Q&As on Reporting 2009-10 FWS Funds from ARRA

NASFAA has received a number of questions about ARRA reporting of 2009-10 FWS funds. The Department of Education's Oct. 10 guidance regarding treatment of the first 2009-10 draw downs is key. ED points out that you do not base reporting on payments to students, but rather on drawdowns from ED's G5 system, applying the formula provided by ED. Here are some questions we have received and the answers based on ED's guidance and some follow-up discussions we have had with the Department.

Must I exclude the ARRA portion of my allocation to figure out how much FWS I can transfer, carry forward or back, use for JLD, etc.?

No. Your allocation is the total of the ARRA portion and the regular portion, and any supplemental funds you received. That total is what you use to determine the amounts available for optional uses such transferring to FSEOG or carrying to another year.

If I used my first draw to carry 2009-10 funds back to 2008-09, does that count for ARRA reporting?

Yes. It does not matter what you use the drawdown for, the first 2009-10 funds you draw down are considered attributable to the ARRA portion. You continue reporting until you reach the amount ED has told you represents ARRA funds.

If I carried funds forward from 2008-09 into 2009-10, how is my ARRA reporting affected?

You must use up your 2008-09 funds before you can start drawing on your 2009-10 allocation, as has always been the case. ARRA reporting applies only to 2009-10 funds. Once you have used up your 2008-09 carry forward, your first drawdowns from your 2009-10 allocation begin your ARRA reporting.

My institution uses its own funds at first to make FWS payrolls and does not begin drawing down federal funds until later. Do I report the disbursements I made with institutional funds?

No. Although for the most part institutional funds labeled as Title IV program payments are considered Title IV disbursements (some exceptions are made based on timing), you have not drawn down any of your federal allocation. Only funds that you draw down from your 2009-10 federal allocation are reported as ARRA spending.

Posted 10/14/09 to www.NASFAA.org. Redistribution to non-NASFAA institutions is prohibited. Please submit Web site questions or comments to Web@NASFAA.org.