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Self-evaluation Guide for inStitutional ParticiPation in title iv and other federal ProGramS
the Self-evaluation Guide has been designed as an in-house tool to help institutions evaluate the efficiency and effectiveness of their administration of financial aid programs and compliance with federal laws and regulations.
2015–16 - THIRTY-FIRST EDITION
FEDERAL WORK-STUDY PROGRAM
PART 2 – Administration of Title IV SECTION VII
i
© 2008–2015 by National Association of Student Financial Aid Administrators (NASFAA). All rights reserved. NASFAA has prepared this document for use only by personnel, licensees, and members. The information contained herein is protected by copyright. No part of this document may be reproduced, translated, or transmitted in any form or by any means, electronically or mechanically, without prior written permission from NASFAA. NASFAA SHALL NOT BE LIABLE FOR TECHNICAL OR EDITORIAL ERRORS OR OMISSIONS CONTAINED HEREIN; NOR FOR INCIDENTAL OR CONSEQUENTIAL DAMAGES RESULTING FROM THE FURNISHING, PERFORMANCE, OR USE OF THIS MATERIAL. This publication contains material related to the federal student aid programs under Title IV of the Higher Education Act. While we believe that the information contained herein is accurate and factual, this publication has not been reviewed or approved by the U.S. Department of Education or the Department of the Interior. NASFAA reserves the right to revise this document and/or change product features or specifications without advance notice. December 2015
NASFAA Self-Evaluation Guide Part 2 Section VII
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 1
VII. Federal Work-Study Program Prepared by __________________ Date ______ Reviewed by __________________ Date ______
Note: Periodically, exceptions to or waivers of certain statutory and regulatory requirements are granted due to national emergencies and/or federally declared disasters. Information regarding exceptions/waivers for the 2015–16 award year may be found in the Guide Instructions. Reference Question Responsible
Office Response
I. General 668.32 675.9
A. Are Federal Work-Study (FWS) funds awarded only to students who:
Meet all applicable general student
eligibility criteria for Title IV aid; ____________
____________
yes no
Demonstrate financial need? ____________
____________
yes no
GEN-15-09 1. When determining the enrollment
status and cost of attendance of a student enrolled in a eligible career pathway program, does the institution exclude any credit or clock hours associated with the adult education component of the program regardless of whether the institution considers the adult education coursework to be remedial?
____________
____________
yes no n/a
675.8(c) 675.10(a) 2015–16 FSA Handbook, p. 6-39
B. Does the institution make Federal Work-Study (FWS) employment reasonably available, to the extent of available funds, to all eligible students?
675.8(d) 2015–16 FSA Handbook, p. 6-39
C. To the maximum extent practicable, do FWS positions complement and reinforce the educational programs or career goals of recipients?
____________
____________
yes no
675.8(e) D. Does the institution ensure FWS
employment may be used for programs that provide support services to students with disabilities?
____________
____________
yes no
675.27(b) E. Does the institution avoid soliciting or
accepting fees, commissions, contributions, or gifts as a condition for FWS employment, and does it prohibit any organization with which it has an employment agreement from doing so?
____________
____________
yes no
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 2
Reference Question Responsible Office
Response
II. Community Service Requirements 675.8(f) 2015–16 FSA Handbook, p. 6-57
A. Does the institution inform all eligible students of the opportunity to perform community services in the local community?
____________
____________
yes no
675.8(f) 2015–16 FSA Handbook, p. 6-57
B. Does the institution consult with local nonprofit, governmental, and community-based organizations to identify community service job opportunities?
____________
____________
yes no
675.2(b), Community services
C. Does the institution classify as community service those services designed to improve the quality of life for community residents, particularly low-income individuals, or to solve particular problems related to their needs, including:
675.2(b), Community services (1)
Services provided in such fields as health care, child care (including child care services provided on campus that are open and accessible to the community), literacy training, education (including tutorial services), welfare, social services, transportation, housing and neighborhood improvement, public safety, emergency preparedness and response, crime prevention and control, recreation, rural development, and community improvement;
____________
____________
yes no
675.2(b), Community services (2)
Work in service opportunities or youth corps activities as defined in section 101 of the National and Community Service Act of 1990 (AmeriCorps) as well as in agencies, institutions, and activities designated in section 124(a) of that Act;
____________
____________
yes no
675.2(b), Community services (3)
Support services to students with disabilities, including students with disabilities who are enrolled at the institution; and
____________
____________
yes no
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 3
Reference Question Responsible Office
Response
675.2(b), Community services (4)
Activities in which a student serves as a mentor for such purposes as tutoring, supporting educational and recreational activities, and counseling (including career counseling)?
____________
____________
yes no
675.18(g)(1) 2015–16 FSA Handbook, p. 6-39
D. Does the institution use at least seven percent of the sum of its initial and supplemental FWS award year allocations to compensate students employed in community service activities?
____________
____________
yes no
675.18(g)(1) 2015–16 FSA Handbook, p. 6-39
E. In meeting community service requirements, does the institution employ at least one FWS student to:
____________
____________
yes no
Perform family literacy activities in a
family literacy project; or
Tutor reading, as part of a reading
tutor project, to children who are preschool age or are in elementary school?
675.18(g)(3) 1. To the extent practicable, in
providing reading tutors, does the institution:
Give priority to students for
tutoring in schools participating in a reading reform project designed to train teachers on how to teach reading on the basis of scientifically-based reading research and funded under the Elementary and Secondary Education Act of 1965; and
____________
____________
yes no
Ensure students employed in a
reading reform project receive training from the employing school in the instructional practices used by the school?
____________
____________
yes no
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 4
Reference Question Responsible Office
Response
675.18(g)(4)(i) F. Does the institution include in its community service definition, positions that perform civic education and participation opportunities in projects that:
____________
____________
yes no n/a
Teach civics in schools; Raise awareness of government
functions and resources; or
Increase civic participation? 675.18(g)(4)(ii)(A) 2015–16 FSA Handbook, p. 6-57
1. Does the institution give priority, to the extent practicable, to the employment of students in projects that educate or train the public about evacuation, emergency response, and injury prevention strategies relating to natural disasters; acts of terrorism; and other emergency situations?
____________
____________
yes no n/a
675.18(g)(4)(ii)(B) a. Does the institution ensure
students employed in such projects receive appropriate training to carry out the required educational services?
____________
____________
yes no n/a
675.18(g)(2) Elec. Ann., 3/27/15
G. If requesting a waiver of the community service expenditure requirements because enforcing the requirements would cause a hardship to students during the award year, does the institution submit its waiver request statement as instructed by the annual deadline established by the U.S. Department of Education (ED)?
____________
____________
yes no n/a
III. Types of Employment 675.20(a) A. Does the institution ensure FWS
students only work for eligible employers including:
____________
____________
yes no
The institution; A federal, state, or local public
agency;
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 5
Reference Question Responsible Office
Response
A private nonprofit organization; or A private for-profit organization? Note: If a proprietary institution, skip
Question B.
675.21(a) B. Does the institution employ FWS
students to work for the institution itself in operations for which the institution contracts with a third party (such as food service, cleaning, security, or maintenance) only if:
The institution is not a proprietary
institution; and ____________
____________
yes no
The contract specifies: The number of students to be
employed, and ____________
____________
yes no
The institution selects the
students to be employed and determines each student’s pay rate?
____________
____________
yes no
Note: If not a proprietary institution, skip
Question C.
675.2(b), Community services, Student services 675.21(b)
C. If the institution is a proprietary institution, does it employ students working for the institution only in FWS jobs that:
Are in community services as defined by regulation; or
____________
____________
yes no
Are on campus; and Involve an aspect or division of
student services directly related to the student’s training or education as defined in regulation,
____________
____________
yes no
Complement and reinforce the
student’s educational program or vocational goals to the maximum extent possible,
____________
____________
yes no
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 6
Reference Question Responsible Office
Response
Do not involve facility maintenance, cleaning, purchasing, or public relations, and
____________
____________
yes no
Do not involve the solicitation of
potential students to enroll at the institution?
____________
____________
yes no
Note: If an institution does not place FWS
students in private nonprofit organizations or federal, state, or local public agencies, skip Question D.
675.22 D. If the student is employed by a private
nonprofit organization or by a federal, state, or local public agency, is the work performed by the student in the public interest (i.e., for the national or community welfare)?
____________
____________
yes no
675.22(b)(1) 1. Does the institution ensure FWS
work does not primarily benefit members of a limited membership organization (e.g., credit union, fraternal or religious order, or cooperative)?
____________
____________
yes no
675.20(c)(2)(v) 675.22(b)(3),(5),(6) 2015–16 FSA Handbook, pp.6-65 to 6-66
2. Does the institution ensure FWS work does not involve:
Work as a political aide for an
elected official;
____________
____________
yes no
Partisan or nonpartisan political
activity;
Association with a faction in an
election for public or party office;
Lobbying at the federal, state, or
local level; or
Employment with ED? 675.22(b)(2) 2015–16 FSA Handbook, p.6-66
3. Does the institution ensure FWS work for elected officials is permissible only for the regular administration of federal, state, or local government?
____________
____________
yes no n/a
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 7
Reference Question Responsible Office
Response
675.22(b)(4) 4. Does the institution ensure a student’s political support or party affiliation is not taken into account during the hiring process?
____________
____________
yes no
Note: If an institution does not place FWS
students in private for-profit organizations, skip Question E.
675.23(b)(1) 2015–16 FSA Handbook, p.6-66
E. If a student is employed in a private for-profit organization, is the work restricted to jobs academically relevant to the student’s educational program to the maximum extent possible?
____________
____________
yes no
675.23(b)(2)(ii) 1. Does the institution ensure FWS
funds are not used to pay an employee who would otherwise be employed by that organization?
____________
____________
yes no
675.23(a) 2. Does the institution use no more
than 25 percent of its total FWS allocation to pay the compensation of FWS students employed by private for-profit organizations?
____________
____________
yes no
Note: If an institution does not place FWS
students in off-campus positions, skip Questions F and G.
675.20(b)(1) F. Does the institution maintain a written
agreement with each agency or organization that employs its FWS students?
____________
____________
yes no
675.20(b)(2) 2015–16 FSA Handbook, p.6-68
1. Does the institution enter into off-campus agreements only with agencies or organizations that have professional direction and staff?
____________
____________
yes no
675.20(b)(1) 2. Does the agreement between the
school and agency or organization specify who will pay the student?
____________
____________
yes no
675.20(b)(1) 3. Does the agreement set forth FWS
work conditions? ____________
____________
yes no
675.20(b)(3)(ii) 2015–16 FSA Handbook, p.6-68
G. Does the institution ensure FWS students working for an off-campus employer are properly supervised?
____________
____________
yes no
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 8
Reference Question Responsible Office
Response
675.20(c)(2)(i)-(iii) H. Does the institution ensure FWS duties for any employer do not impair existing contracts, displace regular employees, or fill jobs that are vacant because of a strike?
____________
____________
yes no
675.20(c)(2)(iv) I. Does the institution ensure FWS work
does not involve the construction, operation, or maintenance of any part of a facility used for religious worship or sectarian instruction?
____________
____________
yes no
675.20(c)(1) J. Do FWS positions (regardless of the
employer) adhere to employment conditions, including pay, that are appropriate and reasonable in terms of type of work, geographical region, employee proficiency, and any applicable federal, state, or local law?
____________
____________
yes no
Immigration Reform and Control Act of 1986, P.L. 99-603
1. Does the institution comply with U.S. Department of Homeland Security (DHS) verification of employment eligibility requirements, including completion of the I-9 form?
____________
____________
yes no
2015–16 FSA Handbook, p. 6-42
K. Does the institution ensure each student is not permitted to work in a FWS position when the student is otherwise scheduled to be in class?
____________
____________
yes no
2015–16 FSA Handbook, p. 6-42
1. If an exception is made, is it made only for documented cases of a class having been canceled or an instructor having excused the student for a specific day?
____________
____________
yes no n/a
IV. Establishing Wage Rates and Making Payments to Students 675.16(a)(5) A. Does the institution ensure a student
earns FWS compensation when the student performs the work?
____________
____________
yes no
675.16(a)(2) B. Does the institution pay a student FWS
compensation at least once a month? ____________
____________
yes no
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 9
Reference Question Responsible Office
Response
675.16(a)(3) 1. Does the institution notify the student of the amount of funds the student is authorized to earn, and how and when the FWS compensation will be paid before the institution makes an initial disbursement to the student for an award period?
____________
____________
yes no
675.16(a)(9) 2. Does the institution indicate it has
made a disbursement of FWS Program funds on the date it credits a student’s account or pays a student directly with:
____________
____________
yes no
Funds received from ED; or Institutional funds used in
advance of receiving FWS Program funds?
GEN-15-09 3. Does the institution treat a student,
who is enrolled in an eligible career pathway program, as ineligible for FWS for a payment period if the only courses the student is enrolled in are courses from the adult education component of the program?
____________
____________
yes no n/a
675.24(a)(1) C. Is compensation for undergraduate
students computed only on an hourly basis for actual time on the job?
____________
____________
yes no n/a
675.24(a)(2) D. Are fringe benefits (e.g., vacation and
holiday pay, sick leave, employer retirement contributions, etc.) excluded from the wage rate?
____________
____________
yes no
675.16(b)(1) E. If it obtains the student’s authorization,
does the institution use FWS funds to credit a student’s account at the institution to satisfy:
Current award year charges for
tuition and fees, institutionally-contracted room and board, and other educationally-related institutional charges; and
____________
____________
yes no n/a
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 10
Reference Question Responsible Office
Response
Charges from any prior award year for a total of not more than $200 for tuition, fees, room, board, and other institutionally related charges?
____________
____________
yes no n/a
675.16(b)(2) 1. If the institution uses FWS funds in
combination with other Title IV funds to satisfy prior award year charges, does the institution ensure it does not use more than $200 of current year Title IV funds?
____________
____________
yes no n/a
675.16(d)(4)(i) F. If a student modifies an authorization,
does the institution ensure the modification takes effect on the date the institution receives the modification notice?
____________
____________
yes no n/a
675.16(d)(4)(ii),(iii) G. If a student cancels an authorization to
use his or her FWS compensation to pay for authorized charges, does the institution:
Use those funds to pay only
authorized charges incurred before the institution received the notice; and
____________
____________
yes no n/a
Pay those funds directly to the
student as soon as possible, but no later than 14 days after the institution receives that notice?
____________
____________
yes no n/a
675.24(a)(3) 2015–16 FSA Handbook, p. 6-45
H. Are graduate students paid a salary or hourly wages in accordance with the institution’s usual employment practices?
____________
____________
yes no n/a
Note: If an institution does not give
academic credit for FWS work performed, skip Question I.
675.20(d)(2) I. If the institution gives academic credit
for FWS work performed, does it ensure the student is not paid:
____________
____________
yes no
Less than he or she would be paid if
no academic credit were received;
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 11
Reference Question Responsible Office
Response
For receiving instruction in a classroom, laboratory, or other academic setting; or
Unless the employer would normally
pay the person for the same position?
675.24(b)
J. Is the minimum wage rate under the Fair Labor Standards Act of 1938 enforced?
____________
____________
yes no
2015–16 FSA Handbook, p. 6-45
1. Does the institution pay students employed under the FWS Program at least the federal minimum wage rate of $7.25 an hour?
____________
____________
yes no
2015–16 FSA Handbook, p. 6-45
2. If FWS employees are subject to both federal and state minimum wage laws, are FWS employees paid the higher of the two minimum wages?
____________
____________
yes no n/a
675.18(h)(1) K. If the institution pays FWS students for
time spent in training that is directly related to any type of FWS employment, is the amount of time spent in training reasonable?
____________
____________
yes no n/a
675.18(h)(2) L. If the institution pays FWS students for
time spent for travel that is directly related to employment in community service activities, including tutoring in reading and family literacy activities, is the amount of time spent for travel reasonable?
____________
____________
yes no n/a
675.25(a) M. Are earnings attributed to FWS and
applied to a student’s cost of attendance (COA) determined by subtracting taxes and job-related costs (e.g., uniforms, transportation to and from work) from gross earnings?
____________
____________
yes no
675.25(b) 1. For a student employed under FWS
during a period of nonenrollment (e.g., summer), does the institution apply the attributed earnings to his or her COA for the next period of enrollment?
____________
____________
yes no n/a
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 12
Reference Question Responsible Office
Response
675.16(e)(1) N. Does the institution pay the student the institutional share at the same time it pays the federal share except for allowable noncash contributions?
____________
____________
yes no n/a
675.16(e)(2) 675.27(a)(1)
O. If the institutional share of wages is paid in the form of tuition, fees, services, or equipment, does the institution pay that share before the student’s final payroll period?
____________
____________
yes no n/a
675.16(e)(3) P. If the institution pays its FWS matching
share in the form of prepaid tuition, fees, or equipment for a forthcoming academic period, does it give the student a statement before the close of his or her final payroll period listing the amounts earned for these items?
____________
____________
yes no n/a
675.16(a)(8) 2015–16 FSA Handbook, p. 4-26
Q. Does the institution refrain from obtaining a student’s power of attorney to authorize disbursement of funds unless it has received prior approval from ED?
____________
____________
yes no
675.16(a)(7) R. Before paying a correspondence
student, does the institution require the student to submit his or her first completed lesson?
____________
____________
yes no n/a
675.16(a)(4) S. Does the institution assume
responsibility for ensuring all students are paid for work performed, even if employed by an off-campus employer?
____________
____________
yes no
675.26(a)(4) T. Does the institution ensure FWS funds
are not used to pay a student after he or she has earned $300 or more over his or her financial need?
____________
____________
yes no
675.16(a)(6) U. Does the institution pay a student after
the student’s last day of attendance for FWS compensation earned while the student was in attendance at the institution?
____________
____________
yes no
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 13
Reference Question Responsible Office
Response
HEA 488A(d) 2015–16 FSA Handbook, p. 6-53
V. Does the institution permit FWS wages to be garnished only to:
____________
____________
yes no
Satisfy a debt owed to ED; Pay any costs of attendance that the
student owes the school during the period of the award; or
Pay any costs of attendance that will
become due and payable to the school during the period of the award?
HEA 488A(d) 2015–16 FSA Handbook, p. 6-53
1. Does the institution oppose any garnishment order it receives for any other type of debt?
____________
____________
yes no
HEA 488A(d) 2015–16 FSA Handbook, p. 6-53
2. Does the institution notify off-campus employers that garnishment of FWS wages for any other type of debt is not permissible?
____________
____________
yes no n/a
Note: If an institution was not affected by a
major disaster or chooses not to continue to pay FWS wages to disaster-affected students, skip Question W.
675.18(i) W. If an institution affected by a major
disaster (as determined by ED) chooses to continue to pay FWS wages to disaster-affected students, does the institution consider a student to be a disaster-affected student only if the student:
Was enrolled at the institution and
received a FWS award for the award period during which the major disaster occurred;
____________
____________
yes no
Earned FWS wages for that award
period; ____________
____________
yes no
Was unable to fulfill his or her FWS
obligation for all or a part of the award period due to the disaster; and
____________
____________
yes no
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 14
Reference Question Responsible Office
Response
Was unable to be reassigned to another FWS job?
____________
____________
yes no
675.18(i)(1) 1. Does the institution: Pay students an amount equal to
or less than the wages the students would have been paid if they had been able to work;
____________
____________
yes no
Pay only students who began
their work obligation, earned FWS funds, or had not separated from their FWS job before the disaster occurred; and
____________
____________
yes no
Comply with the appropriate
matching funds requirements unless it has received a waiver?
____________
____________
yes no
V. Fiscal Procedures and Records 675.19(a)(1) 2015–16 FSA Handbook, p. 6-30
A. Does the institution establish and maintain a system of internal checks and balances to ensure no office can both authorize payments and disburse funds to students?
____________
____________
yes no
675.19(a)(2) 1. If the institution uses a fiscal agent,
does the agent perform only ministerial acts?
____________
____________
yes no n/a
668.163 675.19(a)(3)
2. Does the institution maintain FWS funds in accordance with cash management requirements?
____________
____________
yes no
673.7 675.18(a)
B. Does the institution use its FWS allocation only to:
Pay the federal share of FWS
wages; ____________
____________
yes no
Pay all or a portion of the institution’s
administrative cost allowance; ____________
____________
yes no n/a
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 15
Reference Question Responsible Office
Response
Transfer funds to its Federal Supplemental Educational Opportunity Grant (FSEOG) Program;
____________
____________
yes no n/a
Meet Job Location and Development
(JLD) Program costs; and ____________
____________
yes no n/a
Meet Work-Colleges Program costs? ____________
____________
yes no n/a
675.26(a)(3) C. Does the institution ensure the federal
share of FWS compensation does not exceed 50 percent for students employed by a private for-profit organization?
____________
____________
yes no n/a
675.23(b)(2)(i) 1. Does the institution require a private
for-profit organization to pay the matching share?
____________
____________
yes no n/a
675.26(a)(1) D. Does the institution ensure the federal
share of FWS compensation does not exceed 75 percent for students employed by the institution itself; in a federal, state, or local agency; or in a private nonprofit organization?
____________
____________
yes no
675.26(a)(2) 1. Does the institution ensure the
federal share of a FWS student’s compensation does not exceed 90 percent, if:
The student is employed at a
nonprofit organization or public agency that cannot afford to pay the regular nonfederal share;
____________
____________
yes no
The organization is not part of,
owned by, operated by, or under common ownership, operation, or control of the institution;
____________
____________
yes no
The organization is selected on a
case-by-case basis; and ____________
____________
yes no
No more than 10 percent of the
institution’s FWS students are compensated on this basis?
____________
____________
yes no
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
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© 2015 NASFAA Page 16
Reference Question Responsible Office
Response
675.26(b) E. When determining the federal share of FWS, does the institution exclude fringe benefits and the employer’s share of any Social Security, worker’s compensation, retirement, or other welfare or insurance programs?
____________
____________
yes no
675.26(d) 2015–16 FSA Handbook, pp. 6-21 to 6-22
F. Does the institution pay 100 percent of the compensation earned by a student from its federal share only if the work performed by the student is for the institution itself, for a federal, state, or local public agency, or for a private nonprofit organization, and the student is:
____________
____________
yes no n/a
Federal Register, 11/19/15, pp. 72422 to 72426 2015–16 FSA Handbook, p. 6-22 Electronic Announcement, 4/23/15 2016–17 FISAP Instructions, pp. A-1 to A-2
Enrolled at an institution currently designated as a Historically Black College and University (HBCU) or a Tribally Controlled College and University (TCCU);
Enrolled at an institution that has been previously approved as an institution eligible for a federal share waiver as a Title III/V institution, and continues to receive grant funding under a Title III/V program;
Enrolled in a Title III/V institution that qualifies for one of the following programs: the Strengthening Institutions program (SIP), Alaska Native and Native Hawaiian-Serving Institutions (ANNH), Predominately Black Institutions (PBI), Native American-Serving Nontribal Institutions (NASNTI), Asian American and Native American Pacific Islander-Serving Institutions (AANAPISI), Developing Hispanic-Serving Institutions (HSI), and Promoting Postbaccalaureate Opportunities for Hispanic Americans program (PPOHA); has annually completed the Application to Request Designation as an Eligible Institution, and has been approved for the federal share waiver;
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 17
Reference Question Responsible Office
Response
Employed as a reading tutor for children who are preschool age or who are in elementary school;
Performing family literacy activities
in a family literacy project that provides services to families with preschool age children or children who are in elementary school;
Employed as a mathematics tutor for
children who are in elementary school through the ninth grade; or
Performing civic education and
participation activities?
2015–16 FSA Handbook, p. 6-70
1. Does the institution follow its state’s determination of who constitutes “children who are in elementary school?”
____________
____________
yes no n/a
2015–16 FSA Handbook, p. 6-70
2. Does the institution follow its state’s determination of who constitutes “preschool age children?”
____________
____________
yes no n/a
CB-98-6, Attachment A, Q&A #4 2015–16 FSA Handbook, p. 6-62
3. Does the family literacy program for which the waiver of the nonfederal share of wages is applied provide:
Literacy or pre-literacy education for children who are preschool age or who are in elementary school;
____________
____________
yes no n/a
Literacy training for parents or
caregivers of children in the program;
____________
____________
yes no n/a
A means of equipping parents
and caregivers with the skills needed to partner with their children in learning; and
____________
____________
yes no n/a
Literacy activities between
parents or caregivers and their children?
____________
____________
yes no n/a
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 18
Reference Question Responsible Office
Response
675.26(c) G. If the institution receives more funds from an off-campus employer than are required for the nonfederal share of wages, employer costs, and administrative costs under an employment agreement, are the excess funds:
____________
____________
yes no n/a
1. Used to reduce the federal share on
a dollar-for-dollar basis;
Held in trust for the next year’s off-
campus employment; or
Refunded to the off-campus
employer?
Note: If an institution does not transfer
funds from its FWS allocation, skip Question H.
HEA 488 675.18(e) 2015–16 FSA Handbook, p. 6-14
H. Does the institution observe the 25 percent limitation on the amount of its total FWS allocation (i.e., initial and supplemental amounts) it transfers to FSEOG and/or Federal Perkins Loan Program accounts?
____________
____________
yes no
HEA 488 2015–16 FSA Handbook, p. 6-13
1. Are transferred funds used according to FSEOG and Federal Perkins Loan Program requirements?
____________
____________
yes no
2015–16 FSA Handbook, p. 6-13
2. Are transfers reported on the institution’s FISAP?
____________
____________
yes no
675.18(b)(1) I. If the institution carries forward FWS
funds and expends them in the next award year, does the institution carry forward no more than 10 percent of its total current award year FWS allocation?
____________
____________
yes no n/a
675.18(b)(2) 1. Does the institution spend any funds
carried forward before it spends its current year allocation?
____________
____________
yes no n/a
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 19
Reference Question Responsible Office
Response
675.18(c) J. If the institution carries back FWS funds and expends them in the previous award year, does the institution carry back no more than 10 percent of its total current award year FWS allocation?
____________
____________
yes no n/a
675.18(f) K. Separate from the 10 percent carry-
back limit, if the institution carries back any portion of its total current year FWS allocation for summer employment, does the institution do so only to pay FWS wages earned on or after May 1 but prior to the beginning of the current award year?
____________
____________
yes no n/a
2015–16 FSA Handbook, p. 6-16
L. Does the institution ensure it does not add carry-forward or carry-back funds to the total FWS allocation for an award year when determining the maximum percentage of available funds for:
____________
____________
yes no n/a
Transferring FWS funds to FSEOG; Providing the federal share of wages
in private for-profit jobs; or
Funding the JLD Program? 2015–16 FSA Handbook, p. 6-11
M. If the institution does not use its total FWS allocation, does it release any unexpended amounts to ED?
____________
____________
yes no n/a
675.19(b)(2) N. Does the institution establish and
maintain program and fiscal records that include:
1. A certification from the student’s
supervisor, an official of the institution, or off-campus agency that each student has worked and earned the amount being paid;
____________
____________
yes no
2. A payroll voucher containing
sufficient information to support all payroll disbursements; and
____________
____________
yes no
3. A noncash contribution record to
document any payment of the institution’s share of the student’s earnings in the form of tuition, fees, services, and/or equipment?
____________
____________
yes no n/a
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 20
Reference Question Responsible Office
Response
2015–16 FSA Handbook, p. 6-47
1. Do payroll vouchers include the:
School’s name and address; ____________
____________
yes no
Beginning and ending dates of
the payroll period; ____________
____________
yes no
Student’s name; ____________
____________
yes no
Identification of the student’s job; ____________
____________
yes no
Number of hours worked during
the pay period; ____________
____________
yes no
Hourly wage rate (if an
undergraduate student); ____________
____________
yes no n/a
Hourly wage rate or salary (if a
graduate student); ____________
____________
yes no n/a
Student’s gross and net
earnings; ____________
____________
yes no
Compensation withheld for
federal, state, county, or city taxes, and other deductions;
____________
____________
yes no
Noncash payments (if any); ____________
____________
yes no n/a
Overtime earnings (if any); and ____________
____________
yes no
Check number, duplicate receipt,
or other payment identification? ____________
____________
yes no
675.19(b)(2)(i) 2. For students paid on an hourly
basis, does the certification the student has worked and earned FWS funds include, or is it supported by, a time record showing the hours worked in clock-time sequence or the total hours worked per day?
____________
____________
yes no n/a
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 21
Reference Question Responsible Office
Response
675.20(b)(3)(i) 3. Does the institution ensure work performed by students for off-campus employers is also properly documented?
____________
____________
yes no n/a
Note: If an institution does not use
electronic certification by a supervisor to document a student has worked, skip Question 4.
2015–16 FSA Handbook, p. 6-29
4. If the institution uses an electronic certification by a FWS supervisor that the student has worked and earned FWS funds, does it use the following safeguards against possible fraud and abuse:
Password protection; ____________
____________
yes no
Password changes at set
intervals; ____________
____________
yes no
Access revocation for
unsuccessful log-ins; ____________
____________
yes no
User identification and entry-
point tracking; ____________
____________
yes no
Random audit surveys with
supervisors; and ____________
____________
yes no
Security tests of the coded
access? ____________
____________
yes no
2015–16 FSA Handbook, pp. 6-44 to 6-45
5. Does each FWS position have a job description that includes the following:
Name of the position; ____________
____________
yes no
Classification of the position
(e.g., reading tutor 1, reading tutor 2, laboratory assistant, library technician 1 or 2, etc.);
____________
____________
yes no
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 22
Reference Question Responsible Office
Response
Name and address of the student’s employer (department, public agency, nonprofit organization);
____________
____________
yes no
Department or office in which the
student will be employed; ____________
____________
yes no
Location where the student will
perform his or her duties; ____________
____________
yes no
Name of the student’s
supervisor; ____________
____________
yes no
Purpose/role of the student’s job
within the organization; ____________
____________
yes no
Student’s duties and
responsibilities and how they relate to the purpose/role;
____________
____________
yes no
Rates of pay for the position,
cross-referenced to the wage rates in the institution’s policies and procedures manual;
____________
____________
yes no
General qualifications for the
position and the specific qualifications for the various pay rates associated with the position;
____________
____________
yes no
Beginning and ending dates of
the student’s employment; ____________
____________
yes no
Procedures for determining a
student’s rate of pay when a position has multiple rates; and
____________
____________
yes no
Evaluation procedures and
schedules? ____________
____________
yes no
VI. Job Location and Development Program Note: If the institution does not participate in
the JLD Program, it should skip the questions in Part VI and proceed to Part VII, Work-Colleges Program.
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 23
Reference Question Responsible Office
Response
675.35(a) 2015–16 FSA Handbook, p. 6-72
A. If the institution participates in a JLD Program, does it do so only if it has a Program Participation Agreement (PPA) approved by ED and which includes approval to participate in the FWS Program?
____________
____________
yes no
675.35(b)(3)(i) 1. Does the institution comply with the
prohibition against locating and developing jobs at an eligible institution?
____________
____________
yes no
675.35(b)(3)(ii) 2. Are the jobs located and developed with JLD funds available only to students during and between periods of attendance at the institution, not upon graduation?
____________
____________
yes no
675.35(b)(3)(iii) 3. Has the institution taken steps to
ensure the JLD Program will not displace employees or impair existing contracts for services?
____________
____________
yes no
2015–16 FSA Handbook, p. 6-73
4. Does the institution limit JLD expenditures from FWS funds to the lesser of $75,000 or 10 percent of its total allocation?
____________
____________
yes no
675.33(b) 5. Does the institution use FWS funds
for no more than 80 percent of allowable JLD costs?
____________
____________
yes no
675.33(a) a. Does the institution restrict
allowable costs to those reasonably related to carrying out the JLD Program, excluding any costs related to the purchase, construction, or alteration of physical facilities and indirect administrative costs?
____________
____________
yes no
675.33(c) b. Does the institution keep records
documenting the amount and source of its share of allowable costs (whether in cash or in the form of services)?
____________
____________
yes no
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 24
Reference Question Responsible Office
Response
675.35(b)(3)(iv) 6. Are expended JLD Program funds realistically expected to generate total student wages exceeding the total amount of the federal share of funds spent under the FWS Program?
____________
____________
yes no
675.35(b)(3)(v) 7. If the institution uses federal funds to
contract with another institution, are suitable performance standards a part of the contract?
____________
____________
yes no n/a
Note: If the institution does not enter into
written agreements with other participating institutions, skip Question B.
675.34(a),(b) B. If the institution exercises its option to
enter into a written agreement with other participating institutions to establish and operate job location programs for its students, does the agreement:
Designate the administrator of the
program; and ____________
____________
yes no
Specify the terms, conditions, and
performance standards of the program?
____________
____________
yes no
675.34(c) 1. Does the institution retain
responsibility for the proper disbursement of the federal funds it contributes under an agreement with other eligible institutions?
____________
____________
yes no
675.19 675.36
C. Are procedures and records concerning the JLD Program established in accordance with FWS Program regulations governing fiscal procedures and records?
____________
____________
yes no
VII. Work-Colleges Program Note: If the institution does not enter into a
work-college agreement with ED, it should skip the questions in Part VII.
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 25
Reference Question Responsible Office
Response
675.48(a) 2015–16 FSA Handbook, pp. 6-76 to 6-77
A. If the institution exercises its option to enter into a work-colleges agreement with ED, does it comply with all the appropriate provisions of the Higher Education Act of 1965 (HEA), as amended, and the appropriate provisions of the regulations?
____________
____________
yes no
675.41(a) 675.48(b)
1. Does the institution satisfy the regulatory definition of work-college?
____________
____________
yes no
675.45(c) 675.48(c)
2. Does the institution match the federal funds on a dollar-for-dollar basis?
____________
____________
yes no
675.41(a)(3) B. Unless the student is engaged in an
institutionally organized or approved study abroad or externship program, does the institution require resident students, including at least half of all full-time students, to participate in a comprehensive work-learning-service program for at least 5 hours each week or at least 80 hours during each enrollment period other than summer school?
____________
____________
yes no
675.41(a)(4) 1. Does the institution provide students
participating in the program the opportunity to contribute to their education and the welfare of their community as a whole?
____________
____________
yes no
675.41(b)(1) 2. Is the comprehensive work-learning-
service program an integral and stated part of the institution’s educational philosophy and program?
____________
____________
yes no
675.41(b)(3)-(6) 3. Does the comprehensive work-
learning-service program:
Include learning objectives,
evaluation, and a record of work performance as part of the student’s college record;
____________
____________
yes no
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 26
Reference Question Responsible Office
Response
Provide programmatic leadership by college personnel at levels comparable to traditional academic programs;
____________
____________
yes no
Recognize the educational role
of work-learning-service supervisors; and
____________
____________
yes no
Include consequences for
nonperformance or failure similar to the consequences for failure in the regular academic program?
____________
____________
yes no
675.41(b)(2) 4. Does the institution require
participation in the program by all resident students for enrollment and graduation?
____________
____________
yes no
675.45(a) C. Does the institution use its allocated and
reallocated Work-Colleges Program funds only for:
____________
____________
yes no
Supporting the educational costs of
qualified students through self-help payments or credits provided under the work-learning-service program within the limits of their demonstrated financial need;
Promoting the work-learning-service
experience as a tool of postsecondary education, financial self-help, and community service-learning opportunities;
Carrying out FWS and JLD Program
activities;
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 27
Reference Question Responsible Office
Response
Administering, developing, and assessing comprehensive work-learning-service programs including community-based work-learning alternatives that expand opportunities for community service and career-related work, as well as alternatives that develop sound citizenship, encourage student persistence, and optimize Work-Colleges Program assistance in education and student development;
Coordinating and carrying out joint
projects and activities to promote work-learning-service; or
Carrying out a comprehensive
longitudinal study of student academic progress and academic and career outcomes relative to student self-sufficiency in financing higher education, repayment of student loans, continued community service, kind and quality of service performed, and career choice and community service after graduation?
675.45(b) D. If the institution transfers funds from its
Federal Perkins Loan or FWS programs to its Work-Colleges Program, does it use the transferred funds to pay allowable costs?
____________
____________
yes no n/a
675.46 E. Does the institution ensure it does not
use its allocated and reallocated program funds and funds transferred from its Federal Perkins Loan or FWS programs to pay costs related to the purchase, construction, or alteration of physical facilities, or indirect administrative costs?
____________
____________
yes no
Note: If the institution does not enter into
written agreements with other participating institutions, skip Question F.
NASFAA Self-Evaluation Guide Part 2 Section VII FEDERAL WORK-STUDY
This requirement became effective for the 2015–16 award year. Unless otherwise noted, the requirement was effective 7/1/2015.
© 2015 NASFAA Page 28
Reference Question Responsible Office
Response
675.44(b) 675.47(a),(b)
F. If the institution enters into a written agreement with another participating institution to promote the work-learning-service experience, does the written agreement:
Designate the administrator of the
program; and ____________
____________
yes no
Specify the terms, conditions, and
performance standards of the program?
____________
____________
yes no
675.47(c) 1. Does each institution retain
responsibility for the proper disbursement of the federal funds it contributes?
____________
____________
yes no
Federal Register, 1/12/15, p. 1496
G. Does the institution submit its Work-Colleges Program Expenditures Report for award year expenditures by the annual deadline published by ED?
____________
____________
yes no
See also the Recommended Good Practices section (Part 1, Section VIII) of the Self-Evaluation Guide. Comments on the Administration of the Federal Work-Study Program
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