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909.1 Purpose
CEI constantly monitors its financial aid program to ensure compliance with all mandates and provide timely reporting. CEI uses a system of regular checks and balances to ensure that all funds are disbursed appropriately. To remain current with financial aid updates, CEI maintains a membership in the National Association of Student Financial Aid Administrators (NASFAA), and its financial aid officers participate in its professional development opportunities. They also utilize NASFAA’s compliance checkers on an annual basis to ensure that their procedures remain current and accurate. Staff also review weekly notices from Federal Student Aid Dear Colleague Letters.
909.2 Scope
Overall Program Monitoring: CEI’s Financial Aid and Business Office work collaboratively, but they maintain separate procedures to ensure that there are sufficient checks and balances on financial aid disbursement. The Financial Aid Office (FAO) prepares all disbursements, but it cannot issue any payments or process any refunds. Any actual monetary exchange is handled by the Business Office, which doublechecks the FAO’s lists. The Business Office can flag records for further investigation and thus pause payment, but they cannot add or remove records from the list.
Federal regulations require CEI to submit disbursement records and disbursement adjustment records within mandated timeframes, and CEI must review its cash balances on the US Department of Education’s Common Origination and Disbursement Website (COD) or the G5.
First-Time Borrowers: First-time borrowers are monitored and disbursed differently than others. No loans are released until 30 days after the semester has begun. At that point, the FAO reviews student enrollment data to ensure that students are enrolled in at least 6 credits/half-time. If a student is enrolled in the minimum credits, then the loans can be disbursed.
Daily Monitoring: The FAO receives daily reports of students who complete their Master Promissory Note (MPN). The office staff investigates any record that is not accepted, and no funds are available until all discrepancies are cleared.
Weekly Monitoring: Each Monday, the FAO tests disbursement to review records and catch errors. The FAO runs reject reports through Colleague to monitor the acceptance of loans, and it reconciles the G5 with the Business Office.
All corrections are made before any funds are posted. The Business Office performs an additional review of each record to find errors and to ensure that all criteria are met. Students are notified of any missing requirements.
After both departments verify the records’ accuracy, the funds are posted. The Business Office disburses the funds to students.
10th Day Enrollment and Mid-Term Monitoring: Over-award reports are run after the 10th day attendance checks are completed for both full-semester and 8-week-block courses. This is repeated at mid-term. Staff check for students with an over-award based on their actual enrollment, and adjust the students’ budget per actual enrollment.
At each disenrollment and term benchmark, the Financial Aid Staff performs a ‘Transcript Review’, starting a few weeks prior to fee deadline, then weekly after until the semester Census date, and again for 8-week courses. This process looks for any problems in eligibility. Specifically, they review courses not populating as Title IV eligible. This ensures that all students are in appropriate programs, and for courses that are not counting in the system evaluation for their program, are reviewed for pre-requisites and eligibility for Title IV funding. Each record is updated to show if the student remains eligible for financial aid.
Monthly Monitoring: The FAO pulls a monthly reconciliation report from the COD website. They run internal reports to ensure that loans are accepted appropriately. A report is provided to the Business Office, which provides a snapshot of the fund’s summary balance.
Each mid-month, the office pulls Pell and Loan reconciliation reports from the COD website. This is another check to ensure that all loans are disbursed appropriately. Any problematic loan that isn’t caught in the reject lists will be caught in the monthly reconciliation reports.
Yearly Monitoring: To close the year, CEI receives direct loan notification for a zero balance, if they are reconciled correctly. They also receive a school monitoring report, which monitors both the grant and loan programs. This report ensures that CEI corrects any over-awards, overpayments to students, fixes rejected loan records, and reconciles any unsubstantiated cash. Any correction is submitted to the processor COD.
The Fiscal Cohort Default Rate is published each year by February, as the Department of Education releases the data. Upon publication, the FAO ensures that it is published on CEI’s main website.
Each December, the FAO uses the NASFAA Compliance Checkers to review and update its policies and procedures.
5-Year Review:
Internal: The FAO has a full program review every five years, which is supervised by the Dean of Student Affairs. The FAO is also audited every year and fulfills those requests to maintain compliance.
External: The FAO fulfills the reporting requirements of the Eligibility and Certification Approval report (ECAR).