Is your school having trouble drawing down federal student aid for any of its locations? Earlier this month, the General Services Administration (GSA) as well as the U.S. Department of Education (ED) officially discontinued the use of the Data Universal Numbering System (DUNS) number and began recognizing the Unique Entity Identifier (UEI) as the authoritative identifier for all entities doing business with the federal government. We have heard from a number of clients that their UEI is still in a pending status in GSA’s System for Award Management (SAM) website. The result is that they have been unable to process disbursements in ED’s Common Origination and Disbursement (COD) system or draw down funds in G5 – ED’s delivery system for program award and payment administration.
While we do not have a solution for this problem, we do want to take this opportunity to remind schools about the rules pertaining to late disbursements of federal student aid. Some of our clients have expressed concern that the UEI issue will not be fixed by the time a student completes or withdraws from their program. This is generally the date that a student is considered to become ineligible for Title IV funds. In order for these students to be eligible for a late disbursement of Direct Loan funds, the school must have originated the loan award prior to the student becoming ineligible. This “date of origination” stipulation is often misinterpreted. Many schools believe this is the date the loan record was originated/accepted in COD (which is currently not operational for schools with pending UEI’s), however ED has confirmed that the date of origination is actually the date a school creates the electronic loan origination record in its (meaning the school’s) computer system. If you can document that an electronic loan origination record was created prior to a student’s graduation or withdrawal date, you satisfy the date of origination component required for making a late disbursement of Direct Loans (as long as all other late disbursement requirements are met).
Feel free to contact M&A with any questions on the conditions for late disbursements.
Do you know how the recently completed Negotiated Rulemaking session for Institutional and Programmatic Eligibility will impact your institution? Click here to find out.
