To: 2024 Negotiated Rulemaking Program Integrity and Institutional Quality Committee 

From: Magin Sanchez

February 5, 2024 

Re: Cash Management Regulations 

The additions to the student ledger section of the regulations are an excellent improvement and 

would allow students to use their Title IV funds as they deem best. However, I am concerned 

that by focusing only on the cash equivalent portion of meal plans, students may still be faced 

with losing significant funds if they are unable to use all of their meal credits that do not have a 

cash equivalent each month. Students frequently find that they have unused meal credits at the 

end of each semester. Swipe Out Hunger, a nonprofit organization committed to eradicating 

student hunger by partnering with colleges knows of at least 200 colleges around the country 

that run meal credit donation programs because of the large number of meal credits wasted 

each year. Students who drop out of school, in particular, may need those funds to cover living 

costs and even student loan debt they cannot afford to repay.

In particular, I am concerned that even more institutions could adopt a meal-credit approach in 

response to these regulations, as a loophole that will allow them to continue to hold onto Title IV 

students’ unused funds – effectively, free money for the school at the direct expense of students 

whose school may even require them to purchase more meal plan swipes than they were able 

to use. 

To correct this issue, I am proposing that institutions should also refund students the equivalent 

of the cost value (not retail) to students along with any cash-equivalent funds. 

Cash Management 

§ 668.164 (c)(1), and (2) and (3) - Crediting a student's ledger account 

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(c) Crediting a student's ledger account. 

(1) An institution may credit a student's ledger account with title IV, HEA program funds 

to pay for allowable charges associated with the current payment period. Allowable charges are 

(i) The amount of tuition, fees, and institutionally provided food and housing 

room and board assessed the student for the payment period or, as provided in 

paragraph (c)(5) of this section, the prorated amount of those charges if the institution 

debits the student’s ledger account for more than the charges associated with the 

payment period; 

(A) An institution may only include costs of books and supplies as a part of tuition and fees if the 

institution demonstrates there is a compelling health or safety reason to do so. 
(B) All title IV, HEA program funds allocated for cash value meal plan expenses, including the 

cash value of meal plan funds and the cost value of unused meal plan credits for recipients of 

Title IV, HEA program funds must be fully utilized for the benefit of the respective students. No 

institution may retain unused meal plan funds that were paid for with title IV, HEA program 

funds, and any remaining balance at the end of the payment period must be returned to the 

student as soon as possible but no later than 14 days after the end of the payment period;. A 

school is not required to pay a remaining balance that is less than $1.00. With a student’s 

written authorization under § 668.165(b)(1)(ii)(B), an institution may—

(1) Retain unused cash value meal plan funds and the cost value of unused meal plan 

credits through the earlier of the end of the academic year or 14 days after the end of the 

payment period in which the student ceases enrollment at the institution; or 

(2) Apply unused meal plan funds to unpaid allowable charges; and