By: Alex Skarr, FAS Consultant 

In the ever-evolving landscape of higher education, financial aid software is key in ensuring the accuracy, consistency, and compliance of financial aid awarding processes. Even though many recognize the impact of technology on financial aid operations, it remains an under leveraged tool when it comes to maximizing efficiency, reducing compliance risks, and improving student outcomes. 

76% of institutions believe that technology has transformed enrollment and recruitment—yet financial aid operations often lag behind, relying on outdated processes that compound inefficiencies and compliance risk.  

With continuous changes in regulations and the necessity of managing an extensive array of data points, schools need to optimize their financial aid systems to streamline and enhance operations. By fine-tuning the setup of PowerFAIDS, schools can significantly enhance their financial aid processes. 

Enhanced Accuracy in Awarding Aid 

Manual processes in determining eligibility and awarding aid are susceptible to human error, leading to non-compliance with Title IV federal aid regulations and potential repercussions for institutions. Optimizing PowerFAIDS setup involves automating and refining these processes to minimize manual errors. Schools can leverage the system’s automated workflows to manage the complexities of financial aid, ensuring that students receive the correct aid amounts accurately and efficiently. 

Compliance with Verification Requirements 

Ensuring compliance with verification requirements is critical to the financial aid process. By optimizing PowerFAIDS’ verification workflows, schools can ensure that income, tax, and other required data are reviewed accurately and consistently. This involves configuring the system to automate the review of necessary documentation, guaranteeing precision and adherence to federal regulations. A well-optimized setup helps institutions maintain consistent compliance and provides students with a smooth and efficient aid process. 

Consistent Application of Policies 

Maintaining consistency in applying institutional and federal policies is essential for fairness and transparency in financial aid awarding. Schools can optimize their PowerFAIDS setup by customizing configurations to enforce policies such as Satisfactory Academic Progress (SAP) requirements and professional judgment overrides. These configurations ensure consistent policy application across all cases, eliminating variability that can arise from manual processing. Tailoring the setup to align with specific institutional needs guarantees that every decision adheres to established guidelines.  

Constantly Changing Financial Aid Regulations 

The financial aid regulations landscape is constantly changing, with updates such as those introduced by the FAFSA Simplification Act or modifications to Pell Grant eligibility rules. Schools can optimize their PowerFAIDS setup by regularly updating configurations to reflect these changes in real-time. This proactive approach ensures that policy changes are implemented immediately, reducing the risk of non-compliance and ensuring students receive aid based on the most current regulations. 

Proactive Identification of Compliance Risks 

Proactively identifying and addressing compliance risks is crucial to maintaining the integrity of financial aid processes. Schools can optimize their PowerFAIDS setup by utilizing analytics tools like QC rules, Tasks, and Reports, which highlight potential compliance risks, such as over awards, enrollment discrepancies, or missing documentation. These early warning systems enable institutions to address issues before they escalate, ensuring continuous compliance and minimizing the risk of audits or sanctions. 

Optimizing PowerFAIDS for Your Institution 

Optimizing your school’s PowerFAIDS setup is essential for enhancing the accuracy, consistency, and compliance of financial aid awarding processes. By leveraging automation, real-time updates, and advanced analytics, FAS can help empower your institution to provide students with the financial support they need while upholding the highest regulatory compliance standards. 

Partner with FAS and get your institution’s PowerFAIDS optimized. 

By: Bob Covey-Robbins, Senior FAS Consultant

Editor’s Note (Updated February 14, 2025):

On February 14, 2025, the U.S. Department of Education released Electronic Announcement GE-25-02, extending the deadline for Completers’ Lists and debt reporting for Financial Value Transparency/Gainful Employment (FVT/GE) to September 30, 2025.

• Institutions that missed the February 18 deadline now have more time to submit data.
• Schools that already submitted reports can make corrections until September 30, 2025.
• The Department confirmed there will be no consequences for non-compliance.
• No FVT/GE metrics will be published before the new deadline.

This extension offers additional time, but institutions should use it wisely to ensure compliance and avoid penalties. FAS is here to help—reach out today to prepare for the next cycle!

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FVT/GE reporting is here to stay – are you ready for what’s next? With deadlines extending into 2025 and regulatory oversight tightening, ensuring compliance isn’t just about checking a box—it’s about protecting your institution’s future. If your school has completed its Completers List review and submitted an error-free Student Report and a Programs Report, you likely feel more comfortable than many others at this point. But the real question remains: Where do we go from here? 

Many schools that submitted data by January 15 could not obtain information on any errors that needed to resolution by the deadline, so the Department of Education (ED) reopened NSLDS to permit schools to complete the debt reporting by February 18, 2025. While this extension offers temporary relief, it reinforces a larger reality—FVT/GE compliance is an ongoing process, not a one-time task.  

Preparing for Future FVT/GE Reporting Cycles 

Unless laws change, the work completed so far isn’t a “once and done” deal. In fact, we have not even completed the entire first reporting cycle of FVT/GE. Institutions need to stay proactive to navigate what’s ahead, including new deadlines, evolving compliance expectations and potential regulatory risks.  

According to a Financial Aid Services (FAS) survey, 51% of institutions report being only somewhat confident in their team’s understanding of today’s financial aid regulations.

To help your institution stay ahead, we’ve outlined key deadlines and information below. 

• February 18, 2025 is the deadline to complete reporting. Institutions unable to meet this deadline will be required to submit an explanation to the ED explaining why it cannot comply. However, the complete process has not yet been announced, and there is still no clear understanding of what consequences a school may encounter if it cannot comply.
  
• For schools that were able to complete the reporting, the current regulations indicate that ED will or has already begun transmitting the Completers Lists to another Federal agent to obtain median earnings data.
• ED hasn’t updated GE 24-01, which included timeframe information in the publication of the metrics that will be determined in the coming weeks or months.  As of the date of this writing, the Electronic Announcement indicated that metrics will be published in early 2025, along with notifications to institutions on which programs fail Gainful Employment (GE) standards. Then, shortly after, ED will notify institutions that voluntarily discontinue failing GE programs that substantially similar programs cannot be approved until 3 years have elapsed.
  
• GE-24-01 also indicated that ED will provide additional information in early 2025 on how the metrics will affect the eligibility of failing programs.
• Since the next Completers List is due October 1, 2025, and schools have 60 days to review it, we should expect to receive the lists that need to be reviewed around August 1, 2025. According to current publications, the second year of Student and Program reports for award year 2024-2025 will also be due October 1, 2025. 
  
• The Electronic Announcement also indicates the ED plans to make its disclosure website system available by July 2026. The website will inform current and prospective students about the institutions’ GE and Eligible Non-GE Programs.
  
• GEN-24-04 also indicates that regulations becoming effective July 1, 2026 will require schools to provide warnings to current and prospective students for GE programs at risk of losing Title IV eligibility.
• Effective July 1, 2026, prospective students must acknowledge that they have reviewed the program warnings on ED’s website before entering an enrollment agreement with the institution for any non-degree or graduate program that failed the Debt to Earnings rates.   

FVT/GE Reporting Lessons Learned and Future Planning 

It may be beneficial for schools to have one or more “lessons learned” sessions with the people involved in the first round of FVT/GE Completers List review, Student Reports, and Program Reports. Documenting what went well and what did not, as well as who needed to provide input into the reports, may help make the next cycle go smoother.   

Here are some key areas to assess as your reflect on the process:  

Cross-Departmental Collaboration 

• Which departments needed to provide data for the reports?  

• Were we caught off guard by assuming that the FVT/GE was solely a financial aid office responsibility? 

Time and Resource Management 

• What time commitment was needed to pull data, compile reports, review results, and resolve errors? 

• Did we have the necessary staffing and technology resources to complete the process efficiently? 

• Do we need consulting support now, or will we need it for the next cycle? 

Data Accuracy and Compliance Readiness 

• Did we learn any valuable lessons about our institution’s enrollment reporting accuracy?  

• Did we learn that we need to improve our reconciliation of enrollment data directly or indirectly reported to NSLDS with the institution’s data? 

Institutional Support and Leadership Engagement 

• Did the team have the support of the upper administration to complete the work required? If not, what additional education/communication needs to occur for the next cycle? 

• Is the institution concerned that one or more of its GE programs may fail the required metrics?  If so, is there a plan for how the institution will improve or discontinue the program? 

• Do we have a timeline and strategy for implementing regulations that take effect on July 1, 2026? 

Knowledge Retention and Institutional Readiness 

• Does the institution have one or more champions who have and continue to diligently review all of the resources regarding FVT/GE from ED, NASFAA, National Student Clearinghouse website, Association for Institutional Research, etc.? 

• If key participants leave or change roles, do we have a plan for training their replacements and keeping institutional knowledge intact?

Staying Ahead of the Curve 

While we may be able to breathe a sigh of relief that most of the first reporting cycle is behind us, we must also recognize that, as of this writing, we are only eight months from the next reporting deadline. It is not too soon to begin the appropriate plans and preparations to stay ahead of the curve. 

Don’t wait until the next reporting deadline to take action. Financial Aid Services (FAS) can help you develop proactive strategies to enhance efficiency, build trust, and support your students throughout the process. Our team can assist with everything from internal reviews and data analysis to staff training and policy development.  

Partner with FAS and ensure your institution is prepared for the future of FVT/GE reporting.  

By: Sean Hudson, FAS Consultant

For students, financial aid isn’t just paperwork—it’s the gateway to their education. For institutions, it’s a race against time to deliver funding and build trust. So, how can financial aid offices scale smartly and meet these expectations? It begins with starting early.  Starting early is not just a best practice—it’s a necessity. Nearly 50% of all FAFSA completions occur within the first three months of the cycle. FAFSA cycles tend to lose critical momentum as they progress, with fewer students completing applications over time. By capitalizing on early momentum and avoiding the risks of delayed submissions, institutions can better meet student needs and plan for potential bottlenecks in the process.  

To explore these ideas further, we spoke with Sean Hudson, a former Financial Aid Director and current FAS consultant , asking him to share insights on the importance of starting early, building trust, and scaling operations effectively in today’s higher education landscape. 

Challenges in Financial Aid Operations 

Financial aid offices face significant challenges, from staffing shortages to increasing regulatory demands, requiring creative solutions and adaptability. 

How would you describe the current student experience during the financial aid process, especially during the busiest times of the year?

The current student experience during the financial aid process is less satisfactory now than ten years ago for many reasons.  The primary reason is the reduction in staffing.  Ten years ago, my office consisted of four counselors, two assistant directors, an associate director and a director.  When I left my last position, I had two counselors and myself as the director.  When 80% of students who applied for financial aid have never met with an administrator one-on-one, that isn’t an ideal experience for the student who may need support to make an informed decision.  

What are the effects of working with a smaller staff? 

A smaller staff has a cascading impact on the institution, students and their families. It means less time communicating with students.  The newer technology such as chatbots and auto texting has helped, but it also takes away the human aspect.  The title “Financial Aid Counselor” should be retired.   As a former Director of Financial Aid, I miss the days of sitting across from a student, getting to know them and trying to figure out their best options.  I even miss being pulled in to take sides when students and parents argue over if living on-campus is worth the investment. 

What other factors are putting a strain on financial aid departments? 

The level of reporting put on financial aid offices has steadily increased while the number of staff has, conversely, gone down.  This leaves financial aid professionals figuring out how to do more with less and takes away the time available to communicate with students.  Between Financial Value Transparency, Gainful Employment, FISAP, IPEDS, VA reporting, monthly and yearly Pell & Loan reconciliation, state aid processing, SAP, budget preparation—and implementing new regulatory changes—staff are stretched thin. With fewer people to manage the administrative burden, the risk of human error increases, putting institutions at higher risk of non-compliance and potential penalties. 

The second big thing that has negatively affected the student experience was the failed rollout of the new FAFSA last year. The Department of Education was not forthcoming with colleges on the true realities of the issues.  They sugar-coated the situation and gave schools an unrealistic timeline that we then conveyed to students.  When the dates came and went, students started to distrust us.  I have spoken to colleagues across the country, and they were trying their hardest to maintain dialogue with students, but they had little they could tell them for certain.   

How are financial aid staff members responding to these issues? 

I think financial aid offices are working their hardest to not let students feel isolated.  I know it pains financial aid administrators to not give the same service we used to.  We pride ourselves in helping families and walking hand-in-hand with them through the FA process, unfortunately that has become more difficult over the last several years.   

Building Trust in Financial Aid  

Building trust is essential in financial aid, as students and families need to feel confident not only in the process but also in the people guiding them through it. Starting early and prioritizing transparency are critical steps in creating this trust. 

How does starting early, even without FAFSAs/ISIRs, improve that experience? 

A lot of what we do is rapport building.  We want to gain their trust.  A student may not like the amount of aid they are receiving but if they think the process is fair, they will accept the results.  I’m not saying we need to share every detail of our packaging philosophy, but providing as much transparency as possible is key. 

Building trust will especially be helpful if the student is selected for verification or if we require additional action on their part.  If we have a strong connection established, the family will not question if we ask them for additional documentation or to update the FAFSA.  I want families to know that I would never ask them to do something unless it is necessary. 

Starting the planning and outreach process early also strengthens these relationships. For example, students should know their financial aid counselors. Institutions can send email introductions or highlight staff on social media and websites, allowing families to put a face with a name. Hosting financial aid workshops, sharing deadlines proactively, and providing clear process information early are small steps that make a big difference. These efforts make the process more personal and help families feel supported. 

Institutions often aim to have 50% of their population awarded by a specific date. Why is starting early critical to meeting these timelines, and what happens if schools wait for FAFSAs/ISIRs to start processing? 

Timing is critical in what we do because families are looking at college as an investment.  They are scrutinizing the cost and focusing more on outcomes —what kind of job they can get after graduation and how much debt they will incur.  It’s less about the school’s mission or the quality of facilities and more about return on investment. I read an Ellucian white paper that found 92% of students said they would enroll elsewhere if the financial aid process took eight weeks to complete. You can begin to see how starting early impacts student retention and enrollment.  

Schools really need to sell the value, and that isn’t easy —it requires consistent, positive communication. When I worked at Canisius University, I had a graduate student ask me why they should get a degree in education from my school when they could go three miles away to a state school and pay a fraction of the cost. That’s not an easy question to answer, but it highlights the importance of engaging students early and showing value throughout the financial aid process. 

The Future of Financial Aid 

As higher education evolves, financial aid offices face new challenges—but successful institutions view them as opportunities to adapt in an increasingly competitive and dynamic landscape. 

What do you think has caused the shift in how higher education is valued? 

I think the COVID pandemic had a huge impact on how students view higher education.  Remote learning made students (and parents) question the cost of living on-campus.  Colleges struggled to get students back on-campus after COVID – let alone their employees! 

Beyond the impact of the pandemic, higher education is being challenged to provide more tangible outcomes, such as job placement and manageable debt.  

I spent my entire career working at Catholic colleges and over the last decade there has been a steady shift from clergy college presidents to lay presidents.  There are just no Priests and Nuns left to replace them.  The concern at Catholic colleges is the potential impact on the Catholic mission.  Will potential students view the mission the same way with a lay president? This shift has put pressure on institutions to clearly articulate their value proposition and justify tuition costs.  

What’s the best path forward for the new financial aid year? 

I think to best way to summarize it is – If you wait until the ISIR arrives, you are already too late. Enrollment is a zero-sum game—if you enroll that student, I can’t. The earlier you engage with students, the better your chances of securing their enrollment. 

The October 1st FAFSA begin date has been a huge help. It allows institutions to give awards earlier and with greater accuracy, setting students up for success. However, starting early isn’t just about FAFSA submissions—it’s about proactive communication and outreach. Sharing timelines, requirements, and award information builds trust and keeps students engaged. I’ve personally seen an increase in professional judgments, which can be time-consuming, but it’s a minor price to pay for the benefits of awarding early. Adjusting quickly to changing financial situations shows families that your institution is responsive and supportive, which can make all the difference in their enrollment decision. 

Building Momentum for the Future 

The challenges facing financial aid offices are real, from staffing shortages and compliance demands to the need for greater transparency and trust. But with the right strategies, these challenges can become opportunities. Starting early, engaging families proactively, and prioritizing personalized support are no longer optional—they are essential for meeting student expectations and achieving institutional goals. 

Ready to transform your financial aid operations? Partner with Financial Aid Services to develop proactive strategies that enhance efficiency, build trust, and support your students every step of the way.  

By: Delinda “Lindy” Hall Ed.D.

Financial aid offices increasingly operate under lean budgets and staffing models, where the challenge of “doing more with less”—whether in labor or financial resources—has become the prevailing theme. This pressure doesn’t just stop there; it may also put operations at risk, as financial aid professionals struggle to manage budget constraints, staffing shortages, and evolving compliance demands, all while striving to maintain high-quality support. To maintain compliance, efficiency, and quality service, financial aid offices must recognize early warning signs of operational risk and take proactive steps to address them. 

Financial Aid Operations are at risk when there are:  

• Frequent complaints regarding financial aid from students and parents. 

• Negative audit findings related to the administration of federal financial aid. 

• Multiple emails to the president from the Department of Education. 

• Continuous staffing turnover in key financial aid positions. 

Recognizing these warning signs is only the first step—assessing the broader risks of operating in a lean environment is essential to maintaining institutional stability and avoiding serious consequences such as Heightened Cash Monitoring (HCM), decreased student retention, or lower enrollment yield. 

Measure the Risks of Being Too Lean 

Assessing the risks of operating in a lean environment is essential for maintaining the stability and long-term health of an institution. Recognizing the consequences of non-compliance and overly tight operational models is key to mitigating risk. In Title IV financial aid administration, one of the most serious risks institutions face is being placed on Heightened Cash Monitoring (HCM) by the U.S. Department of Education. 

According to Federal Student Aid, the two HCM categories are: 

Heightened Cash Monitoring 1 (HCM1) 

Schools on HCM1 disburse aid to eligible students using institutional funds, submit disbursement records to the Common Origination and Disbursement (COD) System, which then draws down FSA funds to cover those disbursements, similar to the Advanced Payment Method. 

Heightened Cash Monitoring 2 (HCM2) 

When an institution is placed on HCM2 it no longer receives funds under the Advance Payment Method. Instead, they must disburse aid using institutional funds and then submit a Reimbursement Payment Request to the Department of Education for approval before receiving federal funds. 

Reasons for HCM Placement 

The Department of Education uses HCM when it sees a need for more oversight. This happens if there are financial, administrative, or compliance issues with how the institution manages Title IV program funds. In February 2020, the Office of Inspector General released a report which listed the top five reasons schools were placed on Heightened Cash Monitoring. 

• Negative accreditation actions 

• Late or missing annual financial statements, 

• Inability to meet one or more standards of administrative capability 

• Failure to be financially responsible based on a composite score 

• Severe findings found during a FSA program review 

How to Avoid the Risk of HCM Placement 

Institutions should consider the downsides of being on Heightened Cash Monitoring (HCM) and recognize the value of investing in staffing solutions and technology optimization to improve efficiency. This proactive approach can help avoid the repercussions of HCM, making it a clear case of “pay now or pay later.” According to P3•EDU, an event hosted by the University of Colorado Denver, 75% of university leaders expect public-private partnerships to grow on their campuses, highlighting the increasing importance of leveraging external collaborations to strengthen operations.

Strategies worth exploring to strengthen staffing resources, ensure proper compliance monitoring, and adherence to policies and procedures include:

• Accessing interim staffing during peak processing periods. 

• Utilizing third-party processing for behind-the-scenes process improvements. 

• Investing in training sessions by experts in the areas of Title IV aid administration. 

• Optimizing financial aid technology to streamline and automate processes.  

Implementing these strategies can help institutions avoid risks like HCM placement while strengthening compliance and operational efficiency. 

Technology Resources: An Impactful Tool for Financial Aid 

Enterprise Resource Planning (ERP) technology is either underutilized or improperly configured from the start at many higher education institutions. However, its potential is well worth the investment when implemented strategically.  

Consider how ERP can help your Financial Aid team: 

• Evaluate the financial aid technology setup to optimize performance in response to ongoing changes in business processes. 

• Provide ERP training opportunities for new staff members, as well as refresher courses for veteran staff and tackle your staffing turnover issues. 

• Reassess processes that have become more manual due to poor system setup or system flaws. 

• Appoint a dedicated staff member responsible for configuring and setting up the financial aid systems, ensuring smooth and efficient ongoing operations. 

• Perform regular system upgrades. In the realm of Title IV aid administration and processing, regulations change frequently, and timely system upgrades are essential to ensure ongoing compliance. 

• Schedule intentional collaborative sessions with financial aid and student accounts staff. This fosters teamwork to review business processes and optimize performance. 

Monitoring and ensuring compliance in administering and processing financial aid is essential to administrative effectiveness. Financial Aid Services offers interim staffing, technology optimization, and consulting to improve and sustain a more efficient operational model. Investing proactively in system improvements today is a clear case of ‘pay now or pay later,’ ensuring long-term institutional success while delivering a better experience for both students and staff. 

Partner with FAS to achieve a better operational model for your institution.