4 Reasons Why the FSA Handbook Is Not Your P&P Manual

By Mandy Sponholtz, Director of Operations, Standards of Excellence (SOE) Review Program and Blue Icon Advisors

The Federal Student Aid (FSA) Handbook was designed as a reference tool to provide schools with additional guidance in complying with the laws and regulations governing Title IV aid programs. But copying and pasting the language from the handbook is no substitute for writing your own policies and procedures. Here's why.

1. It's Generic

The FSA Handbook provides general sub-regulatory guidance for all schools to use when implementing rules and regulations. But your policies and procedures (P&P) manual should be specific to your school. Review the handbook language and apply it to your own school's processes and systems to craft your policies and procedures. Some triggers to help make the handbook language specific to your school might be forms you use, school-established deadline dates, or systems-based procedure instructions.

2. It's a Reference

The FSA Handbook was designed as a reference tool, like a dictionary or encyclopedia. Using it (or portions of the language from it) only provides background information, not the reasons behind your school's policies and procedures. Use the handbook as a reference tool by citing pages and language, but always in the context of how your school operates. A few examples of this may include resolving Unusual Enrollment History flags, how you review subsequent Institutional Student Information Record (ISIRs), or determining a withdrawal date for the Return of Title IV funds calculation.

3. It's Impractical

Your P&P manual can be used for training new staff, ensuring consistency of processes, and to help auditors or federal program reviewers understand your practices. Reciting language from the FSA Handbook is not a practical way to achieve these goals. Framing your policies and procedures as a training resource can help ensure it remains a practical tool for your office and auditors.

4. It's Static

Generally, the FSA Handbook is not updated when new regulations, guidance, or court decisions change how you process Title IV aid right now. Often, you have to wait for the Department of Education to publish the next year's version before the handbook will reflect those changes. Your P&P manual is a living document that can, and should, be updated regularly, especially when new rules happen that affect your processes now. 

Are you using the FSA Handbook as your P&P manual? Do you need help making your P&P manual more specific, practical, and dynamic? NASFAA's new consulting firm, Blue Icon Advisors, can help you upload, revise, and check your policies and procedures for compliance or gaps using NASFAA's P&P Builder. Contact Blue Icon today to talk about your P&P project.

 

Publication Date: 8/9/2019


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