Forum topic

Hello, 

I want to understand better what you define as disbursing.   Currently Financial Aid can authorize payments only and they are sent over to Student Accounts. This is for all funds not just Title IV funding.  Student Accounts is the only entity that has the ability to approve funds being applied to the students accounts (disbursed). It was my understanding that Cindy is not doing any of the disbursing of the funds on the student account only authorizing payments. There is a handshake where Cindy selects the authorized payments and this goes over to student accounts to have a different person to approve or reject.  In the case of Title IV funding there is an additional layer of disbursement which is the release of funds to the school through the G5 system which is not handled in Gnecsis and thus I do not know who completes this process.  

The question is what specifically would you like to have changed in the process? 

Below is the applicable Title IV regulations.

2021FSAHbkVol4 - 4–198 

Federal regulations require a school to separate the functions of authorizing payments and disbursing funds so that no single office or individual exercises both functions for any student receiving FSA funds. Even very small institutions with limited staff are not exempt from this requirement. These two functions must be performed by individuals who are not members of the same family 1 , who do not together exercise substantial control over the school, and who are organizationally independent. Individuals responsible for authorizing or disbursing FSA funds may not do both, but they may perform other functions. If these functions are done by computer, no one person may have the ability to change data that affect both the authorization and disbursement of FSA funds.

Typically, the financial aid office is responsible for authorizing disbursements by awarding aid through the need analysis and packaging processes. Awards are then turned over to a business office that typically requests funds from ED’s Grant Administration and Payment System (G5), and disburses the funds by crediting student accounts, delivering checks to students, authorizing an EFT, or delivering cash to students. The person (or office) that awards FSA funds may not sign checks or deliver them to students, nor be permitted to disburse cash to students, or to credit student accounts with FSA funds to cover allowable costs (such as tuition, fees, books, supplies, or other authorized charges). There should also be a separation of functions within the business office. This separation should provide that the individual within the school who reconciles federal cash does not also receive federal cash or disburse it. This will ensure that several individuals at the school evaluate federal funds and, at each step of the process, the applicable regulations are being followed. The person performing reconciliations should receive bank statements and Direct Loan reconciliation reports directly from the respective, appropriate sources. Supervisory approval of the completed reconciliations should also be obtained and documented on the forms. While electronic processes enhance accuracy and efficiency, they also can blur separation of functions so the awarding and disbursement occur virtually simultaneously. Schools must set up controls that prevent an individual or an office from having the authority (or the ability) to perform both functions. In addition, your system also should have controls that prevent cross-functional tampering. For example, financial aid office employees should not be able to change data elements that are entered by the registrar’s office. Finally, your system should only allow individuals with special security classifications to make changes to the programs that determine student need and awards, and it should be able to identify the individuals who make such changes.

You have 4 Aid sources set to Aid Source Type: Government. (Listed below).  Would it work that the developers add a additional security group setting that if checked would not allow a Student Accounts Access person to set the disbursement if the disbursement contained any aid source that was designated as government?

This should work. If you only want to be restricted for Title IV aid then we might want to split out Title IV and Government for the Aid Source Type.  Then we can restrict just Title IV and allow Government to not have the disbursement restriction.  Let me know if you think this will work.

Covid Relief

Department of Defense Tuition Assistance Program

Federal Direct Unsubsidized Stafford

VA Tuition Reimbursement

An update for this will be included in the next release, later this week.