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(Grants) Subject: Federal Pell Grant Program Reconciliation

Posted Date:January 2, 2014

Author: Sue O'Flaherty, Service Director, Program Management, Federal Student Aid

Subject: Federal Pell Grant Program Reconciliation

In a February 19, 2013 Electronic Announcement we published general information regarding Title IV Aid Disbursement Reporting, Excess Cash, and Reconciliation Requirements. In addition, updated disbursement reporting and data submission timelines for all programs were published in a recent Federal Register Notice (see Federal Register Volume 78, Number 130 published on July 8, 2013 for the 2013-2014 deadlines).

In this announcement, we provide specific information to assist your school in reconciling the Federal Pell Grant (Pell Grant) Program. Both the Financial Aid Office and Business Office should review the information provided below.

Pell Grant Reconciliation Defined

Pell Grant Reconciliation is the process by which a school reviews and compares Pell Grant data recorded on the Department of Education’s (the Department’s) systems with the information in the school’s internal records. This process should be performed on a regular basis, and is recommended at least monthly. There are two types of reconciliation, which can be performed separately or simultaneously during the month, including:

  • Internal Reconciliation

  • This is the reconciliation of disbursement transactions (actual disbursements and adjustments) and related cash transactions (Drawdowns, Drawdown Adjustments, Refunds of Cash, and Returns) between your Business Office records and Financial Aid system. If discrepancies are found, your school should document these and resolve them in a timely manner.

  • External Reconciliation

  • This is the reconciliation of internal disbursement and cash balances from the Business Office and Financial Aid Office with disbursement and cash balances from the Common Origination and Disbursement (COD) System. At a minimum, this reconciliation should be completed at least monthly to ensure that data is correct in all systems and that cash management and disbursement reporting timelines are being met. If you have completed your internal reconciliation first, your school will have fewer discrepancies to resolve when you perform this external reconciliation. The Department offers various tools to assist you with external reconciliation. More information about these tools is provided in the attachment to this announcement.

It is very important for schools to maintain good communication between the Business Office and the Financial Aid Office to successfully reconcile both internally and externally. Reconciliation is a shared responsibility. It requires joint action by the Financial Aid and Business Office to identify discrepancies and any missing data, and to correct these in a timely manner.

Schools should document their reconciliation process and the resolution of any identified discrepancies.

Final Reconciliation of a Pell Grant Award Year

In addition to regular monthly reconciliation of Pell Grant data, a final reconciliation should be performed as soon as possible after final scheduled disbursements have been made for the award year. This final reconciliation should ensure that all data is correct, and that Total Net Drawdowns equal Net Accepted and Posted Disbursements in the COD System (Cash > NAPD balances should equal $0.00). This process must be performed within the applicable data submission deadline (defined below), as well as immediately following processing of any additional data by the school (for example, eligible late disbursements or disbursement adjustments made within regulatory timeframes, but which occur after the data submission deadline). There are two deadlines which impact this process:

  • Data Submission Deadline –The datasubmission deadline is published annually in a Federal Register Notice. It is generally the end of September following the end of the award year. For example, the 2013-2014 Award Year will close on September 30, 2014. After this date, the COD System will not accept upward award or disbursement adjustments without prior approval for an extension to the established data submission deadlines (downward adjustments will continue to be accepted). If your school needs to request an extension to the data submission deadline, this request may be submitted via the COD Web site at

  • Funding Cancellation Deadline –Pell Grant fundingavailability is canceled five years after the data submission deadline for the award year. For example, for the 2008-2009 Federal Pell Grant Award Year (July 1, 2008 - June 30, 2009), the funding cancellation date is September 30, 2014 [2009 + 5 = 2014]. After that time, schools will be unable to draw down or adjust further funds via G5 (although refunds of cash will still be accepted), and the COD System will be completely closed to any further award or disbursement processing for that award year. As such, schools must complete all final reconciliation activities well before this final deadline and in accordance with disbursement reporting timelines and the data submission deadline defined above.

Contact Information

For additional information on Pell Grant Program Reconciliation, refer to the attached Questions and Answers document. If you have questions about this announcement or its attachment, contact the COD School Relations Center at 800/474-7268. You may also e-mail

Last Modified: 01/01/2014