Awarding Summer Federal Work Study Presented by: Sam Veeder EASFAA President University of Rochester

Agenda Regulatory Considerations Resources Institutional Budgets Student Budgets Payroll FISAP Reporting Requirements School Example Resources

Institutional Budgets Matching Requirements Transfers to/from Federal Work Study Carry Forward and Carry Back of FWS 2017-18 FSA Handbook, pgs. 6-9 through 6-18

Matching Requirements Federal Share may not exceed 75% of wages, except… Up to 90% for up to 10% of students at private non-profit organization or federal, state, local public agency Up to 50% for private for-profit employer Up to 100% for reading/math tutor, family literacy, civic related, and for schools eligible under 34 CFR parts 606-609

Program Transfers From Work Study to SEOG or Perkins Can Transfer up to a total of 25% of annual (initial plus supplemental) FWS allocation to SEOG and/or Perkins FWS funds carried forward or back do not change the basis for the 25% maximum transfer 2017/18 FSA Handbook page 6-12

Program Transfers From SEOG to FWS SEOG FWS Perkins 25% 25% Can transfer up to a total of 25% of SEOG allocation to Federal Work Study SEOG FWS Perkins 25% 25%

Carry Forward/Carry Back Carry Forward up to 10% of current year FWS allocation to cover next award year expenditures Funds carried forward must be spent before the institution spends current year allocation 34 CFR 675.18(b) Carry Back up to 10% of current year FWS allocation to cover expenditures incurred in the previous award year 34 CFR 675.18(c)

Carry Back for Summer Employment Carry back and expend in prior award year any portion of FWS allocation for the current year to pay student wages earned on/after May 1st but prior to July 1 34 CFR 675.18(f) This carry back for summer employment is in addition to the 10% carry back

Student Budgets All Enrolled students Enrolled Less than Half-time Non-Enrolled students “Developing the Cost of Attendance” NASFAA Monograph, 6/07, Number 20 HEA Section 472 2017/18 FSA Handbook page 3-35

All Enrolled Students COA - EFC = Need Summer can be a header or trailer Same EFC for FWS and other Title IV programs (except Pell) Consistency for periods that cross over award years (See Chart in 2017/18 FSA Handbook page 3-155)

Enrolled Less than Half-time Can provide Pell and Campus Based aid to less than 1/2 time students 2017/18 FSA Handbook pgs. 3-35 through 3-38 DCL GEN 06-05 HEA Section 472 (4) COA - EFC - Need Need - other resources = Maximum FWS award COA includes: Tuition/fees, books/supplies, Transportation, dependent care expenses, room/board (school option) for no more than 3 semesters – 2 consecutive (exclude misc. expenses)

Non-Enrolled Students “The principal behind awarding FWS for periods of non enrollment is that earnings during this period will assist with upcoming year educational costs. Technically, FWS funds are not awarded for periods of non-enrollment. Instead, they are awarded for the upcoming period of enrollment. Many of the restrictions governing FWS awards for periods of non-enrollment stem from this principle.” “Awarding FWS for Periods of Non-Enrollment” NASFAA Q&A, 5/14/98 FWS Periods of Non-Enrollment Q & A’s https://cbfisap.ed.gov/ecb/faq/main_content.html (page 16)

Expectation of Enrollment When awarding FWS during periods of non-attendance, school is required to document student’s eligibility for FWS and that the school had reason to believe the student intended to enroll for the upcoming semester. What if the student does not enroll? At a minimum, must have written documentation the student accepted offer of admission for the upcoming semester. CB-97-12, July 1997 2017/18 FSA Handbook, 3-141 and 6-29

Awarding Non-Enrolled Students Always awarded as a header – eligibility calculated using upcoming year’s COA and EFC. 2017/18 FSA Handbook pg 3-141 Student’s attributed earnings must be counted as resource when packaging for upcoming year – also called “net earnings” 675.25

Net, or Attributed, Earnings Actual gross FWS earnings - Taxes (actually paid) - Job related costs (Job related costs - uniforms, transportation to/from work, room and board only if costs are incurred solely for purpose of the FWS job, and other reasonable costs directly related to the student’s employment) = Net FWS earnings Resultant net, or attributed, earnings must be applied to COA for the next enrollment period 2017/18 FSA Handbook pg 3-140 through 3-141 & 6-30

Determining Award Year for Crossover Periods When awarding FWS for a period that “crosses over” two fiscal years, must consider both the award year to use for student budget and award year to use for paying student. Can be different! 2017/18 FSA Handbook 3-154 and 4-43

Paying Students FWS students must be paid for all hours worked 2017/18 FSA Handbook 6-30; Fair Labor Standards Act Wages are earned when student performs work When payment period crosses over two award years… pay for hours worked prior to 7/1 from prior year’s FWS allocation pay for hours worked on/after 7/1 from the upcoming year’s FWS allocation 2017/18 FSA Handbook, pg 4-43

FISAP Reporting Requires breakdown of campus based fund expenditures by program 2017/18 FSA Handbook pg. 6-32 – 6-38

FISAP Reporting If students are paid FWS wages, must report this information on FISAP: Must have valid ISIR for year earned FWS Place student on income grid Report original plus supplemental FWS allocation and any funds returned Report funds transferred to/from FWS, and any funds carried forward and/or carried back Carry back for summer employment is listed separately Report total number of students worked and amount earned Remember to track community service and tutors separately May take administrative cost allowance

School Example Awesome Law School Institutional Budget Student Budgets Paying Students FISAP Student Forms

Institutional Budget Awesome Law School given FWS budget for fiscal year by main aid office Majority of FWS budget for law students used during summer months (May – Aug) Awesome Law School awards FWS for 4 award periods: Fall Spring Summer I (mid-May to June 30) Summer II (July 1 to mid-August)

Student Budgets Different process for categories below: Not Enrolled Enrolled Less than ½ time Determine which category student fits into, then develop budget and award aid based on the requirements for that category of student.

Non-Enrolled Students Requirement is that student must be planning to re-enroll for fall Student signature on Summer FWS request form, states student must return in fall and earnings from summer will be used as resource for upcoming year (which could reduce loan eligibility). Requests to transfer? Always reviewed as a header FWS eligibility determined using upcoming year’s COA and EFC e.g. Fall/Spring COA - 9 month EFC Financial Need (FWS eligibility)

Non-Enrolled Students, Net Earnings When awarding Fall/Spring aid, must use the student’s net, or attributed, FWS earnings from the summer (period of non-attendance) as a resource. How does Awesome Law School Handle This? FA/SP awards are made in June – before actual summer earnings are known Our students’ need is usually high enough that we can count entire summer FWS award ($5000) as resource w/out effecting FA/SP aid. When students apply for a GPLUS/private loan up to COA is when we use net earnings. Once summer hours completed, get actual earnings from payroll, subtract any documented costs related to summer FWS job (most common – T pass/parking, rent if stayed in town solely for job and provide lease agreement). Use FA/SP COA minus all other FA/SP aid minus net earnings to determine maximum amount of GPLUS/private loan.

Enrolled Students FWS can be awarded as header or trailer Must use same year’s EFC for FWS and loans Awesome Law School uses borrower-based academic year for Direct loans – determine loan period and use same award year and EFC for loan as FWS e.g. SU/FA Stafford Loan uses SU/FA COA and upcoming year’s EFC for both loan and FWS e.g. SP/SU Stafford Loan uses SP/SU COA and previous year’s EFC for both loan and FWS e.g. Summer only can use either EFC for both loan and FWS

Enrolled Less than Half-time Awesome Law School students are almost always at least ½ time Can award FWS as header or trailer – using either year’s EFC Award using COA – EFC = Need COA can include: Tuition and fees Room/Board Books and supplies Transportation Dependent care expenses Cannot include misc. expenses

Paying Students Students must be paid from the award year in which the funds were earned – regardless of when timesheet submitted! At Awesome Law School, once student accepts FWS award and notifies us of the employer, student is given FWS Information Packet to be completed before work begins Law students earn $12/hour Must pay student for hours earned even if over award amount

FISAP Reporting The law school provides for the bulk of Awesome’s 7% community service requirement for FWS Awesome Law School policy: All law students must work in a law-related position. Eligible jobs include research assistant for professors, public interest work for federal, state, local public agencies or private non-profit organization. Caveat! If awarded FWS to a student based on upcoming year’s FAFSA and student begins work prior to July 1st and has not filed FAFSA before, how report on FISAP? Earnings prior to July 1st must be paid from prior year allocation and reported on prior year FISAP But…no FAFSA for student. How place on income grid? Per Dept of Ed, use upcoming year’s ISIR information (that student was awarded from) for completion of the prior year’s FISAP. But…not in writing??

Additional Resources FWS Recordkeeping Requirements 2017/18 FSA Handbook 6-29 through 6-32 NASFAA Answers Summer Financial Aid Questions NASFAA News 6/9/03 Policies and Procedures Templates Dept of Ed – Section 5 NAFSAA – Sections 3.3.1; 7 and 8.8 NASFAA Self Evaluation Guide – FWS section FSA Assessments – FWS section Federal Register – Part 675