The world of financial aid stays interesting…all year round!  Just as you are working on awards for 2014-2015 for students about to start this new award year, you have to switch gears in your thinking—in two directions.  It is now time to start thinking ahead to 2015-2016 if your institution is interested in participating in any of the Campus-Based programs of the Title IV Federal Student Aid Programs.  That is, if you desire your institution’s participation in any one or more of the Federal Supplemental Educational Opportunity Grant (FSEOG), Federal Work-Study (FWS), or Federal Perkins Loan (Perkins) programs in the 2015-2016 award year, it is time to begin preparation for, and completion of, the Fiscal Operations Report for 2013-2014 and Application to Participate for 2015-2016 (FISAP). [Note:  Based upon current funding authorization by Congress, no new Perkins Loan program participants will be authorized in 2015-2016 since no new Federal Capital Contribution (FCC) will be allocated in the Perkins Loan program.  Schools with current Perkins Loan funds may continue to request Levels of Expenditure for 2015-2016.]  As the name of the FISAP indicates, it is also time to begin wrapping up the 2013-2014 award year and report final expenditures for that year.  So, are you ready to work with three award years at once?

Requirement to Submit the FISAP

The basic requirement to annually submit the FISAP is contained in the regulations put forth by the U.S. Department of Education (ED).  The requirement to submit the FISAP as an application for funding to participate in the Campus-Based programs is detailed in 34 CFR 673.3.  The necessity of the report component of the FISAP is delineated in the regulations specific to each of the Campus-Based programs.  Specifically, the requirement to report annually is in 34 CFR 676.19(b)(3) for FSEOG, 34 CFR 675.19(b)(3) for FWS, and 34 CFR 674.19(d)(2) for Perkins Loans.  The timely submission of fiscal reports is stipulated in 34 CFR 668.16(i), which is in the administrative capability section of the regulations.  The FISAP is submitted through the eCampus-Based System (eCB).a [Note that in the remainder of this Regulatory Bulletin, when an asterisk (*) is used at the end of a statement or phrase, that asterisk indicates that FAME clients for whom FAME submits the FISAP will receive more information directly related to that topic from FAME.  Client schools will receive specific instructions on the steps necessary for FAME to complete the FISAP on their behalf.]

Deadline for FISAP Submission

The “Notice of the 2014-2015 Award Year Deadline Dates for the Campus-Based Programs” was published in the Federal Register on January 15, 2014.  It is in Volume 79 of the Federal Register, page 2646 (79 FR 2646).  In that notice, ED announced that the deadline for submission of the 2015-2016 FISAP is Wednesday, October 1, 2014.  To meet the deadline, all FISAPs presented electronically must be transmitted by 11:59:00 p.m. (Eastern Time) on the deadline date.  The transmission of the FISAP must be accepted prior to midnight to be within the deadline.  (FAME FISAP clients will need to complete the online questionnaire in FAME Connect by August 1, 2104.*)

Any institution that chooses to sign its FISAP manually via a paper certification and signature page must ensure that it is postmarked by the deadline date and/or have a receipt stamped with the date of submission not later than the deadline date to be considered having been sent on time.  If a manual signature option is chosen and it is shipped via a commercial delivery company (e.g., FedEx, UPS, DHL, etc.), the delivery must occur no later than 4:30 p.m. (Eastern Time) on the deadline date of October 1, 2014.

Electronic Signatures as New Option for This Year’s FISAP

Electronic signatures (eSignatures) will be accepted this year as an option when submitting the FISAP.  Effective August 1, 2014, schools will have the capability to submit the FISAP signature pages and other documents within the eCB System.  The Chief Executive Officer’s (CEO) signature is still the signature required for successful submission of the FISAP.  (The CEO may also be known as President, Chancellor, owner, etc., at some institutions.)  ED is encouraging schools to utilize the eSignature process as it expedites processing and reduces paper document production, handling, and mailing.*

Secure Access and the eSignature Process

ED has informed the financial aid community that, also effective August 1, 2014, access to the eCB Web site will require use of Two Factor Authentication (TFA).  While the TFA process will be mandatory for anyone needing access to the eCB Web site on or after the stated effective date, it is especially important to be aware of the impact for the school’s CEO.  The CEO will be obliged to have an FSA User ID and password, as well as a TFA token, to log in to the eCB Web site to electronically sign the FISAP.  Therefore, schools that wish to sign the FISAP electronically must take action now to ensure the school’s CEO is registered as an authorized user in the eCB System (with “Read”, “Write”, and “Submit” access), has an FSA User ID and password, as well as a registered TFA token.  Each of these secure access components is necessary in order to electronically sign the FISAP.  It is important to note that the FISAP form must be submitted before the eSignature process may be accomplished for the FISAP.  Further, schools should be aware that any FSA User ID that has not been used in the past 90 calendar days will be suspended.  An FSA User ID that has not been used in more than a year is automatically deactivated.  More information about the TFA process in the eCB System is available in ED’s June 26, 2014, Electronic Announcement.*

Manual Signature Option

rushAlthough ED encourages all schools to utilize the eSignature process, schools may currently still choose instead to print out the signature documents and send them to ED manually.  The FISAP must first be completed electronically, but the signature pages may then be mailed.  In order to submit the required signatures by paper the school must print the certification and signature pages and have the CEO sign the forms with an original, “wet” signature.  The forms must then be mailed or delivered by commercial delivery to the FISAP Administrator.*

 

NOTE:  The mailing/delivery address for hardcopy signature pages is new this year.  The signature pages must be delivered to the following address:

7-15-2014 9-56-22 AM

 

 

 

 

 

As stated earlier, signature pages that are mailed through the U.S. Postal Service must be postmarked by the deadline date and/or have a receipt stamped with the date of submission being not later than the deadline date to be considered having been sent on time.  If the manual signature option is chosen and the signature page is shipped via a commercial delivery company, the delivery must occur no later than 4:30 p.m. (Eastern Time) on the deadline date.

Lobbying Certification and Lobbying Form (SF-LLL)

Since the lobbying certification is included in the FISAP Signature/Certification and Warning page of the FISAP, the certification is able to be signed by e-Signature, or manually, as described earlier for the FISAP signature submission.  If a school received more than $100,000 in the award year from FSEOG and/or FWS and the school engages in lobbying activities, the school must submit the Standard Form-LLL, Disclosure of Lobbying Activities (Lobbying Form).  The form must now be submitted electronically via the eCB Web site when submitting the FISAP.  Once it is submitted, the school may sign the Lobbying Form electronically or manually.  This form must be signed by the CEO and submitted with the FISAP signature package.  (If submitted by hard copy rather than electronically, it must be sent to the address given above for a paper FISAP signature submission.)

Edits Possible Later

As is the case each year in the FISAP process, when the FISAP is submitted ED runs it through a “real-time validation” analysis to determine whether there are errors in the reported data.  If there is a perceived error based upon the real-time validation analysis, the school can view a listing of its FISAP edit errors on the eCB Web site.  The corrections and edits to previously submitted data are allowed through this edit process.  The corrections and edits to data are required to be submitted by December 15, 2014.*

Tips for a Successful 2015-2016 FISAP Experience

  • Confirm that any eCB user that will need access to the FISAP has valid, unexpired User IDs and passwords, as well as TFA tokens.  User IDs and passwords expire after 90 days of inactivity and are suspended.  After a year of non-use, a User ID is deactivated.  (Reminder:  As this is the first year for the eSignature option, most CEOs will need to obtain User IDs, passwords and TFA tokens as soon as possible.)*
  • Add to your calendar a schedule to become familiar with the FISAP Desk Reference and instructions before you need to start completing the FISAP.
  • Plan a FISAP meeting with any stakeholders in the process.  For example, you will need enrollment data, total tuition and fee revenue, letterprogram fund balances and expenditures, etc., so you will want to discuss the different data items needed with the appropriate staff that will assist in providing the information.
  • Ensure 2013-2014 Campus-Based fund accounts are reconciled and balanced to have an accurate record of expenditures, etc.*
  • For those schools that had Campus-Based funds in 2013-2014, ensure that all of the 2013-2014 Campus-Based allocations were expended appropriately.  Unexpended allocations that are not released for reallocation can have a negative effect on your future allocations.  If all 2013-2014 allocations were not expended, make certain to complete Section A of the 2013-2014 Campus-Based Reallocation Form at the eCB Web site.  If you want to request additional 2014-2015 FWS funds that will be used to employ students in community service jobs, you will also want to complete Section B of the Reallocation Form.  This form must be submitted not later than Monday, August 18, 2014.*
  • Verify that your current CEO’s name is listed on your school’s Program Participation Agreement (PPA).  It is true that any change in your institution’s CEO was to have been reported within 10 days of the change.  However, it is wise to make certain that the update was actually made and that the PPA shows the current CEO.  This is important, in part, due to the fact that the FISAP signature page will be pre-populated with the CEO’s name, title, e-mail address, telephone number and fax number as shown on the PPA when the page is printed.
  • If the manual signature option is chosen for submitting the FISAP certification and signature page, ensure you use the NEW address listed earlier when mailing it.*

 

(EA06262014; EAs06302014; FR79-01152014)

The information provided to you is FAME’s opinion based upon our interpretation of the issues and details provided, and our interpretation of the Title IV regulations, legislation, and U.S. Department of Education guidance, as applicable. FAME shall not be liable for any error contained herein or for any damages whatsoever arising out of or related to the use of this information.