure the school’s records are consistent with NSLDS, reconcile any discrepancies, and update NSLDS accordingly. ED strongly encourages schools to complete this reconciliation with NSLDS at least quarterly.

Schools can order a reconciliation report from the NSLDS Professional Access website. Once logged into the NSLDS Professional Access website, select “REC005 Perkins Extract by Parameters” under the Report tab. Be sure to order two separate report requests: one report should have the desired loan status of “Open” selected and the second report should have the desired loan status of “Open-Pending Transfers Only” selected. Note: Ordering only the “Open” status loans report will not necessarily return a report with the school’s complete open loan portfolio.
Until the Department accepts a loan for assignment and is able to successfully report on the loan in NSLDS, the loan is still the responsibility of the school. The school will receive an acceptance letter when the loan is accepted for assignment by the Department. At that time, the school must report the loan to NSLDS as transferred for assignment using the “AE” Code for Loan Status (NSLDS Perkins DPI, Field Code #263) and the assignment form’s “certification date” as the Date of Loan Status (NSLDS Perkins DPI, Field Code #262).


It’s time to review your school’s TG numbers again. Mark your calendars for December 14, this year’s TG deadline.

Every year, each school must review the services associated with each of its SAIG mailboxes (i.e. Destination Points and TG numbers) and Electronic Services accounts (it’s a two-step process) and validate that each user is still active and requires access. If not, their access should be adjusted or removed as needed. This annual process has come to be known as “Active Confirmation of TG numbers”. During the review process school administrators should be sure to remove access to any services or systems that a staff member no longer needs, for example when someone changes jobs and no longer needs access. School administrators must also be sure to delete any people who are no longer employed by the school from their list.

As in previous years, the Department of Education has announced that in an ongoing effort to ensure the security of Federal Student Aid’s data systems, they are continuing a process by which every school that is enrolled in the Student Aid Internet Gateway (SAIG) must review and validate its assigned TG numbers. After conducting the review, you will be required to provide active confirmation that all your staff members with TG numbers still need that access. This review and validation must be completed by December 14, 2018. Failure to complete this process may result in the loss of access to the Federal Student Aid data systems, including your ability to access NSLDS, COD CPS and even receive ISIR data.
To properly validate any TG numbers and FAA Access accounts associated with your institution, you must follow these steps:
• Go to the SAIG Enrollment Web site ( and click the “Primary Destination Point Administrator Access” link.
• Once logged in you may “Validate Your Organization’s SAIG Mailboxes” by clicking the link and entering your institution’s Primary TG number.
• Then simply validate or delete the services you want associated with your TG.
• Then repeat this for each remaining TG number.
• Once all of the TG numbers have been removed from the list you’re done. Simple.
• The process for confirming or removing old users is easy too.
• To validate or delete electronic service users, click the “Manage Electronic Services” link and enter the TG number that is currently enrolled to send and receive CPS batch services for your organization.
• Next select “Validate Existing Users” to get a list of employees at your institution who are enrolled for FAA online access.
• Click either Validate or Delete. *Remember, you should delete old users’ access.
For more information check out the latest Electronic Announcement from Federal Student Aid here.


According to a recent announcement from Federal Student Aid (FSA), some FAFSA applicants who attempted to file a correction to their 2018-2019 FAFSA received 2017 tax year data instead of the correct 2016 tax year data. It appears that this glitch affected only a small number of applicants, particularly those who made a correction to their 2018-2019 FAFSA between September 30, 2018, and October 4, 2018, and used the IRS Data Retrieval Tool to transfer their tax information from the IRS to the FAFSA. FSA identified the issue and resolved the problem with the IRS Data Retrieval Tool on October 4th, 2018, so it shouldn’t happen again.


On October 26, 2018, the Central Processing System reprocessed the ISIRs of affected applicants and voided the bad transactions – but they did NOT correct the tax information so ISIR corrections still need to be made. Instead, emails are being sent to affected applicants alerting them to the problem and informing them to go online and make another ISIR correction by transferring the correct 2016 IRS tax information to the FAFSA using the DRT. This issue reportedly impacted a very small number of applicants, but it is important to note that the reprocessed transactions are intended solely to alert impacted applicants and institutions that action is required; the CPS reprocessing did not modify the financial information transferred from the IRS.

Several methods exist for schools to identify records resulting from the October 26 reprocessing:
Reprocessed Institutional Student Information Records (ISIRs) will be sent under the IGSG19OP message class.
SARs and ISIRs will include SAR comment code 172, which states “This SAR was produced because we processed a change to your information based on information reported to us by another agency or because of a processing system change. Review your SAR to see what effect, if any, this change has had on your application, and call 1-800-4-FED-AID (1-800-433-3243) if you have any questions.”

ISIRs produced because of the reprocessing will include a value of “04” for the Reprocessed Reason Code (ISIR field #248).

The FAA Information page in Student Inquiry on the FAA Access to CPS Online Web site will display “04 – Reprocessed for wrong tax year transferred from IRS DRT” for the Reprocessing Code for the transaction resulting from the reprocessing. The Reprocessing Reason Code 04 description will not display in FAA Access to CPS Online until after FSA implements updates to the site in a future release.


Some of the ideas put forth for Reauthorization of the HEA, include eliminating the drug-related eligibility questions on the FAFSA. Presently, students who report on their FAFSA that they were convicted of possessing or selling illegal drugs must complete the Student Aid Eligibility Worksheet for Question 23 to determine if they are eligible for Federal Student Aid. The 2019-2020 Student Aid Eligibility Worksheet for FAFSA Question 23 can be found here.