Posted Date: March 15, 2013
Jeff Baker, Director, Policy Liaison and Implementation, Federal Student Aid
Subject: 2012-2013 Deadline Date Notice - Important Pell Grant Reporting Deadline Change
On February 28, 2013, we published a Federal Register notice that established the 2012-2103 award year deadline dates by which students and institutions must submit information to FSA's Central Processing System (CPS) and by which institutions must submit information to FSA's Common Origination and Disbursement (COD) System.
Among the deadlines that is established in the February 28, Federal Register notice, and in similar notices for previous award years, is the timeframe for when an institution must submit to COD Pell Grant and Direct Loan disbursement information, including adjustments to previously reported disbursements. For previous award years, the notice provided that institutions must submit such records to COD within 30 days of making the disbursement or the adjustment. The 2012-2013 award year Federal Register notice reduces that timeframe to 15 days for disbursements or adjustments made on or after April 1, 2013.1 Since for most institutions reporting disbursement information to COD is a highly automated process, requiring institutions to report disbursement and adjustment information within 15 days is not only reasonable, but accommodating to the important need for updated information as discussed more fully below.
While it has always been important for institutions to comply with the Pell Grant disbursement reporting requirements, the possibility that a student may exceed the limitation on Pell Grant eligibility because of the new Pell Grant duration of eligibility provisions established by the Consolidated Appropriations Act, 2012 (Public Law 112-74) makes it even more critical that reporting be done timely. Doing so will allow our systems to provide all institutions with more timely Lifetime Eligibility Used (LEU) information and prevent the possibility of an overpayment that would become the responsibility of the student.
Because of the importance of this issue, the February 28, 2013 Federal Register notice also included the following:
An institution's failure to submit disbursement records within the required timeframe may result in the Secretary rejecting all or part of the reported disbursement. In addition, such failure may result in an audit or program review finding.
1 We expect that the corresponding Federal Register notice for the upcoming 2013-2014 award will require all reporting to be made within 15 days.
In an August 13, 2012 Electronic Announcement concerning the timeliness of reporting of disbursement information to help avoid institutional and, more importantly student, liability for overpayments we provided examples of how and why it matters that institutions report Pell Grant information, not only within the timeframe established in the Federal Register, but even sooner. Therefore, to protect our students from the consequences of being required to repay Pell Grant funds simply because an institution did not submit records to COD as quickly as possible, we once again request that institutions report Pell Grant information as soon as possible and not wait until the end of the required 15 days that is established in this 2012-2013 notice.
Once again, we thank you for your continued support of our efforts to protect both the Federal taxpayer and our needy students.