Fed-Updates Financial Aid Newsletter – April 14, 2020

Newsletter topics: CARES Act, Updated Guidance – COVID-19, eZ-Audit Reporting Requirements, Annual Student Loan Acknowledgement, Foreign Schools – Financial Statement Audits and Compliance Attestation Engagements, COD System, and various resources

Note: Fed-Updates newsletter updates are excerpts from original announcements posted on the IFAP website. 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’ll find additional information on the IFAP website. Reminder: Deadlines and event dates are noted in our newsletters are subject to change as determined by the Department of Education.

FA Solutions – March 19, 2020 Update from our CEO – When FA Solutions was first established, we had the goal of being able to offer complete redundancy of coverage in the event Florida experienced a hurricane, or some other natural disaster. To do this, we invested heavily in cloud based technology to allow for remote staffing, and the ability for our employees to travel to unaffected areas if necessary so that work could be adequately performed, and service to students could continue with limited, or no interruption. We are happy to report that this has been heavily tested and fully operational. What we didn’t realize at the time was that together we built a business model that would be able to offer consistency of coverage even during a national emergency, such as the one being experienced today. As of now, FA Solutions expects full-service operations to continue without interruption. This includes the FA Solutions processing and leadership teams, as well as Student Communication through our Student Experience Center. We do ask that each of our school partners stay in complete communication with our teams, so that updates from both sides happen consistently. You are important to us!

Secretary DeVos Rapidly Delivers More Than $6 Billion in Emergency Cash Grants for College Students Impacted by Coronavirus Outbreak – April 9, 2020 press release – First wave of CARES Act funding will provide aid to students for expenses like course materials, technology, housing, food, health care, and childcare.

UPDATED Guidance for interruptions of study related to Coronavirus (COVID-19): The Department appreciates that postsecondary institutions and their students face unique and urgent circumstances as a result of the novel coronavirus disease (COVID-19) pandemic. This guidance provides updated information that expands upon the Department’s March 5, 2020, guidance and provides additional regulatory flexibilities due to the lawful declaration of the COVID-19 national emergency. Please review the April 3, 2020 electronic announcement for additional information.

Financial Responsibility and eZ-Audit Reporting Requirements: The final regulations published on September 23, 2019 (https://ifap.ed.gov/federal-registers/fr092319) establish, in part, new Financial Responsibility reporting requirements stemming from changes in accounting standards and recommendations made by the community.  In the attachment to this Electronic Announcement (EA) several concerns raised by institutions, auditors, and other community partners regarding how these requirements will be implemented are addressed. Please review the April 9, 2020 electronic announcement for additional information.

Annual Student Loan Acknowledgement – Preliminary Implementation in Late April 2020, Borrower Completion Requirement Delayed until 2021: In response to school concerns and the unprecedented disruptions caused by the coronavirus (COVID-19), Federal Student Aid will be delaying the requirement that borrowers complete the Annual Student Loan Acknowledgement prior to disbursement for the 2020–21 Award Year. Instead, the borrower completion requirement will begin with the 2021–22 Award Year. Please review the March 27, 2020 electronic announcement for additional information.

Foreign school update ID: FS-2020-01 – Availability of Guide for Financial Statement Audits and Compliance Attestation Engagements of Foreign Schools – The U.S. Department of Education, Office of Inspector General has published its new Guide for Financial Statement Audits and Compliance Attestation Engagements of Foreign Schools (Guide). This Guide supersedes the Foreign School Audit Guide (September 2002) and the related amendments to that guide and is effective for fiscal years ending on or after December 31, 2020. Early implementation is not permitted.

Failure to submit foreign school financial statement audits and compliance attestation engagements performed in accordance with this Guide may result in your audits being rejected. If you are a foreign school, please ensure that your auditor is using this Guide for audits of fiscal years ending on or after December 31, 2020. Please review the April 7, 2020 electronic announcement for additional information.

COD System Implementation for 2020–21 Award Year: During the period April 24-26, 2020, implementation of the Common Origination and Disbursement (COD) System functionality will take place. Please review the April 9, 2020 electronic announcement for additional information.


  • 2020-03-31 – 2020–2021 COD Technical Reference (March 2020 Update)
  • 2020-04-07 – Federal Family Education Loan Program Special Allowance Rates for the Quarter Ending March 31, 2020


  • 2020-04-02 – NPRM – Distance Education and Innovation



We recently updated the web links in this section: The following are a few helpful links to information pages available on the IFAP website:  Early FAFSA, Grant and Direct Loan (COD) Processing InformationTraining Resources, and iLibrary, which includes many resources, such as a consolidated list of Electronic AnnouncementsDear Colleague LettersFederal Registers,and NSLDS reference materials and more. Please review the IFAP 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.