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Wood Mason

U.S. Department of Education

Managing Title IV Funds:

Follow the Money

Agenda (mileposts on our journey)

• Guides/resources

• G5

• Annual Funding

• Drawing Funds

• Refunding Funds

• Adjusting Funds

• Completing Annual Reconciliation

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Guides/Resources

• Blue Book • http://ifap.ed.gov/ifap/BlueBook.jsp

• FSA Handbook - Volume IV • http://ifap.ed.gov/fsahandbook/1415FSAHbkVol4.html

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Guides/Resources

• G5 Help Desk • Phone: 888-336-8930 / 8:00 a.m. - 6:00 p.m. (ET)

E-mail: edcaps.user@ed.gov

• eCampus Based Help Desk • Phone: 877-801-7168 /8:00 a.m. - 8:00 p.m. (ET)

• E-mail: CBFOB@ed.gov

• COD Help Desk / 8:00 a.m. - 8:00 p.m. (ET)

• Grant Programs: 800-474-7268/ Direct Loan Program: 800-848-0978

• Foreign Schools: 571-392-3737

• E-mail:CODSupport@ed.gov

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Follow the Money

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Payment Data

Disbursement Records / FISAP

Payment

COD eCB

G5

www.g5.gov

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G5

• To access G5

• Your school must have a DUNS number

• The Data Universal Numbering System (or D-U-N-S Number) is a

unique nine-digit identification code that is assigned to a school. G5

grantees and payees must register their D-U-N-S number and TIN

with the System for Award Management (SAM)

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G5, continued

• Establish a user ID

• Each user establishes their own access

• Click on “Not Registered?” Sign up

• Read only available for FAAs

• Establish a bank account for deposit of funds

• May be one or multiple federal funds bank accounts

• If one bank account must be able to identify different types of Title IV funds

• Maintaining and accounting for Funds 34 CFR 668.163

• Blue Book, Volume 5 page 22

• Designate a bank account for the return of funds

• May be the same as the one used for deposit of funds

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G5, continued

• Funds transmitted to school’s bank account

• ACH

• Direct Deposit Sign Up Form (SF1199a)

• Request prior to 3 p.m. (ET) deposited next business day

• FEDWIRE

• A Bank fee may be charged

• Requests prior to 2 p.m. (ET) deposited same day

• Instructions can be found on G5 website under FAQ’s/banking

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G5 Award Numbers • G5 award numbers are school, program, and award year

specific

• Example for 2014-15 award year

• Funds are drawn or returned by program and year

• #### represents each school’s unique G5 (gaps) ID

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Program G5 Award Number Award Year

Direct Loan P268K15#### Trailing Year

TEACH Grant P379T15#### Trailing Year

Pell Grant P063P14#### Leading Year

IASG P408A14#### Leading Year

Campus-Based FWS: P033A14####

SEOG: P007A14####

Leading Year

Title IV Processing Systems

• COD (Common Origination & Disbursement)

Direct Loans

TEACH Grants

Pell Grants

IASG (Iraq Afghanistan Service Grants)

• eCB (electronic Campus Based)

SEOG (Supplemental Economic Opportunity Grants)

FWS (Federal Work-Study)

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Pell, CB, and IASG Annual Funding

• Each award year a new current funding level (CFL) or

authorization is established

• Campus-Based funding is based on data reported on the

FISAP

• Tentative allocations published January

• Final notice of allocations published April

• PELL and TEACH funding is initiated by the reporting of

accepted actual disbursements

• Records first- i.e., submit the records and the funds will be available to

draw in G5 either later that day or the following day

• Iraq Afghanistan Service Grant (IASG) funding case by case

manual increase based on anticipated disbursements

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Pell Grant Admin Cost Allowance

• Three times during an award year cycle

For 2014-15:

March 2015

August 2015

August 2016

• NO DRAWDOWNS

• Payments sent directly to bank accounts by G5 for ACA

only

Direct Loan Annual Funding

• Advance Funding

o Initial authorization - Spring

o Subsequent increase late November and additionally as

needed

• Foreign Schools/HCM1

o No initial authorization

o Records First - Accepted actual disbursements increase

funding

• HCM2/Reimbursement

o Records First - Funds requested by FSA

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DL Advance Funded

• Initial CFL is approximately 60-65% of the amount of the

disbursement records on file from the previous year

• Increase in mid-year

• Need additional funds?

o Send in actual disbursements up to seven days in advance

o Call COD Customer Service to request an increase (must not have

any unsubstantiated funds)

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Annual DL Funding Approaches Draw Funds

from G5

Draw Funds

from G5

Draw Funds

from G5

School Disburse

Funds

School Disburse

Funds

School Disburse

Funds

COD Report Disbs

COD Report Disbs

COD Report Disbs

3 Business Days 15 Days

15 Days

3 Business Days

Advanced funding approach

Records First – self reimbursing approach Many schools choose this method to facilitate reconciliation

Records First – future-dated disbursement approach

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DL Funding Information

• Funding can be at the location level

• A main campus can fund for itself and its additional

locations but a location cannot fund for other locations

• Example: Gcode or Ecode

• Award in G5 is specific to the Direct Loan school code

that originated the loan

• If both a main campus (Gcode) and additional location (Ecode) are

originating their own loans, then each will have their own award in

G5 identified by a unique 4-digit G5 (gaps) ID at the end of the

award ID

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COD Daily Funding Process

Disbursement Records drive

Current Funding Level (CFL)

DAILY DEADLINES

10:00 a.m. ET in COD – Same day in G5

10:00 p.m. ET in COD – Next day in G5

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Fiduciary Responsibility

• Schools have a responsibility to:

o Safeguard FSA funds

o Ensure FSA funds are used for intended purposes

o Maintain records of the eligibility of each Title IV aid recipient and

the amount and date of each posting or return of aid

o Return funds on student’s behalf to loan programs

o Return to ED funds that cannot be used as intended

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Drawing Funds

• Authorization/CFL vs. Available funds

• Authorization refers to the total amount of aid made available to

date for the entire award year for that award- may include funds

already drawn

• Available funds refer to the authorization minus funds already

drawn

• Funds may only be drawn based on immediate need, i.e.

what will be disbursed or has already been disbursed

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Drawing, Adjusting, and Refunding

Funds via G5

Training on G5 functionality is available from the Main page after log in

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Cash Management

• 15 day reporting requirement for disbursements and

disbursement adjustments

• Federal Register published July 11, 2014 • An institution must submit Pell Grant, Iraq and Afghanistan Service

Grant, Direct Loan, and TEACH Grant disbursement records, as

applicable, no later than 15 days after making the disbursement or

becoming aware of the need to adjust a student's previously reported

disbursement

• 34 CFR 668.164(a), “Title IV funds are disbursed on the date that the

institution: (a) Credits those funds to a student's account in the

institution's general ledger or any sub ledger of the general ledger, or (b)

pays those funds to a student directly. Title IV funds are disbursed even if

an institution uses its own funds in advance of receiving program funds

from the Secretary”

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Title IV Excess Cash

• Schools must disburse Title IV funds to a student within 3

business days of receiving the funds in its federal funds

bank account

• Title IV funds that are not disbursed before this deadline

are Title IV excess cash and must be returned

immediately

• In some cases, funds may be held

• additional 7 calendar days

• Blue Book volume 5 page 24

• Schools may NOT hold additional funds

while reconciling accounts

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Adjusting Funds

• Adjusting of funds not allowed in G5 for Campus-Based

• Adjust via the FISAP

• Adjustments and corrections can be made for up to 5 years

• Contact the eCB help desk for assistance

• G5 adjustment of funds for Pell, Direct Loans, or TEACH

• Only allowed to correct either a draw or return of funds to the

incorrect award year or program

• Should be made as soon as possible

• NEVER allowed for reconciliation

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FSA Initiated Reductions

• Campus-Based

• Reduction of funds to expenditures reported

• 2012-13 FISAP reduction will occur February 2015

• Pell

• Unresolved POPs (Potential Overaward Process)

• Verification W not updated

• For both, COD will generate an Negative Disbursement (ND) record

• Results in an Unprocessed Deobligation (UD)

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FSA Initiated Reductions

• TEACH Grants

• Program year closeout- funds reduced to Net Draws (ND)

• Direct Loans

• Placement on Heightened Cash Monitoring 1 status (HCM1)

• Program year closeout

• Both result in funds reduced to the greater of Net Accepted and Posted

Disbursements (NAPD) or Net Draws (ND)

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Returning Funds

• What are some reasons a school must return funds?

• Unable to disburse all that was drawn (excess cash)

• Funds drawn by mistake from the wrong award or award year

• Returning unclaimed funds

• R2T4 calculations which require a return of funds in addition to a

disbursement adjustment

• COD automated negative disbursements (Pell- Verification W and

POP)

• Owing funds based on a program review or audit

• Student no longer wants/needs funds (Direct Loans 120 day rule)

• Within 120 days school returns funds to G5 account and processes disbursement

adjust

• Greater than 120 days BORROWER returns funds via his/her servicer

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Recovery of Unclaimed Funds

• Student credit balance check mailed and comes back or

EFT rejected

o School has 45 days to either return funds to ED or to try to disburse

again

o May continue trying so long as unclaimed funds are returned to ED

within 240 days of when check or EFT was issued

• Student credit balance check mailed but is never cashed

o School has 240 days to return funds to ED

2014-15 FSA Handbook Volume 4 page 48

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Returning Funds

Two more reminders: o If returning funds as the result of an audit or Program Review

liability follow the directions in the final audit or Program Review

Determination Letter

o The 120-day rule is not applicable if you are returning Direct

Loan Program funds due to regulatory or statutory requirements

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How to Refund Funds • All programs - ELECTRONICALLY via G5

• 2014-15 FSA Handbook, Volume 4 Chapter 4

• Blue Book, Volume 5 Chapter 5

• Paper checks will no longer be accepted for Direct Loans after

December 31, 2014 • http://ifap.ed.gov/eannouncements/022614DLProcessingInfoDiscontinPaperCheck

ProcessDLRefundsCashBeginJan12015.html

• If exceptional circumstances require your school to refund

Grant funds via paper check • Make check payable to U.S. Department of Education

• Use a separate check for each award/year

• Note the school’s DUNS # and award number (i.e., P063P14####) on the front of

the check

• U. S. Department of Education, PO Box 979053, St. Louis, Missouri, 63197-9000

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Setting Up a Refund Bank Account

via G5

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Creating a Refund via G5

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Electronic Refunds

• Posts to G5 within three business days

• Updates in COD within 5-7 days

• Schools control the process

• Schools direct from which bank account the money is refunded

• Multiple refunds on one screen and at one time

• Electronic processing reduces human error and delays

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Reconciliation Requirements • Monthly reconciliation REQUIRED for Direct Loans, TEACH,

FWS, and SEOG

• Regular reconciliation recommended for all programs

• Why?

• Identifies issues with meeting other cash management and disbursement reporting

requirements

• Demonstrates administrative capability

• What are the related regulatory requirements?

• Direct Loan- 34 CFR 685.300(b) (5)

• TEACH – 34 CFR 686.37

• FWS- 34 CFR 675.19 (b)(2)(iv)

• SEOG- 34 CFR 676.19 (b)(2)

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Reconciliation Resources

• eCB help desk for Campus-Based questions

• COD CSRs and Reconciliation Specialists for Grants and

Direct Loans

• G5 help Desk

• G5 reports- external award activity report

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Reconciliation - G5 external award activity

Note one Payee for two Grantees

User defined Recipient Reference Number

Exported to Excel

Note availability

of funds

For Campus based

13-14

Note last date

To draw funds

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External Award Activity Detail

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COD Reports and Web Screens

• COD reports

• School Account Statement (SAS) - contains both cash and

disbursement data - Direct Loan and TEACH Grant

• Pell Year to Date or Reconciliation File (disbursements only)

• Electronic Statement of Account (summary cash and disbursement)

• COD web screens

• School Summary

• Funding Information

• Summary Financial Information

• Cash Activity

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COD- School Summary Information

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COD- School Funding Info- Pell

Life Long Learning College

Pell CFL

based on

Disbursements and

adjustments

Note Pell Unduplicated recipients

And Total ACA paid

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COD- School Funding Info- DL

Life Long Learning College

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COD- School Summary Financial

Life Long Learning College

Direct Loans

Mirrors the SAS

Cash Summary

Updated Daily

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COD – Cash Activity

Life Long Learning College

Draw fully

Substantiated?

Draw= Accepted

And posted

Disbursements

applied

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Completing Reconciliation

• Deadlines for closeout

• Grants, TEACH, and Campus-Based - September 30 annually

• Direct Loans – Last business day of July the year following award

year processed, i.e. 2013-14 must be closed out by July 31, 2015

• Closeout may be completed as soon as processing is completed

• Direct Loans must have a School account statement with a $0 Ending Cash balance

and have received a Zero Balance letter

• Adjustments to FISAP for reconciliation may be requested

until December 15th as long as a FISAP was filed timely

• Extended processing

• Requested via COD website for Grants and Loans

• Required for any Direct Loan processing after the close out deadline

• Required for Pell for disbursement increases only

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Post Deadline/Extending Processing

Life Long Learning College

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Help Desk Information • G5 Help Desk

• Phone: 888-336-8930 (no cost per call)

TDD: 866-697-2696 (no cost per call)

E-mail: edcaps.user@ed.gov

Website: https://www.g5.gov

Office Hours: 8:00 a.m. - 6:00 p.m. (ET), Monday through Friday

• eCampus-Based Help Desk

• Phone: 877-801-7168 (no cost per call)

E-mail: CBFOB@ed.gov

Website: https://cbfisap.ed.gov

Office Hours: 8:00 a.m. - 8:00 p.m. (ET), Monday through Friday

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Help Desk Information, continued

• COD School Relations Center

• For questions related to Common Origination and Disbursement

(COD), ACG, Iraq and Afghanistan Service Grant, National SMART

Grant, Pell Grant, TEACH Grant, and Direct Loan processing.

• Grant Programs: 800-474-7268

• Direct Loan Program: 800-848-0978

• Foreign Schools: 571-392-3737

• FAX: 877-623-5082

• E-mail:CODSupport@ed.gov

• Website: https://cod.ed.gov/cod/LoginPage

• Office Hours: 8:00 a.m. - 8:00 p.m. (ET), Monday-Friday

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Contact Information

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Wood Mason U.S. Department of Education

Federal Student Aid

Atlanta, GA

770.383.9662

wood.mason@ed.gov