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(General) Subject: Title IV Aid Disbursement Reporting, Excess Cash, and Reconciliation Requirements

Posted Date:February 19, 2013

Author: William Leith, Service Director, Program Management, Federal Student Aid

Subject: Title IV Aid Disbursement Reporting, Excess Cash, and Reconciliation Requirements

In this announcement, we remind schools of the general disbursement reporting, excess cash, and reconciliation requirements for all Title IV programs. Because these requirements apply to disbursement and financial data, both the Financial Aid Office and Business Office should review the information provided below.

Disbursement Reporting Requirements

The disbursement and disbursement adjustment reporting requirements for all Title IV aid are announced in an annual Notice published in the Federal Register. The most recent Notice, published on June 29, 2012, specifies that a school must submit disbursement records no later than 30 days after making the disbursement or becoming aware of the need to adjust a student's previously reported disbursement.

Note: Please monitor the Information for Financial Aid Professionals (IFAP) Web site for the upcoming annual Federal Register Notice announcing disbursement reporting deadlines. Publication of the annual Notice is imminent.

Excess Cash Requirements

The Department of Education (the Department) 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 an additional 7 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 additional 7-day period.

See 34 CFR 668.162 for the federal regulations that govern requesting funds for the Title IV programs and 34 CFR 668.166 for the excess cash regulations.


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 with the information in the school's internal records. 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.

If completed on a regular basis, reconciliation can assist schools in determining whether the disbursement reporting and excess cash deadlines noted above are being met, and also whether any additional data needs to be submitted to ensure all school data is reflected correctly in the Department's records. For the Direct Loan program, schools must reconcile at least monthly to meet regulatory requirements.

Additional guidance about reconciliation for specific Title IV aid programs will follow in coming months. Schools can also refer to the Blue Book (Volume 5) or the .

Final Reconciliation

If a school is meeting all disbursement/adjustment reporting, excess cash, and reconciliation requirements, a final reconciliation should begin no later than the last award or payment period end date at the school for a given program and year. A school should be able to reconcile to a zero ending cash balance soon after its final disbursements and should not carry an ending cash balance (positive or negative) for an extended period.

Contaor an extended period.

Contaement reporting, excess cash, or reconciliation questions specific to the Federal Pell Grant or Direct Loan programs, contact the COD School Relations Center at 800/474-7268 for Grants and 800/848-0978 for Direct Loans. You may also e-mail

For reconciliation questions specific to the Federal Work-Study, Federal Supplemental Educational Opportunity Grant, or Federal Perkins Loan programs, contact the Campus-Based Call Center at 877/801-7168. You may also e-mail

Last Modified: 02/18/2013