How Are COVID-19 Related FSEOG and FWS Expenditures Reported On the FISAP?

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For guidance on how schools should report FSEOG and FWS expenditures as a result of COVID-19 and the CARES Act on the FISAP, see the August 3, 2020 Electronic Announcement, which reads in part:
 

  1. Schools that return more than 10% of their 2019-20 total (initial plus supplemental) Federal Work-Study (FWS) and/or Federal Supplemental Educational Opportunity Grant (FSEOG) programs allocation do NOT need to request an underuse waiver in Part II, Section C. Underuse penalties will not be applied on any 2021-22 FWS or FSEOG awards for all schools due to the impact of the COVID-19 emergency.
     

  2. Section 3503 of the CARES Act permits schools to transfer up to 100% of their unexpended FWS allocation to FSEOG. Any amount transferred must be reported in Part IV, Section B, Field 2, and Part V, Section B, Field 4a. Edits 08011, 09043, and 09190 may be prompted during the validation process (prior to submission). These are “soft” edits that will not prevent submission and can be explained using the option to “provide additional information.” A brief, one-line explanation will suffice to resolve the edits.
     

  3. Per Section 3503 of the CARES Act and guidance issued in a May 15, 2020 Electronic Announcement, an institution may reimburse itself from the FWS allocation for the nonfederal portion of wages paid to students on or after March 13, 2020. Likewise, an institution may, for all disbursements of FSEOG made on or after March 13, 2020, reimburse itself from the FSEOG allocation for the nonfederal portion of FSEOG awards contributed through a fund-specific match.
     

    The institutional share your school contributed for each program must be reported accurately in Parts IV and V, Section C, Field 13. Edits 08090, 08095, and 09220 may be prompted during the validation process. These are “soft” edits that will not prevent submission and can be explained using the option to “provide additional information.” A brief, one-line explanation will suffice to resolve the edits.
     

  4. Section 3504 of the CARES Act provides that a school may use any amount of its FSEOG allocation (including funds transferred from FWS) to award emergency financial aid grants to assist undergraduate or graduate students for unexpected expenses and unmet financial need as the result of a qualifying emergency. See a May 15, 2020 Electronic Announcement for more information.
     

    Emergency FSEOG payments must be reported in Part IV, Section F, Information about FSEOG Disaster-Affected Students. They should also be included within the total amount of Funds to FSEOG Recipients reported in Section C, as well as the Federal Funds Spent for the FSEOG Program in Section D.
     

    While emergency FSEOG payments should also be included in Part VI, Section A, Distribution of Program Recipients and Expenditures by Type of Student, note that any emergency payments made to graduate students cannot be included in this section. As a result, edit 11220 may be prompted during the validation process. This is a “soft” edit that will not prevent submission and can be explained using the option to “provide additional information.” A brief, one-line explanation will suffice to resolve the edit.
     

  5. Any FWS wages paid to students after they ceased working due to COVID-19, per Section 3505 of the CARES Act and the guidance provided in an April 3, 2020 Electronic Announcement, must be reported in Part V, Section K, Information about FWS Disaster-Affected Students.

Refer to the August 3rd announcement for additional general FISAP reporting guidance. Also refer to the Online Training Module – Completing the 2021–22 FISAP for assistance. Specific questions must go directly to the COD School Relations Center at 1-800-557-7394 and  CODSupport@ed.gov.

According to guidance NASFAA has received from the U.S. Department of Education (ED), even though the FISAP submission deadline has been extended, the reporting year remains the same. The school should still report on campus-based program activity from July 1, 2019 through June 30, 2020.

Note About Deadlines: According to the July 10, 2020 Electronic Announcement, "The Department is extending the deadline for submission of the 2021-2022 FISAP until November 2, 2020. The December 15, 2020 deadline for submission of FISAP edit corrections and the Perkins Cash on Hand Update remains unchanged." Normal award year processing deadlines announced in the November 1, 2019 Federal Register continue to apply.

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