I didn’t see Post 17 because I was posting at the time it appeared. @thumper1 is correct. Here is the regulation: https://ifap.ed.gov/fsahandbook/attachments/1617FSAHbkVol3Chapter7.pdf (page 3-142). You may want to direct your financial aid office to the regulation, which is contained in the Federal Student Aid Handbook (the financial aid bible). The relevant language:
PELL GRANTS AS FIRST SOURCE OF AID
Pell Grants are considered to be the first source of aid to the student, and packaging FSA funds begins with Pell eligibility. A correctly determined Pell Grant is never adjusted to take into account other forms of aid. Therefore, if a student’s aid package exceeds his/her need, you must attempt to eliminate the overaward by reducing other aid your school controls.
The Department issues Pell payment schedules that base the award solely on the student’s cost of attendance, EFC, and enrollment status. As we’ll see, aid from the other FSA programs must be awarded to ensure that the student’s need is not exceeded, unless certain types of aid are used to replace the EFC, as permitted.
Traditional financial aid practice suggests that you would also adjust non-federal aid awards, if necessary, to ensure that the student’s financial need is not exceeded. But it’s possible that the student will receive a scholarship or other aid that you can’t adjust and is large enough (in combination with the Pell Grant) to exceed the student’s need. In this case, the student is still eligible for a Pell Grant based on the payment schedule. However, you can’t award any FSA funds other than the Pell Grant.
(Note: FSA funds means Federal Student Aid funds - or Title IV federal aid)