Mapping Your Future: A time of peace, love, and reconciliation requirements


A time of peace, love, and reconciliation requirements

By Catherine Mueller

December 12, 2018

Not to dampen anyone's holiday mood, but the Department of Education issued a reminded schools this week of the general disbursement reporting, excess cash, and reconciliation requirements for all Title IV programs.

In a December 10 Electronic Announcement, the Department of Education said both the business office and the financial aid office should review the requirements.

Disbursement reporting requirements

The disbursement and disbursement adjustment reporting requirements for all Title IV aid are announced in an annual Federal Register Notice. The most recent Federal Register Notice, published on December 4, specifies that a school must submit disbursement records no later than 15 days after making the disbursement or becoming aware of the need to adjust a student's previously reported disbursement.

Excess cash requirements

The Department of Education considers excess cash to be any amount of Title IV funds (other than Federal Perkins Loan Program funds) that a school does not disburse to students or parents by the end of the third business day after the date the school (1) received the funds from the Department, or (2) deposited or transferred to its federal account previously disbursed Title IV funds received from the Department. In some circumstances, cash may be held for up to seven calendar days if a school meets the excess cash tolerance and can disburse the aid to students within that time frame. In no circumstance should cash balances remain beyond the seven-day period.


Reconciliation is the process by which a school reviews and compares Title IV aid (grants, loans, and campus-based aid) recorded on the Department's systems (COD/G5) with the information in the school's internal records. Schools should reconcile both internally (between Business Office and Financial Aid Office data) and externally (between school data and the COD System/G5). Through reconciliation, disbursement and cash discrepancies are identified and resolved in a timely manner to ensure the school meets all regulatory requirements. Schools must document their reconciliation efforts and retain this documentation for auditing purposes.

More information

For disbursement reporting, excess cash, or reconciliation and processing questions, contact the COD School Relations Center at 1-800-848-0978. You also may email