August 4, 2020

080320FisOperRpt1920AppPartici2122FISAPRptInstCARESAct

080320FisOperRpt1920AppPartici2122FISAPRptInstCARESAct

Subject

Fiscal Operations Report for 2019–20 and Application to Participate for 2021–22 (FISAP) Reporting Instructions and Additional Flexibilities Under the Coronavirus Aid, Relief, and Economic Security Act (CARES Act)

The Fiscal Operations Report for 2019–20 and Application to Participate for 2021–22 (FISAP) is now available on the Common Origination and Disbursement (COD) website.

Schools that had Campus-Based expenditures for the 2019–20 Award Year and schools that wish to request funding under the Campus-Based programs for the 2021–22 Award Year are required to electronically submit a FISAP via the COD website. The deadline for the electronic submission of the FISAP has been extended to 11:59 p.m. Eastern time (ET) Nov. 2, 2020. Transmission must be completed by midnight.

In a June 3, 2020 Electronic Announcement, schools were informed of the availability of the final 2021–22 FISAP Form, Instructions, Desk Reference and 2021–22 Technical Reference.

Supplemental FISAP Reporting Instructions due to the CARES Act/COVID-19 Emergency

  1. Schools that return more than 10% of their 2019–20 total (initial plus supplemental) Federal Work-Study (FWS) and/or Federal Supplemental Educational Opportunity Grant (FSEOG) programs allocation do NOT need to request an underuse waiver in Part II, Section C. Underuse penalties will not be applied on any 2021–22 FWS or FSEOG awards for all schools due to the impact of the COVID-19 emergency.

  2. Section 3503 of the CARES Act permits schools to transfer up to 100% of their unexpended FWS allocation to FSEOG. Any amount transferred must be reported in Part IV, Section B, Field 2, and Part V, Section B, Field 4a. Edits 08011, 09043, and 09190 may be prompted during the validation process (prior to submission). These are “soft” edits that will not prevent submission and can be explained using the option to “provide additional information.” A brief, one-line explanation will suffice to resolve the edits.

  3. Per Section 3503 of the CARES Act and guidance issued in a May 15, 2020 Electronic Announcement, an institution may reimburse itself from the FWS allocation for the nonfederal portion of wages paid to students on or after March 13, 2020. Likewise, an institution may, for all disbursements of FSEOG made on or after March 13, 2020, reimburse itself from the FSEOG allocation for the nonfederal portion of FSEOG awards contributed through a fund-specific match.

    The institutional share your school contributed for each program must be reported accurately in Parts IV and V, Section C, Field 13. Edits 08090, 08095, and 09220 may be prompted during the validation process. These are “soft” edits that will not prevent submission and can be explained using the option to “provide additional information.” A brief, one-line explanation will suffice to resolve the edits.

  4. Section 3504 of the CARES Act provides that a school may use any amount of its FSEOG allocation (including funds transferred from FWS) to award emergency financial aid grants to assist undergraduate or graduate students for unexpected expenses and unmet financial need as the result of a qualifying emergency. See a May 15, 2020 Electronic Announcement for more information.

    Emergency FSEOG payments must be reported in Part IV, Section F, Information about FSEOG Disaster-Affected Students. They should also be included within the total amount of Funds to FSEOG Recipients reported in Section C, as well as the Federal Funds Spent for the FSEOG Program in Section D.

    While emergency FSEOG payments should also be included in Part VI, Section A, Distribution of Program Recipients and Expenditures by Type of Student, note that any emergency payments made to graduate students cannot be included in this section.As a result, edit 11220 may be prompted during the validation process. This is a “soft” edit that will not prevent submission and can be explained using the option to “provide additional information.” A brief, one-line explanation will suffice to resolve the edit.

  5. Any FWS wages paid to students after they ceased working due to COVID-19, per Section 3505 of the CARES Act and the guidance provided in an April 3, 2020 Electronic Announcement, must be reported in Part V, Section K, Information about FWS Disaster-Affected Students.

General Reporting Reminders

  1. Updates to the FISAP and instructions have been outlined in a June 3, 2020 Electronic Announcement.

  2. Only Federal Pell Grant disbursements made from 2019–20 funds should be reported in Part II, Section E, Field 23. If crossover payments are made from 2020–21 funds, the disbursements should be reported in next year’s FISAP (Fiscal Operations Report for 2020–21 and Application to Participate for 2022–23).

  3. The financial aid and business office staff must coordinate efforts to reconcile and report accurately on the FISAP.

  4. If funds are drawn from G5 that exceed the amounts reported on the FISAP, a negative balance will result, and the school will need to return funds to G5.

    Example: If a school’s FWS authorized amount was $50,000 and the school reported an expended amount of $40,000 on its FISAP, the school’s award will be closed out at the expended amount of $40,000. If more than $40,000 has been drawn in G5, a negative balance for the amount over $40,000 will result and that amount must be returned.

  5. Appropriate Administrative Cost Allowance (ACA) should be calculated and claimed (see Volume 6 of the Federal Student Aid Handbook). After Dec. 15, 2020, schools are not permitted to make any additional claims to the ACA that were not previously reported on its FISAP.

    Note: No Federal Perkins Loan Program ACA is permitted to be claimed.

  6. Report the federal share of Perkins Loan funds that your school returned to the Department of Education in Part III, Section A, line 28.1 “Repayments of fund capital to federal government” (formerly line 28).

  7. Report the institution’s service cancellation reimbursement amount that your school was instructed to reimburse itself from the Perkins Fund in Part III, Section A, line 28.2 “Service cancelation reimbursement received on or after 07/01/2019.”

  8. Report the institutional share of Perkins Loan funds that you returned to your school in Part III, Section A, line 30.2 “Repayments of excess/liquidated fund capital to Institution.”

Contact Information

For additional information about the FISAP or the referenced documents, contact the COD School Relations Center at 1-800-848-0978. You may also email CODSupport@ed.gov.