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Award Aid - Why do some think it needs to be part of the COA and go though FA?
I've asked this question in multiple budget trainings and COE priority trainings, PLUS I asked the FSAtraining help desk about Award Aid as "Other Aid" in the FAFSA/Federal Aid regulations. No one can answer me!
Scenario: The Financial Aid office is 1- using SSS Award Aid to pay off balances owed in student accounts before deployment. 2 - saying SSS Award Aid is part of the Max Cost of Attendance and refusing to distribute it to students who've reached that threshold.
(Our FA director was formerly at a big city college and we like to think she's very knowledgeable on SSS Award aid since that college has several TRIO programs.)
Our COE trainers believe that Award Aid is separate from Financial Aid and should not go through that office and should be issued as a separate check, much like I've done for Upward Bound stipends in the past. However, my management team and FA want it to go through FA to check on the COA and then the Business Office through the student account and then whatever is left to the student.
I want a regulation and I want to step up with my Program officer and correct these misinterpretations.
What is the law? What is the regulation on TRIO award aid? I find mention in the ECFR - but no specifics how it should be deployed?
Great question — this one gets misinterpreted often.
The governing citation is 34 CFR §646.30(e) under the Student Support Services (SSS) Program regulations. It authorizes SSS projects to provide grant aid only to current participants who are also receiving a Federal Pell Grant during that same academic year. The funds are meant to supplement, not replace other sources of financial aid.
In practice, the Financial Aid Office must be directly involved in determining who receives SSS grant aid and the amount of each award. This isn’t just best practice, it’s a federal assurance requirement under 34 CFR §646.11(d), which states that “the institution’s financial aid office will consult with the SSS project with respect to which SSS participants should receive grant aid and the amount of the grant aid awards.”
This coordination ensures compliance with Title IV rules regarding Cost of Attendance (COA) and prevents overawards, which occur when total aid exceeds allowable limits. The Business Office typically processes SSS grant aid through the student’s account so that it appears on the official aid record, and any remaining balance can be refunded to the student.
It’s important not to confuse SSS grant aid with Upward Bound stipends.
• Upward Bound stipends (regulated under 34 CFR §645.30(f)) are considered participant support payments, not financial aid. They can be issued directly to students as compensation for participation or performance.
• SSS grant aid, however, is a form of federal student financial assistance, tied to Pell eligibility, and therefore must be coordinated through the Financial Aid Office and reflected in the student’s aid package.
There isn’t a prescribed federal deployment method, but ED requires that whatever process is used must be documented, consistent, and compliant with both TRIO regulations and the Uniform Guidance at 2 CFR Part 200.
For reference:
34 CFR §646.30 – Student Support Services Program
34 CFR §646.11 – Assurances
34 CFR §645.30(f) – Upward Bound Participant Stipends