University Policy 4201: Scholarship Awarding

Category: Academic Affairs
Subcategory: Academic Fees & Awards
Covered Individuals: Current USU Students
Responsible Executive: Vice President for Strategic Enrollment
Policy Custodian: Student Financial Services, Executive Director of Student Financial Services
Last Revised: 2025/10/31
Previous USU Policy Number: 532
Download the PDF File for Policy 4201

4201.1 PURPOSE AND SCOPE

Utah State University (USU) provides Scholarships to undergraduate and graduate students through funds provided by donors, federal and state governments, and USU general funds. This policy provides a framework to (i) foster accountability, protect employee integrity, and safeguard USU funds; (ii) ensure that proper stewardship, guidelines, and internal controls are in place to achieve the highest level of public trust; and (iii) ensure that student needs are considered in the process.

This policy applies to both Qualified and Non-qualified Scholarships.

4201.2 POLICY

2.1 Legal Compliance

Scholarship funds must be administered and awarded in accordance with applicable federal, state, and local law and USU policies and procedures, including USU’s Notice of Non-Discrimination. When the funds are associated with a gift, the University endeavors to use the funds in keeping with the donor’s intent. If a gift or endowment agreement includes selection criteria that are unlawful or otherwise not compliant with USU policy, then USU, through University Advancement, will work with the donor (if the donor is still living) to release or modify the criteria. In cases where the donor is no longer living, University Advancement will work with the Office of General Counsel to release or modify the selection criteria as permitted by applicable law (e.g., Utah Code 51-8-501), which may require approval by the
Attorney General for authorization. Scholarships can be awarded to a student without lawful immigration status if the student complies with all applicable and then-current legal requirements, including those set forth in Utah Code 53H-11-203.

2.2 Determining Financial Need

When determining financial need for Financial Need-Based Scholarships, the Scholarship Awarding Unit must use the Free Application for Federal Student Aid (FAFSA) as the official resource. If an alternate or augmented financial need calculating mechanism is needed, it must be approved by the Central Scholarship Committee.

2.3 Scholarship Committees

Scholarship Awarding Units must establish a committee for each Scholarship that it administers. Individual Scholarship Committee members are each responsible for complying with this policy. The structure and membership of each Scholarship Committee will be determined and documented by the Scholarship Awarding Unit. The number of committee members should be limited to only those necessary to administer the Scholarship. Donor(s) associated with the funding of the Scholarship and
students are not permitted to participate in the Scholarship reviewing or awarding processes. All Scholarship committee members must be current on their Family Educational Rights and Privacy Act (FERPA) training and conflict-of-interest disclosures (See USU Policy 2201: Student Records and USU Policy 2301: Individual Conflicts of Interest). Scholarship committees must use the USU-approved scholarship platform to review requirements, applicants, and determine Scholarship recipients, unless otherwise specifically authorized by Student Financial Support. Each Scholarship Committee must administer the Scholarship in keeping with applicable donor agreements. Questions regarding donor agreements, selection criteria, or donor intent must be coordinated with University Advancement. 

2.4 Documentation

Scholarship Awarding Units must maintain proper documentation in keeping with all related procedures. At a minimum, proper documentation includes committee membership, conflict of interest statements, the application review and awardee selection process, point of contact information, and all scholarship communication, such as notifications and approvals for any exceptions. Documentation must be retained for a minimum of 6 years after the awarding cycle in an electronic format and at a location accessible by Student Financial Support and/or Internal Audit.

2.5 Publication of Scholarship Information

Scholarship Awarding Units must publish required Scholarship information as specified in applicable procedures, including, at a minimum, application deadlines, scholarship criteria, a scholarship appeal process, and conflict of interest statements for any Scholarship Committee members. 

2.6 Acceptance Process

Scholarship Awarding Units must issue an award notification to students selected for the Scholarship in keeping with applicable procedures. Students must officially accept their Scholarship(s) through a process approved by Student Financial Support. Institutionally funded Scholarships for first-time students (e.g., academic, need, legacy, etc.) may be accepted through the Confirmation of Enrollment process. All other Scholarships must be accepted in a USU-approved scholarship platform. 

2.7 Training

All employees involved in Scholarship awarding must receive relevant training from Student Financial Support or the Scholarship Management Committee. These individuals provide the necessary knowledge, skills, and abilities to function within and contribute to a compliant Scholarship-awarding environment. Scholarship Awarding Units are responsible for keeping personnel current on such training.

2.8 Separation of Duties

In administering Scholarships, duties must be appropriately segregated such that no one person has control of both awarding and funding of Scholarships. If a Scholarship Awarding Unit has questions about scaling procedures to accommodate smaller operations, it must contact Student Financial Support for guidance prior to establishing processes or compromising the separation of duties.

2.9 Reconciliation

Reconciliation of Scholarship awards must be regularly completed and reviewed by the Business Services team and administrators (i.e., Dean’s Office, Department Heads, etc.) associated with the Scholarship Awarding Unit. 

2.10 Timely & Accurate Reporting

Scholarship-awarding reports must be accurate and made available to appropriate Scholarship Awarding Unit personnel in a timely manner.

2.11 Exemption for Intercollegiate Athletic Scholarships and Grants-In-Aid Program

The Vice President and Director of Athletics, as designated by USU Policy 1000C.47(8), retains supervision of “the intercollegiate athletic scholarship and grants-in-aid program and all athletic awards after consultation with and approval of the Athletic Council.” The administration, internal controls, processes, and procedures for athletic scholarships are excluded from this policy. However, coordination between Student Financial Support and Athletics is required for Scholarship administration, which includes institutional, college, or state aid programs.

4201.3 RESPONSIBILITIES

3.1 University Advancement

University Advancement is responsible for (i) interpreting donor agreement language if unclear; (ii) approving the use of additional application materials to award Scholarships; (iii) collaborating with donors to modify Scholarship selection criteria, when appropriate; and (iv) when no donor is available, consulting with the Office of General Counsel to release or modify the gift’s purpose in accordance with statute and donor intent.

3.2 Student Financial Support 

Student Financial Support is responsible for (i) collaborating with Scholarship Awarding Units to create ethical scholarship-awarding procedures; (ii) coordinating with Athletics to administer institutional, college, or state aid programs; (iii) providing training for Scholarship committee members on best practices for Scholarship awarding; (iv) providing best practices for appropriate internal controls such as separation of duties and compensating controls; (v) conducting review of Scholarship awarding procedures as needed; (vi) chairing the Scholarship Management Committee; (vii) establishing the process by which Scholarships are applied to student accounts; and (viii) oversight of the approved USU scholarship awarding platform.

3.3 Scholarship Awarding Units

Scholarship Awarding Units are responsible for (i) maintaining appropriate documentation and publishing information as outlined in 4201-PR1: Scholarship Awarding Procedures; (ii) ensuring that its Scholarship committee members receive appropriate training; (iii) establishing Scholarship-awarding procedures that promote appropriate use of funds; (iv) implementing timely and accurate reporting and preventative measures such as separation of duties and regular reconciliation of Scholarships; (v) providing access to required information for audit purposes; and (vi) notifying students of Scholarships as outlined in 4201- PR1: Scholarship Awarding Procedures.

3.4 Office of General Counsel

The Office of General Counsel is responsible for (i) assisting University Advancement in modifying the purpose of a gift when Scholarship awarding is not feasible based on the donor’s selection criteria and the donor is no longer living; and (ii) collaborating and coordinating with the Office of the Utah Attorney General as necessary.

3.5 Internal Audit

Internal Audit is responsible for reviewing and measuring the effectiveness of the controls and procedures used by Scholarship Awarding Units, as needed, and has the authority to review and measure the effectiveness of scholarship controls and procedures at their discretion with minimal or no notice to the Scholarship Awarding Unit. 

3.6 Central Scholarship Committee

The Central Scholarship Committee is responsible for (i) establishing University-wide criteria and requirements that Scholarship Awarding Units must implement in their own scholarship-awarding procedures; and (ii) serving as a primary source of information, education, and assistance on policy topics. The Central Scholarship Committee includes two standing members – the Vice President of Strategic Enrollment Management and the Department Head of Student Financial Support. In addition, the Central Scholarship Committee will include one academic dean or designee to be appointed by the Provost for a two year term; one financial officer to be appointed by the Vice President of Business and Finance for a two year term; and one University Advancement representative to be appointed by the Vice President of Advancement for a two year term.

3.7 Scholarship Management Committee

The Scholarship Management Committee is responsible for overseeing the implementation of Scholarship awarding procedures and ensuring Scholarships are administered in accordance with this policy. The Scholarship Management Committee comprises representatives from Student Financial Support, University Advancement, all Academic Colleges, and other units/divisions as requested by the Scholarship Management Committee. The Scholarship Management Committee should meet monthly (or as often as needed) to ensure compliance with Scholarship administration and the implementation of this policy. Student Financial Support will oversee the Scholarship Management Committee. 

4201.4 REFERENCES

4201.5 RELATED USU POLICIES

4201.6 DEFINITIONS

  • FAFSA means the Free Application for Federal Student Aid and is the basic student financial aid application form used by all two and four-year colleges, universities, and career schools for the awarding of federal student aid and most state and college aid. At USU, Student Financial Support administers Title IV aid, which is available to students by completing the FAFSA.
  • Financial Need-Based Scholarship means a Scholarship awarded based on financial need as defined by the FAFSA.
  • Non-Qualified Scholarship means any portion of a Scholarship that does not qualify as a Qualified Scholarship, as defined herein. Non-Qualified Scholarships are included in the gross income of the recipient and are subject to withholding for tax purposes. Withholdings are to be applied by the institution for specified citizenship codes, such as nonresident aliens living in the US. International students may be charged an international tax if the Scholarship exceeds their qualified charges. For non-degree-seeking, nonresident candidates and nonresident postdoctoral research scholars, the entire Scholarship is taxable and included in taxable income.
  • Qualified Scholarship means any portion of a Scholarship that is used for qualified tuition and related expenses, as set forth in 26 US Code Section 117. Qualified tuition and related expenses consist of tuition and fees required for the enrollment or attendance of a student at USU and fees, books, supplies, and equipment required for courses of instruction at USU. Qualified scholarship payments to nonresident aliens are not taxed or reported to the IRS.
  • Scholarship means a qualified or non-qualified grant or payment made to support a Utah State University student's education. Scholarships are awarded based on need, academic achievement, or other merits. Scholarships may be referred to by various titles (e.g., award, grant, fellowship) and issued by the institution, colleges, or departments. For purposes of this policy, Scholarships include both Non-Qualified Scholarships and Qualified Scholarships, as defined herein.
  • Scholarship Awarding Unit means any USU unit (e.g., college, department, etc.) that issues, evaluates, or oversees Scholarships. Each Scholarship Awarding Unit determines how scholarships are processed within the unit, and whether one procedure is sufficient for the entire unit or if multiple procedures are necessary.

Information below is not included as part of the contents of the official policy. It is provided only as a convenience for readers/users and may be changed at any time by persons authorized by the president. 

RESOURCES

Procedures

4201-PR1: Scholarship Management Committee Procedures 

Contacts

Executive Director of Student Financial Support

POLICY HISTORY

Original issue date: 2017/08/09
Last revision date: 2025/10/31
Next scheduled review date: 2028/07/01
Previous revision dates: 2025/07/09, 2022/10/26, 2021/05/26, 2017/08/09