Top 5 Takeaways from Recent Financial Aid Regulations

In the past several weeks, many new regulations have been pushed to title IV approved schools. If you  don’t follow these every day, you could easily miss something important and impactful. So, here’s our  five takeaways from recent DOE financial aid regulations. 

1. Loan repayment is on ‘pause’ until May 2022. 

Enough said! 

2. Professional Judgment a Growing Area of Concern for OIG 

As a part of a recently released report from the Department of Education’s (ED) Office of Inspector General (OIG), the internal watchdog identified concerns with school policies concerning professional judgment (PJ), indicating that institutions need to follow established institutional policies and that policies need to rely heavily on documentation to support the PJ decision made. It is strongly encouraged that school ensure they have proper documentation and strong policies and procedures that they adhere to in the area of professional judgement. 

3. Clock hour proration 

If a school is allowed to graduate a student before successfully completing all the clock hours in the program, the Title IV financial aid must be prorated. A student’s eligibility for Title IV aid in a clock-hour program is based, in part, on the overall number of clock hours in the student’s program of study. When an institution allows a student to graduate from a clock hour program without completing all of the established hours in the program, the institution has effectively shortened the program’s length – resulting in reduced Title IV eligibility – for the student. Therefore, if a student graduates from a clock hour program without successfully completing all of the established clock hours in the program, the institution must recalculate the student’s eligibility for all Title IV aid in the program and must perform a new proration of the student’s Pell Grants and Direct Loans as if the student had been enrolled in a program with fewer clock hours. Then, if the institution had disbursed Title IV aid in an amount greater than the amount that it recalculates, the institution must return the difference between the recalculated amount of Title IV for which the student was eligible based on enrollment in the shorter program and the amount that was disbursed. The institution, not the student, is ultimately responsible for returning the Title IV aid in these situations. 

 4. Verifications for 2022 – 2023 

Verification groups remain the same. Also, the DOE removed high school completion status as a verification item under the V4 and V5 tracking groups where... 

∙ high school completion (or recognized equivalent) is still required for Title IV eligibility ∙ institutions will only be required to report the verification results of a student’s identity ∙ does not impact an institution’s ability to self-select FAFSA items under the institution’s own verification policy 

5. Unique Entity Identifier Update 

As per the Department of Education by April 4, 2022, schools will no longer be using DUNS numbers and transition to new Unique Entity Identifier. At that point, entities doing business with 

the federal government will use a Unique Entity Identifier (SAM) created in SAM.gov. They will no longer have to go to a third-party website to obtain their identifier. This transition allows the government to streamline the entity identification and validation process, making it easier and less burdensome for entities to do business with the federal government. The Integrated Award Environment (IAE) manages several systems including SAM.gov, FPDS, eSRS, FSRS, CPARS and FAPIIS. Current SAM.gov registrants have already been assigned their Unique Entity Identifier (SAM) and can view it within SAM.gov. To learn more about this transition, please see the information below. Join and follow our community on Interact to be notified about the latest news and information about the upcoming Unique Entity Identifier (SAM) changes happening at IAE.

Of course, this list could go on and on. So let our financial aid and compliance experts help your  department boost its efforts. Contact us today to explore options. Get FA Solutions   and ECM today! 

Thank you for taking the time to review our newsletter! 

Rob Wright 

(813) 435-6227 

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