Policy
In accordance with 34 CFR 673.5 and 685.102(b), any funds a student receives because of being enrolled in postsecondary education are considered other financial assistance (OFA) and must be counted as OFA when packaging the student. There is no de minimis amount for reporting purposes.
General Procedures and Rules
Once a UMW department/office becomes aware of potential OFA provided to a student, reporting should be done as soon as possible to avoid potential negative impacts to the student such as a reduction in aid and increase in student bill. UMW uses Federal Methodology to establish financial need for Title IV aid and also for need based employment calculations.
What is considered OFA?
Financial Assistance must be included in a student’s total financial award total if:
- The assistance is paid because of enrollment in a postsecondary educational institution; OR
- The assistance that is paid is intended to cover postsecondary educational expenses.
Situations
When the school covers the expenses only and the student never receives any funds they could spend on other things:
- If the trip or conference meets requirements of the student’s academic program, the trip or conference expenses should be included in the student’s cost of attendance (COA) and the funds paid by the school should be included as other financial assistance (OFA) when awarding/packaging the student with Title IV aid. **This will offset the cost with the payment, no impact to the student aid but must be documented. The giver must provide documentation that the trip or conference is a requirement of the student’s academic program. A confirmation from the students’ academic advisor or a member of the Academic Services office will suffice.
- If the trip or conference does not meet any requirements of the student’s academic program, the value of the trip or conference must be included as OFA. The value of the trip is not included in the students’ yearly COA. Even if funds are earmarked to cover costs that are not included in the COA (such as recommended optional enrichment activities), it is still considered OFA.
- EXCEPTION: If the school pays the trip or conference costs directly, such as by direct reimbursement of those expenses by the school, the covered expenses are not considered to be OFA. For example, if the student pays the expenses and submits receipts to the school, and the school reimburses the student for exactly those actual expenses incurred, it is not OFA.
- In either situation, if the student receives funds not associated with any documented costs (spending money), it is included as OFA.
If a student receives assistance during a period of nonattendance (such as summer or other breaks), and those funds are provided to the student due to postsecondary enrollment, then those funds are OFA towards the upcoming period of enrollment.
For example, if the student is not enrolled for the summer but receives grant funds to cover summer housing, those funds are OFA towards the upcoming period of enrollment (not for the summer).
When the student is not enrolled during the summer between academic years, the student does not have a COA to offset the assistance, so it must be attributed to the upcoming period of enrollment.
The same is true for internships, fellowships, assistantships, research positions, etc. where the student receives assistance other than non-need-based loans. If a fellowship is considered employment under federal or state law, it would be exempt from OFA reporting. Fellowships that are not employment under federal or state law are reported as OFA.
Post-enrollment and graduation awards are OFA if they are given due to postsecondary enrollment or to pay postsecondary costs. NASFAA has confirmed with ED that, if the school was aware of the reasonable possibility of such an award, it is OFA and should have been included in the student’s aid package for the recently concluded period of enrollment.
Emergency Aid is not OFA. To be defined as Emergency Aid:
- The amount must be reasonable, as defined by the school;
- You cannot simply call a grant or scholarship emergency assistance in order to avoid treating it as OFA;
- Emergency assistance will include institutional emergency assistance (e.g., unexpected loss of housing, unexpected transportation costs, and other unexpected special circumstances that warrant emergency funds);
- Emergency assistance would not be the awarding of additional funds as a result of a professional judgment (PJ) adjustment within the school’s normal procedures for making PJ adjustments; and Federal emergency assistance usually comes specifically designated as such.
What if the gift is provided by a student organization? Student organizations are outside of the scope of this policy.
If a fellowship is considered employment under federal or state law, it would be exempt from OFA reporting. Fellowships that are not employment under federal or state law are reported as OFA.
Most veterans’ education benefits do not need to be reported as OFA.
How to Report Other Financial Assistance
To report OFA, please complete the Reporting Payments/Gifts to UMW Students Form, located below or on the UMW Financial Aid Forms page. Questions may be directed to finaid@umw.edu.