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Glenn Hegar  ·  Texas Comptroller of Public Accounts

Reporting Requirements for Annual Financial Reports of State Agencies and Universities

Pass-Through Activity

Miscellaneous Topics
Unexpended vs. Expended Federal Funds

Contracts and grants for which money was not received but from which expenditures were made are reported as a federal receivable. These expenditures are reported in the SEFA web application.

Reporting of Student Financial Aid Title IV Funds in SEFA

Student Financial Aid (SFA) Title IV funds include programs such as Pell and Federal Supplemental Educational Opportunity Grants (FSEOG). Use the following guidelines when reporting SFA Title IV funds in SEFA.

  • Even if a university uses its own funds in advance of receiving program funds from the federal government, in accordance with the regulations in GASB 34 and CFR 668.164, the Pell and FSEOG funds are considered as disbursed on the earlier of the date that the university either:
    • Credits those funds to a student’s account in the university’s general ledger or any sub ledger of the general ledger
    • Pays those funds to a student directly
  • All amounts disbursed to students under Pell and FSEOG are reported in SEFA in the accounting period they are disbursed.
  • Pell Grant funds are considered non-operating federal revenue.

Revenue Recognition of SFA Title IV Funds

SFA Title IV funds are subject to GASB 33. Use the following guidelines in determining when and how to recognize SFA Title IV revenue from programs such as Pell and FSEOG.

  • Requirements of GASB 33:
    • SFA Title IV funds are voluntary nonexchange transactions (unlike tuition revenues, which are exchange transactions).
    • According to GASB 33, voluntary nonexchange transactions, revenues and expenses/expenditures are recognized when all applicable eligibility requirements are met or resources are received, whichever is first.
  • Eligibility Requirements:
    • Among other requirements, a student is considered eligible for SFA Title IV programs if he or she is a regular student, enrolled or accepted for enrollment in an eligible program at an eligible university.
    • Whether or not classes have begun or are in process is not a determinate for the recognition or deferral of revenue from these programs.
  • Recognition of Unearned Revenue:
    • Federal funds for SFA Title IV programs received after the eligibility determination are not accounted for as unearned revenue (even if the eligibility was determined and funds received prior to the period when instruction begins).
    • There may be instances where federal funds received prior to eligibility determination are accounted for as unearned revenue.
Glenn Hegar
Texas Comptroller of Public Accounts
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