Advising and counseling students and their families can be a burdensome responsibility for any seasoned financial aid administrator especially when complied with our daily job tasks.  How can you ensure you’re assisting your students to the best of your ability?  By taking advantage of training opportunities and sharpening our skills, we can guarantee that we are providing the most accurate information and in the most helpful way possible.

The National Training for Counselors and Mentors (NT4CM) is currently offering training to help give you the skills needed to advise students and their families. NT4CM’s professional trainers provide comprehensive and current information on federal and state student aid programs, scholarship searches, and financial aid fraud.

Training from NT4CM provides you with the following additional benefits:

• Free fact sheets, brochures, and PowerPoint presentations to help you assist your students effectively
• Continuing education units (CEUs) toward your professional education requirements
• A venue to share your knowledge and experiences with other counselors and mentors and to network with college financial aid professionals in your area
• Ongoing information and support after the training

Online WebEx Training Schedule
Register online or e-mail training@asa.org for more information.

So, in an effort to guarantee sustainability of these programs, on October 28, 2010, President Obama signed into law new rules ensuring program integrity among institutions of higher education.  These new rules included the following:

• Holding Programs Accountable for Preparing Students for Gainful Employment
• Protecting consumers from misleading or overly aggressive recruiting practices, and clarifying state oversight responsibilities.
• Ensuring that only eligible students receive federal funds.
• Clarifying the courses that are eligible for federal aid, and the amount of aid that is appropriate.

To date, many resources have been made available to aid administrators to ensure compliance with these new regulations.  NASFAA is currently offering a webinar training series on these new regulations.  The second part of their series, Program Integrity Part II, is scheduled for January 27, 2011.  This session will focus on Ability to Benefit, HS Diploma, Verification, Satisfactory Academic Progress, Arrangements between Institutions, Incentive Compensation, and Misrepresentation.  For more information and to register, go to https://www1.gotomeeting.com/register/837545928.

So, how can you go about this process?  First, let’s look at the various resources available to you.  In order to balance your school’s records, you will need to run various financial aid and business office loan detail reports.  In order to balance with ED, you can refer to your Student Account Summary (SAS), which is generated by COD on the 1^st of weekend of each month.  You can also go to COD’s website for other DL Reports or you can contact COD and talk to a Reconciliation Specialist.  Also available to you through the FSA Download Site, is the Direct Loan Tools Software.

As you proceed with reconciling, you will need to document all of your efforts.  You will need to research, document and resolve any discrepancies between the FAO, Business Office & COD systems.  Some common discrepancies may include timing issues, drawing down or disbursing in the wrong academic year, unsent disbursement batches, returning excess cash that should have been a payment or issuing a payment that should have been excess cash.

Once all systems match, the loan detail reports balance and any discrepancies have been resolved, your reconciliation is complete!

With many loans hitting accounts in September, it’s important that you have a solid understanding of reconciliation.  In order to help schools (specifically those using Banner), The Higher Education Assistance Group, Inc. (HEAG) is pleased to be offering a FREE webinar on Direct Loan Reconciliation on October 29, 2010 at 11 am (EST). This training webinar is intended for financial aid, students accounts or finance department personnel and will focus on Banner and Direct Loan tools. All participants will receive detailed procedural instructions that will help guide you through the process. Again, this is for Banner schools.

Registration deadline is Wednesday, October 27, 2010. Please contact Raymond Nault via email at rnault@heag.cnc.net or by phone 401-636-2917 with any questions.

HEAG is a financial aid and higher education consulting group located in Wellesley, MA. More information about us can be found on our website atwww.heag.us. This webinar is part of a series of free training opportunities provided to colleges and universities. www.heag.us

The following letter from U.S. Education Secretary Arne Duncan was e-mailed to college presidents October 26, 2009

THE SECRETARY OF EDUCATION WASHINGTON, DC 20202

As this academic year moves forward, it is hard to believe we already need to consider the 2010-2011 year to come. In doing so, I am writing to seek your assistance and offer mine in taking the necessary steps to ensure uninterrupted access to federal student loans by ensuring your institution is Direct Loan-ready for the 2010-2011 academic year.

Eighteen months ago, uncertainty in the financial markets seriously threatened the availability of Federal Family Education Loan (FFEL) Program loans for the upcoming 2008-09 academic year. Congress acted quickly to provide the Department of Education with unprecedented temporary authority to directly finance loans made through FFEL Program lenders. The goal was to ensure that every student or parent with a need for a federal loan would be able to get one, whether or not the student’s educational institution had taken the steps to provide loans through the Direct Loan Program (where loan access was not affected). This stopgap measure, the Ensuring Continued Access to Student Loans Act (ECASLA), was helpful in assisting FFEL Program lenders in making $61.3 billion in new loans to students and their parents this past year. And the bulk of those funds—some $46.3 billion—was provided by the Department of Education.

While many institutions like yours continued to use the FFEL Program loan delivery process last year, more than 500 others responded to the uncertainty by switching to the Direct Loan Program. These colleges’ move to direct lending happened in an efficient and effective manner, without any interruption of service to students, and the number of Direct Loans increased by nearly two-thirds compared to the previous year. As you know, the Direct Loan Program provides students with the same types of loans, with essentially the same terms, as those made in the FFEL Program.

I do not anticipate any major loan access problems during the remainder of this academic year because Congress’s temporary measure remains in effect. However, while there are encouraging signs that the financial markets are rebounding, the most prudent course of action is for you to ensure that your institution is Direct Loan-ready for the 2010-2011 academic year. That way, loan access for your students will be assured. As you may know, President Obama has proposed that Congress make the loan system more reliable by moving to a 100 percent Direct Loan delivery system. In any event, under current law, ECASLA will expire, and the continued participation of FFEL Program lenders will be in question.

The Department of Education stands ready to assist with any questions you and your staff may have about becoming Direct Loan-ready. Many institutions have already taken the initial step of contacting us to ensure the appropriate transition steps have been taken at Federal Student Aid to begin the process. If your school has not taken this initial step, we recommend that you do so. Please also reach out to your technology, financial aid, and business offices to make sure they are working together to ensure federal loan access for your students and their parents. If they are unsure of the steps to take, please have them contact our school relations center at 1-800-848-0978, or e-mail us at DLEnrollment_FSA@ed.gov with questions.

Thank you for your attention to this important matter.

Arne Duncan

Preparers must include their name, their company’s name (if applicable), their address or the company address, and either their SSN or the company Employer Identification Number (EIN, as assigned by the IRS). With the paper FAFSA, the preparer must also sign and date the form. The wording for the related questions on the 2009-10 FAFSA has been updated.

Preparers must also:

• Clearly inform each individual upon initial contact, including via the Internet or phone, that the FAFSA is free and can be completed electronically or on paper without professional help
• Include in any advertising clear and conspicuous information that the FAFSA is free and can be completed electronically or on paper without professional help
• Link their web site, if they use one to advertise or provide information or services to consumers, to FAFSA on the Web
• Not produce, use, or disseminate any form other than the FAFSA for the purpose of applying for Title IV aid.

A preparer who knowingly provides false or misleading information on the application is subject to the same penalties as an applicant.

A preparer is permitted to collect source information from a student or parent, including IRS tax forms, in providing consultative and preparation services in completing the FAFSA.

Author: Jana Hernandes, Service Director, Operations, Federal Student Aid (September 10, 2009)

We are pleased to announce the availability of “A Guide to Creating a Policies and Procedures Manual.” We have developed this guide to assist schools in creating and revising written documentation of how they comply with the various federal regulations pertaining to the administration of the Title IV programs. The guide features activities designed to help a school meet the minimum general requirements with regard to documented policies and procedures. The document also highlights additional areas for which written policies and procedures are suggested in the Federal Student Aid Handbook.

Although the regulations do not specifically require schools to consolidate their documentation in the form of a policies and procedures manual, schools that have a manual often find it easier to implement and adhere to established procedures. The use of a manual also helps schools routinely review and update their operations and may streamline school audit and program review experiences. It is a tool to assist schools in being good stewards in the administration of the Title IV programs and the delivery of funds and services to students.

Note: This document has been prepared to provide schools with basic guidance to develop policies and procedures. However, it should not be assumed that this document is all- inclusive. For a more complete explanation of specific program requirements, a school should refer to the applicable statutes, regulations, and the Federal Student Aid Handbook. It is the school’s responsibility to ensure that all Title IV requirements outlined in statute and regulations are met.

The policies and procedures manual guidance is available on the Quality Assurance Web site at the following link: http://ifap.ed.gov/qahome/qaassessments/makingofapandpmanual.html. If you have questions about the policies and procedures manual guidance, contact Michael Cagle at michael.cagle@ed.gov or Holly Langer-Evans at holly.langer-evans@ed.gov.

On July 1, 2009, President Obama signed H.R. 1777 into law as Public Law 111-39, making technical corrections to the Higher Education Act (HEA). Among other things, H.R. 1777 updated the list of programs that meet the definition of “veterans’ education benefits” in section 480(c) of the HEA by including new programs and revising the statutory citations. Those programs are included in the attachment to this announcement. Note that section 480(c) includes, along with a listing of education benefit programs administered by the Department of Veterans Affairs (VA), certain ROTC programs that are administered by the Department of Defense (DOD).

In an electronic announcement posted on IFAP on July 2, 2009 we informed you that H.R. 1777 changed the effective date for the exclusion of Federal veterans’ education benefits, as defined in section 480(c) of the HEA, as estimated financial assistance (EFA) to July 1, 2009 (beginning with the 2009-2010 award year).

The following Questions and Answers (Q&A) provide additional information on the treatment of Federal veterans’ education benefits for purposes of the Title IV student assistance programs.

Q1: Is the required institutional matching contribution under the new VA “Yellow Ribbon Program”, considered Federal veterans’ education benefits, and therefore excluded from EFA?  Or is only the amount of the VA Federal funds provided to the student considered to be Federal veterans’ education benefits and only that amount excluded from EFA?

A1: The Yellow Ribbon G.I. Education Enhancement Program (Yellow Ribbon Program) is a new program authorized by the Post-9/11 Veterans Educational Assistance Act of 2008 (Post-9/11 GI Bill), which added a new Chapter 33 to title 38 of the United States Code. Chapter 33 authorizes both a basic education benefit and the Yellow Ribbon Program. Under the Yellow Ribbon Program, an eligible institution may voluntarily enter into an agreement with the VA to jointly pay all or a part of the portion of the eligible veteran’s tuition and fees that exceeds the maximum amount otherwise provided under the basic Post-9/11 GI Bill benefit program. The VA matches, on a dollar-for-dollar basis, the amount contributed by the institution under the Yellow Ribbon Program.

Because the Yellow Ribbon Program provides veterans’ education benefits under chapter 33 of title 38 of the United States Code, all funds provided under this program, including funds provided by the institution as its contribution, are considered Federal veterans’ education benefits under section 480(c) of the HEA, and therefore both portions are excluded from EFA. However, only the Yellow Ribbon portion of the institutional award is excluded. For example, assume an institution’s tuition and fees for a veteran are $10,000 but the veteran will only be receiving $4,000 toward tuition and fees under the basic Post-9/11 GI Bill benefit program. Also assume that the VA and the institution entered into an agreement where the tuition and fee gap of $6,000 will be covered under the Yellow Ribbon Program. Thus, both the VA and the institution would each provide an additional $3,000 toward the veteran’s tuition and fees. Assume that the institution was using a $5,000 institutional scholarship to meet its Yellow Ribbon contribution for this student. Under this scenario, the full amount of the basic Post-9/11 GI Bill benefit program of $4,000 and the $3,000 contribution from the VA under the Yellow Ribbon Program would be excluded from EFA, as would the required $3,000 institutional contribution from the $5,000 scholarship. The remaining $2,000 of the $5,000 institutional scholarship must be considered EFA.

Q2: Does the exclusion from EFA of Federal veterans’ education benefits apply to all of the components of the assistance or to only to certain components? For example, does it apply only to amounts provided for subsistence or to only amounts provided for tuition and fees?

A2: Amended section 480(c) of the HEA includes the words “. . . benefits under the following provisions of law . . .”. Therefore, the exclusion from EFA applies to all of the benefits provided under the designated program. For example, all benefits provided under the Post-9/11 GI Bill are excluded regardless of whether the assistance was for tuition and fees, books and supplies, or as a monthly housing allowance.

Q3: Does the exclusion of Federal veterans’ education benefits from EFA apply where a veteran’s spouse or dependent is applying for Federal student aid and the spouse or dependent is receiving Federal veterans’ education benefits because of the status of the veteran?

A3: Any Federal veterans’ education benefits listed in section 480(c) of the HEA that are received by an aid applicant must be excluded from EFA even if the aid applicant is receiving those benefits as a spouse or dependent of a veteran.

Q4: Are the education benefits provided under the DOD’s Reserve Officers Training Corps (ROTC) considered Federal veterans’ education benefits and therefore not considered EFA even though they are not administered by the VA and are not provided to veterans?

A4: As noted earlier, the amended section 480(c) of the HEA includes, in addition to education benefit programs administered by the VA, two ROTC programs that are administered by the DOD. These are the scholarship benefits provided under the Senior Reserve Officers Training Corps (ROTC) in chapter 103 of title 10 of the United States Code and the subsistence allowance benefits provided under the ROTC in chapter 3 of title 37 of the United States Code. Therefore, education benefits from these two ROTC programs must be excluded as EFA even though they are not VA programs and the recipients are not veterans.

Q5: Are “tuition assistance” programs provided by the DOD (or the individual military services) Federal veterans’ education benefits and therefore not considered EFA?

A5: The only VA or DOD benefits that are to be excluded from EFA are those listed in section 480(c) of the HEA. Any benefits provided under any other program must be included as EFA in the calculation of the student’s eligibility for Title IV student assistance. For example, the Tuition Assistance Program of the Army Continuing Assistance System and the Army National Guard Federal Tuition Assistance Program are not programs included in section 480(c) of the HEA. Therefore benefits received under those programs must be included as EFA.

Q6: Since the law now removes as EFA all Federal veterans’ education benefits, may the institution exclude from the student’s cost of attendance (COA) the amount of those benefits that cover all or a portion of a specific component of the student’s COA? For example, may an institution exclude from the tuition and fees component of a student’s COA the amount paid by the VA for the veteran’s tuition and fees since it is not included as EFA?

A6: No. The institution may not exclude from the student’s COA, either generally or under the professional judgment provisions of the HEA, the amount of Federal veterans’ education benefits that cover all or a portion of a specific component of the veteran’s COA. The statutory exclusion from the definition of EFA of Federal veterans’ education benefits was done to remove consideration of those benefits in determining the student’s financial need. If the institution also excluded from the student’s COA the amount of Federal veterans’ education benefits that cover all or a portion of a specific component of his or her COA, the institution would be negating the purpose of the change made in the law.

Please note that this requirement for the treatment of Federal veterans’ education benefits with regard to COA is not to be confused with the recent statutory change to section 472(3)(C) of the HEA. Effective July 1, 2010, that provision requires that COA not include a housing allowance for aid applicants who live in housing located on a military base or for which a military housing allowance as provided under section 403(b) of title 37 of the United States Code – Pay and Allowances of the Uniformed Services.

Q7: Since these Federal veterans’ education benefits are no longer considered EFA, may they be included as income in the calculation of a student’s expected family contribution (EFC)?

A7: No. Federal veterans’ education benefits, as defined in section 480(c) of the HEA, have been and continue to be excluded from the calculation of a student’s EFC.

Q8: Do the words “including but not limited to” in section 480(c) of the HEA allow a school to exclude from EFA educational benefits received by a student from other programs not listed in section 480(c)?

A8: No. The statutory use of the words “including but not limited to” are intended to provide the Secretary with the flexibility needed in the event that (1) a new qualifying Federal veterans’ education benefit program is created or (2) the name or statutory citation of one of the currently listed programs is changed. As stated earlier, only benefits received under one of the programs specifically listed in section 480(c) of the HEA are to be excluded from EFA.

If you have any questions regarding this topic, please contact our Research and Customer Care Center staff. Staff is available Monday through Friday between the hours of 9:00 AM and 5:00 PM (Eastern Time) at 1-800-433-7327. After hours calls will be accepted by an automated voice response system. Callers leaving their names and phone numbers will receive a return call the next business day. Alternatively, you may FAX an inquiry to the Research and Customer Care Center at (202) 275-5532, or e-mail the Care Center at fsa.customer.support@ed.gov.

July 12, 2009

In a January 30, 2009 Electronic Announcement on the Information for Financial Aid Professionals (IFAP) Web site, we provided customer service contact information for Federal Family Education Loan (FFEL) Program loans that the Department of Education (the Department) purchases from FFEL loan holders. Through methods commonly referred to as “PUT” by FFEL loan holders and the Department, the Department becomes the owner and servicer of the purchased loans. Upon purchase of a loan, both the prior FFEL loan holder and the Department correspond with an affected borrower.

Toll-Free Hours of Phone No. Operation

• For Collections 866/938-4749 Mon-Fri 8am-11pm (EST)
• For Schools 866/938-4750 Mon-Fri 8am-8:30pm (EST)
• For Borrowers 800/508-1378 Mon-Fri  8am-11pm (EST)

The Department awarded Title IV Student Loan Management/Servicing contracts to AES/PHEAA of Harrisburg, Pennsylvania; Great Lakes Education Loan Services, Inc. of Madison, Wisconsin; Nelnet, Inc. of Lincoln, Nebraska; and Sallie Mae  Corporation of Reston, Virginia. The award of these contracts provides the Department with the capacity necessary to support anticipated increases in the number of loans owned by the Department and ensures borrowers receive the assistance they need to effectively manage their federal student loan obligations.

Author: James F. Manning, Acting Chief Operating Officer