Administrative Capabilities

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Policy Number:

UW-1036

Old Policy Number:

OSFA 201

Responsible Office:

Office of Student Financial Aid

University Policy

Rationale/​Purpose:

To participate in any Title IV, Higher Education Act (HEA) program, UW-Madison must demonstrate the institution is capable of properly managing each Title IV program it administers while educating and preparing students. UW-Madison establishes and maintains such administrative and fiscal procedures and records as necessary to ensure proper and efficient administration of funds received under the Title IV, HEA programs.

This policy demonstrates UW-Madison’s administrative capability through its identification of the institution’s Financial Aid Administrator, fiscal and cash management, third party servicer relationships, and records retention.

Scope:

The administration of federal, state, institutional, and outside aid offered to UW-Madison students through the Office of Student Financial Aid.

Policy:

Financial Aid Administrator and Staff

UW-Madison and the Office of Student Financial Aid (OSFA) designates the Director of Financial Aid as a capable individual responsible for administering and coordinating Title IV, HEA programs with the institution's other Federal and non-Federal financial assistance programs. The individual is identified on the institution's Eligibility and Certification Approval Report (ECAR) and the Program Participation Agreement (PPA).

OSFA uses an adequate number of qualified persons to administer the Title IV, HEA programs as well as all other state of Wisconsin and institutional aid programs considering the following:

• Number and types of aid programs participated in at UW-Madison
• The number of applications evaluated
• The number of students who receive any student financial assistance and the amount of funds administered
• The student information system (SIS) used by OSFA
• The degree of automation used in the administration of all financial aid programs
• The number and distribution of financial aid staff
• The use of third-party servicers to aid in the administration of all financial aid programs

Separation of Duties

There exists a clear and separate division of responsibility for the administration of Title IV funds at UW-Madison. Title IV, HEA programs are administered with adequate checks and balances in UW-Madison's system of internal controls, and the functions of authorizing payments and disbursing funds are divided between the Office Student Financial Aid and the Bursar’s Office. One office does not have the sole responsibility of both functions.

Records Retention

UW-Madison follows the policies spelled out in the University’s program participation agreement by maintaining such administrative and fiscal procedures and records as may be necessary to ensure proper and efficient administration of funds received under the Title IV, HEA programs, together with assurances that UW-Madison will provide, upon request and in a timely manner, information relating to the administrative capability and financial responsibility of UW-Madison. These include:

• Program eligibility to participate in Title IV programs
• Fiscal records of Title IV program transactions
• Eligibility to receive aid programs
• Systematic and organized records readily available for review by the Secretary of Education

Retention of records designated by the Secretary of Education

Fiscal and Cash Management

UW-Madison uses the Advance Payment Method and disburses Title IV aid prior to drawing down federal funds from the U.S. Department of Education’s G5 portal.

3^rdParty Servicers

UW-Madison exercises caution in selecting third-party servicers, financial aid consulting services, financial aid management systems (software), and/or the electronic data storage systems it utilizes to assist in the administration of the Title IV programs.

• Regardless of whether an entity is considered a third-party servicer for Title IV purposes, UW-Madison has a fiduciary responsibility to ensure the policies, procedures, products, and systems that the servicer utilizes are compliant with applicable laws and regulations.
• UW-Madison must have access to all records (paper or electronic) created or maintained by a third-party servicer and make those records readily available to any auditing or review entity (Legislative Audit Bureau, U.S. Department of Education, etc.) to review upon request.
• UW-Madison must implement appropriate safeguards to protect student records and ensure any information shared from education records is only used for the purpose(s) for which the information was disclosed.
• UW-Madison will be held responsible for any liability incurred as a result of software deficiencies, incorrect consulting advice, lost or damaged records, and/or third-party servicer violations.

External References:

34 C.F.R. § 668

34 C.F.R. § 674.19(e)

34 C.F.R. § 675.19(b)

34 C.F.R. § 676.19(b)

34 C.F.R. § 682.610(b)

34 C.F.R. § 685.309(c)

34 C.F.R. § 686.38

34 C.F.R. § 690.82(a)

Policy Administration

Approval Authority:

Director of Student Financial Aid

Policy Manager:

Associate Director for Federal Awards

Contact:

Associate Director for Federal Awards -- Shane Maloney, shane.maloney@wisc.edu, (608) 262-3384

Revised Dates:

01-01-2020

Reviewed Dates:

01/01/2020

Retrieved:

04-27-2024 02:36:55