March 19, 2019
FinAid – Ever changing and ALWAYS challenging.
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Rob Wright,
Pam Notemyer Rogers,

Please note that deadlines and event dates noted in all of our newsletters are always subject to change as determined by the Department of Education.

Important Note:  FA Solutions‘ Fed-Updates Newsletter updates are excerpts from original announcements posted on the IFAP website so please review the entire update by clicking the link included with each posting. We’re not able to include all Federal updates and deadlines, but you will find additional information on the IFAP website

REMINDER – Annual DUNS Number Registration Renewal with System for Award Management Database: This announcement is a reminder that all schools must complete the registration confirmation of their DUNS number annually. To prevent delays in the receipt of Title IV program funds, we encourage all schools to complete their annual confirmation of their DUNS number with the SAM website. A 60-day and 30-day reminder email will be sent to the Point of Contact (POC) and alternate POC for your school prior to your school’s renewal deadline. Please review the March 18, 2019 electronic announcement for additional information.

Determining the prorated amount of charges associated with a payment period: The Department of Education (DOE) has received several requests for clarification of the provisions found in 34 CFR 668.164(c) related to crediting a student’s ledger account with Title IV funds to pay for allowable charges associated with a payment period, particularly where an institution debits that account at the beginning of the student’s enrollment for the entire cost of books, supplies, and equipment (including the cost for kits) to be used throughout the program. Additionally, the DOE has been asked to provide specific guidance on determining whether a charge for books and supplies is an institutional or non-institutional charge. The Office of Postsecondary Education has issued an announcement that explains the relevant provisions, places those provisions in context relative to the ways in which institutions charge for books, supplies, and equipment, and responds to questions that the Office has received regarding this matter. Please review the March 5, 2019, electronic announcement for additional information.

First Pell Grant Administrative Cost Allowance Payments for 2018-19 Award Year: The Federal Pell Grant (Pell Grant) regulations at 34 CFR 690.10 provide for an Administrative Cost Allowance (ACA) payment of $5.00 to each participating school for each student who receives a Pell Grant at that school for an award year. These funds may be used only to defray the costs of administering the Pell Grant, Federal Supplemental Educational Opportunity Grant, Federal Work-Study, and Federal Perkins Loan. The first ACA payment for the 2018–19 Award Year is based on records that the COD System has processed from the start of the Pell Grant 2018–19 Award Year on July 1, 2018 up to the date that the first ACA payments are processed for the 2018–19 Award Year. Federal Student Aid began processing the Pell Grant ACA payments for all schools on February 27, 2019. Please review the March 1, 2019 electronic announcement for additional information.

2019–20 Federal Work-Study Program Community Service Waiver Requests: Section 443(b)(2)(A) of the Higher Education Act of 1965, as amended (HEA) and the corresponding regulations at 34 CFR 675.18(g) set forth the Federal Work Study (FWS) community service expenditure requirements that a school must meet unless the school is granted a waiver from the Secretary. The deadline for electronic submission of a school’s 2019–20 FWS Community Service waiver request is 11:59 p.m. Eastern time (ET) on Monday, April 22, 2019.  Completed submissions must be accepted by the COD system by midnight ET. A waiver request that is received after April 22, 2019 will not be considered. Please review the March 18, 2019 electronic announcement for additional information.

COD System Implementation for 2019–20 Award Year: During the period April 5-7, 2019, Federal Student Aid (FSA) plans to implement Common Origination and Disbursement (COD) System functionality that supports the Campus-Based programs and the processing of Federal Pell Grant (Pell Grant), Iraq and Afghanistan Service Grant, Teacher Education Assistance for College and Higher Education (TEACH) Grant, and William D. Ford Federal Direct Loan (Direct Loan) awards for the 2019–20 Award Year. With this implementation, FSA will also transition the Return of Title IV (R2T4) on the Web application to the COD System. Please review the March 14, 2019 electronic announcement for additional information, as well as R2T4 Transition announcements #1 (December 20, 2018), #2 (February 28, 2019), and #3 (March 1, 2019).

Reminder of Valid Signature Rules for Printed FAFSA Signature Pages: Federal Student Aid wishes to remind financial aid administrators (FAAs) of the general rules and requirements when assessing the validity of student and parent signatures on paper signature pages. By providing this information, FSA hopes to augment the overall guidance FAAs provide for this process when assisting applicants and their parents with Free Application for Federal Student Aid (FAFSA) form completion. Please review the March 18, 2019 electronic announcement for additional information.

Guidance Concerning Some Provisions of the 2016 Borrower Defense to Repayment RegulationsThe US Department of Education (Department) has issued guidance to provide institutions of higher education with information to assist them in meeting their obligations under the Higher Education Act of 1964 and implementing regulations, specifically at 34 CFR 668.41, 668.171, and 685.300 that the Department enforces. Please review the March 15, 2019 electronic announcement for additional information.

NOTE: Due to limited space in our newsletter, only the titles and links to the updates below are provided here.


NSLDS reference materials:

  • 2019-03-12 Guaranty Agency (GA) Data Provider Instructions (Version 5.0)
  • 2019-03-07 Newsletter 63: Enrollment Reporting Enhancements and Previously Retrieved Borrower Search


  • 2019-03-01 Proposed 2020 Update to the Classification of Instructional Programs (CIP) and Request for Comment

INFORMATION PAGES FOR SCHOOLS TO MONITOR WEEKLY: The list below represents just a few of the information pages available on the IFAP website. Please review the organization’s website for additional guidance, resources, deadlines, and information related to the administration and processing of Title IV federal student aid.

Thank you for taking the time to review our newsletter!
Rob Wright
Disclaimer of Liability: Every effort is made to provide accurate and complete information in FA Solutions’ newsletters. However, FA Solutions makes no claims, promises or guarantees about the accuracy, completeness, or adequacy of the contents of the newsletters and expressly disclaims liability for errors and omissions in the contents of its newsletters. Although FA Solutions may include links providing direct access to other Internet resources, including Websites, FA Solutions is not responsible for the accuracy or content of information contained in these sites.