Heightened Cash Monitoring

Heightened Cash Monitoring

The U.S. Department of Education may place institutions on a Heightened Cash Monitoring (HCM) payment method to provide additional oversight of cash management. Heightened Cash Monitoring is a step that FSA can take with institutions to provide additional oversight for a number of financial or federal compliance issues, some of which may be serious and others that may be less troublesome.

There are two levels of Heightened Cash Monitoring:

  • Heightened Cash Monitoring 1 (HCM1): After a school makes disbursements to eligible students from institutional funds and submits disbursement records to the Common Origination and Disbursement (COD) System, it draws down FSA funds to cover those disbursements in the same way as a school on the Advance Payment Method.
  • Heightened Cash Monitoring 2 (HCM2): A school placed on HCM2 no longer receives funds under the Advance Payment Method. After a school on HCM2 makes disbursements to students from its own institutional funds, a Reimbursement Payment Request must be submitted for those funds to the Department.

Schools may be placed on HCM1 or HCM2 as a result of compliance issues including but not limited to accreditation issues, late or missing annual financial statements and/or audits, outstanding liabilities, denial of re-certifications, concern around the school's administrative capabilities, concern around a schools' financial responsibility, and possibly severe findings uncovered during a program review. Additionally, the Department may place a school on the “Reimbursement” payment method if it determines that the school needs the highest level of monitoring. The “Reimbursement” payment method is similar to HCM2, except the Department reviews the documentation for all students and parents included in the payment request, not just a sample. Some schools are on this list due to preliminary findings made during a program review that is still open. Those findings could change when the program review is completed.

Additional information about HCM and Reimbursement is available in the FSA Handbook.

Institutions on HCM by quarter:

*Note: The list above includes those institutions which were on HCM, as of March 1, 2015. A previous published version of this list also included names of institutions that were in the process of being removed from HCM. Those institutions were removed from the list.