Kristina,
You are absolutely correct! The FAO should ALWAYS refer to the regulation(s) and use the Handbook and guidance from ED as important but none the less, as secondary information. In my experience I have found that too many FAO's rely too heavily on the Handbook and advice from colleagues to make decisions. This practice is not worth the risk!
Cindy Kohlman
The Financial Aid Officer is still responsible for proper administration of Title IV programs in compliance with law and regulation regardless of the annual handbook or informal advice from the Department of Education.
The institution is ultimately responsible for administering Title IV programs correctly even if incorrect advise was given. That is why it is important for the FAO to fully understand the regulations and view them as a positive force versus a road block.FAOs with strong knowledge and understanding will be able to assist the institution and help reach its goals and objectives while still remaining complaint at all times.