Requirements for Title IV disbursement reporting, excess cash, and reconciliation

By Marlene Seeklander

Woman Writing on a Notebook Beside Teacup and Tablet Computer

College financial aid and business professionals manage many critical responsibilities. Among those responsibilities are the requirements for disbursement and financial data.

In a January 8 Electronic Announcement, the Department of Education outlined the key components of the disbursement and financial data requirements. More detailed information on each is included in the announcement.

  • Disbursement Reporting Requirements – A school must submit disbursement records no later than 15 days after making the disbursement or becoming aware of the need to adjust a previously reported disbursement.
  • Excess Cash Requirements – Any excess cash not disbursed to students or parents by the third business day may be held for up to seven calendar days.
  • Reconciliation – Regulations require schools to reconcile at least monthly for the Direct Loan programs and campus-based programs and schools are encouraged to reconcile Pell Grant and TEACH Grant programs. Reconciliation is the comparison of internal data (business office and financial aid data) and external data (between school data and the COD System/G5) to identify any issues or discrepancies.
  • Final Reconciliation – A final reconciliation should start no later than the last award or payment period end date for a given program and year in order for a school to reconcile to a zero-ending cash balance. Closeout can then be confirmed through the “School Balance Confirmation” page on the COD website for Direct Loan, Pell Grant, and TEACH Grant programs.

Questions regarding disbursement reporting, excess cash, or reconciliation and processing should be directed to the FSA Partner and School Relations Center at 1-800-848-0978 or by email to CODSupport@ed.gov.

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