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Deductible (CPYD) versus Non-Deductible (CPYN) CSL Overawards #1738

Closed JasonCTang closed 1 year ago

JasonCTang commented 1 year ago

CSL overaward amounts generated that are less than $250, or overawards calculated prior to 96/97 program years are considered Non-Deductible, as they will not be automatically deducted from a new funding application.

SFAS treats Deductible and Non-Deductible CSL overawards as separate balances. Use CPYN instead of CPYD when adjusting non-deductible CSL overawards.

Non-deductible overawards can only be reduced by a manual entry by Ministry Staff. The non-deductible overawards WILL NOT be included in the tuition remittance and ECERT calculations.

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JasonCTang commented 1 year ago

Hi Josh,

Just providing an update based on Hugh’s original question attached and yours below.

To answer Hugh’s question, as Federal policy states “Only overawards of $250 and more are subject to recovery”, I believe there is no requirement for SIMs to treat all overawards as deductible.

In checking in with Jeremy, from my understanding, we currently do not accumulate overwards under $250 to be deducted once it is greater than or equal to $250 – so multiple overaward amounts that are non-deductible but add up to $250 or more in the current state (and the SIMs state) are/can be disregarded as it does not align with Federal policy.

Currently, we do manually adjust any non-deductible overaward balances when a student indicates to us that they paid this balance to NSLSC (even though the student does not need to make payment as Federal policy states overawards under $250 do not need to be recovered). While it has absolutely no impact on a student’s funding, it is simply done because the student has made payments so the amount should be resolved.

Jeremy suggested that in SIMS we remove the differentiation between non-deductible and deductible overawards and write in a business rule that any overaward less than $250 is ignored by SIMS to align with federal policy. The information still needs to be recorded somewhere in SIMS but it does not factor into a students account.

Let me know if this answers you and Hugh’s questions, happy to discuss more.

Erik Jin | Policy Analyst StudentAid BC | Ministry of Post-Secondary Education and Future Skills

From: Jin, Erik X PSFS:EX Sent: February 23, 2023 12:54 PM To: Lakusta, Joshua PSFS:EX Joshua.Lakusta@gov.bc.ca Cc: Monticone, Claire PSFS:EX Claire.Monticone@gov.bc.ca Subject: RE: Policy around non deductible overawards

Hey Josh,

Thanks for looping me in. Me and Claire have a meeting scheduled at 2:45 to discuss further on this and I’m going to see if I can reach out and get more info from Blaine and/or folks in FIN regarding where and why exactly the cumulative growth and collection practice/policy came from for amounts below $250 and then requiring collection once it reaches $250 or more.

Federal policy says amounts under $250 do not require collections/deductions, and from my understanding it doesn’t look like there is a requirement or policy from CSFA that speaks to our current process, since CSFA policy states amounts under $250 are not subject to recovery and is for each review/instance that the threshold applies, as opposed to over multiple instances that add up to $250 or greater. So it looks like it is our own provincial piece.

Claire also found out that in our past PM, we had a line mentioning specifically that “If a student does not repay an overaward totaling $250 or more per application (effective the 1996-1997 program year or later), the amount will be deducted from the next Canada Student Loan award calculated…”. This was removed due to ‘out-dated content applying to very few students' and 'old content for pre-2005 loans' so I’m wondering if this also plays a part as well as it’s interesting that a federal policy requirement was removed from our provincial manual.

Will keep you posted, if you like I can send the invite to our 2:45 meeting today as well, but don’t want to add more to your already big plate!

Erik Jin | Policy Analyst StudentAid BC | Ministry of Post-Secondary Education and Future Skills

From: Lakusta, Joshua PSFS:EX Joshua.Lakusta@gov.bc.ca Sent: February 23, 2023 12:09 PM To: Monticone, Claire PSFS:EX Claire.Monticone@gov.bc.ca; Morris, Alexandra PSFS:EX Alexandra.Morris@gov.bc.ca; Jin, Erik X PSFS:EX Erik.Jin@gov.bc.ca Cc: Pearson, Jeremy PSFS:EX Jeremy.Pearson@gov.bc.ca Subject: Policy around non deductible overawards

Hello to you both, I am hoping you can assist me in a policy breakdown on nondeductible overawards. So these are over awards that are from pre 1996 or are less than $250. Through my digging through federal policy it describes the overawards as under $250 as non-recoverable. I am just curious why we historically have allowed these to cumulatively grow past $250 and then collect them at that point. I am just looking for direction on where this process/policy comes from because I don’t see it. Thanks,

Joshua Lakusta |A/Business Application Advisor StudentAid BC | Ministry of Post-Secondary Education and Future Skills Phone: 778 405-1528 www.studentaidbc.ca

JasonCTang commented 1 year ago

As per previous comment, policy has confirmed that we can just drop any overawards under $250 and not worry about accuring them and as a result, there is no -non-deductible overawards to track and display.