Professional Documents
Culture Documents
CHAPTER
11
Standards
In this chapter, we discuss the financial standards
schools must maintain to participate in the FSA programs.
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GENERAL STANDARDS
Proprietary or private nonprofit institution
A proprietary or private nonprofit institution is financially
responsible if the Department determines that
Composite score
Ratios cite The composite score standard combines different measures of
34 CFR 668.171(b)(3) fundamental elements of financial health to yield a single measure of a
school’s overall financial health. This method allows financial strength
Use of long-term debt in in one area to make up for financial weakness in another area. In
financial responsibility calculation addition, this method provides an equitable measure of the financial
In DCL: GEN-03-08, July 15, 2003 the health of schools of different sizes.
Department revised the treatment of long-
term debt as currently described in Note: When a change in ownership occurs, the Department applies
34 CFR 668.172(b) and Appendices A and B
the standards in 34 CFR 668.15.
to Subpart L of 34 CFR Part 668. In
calculating its Primary Reserve Ratio, an
institution may now include “all debt
The composite score methodology takes into account the
obtained for long-term purposes” in its differences between proprietary institutions and private nonprofit
calculation. institutions. The variance takes into account the accounting
differences between these sectors of postsecondary institutions.
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However, the basic steps used to arrive at the composite score are the
same. For complete information on the calculation of the composite
score, schools should refer to Appendices A and B of Subpart L in the
General Provisions regulations.
The Department issued guidance on the treatment of long-term and Treatment of long-term debt cite
other debt in calculating these ratios in DC-GEN-01-02. That DC GEN 03-08, July 2003
guidance was updated in DC-GEN-03-08. Under this revised 34 CFR 668, Subpart L, Appendices A & B
guidance for the Primary Reserve Ratio calculation, all long-term
debt obtained for the institution's purposes may be included.
However, it is important to note that the overall level of debt obtained
for long-term purposes that can be included in the numerator of the
New
Primary Reserve Ratio is limited under the regulations. It cannot
exceed the amount of the institution's net property, plant, and
equipment.
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The example below illustrates the calculation of a composite score
for a proprietary institution.
Modified Equity
___________________ $810,000
___________
Equity Ratio = = = 0.332
Modified Assets $2,440,000
Composite Score
Sum of All Weighted Scores
0.480 + 0.797 + 0.809 = 2.086 rounded to 2.1
*The definition of terms used in the ratios and the applicable strength factor algorithms and weighting percentages
are found in the Student Assistance General Provisions (regulations) (34 CFR 668) Subpart L, Appendix A for
proprietary institutions and Appendix B, for private nonprofit institutions.
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Once a composite score is calculated, it is measured along a
common scale from negative 1.0 to positive 3.0 as indicated in the
chart below. This scale reflects the probability a school will be able to
continue operations and meet its obligations to students and the
Department.
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Making new awards with 1. deposited or transferred the funds into the bank
returned funds account it maintains for federal funds no later than 30
After a school has returned unearned days after the date it determines that the student
funds to its federal account, provided those withdrew;
funds were originally received from the
Department or from an FFEL lender under a
An institution that maintains a separate federal bank
process that allows the institution to reuse
the unearned funds, the school can use the
account must deposit to that account, or transfer from
funds to make disbursements to other its operating account to its federal account, the amount
eligible students. of unearned program funds, as determined under the
Return of Title IV funds regulations. The date the
institution makes that deposit or transfer is the date
used to determine whether the institution returned the
funds within the 30-day timeframe permitted in the
regulations.
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Compliance thresholds
The Department provides for a small margin of error in
determining that a school has paid all required refunds and
returns on time. The Department considers a school to have paid
returns in a timely manner if:
Letter of credit
Public institutions and institutions covered by a state tuition
recovery fund are not subject to the letter of credit requirements.
If any other institution exceeds the compliance thresholds in
either of its two most recently completed fiscal years, the institution
must submit an irrevocable letter of credit acceptable and payable
to the Department. The letter of credit must be equal to 25% of
the returns the institution made or should have made during its
most recently completed fiscal year.
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2. it did not fail to make timely returns.
An institution that submits an appeal, together with all
required supporting documents by the date the letter of credit
would be due is not be required to submit a letter of credit unless
the Department notifies the institution that its request has been
denied.
Public schools
A public school is financially responsible if its debts and liabilities
are backed by the full faith and credit of the state or other government
entity. The Department considers a public school to have that backing
if the school notifies the Department that it is designated as a public
school by the state, local, or municipal government entity, tribal
authority, or other government entity that has the legal authority to
make that designation. The school must also provide the Department
with a letter from an official of the appropriate government entity
confirming the school’s status as a public school. A letter from a
government entity may include a confirmation of public school status
for more than one school under that government’s purview. The letter
is a onetime submission and should be submitted as a separate
document.
Public schools also must meet the past performance and affiliation
standards discussed below, and must submit financial statements
prepared in accordance with generally accepted accounting principles
(GAAP) and prepared on the accrual basis. Public schools’ audits,
financial statements, and letters confirming their status as public
institution are submitted through the Department’s eZ-AUDIT
Electronic Financial Reporting System (see chapter 11) .
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Zone alternative
A participating school that fails to meet the composite score
standard (i.e., has a composite score of less than 1.5) but meets all
other standards may demonstrate financial responsibility for up to
three consecutive fiscal years if the Department determines that the
school’s composite score is equal to 1.0 to 1.4 for each of those years
and the school meets specific monitoring requirements.
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improve its financial condition to attain a composite score of at least
1.5 by the end of the three-year period, the school must satisfy another
alternative standard to continue participating. In addition, if a school
fails to comply with the information reporting or payment method
requirements, the Department may determine that the school no
longer qualifies under this alternative.
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determined by the Department. (This amount must be equal
to at least 10% of the FSA program funds received by the
school during its most recent fiscal year.)
The school must comply with the requirements under the zone
alternative.
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The Department may consider a school that does not meet this
requirement to be financially responsible if the school:
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FINANCIAL STATEMENTS
All financial statements are received by the Document Receipt and
Control Center (DRCC) through the Department’s eZ-AUDIT
Electronic Financial Reporting System. The Department screens
financial statements it receives, makes a preliminary calculation of a
school’s composite score, and based on a checklist of minimum
requirements, determines whether the statements are materially
complete. In some cases a school may receive a more thorough
analysis of its financial statements.
FOREIGN SCHOOLS
Unless a participating foreign school received less than $500,000
(in United States dollars) in FSA program funds during its most
recently completed fiscal year, the school must meet the financial
responsibility standards for domestic schools. A foreign school that
received $500,000 or more in FSA program funds during its most
recently completed fiscal year must have its audited financial statement
prepared in accordance with U.S. Generally Accepted Accounting
Principles (GAAP) and audited in accordance with Generally
Accepted Government Auditing Standards (GAGAS). In addition, the
school’s financial statement must be submitted in English.
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