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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!


Higher Ed Executives Financial Aid Consultants


One of the functions of the U.S. Department of Education is to oversee the Federal Student Aid programs to ensure they are administered correctly and that institutions are meeting the FSA requirements for institutional eligibility, financial responsibility, and administrative capability.

School Participation Divisions review information about each title iv approved school from a variety of sources including accrediting agencies, state licensing boards and agencies, student complaints and of course, financial and compliance audits.

This information is evaluated by ED and FSA to assess potential risk to the FSA programs and if necessary, act to investigate a school. One of the ways ED does this is by conducting program reviews at schools that exhibit certain indications of problems or pose a potentially significant risk of failing to comply with the rules and regulations governing title iv participation.

Knowing what to watch out for can help you avoid compliance problems.

These findings represent data ED reported based on findings from Program Review audits and compliance examinations reports conducted by FSA and published in the last twelve months for fiscal year 2018.

  1. NSLDS Roster Reporting – Inaccurate/Untimely Reporting
  2. Crime Awareness Requirements Not Met
  3. Return of Title IV (R2T4) Calculation Errors
  4. Drug Abuse Prevention Requirements Not Met
  5. Student Credit Balance Deficiencies
  6. Consumer Information Requirements Not Met
  7. Verification Violations
  8. Entrance/Exit Counseling Deficiencies
  9. Inaccurate Recordkeeping
  10. Satisfactory Academic Progress Policy Not Adequately Developed/Monitored

Findings like these are preventable.

Higher Ed Executives provides colleges and universities with objective and confidential assessments that can help you uncover unknown compliance problems and improve title iv administrative and operational procedures and processes.

Our comprehensive assessments cover the full spectrum of FSA requirements for institutional eligibility, financial responsibility, and administrative capability.

Call us today for a free no obligation consultation and to find out how our assessments can work for you.

Call 203-836-4806



Federal student Aid just released guidance allowing schools and college financial aid administrators to accept a signed copy of a 2016 or 2017 income tax return in lieu of tax transcript for the 2018-2019 and 2019-2020 award years as applicable. The announcement provides immediate relief to students beleaguered with problems obtaining the official IRS tax return transcript as has been required until now.

Students and parents who did not file and were not required to file a tax return are still required to provide verification of nonfiling from the IRS, but under the new guidance if the individual is unable to obtain verification of nonfiling from the IRS or other tax authorities and, based upon the institution’s determination, it has no reason to question the student’s or family’s good-faith effort to obtain the required documentation the institution may accept:

  • A signed statement certifying that the individual
    • Attempted to obtain the verification of nonfiling from the IRS or other tax authorities and was unable to obtain the required documentation; and
    • Has not filed and is not required to file a 2016 or 2017 income tax return, and a listing of the sources of any 2016 or 2017 income earned by the individual from work and the amount of income from each source; and
  • A copy of IRS Form W–2, or an equivalent document, for each source of 2016 or 2017 employment income received by the individual.

FSA also released an announcement informing the Financial Aid community that the Central Processing System will be 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. “

When the shutdown is over, CPS will reprocess ISIR records for impacted students. You can read all about it here in this electronic announcement from FSA.



Higher Ed Executives Financial Aid Consultants Can help you gain compliance with title iv cash management regulations

FSA recently released an electronic announcement reminding institutions of the requirements for proper cash management compliance. Disbursing aid timely, resolving excess cash and reconciliation are necessary procedures and controls to ensure compliance with the federal regulations. Noncompliance in these areas often results in institutions being placed on the Heightened Cash Monitoring disbursement method and often with a requirement that the school post an irrevocable Letter of Credit equal to a percentage of title iv funds that have been drawn down in prior years. It’s not pretty. The simplest thing to do to avoid this is to have a handle on some cash management basics.

Three Steps to Cash Management Compliance:

1. Submit disbursement records timely.

All disbursement records should be sent to COD within 15 days after making the disbursement or becoming aware of the need to adjust a student’s previously reported disbursement.

2. Keep an eye out for excess cash and if necessary, return any undisbursed funds to the Department.

Excess Cash is any amount of title iv funds (excluding Perkins) that the school does not disburse to students or parents by the end of the third business day after the date the school received funds from the department. Excess cash can also occur when a school deposits previously disbursed funds into their federal bank account and lets it sit for more than three days before disbursing it to another student or returning it to the Department.

3. Reconcile regularly.

If you are reconciling all title iv disbursements on at least a monthly basis, you’ll be in a good position to ensure that you are meeting the disbursement reporting and excess cash deadlines. Regularly reconciling both internally between business office and financial aid office data as well as externally between financial aid office data and the Department’s COD and G5 systems will make final reconciliation and program year closeouts a snap. Plus, your auditors will be very happy to see the proof of your regular efforts.


If you’ve done everything right in the fall, disbursing for Spring Semester is as easy as a push of a button. Is it ever that easy though? Yeah right.
January 2019 will begin the COD system’s “Peak Processing Period” for the 2018-2019 Award Year. During this time origination and disbursement batch processing may take up to 24 hours. Mondays and Tuesdays are busiest processing days at COD and they recommend that schools with the ability to schedule their batch submissions later in the week do so. Everything else is expected to run according to schedule according to a recent electronic announcement which says that if processing takes longer than 24 hours, COD’s School Relations Center will contact any affected schools on the next business day. Happy Processing!


New and updated reference materials have been released by Federal Student Aid following recent enhancements to the for the National Student Loan Data System and NSLDS Processional Access website. There are several new reports and updated file layouts that you’ll need to be familiar with so we’ve broken them down for you below.
On October 31, new NSLDS Transfer Student Monitoring/Financial Aid History Batch File Layouts were released.
NSLDS combines the Transfer Student Monitoring (TSM) and Financial Aid History (FAH) batch processes into one input format file and one output format file. Beginning on December 23, 2018 NSLDS will begin using the updated file format which combines the TSM and FAH files into one. According to NSLDS, requests will need to be in the correct file formats and submitted as an input file through the Student Aid Internet Gateway (SAIG) message class, TRNINFIN. After NSLDS verifies that the data requests are in the proper file formats, an output processed file will be sent back to the end user. Depending on the data type requested, the output file will be returned through the SAIG in the TRLTRPOP, TRALRTOP, FAHREPOP, or FAHEXTOP message classes. Because of 2018-2019 processing changes, updates were made to the Transfer Student Monitoring/Financial Aid History batch file record layouts’ field content. The file layout sections include an Add/Modify column annotating specific changes. Be sure to update your systems accordingly.
As explained in NSLDS Newsletter 61,enhancements were recently made to NSLDS to help schools manage aid overpayments that have been reported to the NSLDS website. The new Aid Overpayment Compliance Report was developed to assist schools identify unresolved overpayments that have exceeded the maximum timeframe for resolution. The report will allow schools the ability to research which overpayment records should be updated or deleted on NSLDS and which need to be referred to the Department of Education for collection.
The Aid Overpayment Compliance Report provides school users with a list of overpayments that are assigned to the requested school and either need to be updated on the National Student Loan Data System for Financial Aid Professionals (NSLDSFAP) website or need to be assigned to the Department of Education (ED).
The Aid Overpayment Compliance Report can be requested on demand through the Report List on the Report Tab of the NSLDSFAP website or can be scheduled for a quarterly or monthly distribution.  The scheduled report is delivered via the Student Aid Internet Gateway (SAIG).
NSLDS announced plans to begin sending quarterly Aid Overpayment Email Notifications to schools with reported aid overpayments that need to be updated.
NSLDS also announced the availability of a new report called the Enrollment Reporting No Certified Programs Report (SCHEP1). It provides school users with an extract of students that have appeared on the school’s Enrollment Reporting Roster without a certified program within a specified timeframe for a six-digit School Code or eight-digit School Location Code. The ER No Certified Programs Report includes the current campus-level enrollment information for the student.  Using the Certification Date Begin field, the user chooses a date to limit output to students that have a reported certification on or after the date entered through the date the report is requested. Additionally, the report can be limited to a Social Security Number (SSN) and Last Name range. The report can be sorted by Student SSN only, or by School first, then Student SSN. The report is sent to the SAIG mailbox associated with the NSLDS User ID requesting the report.
NSLDS also announced the release of updated Record Layouts for the NSLDS School Portfolio Report (SCHPR1) in both CSV and Fixed-Width formats. The School Portfolio Report provides school users with information about all William D. Ford Federal Direct Loan (Direct Loan) and/or Federal Family Education Loan (FFEL) program loans. The report output includes both consolidation loans and their underlying loans. Additionally, the report contains other useful loan information such as loan amount, current outstanding principal balance, current outstanding interest balance, delinquency date, discharge and rehabilitation/repurchased and repayment plan information.
The School Portfolio Report (SCHPR1) can be requested ad hoc through the list of school reports on the Report tab of the NSLDS Professional Access Web site or as a scheduled report from the School Profile section on the Org tab of the NSLDS Professional Access Web site.  The report is delivered via the Student Aid Internet Gateway (SAIG).


The NSLDS Enrollment Reporting Guide has been updated again. The November 2018 update includes a new section on the Maximum Eligibility Timeline that was implemented earlier this year to assist schools in managing their reporting responsibilities under the 150% SULA rules. NSLDS Newsletters 58, 59 and 60 have been added, as have the April 20 and 21, 2017 Electronic Announcements related to summer enrollment, submission dates, effective dates, certification dates and compliance notifications.
Enrollment Reporting is required for all schools participating in Title IV aid. The collection of enrollment data is essential to the Department. It protects the rights of borrowers by ensuring that loan interest subsidies are based on accurate enrollment data. It ensures loan repayment dates are accurately based on a student’s last date of attendance. It allows in-school deferments to be automatically granted to students using NSLDS enrollment data. It provides vast amounts of critical data about the effectiveness of Title IV aid programs, including completion data.
You can get the November 2018 NSLDS Enrollment Reporting Guide on the Information for Financial Aid Professionals website.


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.