1 2008 State Program Review Process Presented by GSFC Compliance Team.

34
1 2008 State 2008 State Program Review Program Review Process Process Presented by Presented by GSFC Compliance GSFC Compliance Team Team

Transcript of 1 2008 State Program Review Process Presented by GSFC Compliance Team.

Page 1: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

11

2008 State 2008 State Program Review Program Review

ProcessProcessPresented byPresented by

GSFC Compliance GSFC Compliance TeamTeam

Page 2: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

22

2008 State Program 2008 State Program Review ProcessReview Process

Agenda Agenda Welcome and IntroductionsWelcome and Introductions

2008 Program Review Overview2008 Program Review Overview

Program Review TimelineProgram Review Timeline

Questions and DiscussionQuestions and Discussion

Page 3: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

33

IntroductionIntroduction

Goal – To make you familiar with Goal – To make you familiar with the processthe process

Materials:Materials:– Information packet, orInformation packet, or– www.gsfc.orgwww.gsfc.org – Click on ‘School & – Click on ‘School &

Lender Information’, then scroll to Lender Information’, then scroll to GSFC Compliance DocumentsGSFC Compliance Documents

Staff IntroductionsStaff Introductions HousekeepingHousekeeping

Page 4: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

44

Goals Goals

Improve Administration of ProgramsImprove Administration of Programs

Educate and Train Institutional StaffEducate and Train Institutional Staff

Safeguard Public FundsSafeguard Public Funds

Be Clear, Consistent, and ConciseBe Clear, Consistent, and Concise

Page 5: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

55

Implementation Implementation

Began with the 2007 Review Began with the 2007 Review CalendarCalendar

Included 40 InstitutionsIncluded 40 Institutions Employed a Benchmark Employed a Benchmark

ComponentComponent

Page 6: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

66

Review Process Prior Review Process Prior to 2007to 2007 All Institutions Reviewed AnnuallyAll Institutions Reviewed Annually Typical Sample Size was 30-40 Typical Sample Size was 30-40

FilesFiles Length of ReviewLength of Review Review Was Conducted Only on Review Was Conducted Only on

Selected Award Year Selected Award Year

Page 7: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

77

Current Review Current Review ProcessProcess Each Institution to be Reviewed at Each Institution to be Reviewed at

Least Once Every Three YearsLeast Once Every Three Years Sample Size is Based on a Statistically Sample Size is Based on a Statistically

Sound Methodology (95% Confidence Sound Methodology (95% Confidence Level with +/- 10% Margin of Error)Level with +/- 10% Margin of Error)

Review Timeframe is 2 DaysReview Timeframe is 2 Days All State Awards for Students in All State Awards for Students in

Sample are Examined for ReviewSample are Examined for Review

Page 8: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

88

Tracking Institutional Tracking Institutional Progress Through Progress Through Benchmarking Benchmarking

Benchmarking tracks the progress of Georgia Benchmarking tracks the progress of Georgia institutions in the proper administration of State institutions in the proper administration of State Programs.Programs.

Findings types are assigned a value based on Findings types are assigned a value based on severityseverity

Number of incidents for each finding type are Number of incidents for each finding type are multiplied by the value of each finding to arrive multiplied by the value of each finding to arrive at a finding scoreat a finding score

The finding score is then compared to the sample The finding score is then compared to the sample size, which determines a Benchmark Scoresize, which determines a Benchmark Score

This Benchmark Score is used to determine which This Benchmark Score is used to determine which institutions will benefit the most by having GSFC institutions will benefit the most by having GSFC efforts directed towards assisting them in the efforts directed towards assisting them in the administration of the State Scholarship and Grant administration of the State Scholarship and Grant ProgramsPrograms

Page 9: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

99

Benchmark Values for Benchmark Values for Finding TypesFinding Types

5 – Fraud by an institution or False 5 – Fraud by an institution or False Certification of award Certification of award

4 – Administrative problem affecting a 4 – Administrative problem affecting a significant portion of the population - GPA, significant portion of the population - GPA, Refunds, Invoicing, ResidencyRefunds, Invoicing, Residency

3 – Administrative errors affecting smaller 3 – Administrative errors affecting smaller population - Selective Service, SAP, population - Selective Service, SAP, Citizenship, Default, Book Allowance, Citizenship, Default, Book Allowance, Enrollment, Exceeded HoursEnrollment, Exceeded Hours

2 – Missing or Incorrect Documents - Missing 2 – Missing or Incorrect Documents - Missing Transcript, Missing ApplicationTranscript, Missing Application

1 – Non-Monetary Exceptions - Incorrect 1 – Non-Monetary Exceptions - Incorrect Reporting of Data, No Book Allowance Reporting of Data, No Book Allowance authorization authorization

Page 10: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

1010

Institution’s Institution’s Benchmark ScoreBenchmark Score

Finding Value / Sample Size = Finding Value / Sample Size = Institution’s Benchmark ScoreInstitution’s Benchmark Score

Example:Example: 3 incidences of incorrect 3 incidences of incorrect determination of Residency determination of Residency (value of 4) will result in a finding (value of 4) will result in a finding rate of 12 (3x4). If 90 files are rate of 12 (3x4). If 90 files are sampled, the resulting sampled, the resulting Benchmark Score will be 13.33Benchmark Score will be 13.33

Page 11: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

1111

Benchmarking ImpactBenchmarking Impact

Last Year We Reviewed Schools Last Year We Reviewed Schools Based on the 2006 Benchmark Based on the 2006 Benchmark ScoresScores

40 Schools40 Schools 2006 Benchmark Scores Used Solely 2006 Benchmark Scores Used Solely

for Determining 2007 Review Rosterfor Determining 2007 Review Roster Tracking Benchmark Scores Began Tracking Benchmark Scores Began

in 2007in 2007

Page 12: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

1212

Institutional Review Institutional Review Roster for 2008Roster for 2008 Repeating reviews at a portion of Repeating reviews at a portion of

the schools reviewed in 2007the schools reviewed in 2007 Exempted in 2006Exempted in 2006 Schools with a 2006 Benchmark Schools with a 2006 Benchmark

Score of zeroScore of zero

Page 13: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

1313

Sample Size Sample Size

Based on number of awardsBased on number of awards Number of files required to Number of files required to

achieve a 95% confidence level achieve a 95% confidence level with a +/- 10% margin of error with a +/- 10% margin of error raterate

Typically 80-90 filesTypically 80-90 files

Page 14: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

1414

Policies & Procedures Policies & Procedures

Preliminary Report to Institutional OfficersPreliminary Report to Institutional Officers Final Report to PresidentFinal Report to President Remittance of liabilities not due until after Remittance of liabilities not due until after

the Final Report is issuedthe Final Report is issued Strict adherence to the review timelineStrict adherence to the review timeline Multiple year reviewMultiple year review Sample selection with a variety of criteria Sample selection with a variety of criteria

– presence of electronic applications, – presence of electronic applications, cancellations, and citizenship statuscancellations, and citizenship status

Page 15: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

1515

Training Referrals Training Referrals

Training ReferralsTraining Referrals Mandatory ReferralsMandatory Referrals

Page 16: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

1616

Goals Goals

It is the intent of GSFC to It is the intent of GSFC to demonstrate good stewardship of State demonstrate good stewardship of State Funds. Success with the current review Funds. Success with the current review procedures will be measured by:procedures will be measured by:– Improving Benchmark Scores of All Improving Benchmark Scores of All

Participating InstitutionsParticipating Institutions– Developing better relationships with Developing better relationships with

Georgia institutionsGeorgia institutions– Improving the confidence level in GSFCImproving the confidence level in GSFC

Page 17: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

1717

Review PreparationReview Preparation

Review Notification Letter Review Notification Letter -Selected / Not Selected-Selected / Not Selected

Review ScheduleReview Schedule

*New*New – Program Review Schedule Request – Program Review Schedule Request Form Form

Request for DocumentationRequest for Documentation

Page 18: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

1818

• Administrative Questionnaire

• School Catalog & Student Handbook

• Current Financial Aid Policies & Procedures

• Scholarship & Grant Reconciliation

• User Guide for Computer System

Documents to Submit Documents to Submit Prior to ReviewPrior to Review

Page 19: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

1919

Sample ListsSample Lists

Sample list delivery dateSample list delivery date- 5 business days prior to the - 5 business days prior to the reviewreview

Notify Compliance if:Notify Compliance if:- Contact person changes; or- Contact person changes; or- Your email is inaccessible- Your email is inaccessible

Page 20: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

2020

The Entrance Interview The Entrance Interview Session Session More School ParticipationMore School Participation Confirm On-site Review TimeConfirm On-site Review Time Identify the School Contact PersonIdentify the School Contact Person Review School Security ProceduresReview School Security Procedures Ensure Availability of DocumentsEnsure Availability of Documents Cover Scope of the ReviewCover Scope of the Review Discuss the School’s Last Program ReviewDiscuss the School’s Last Program Review School’s QuestionsSchool’s Questions

Page 21: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

2121

The Exit Interview The Exit Interview SessionSession Verify the Return of all School DocumentsVerify the Return of all School Documents Collect all Review DocumentsCollect all Review Documents Summarize the Review FindingsSummarize the Review Findings Distribute Copies of the Review Findings, Distribute Copies of the Review Findings,

Deficiency Code List and Sample Documentation Deficiency Code List and Sample Documentation ListList

Discuss ‘Next Step’ in the Review Process Discuss ‘Next Step’ in the Review Process -30 days, preliminary report -30 days, preliminary report -30 days, school response time -30 days, school response time

Deficiency ResolutionDeficiency Resolution On-site Review CompletedOn-site Review Completed

Page 22: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

2222

Program Review Program Review ReportsReports Two reports will be issued as a Two reports will be issued as a

result of the program reviewresult of the program review

The Preliminary Report and the The Preliminary Report and the Final ReportFinal Report

Page 23: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

2323

Preliminary ReportPreliminary Report

Issued within 30 days of the on-site Issued within 30 days of the on-site reviewreview

Changes found in the Preliminary ReportChanges found in the Preliminary Report

- Sent to Financial Aid Office, - Sent to Financial Aid Office, Admissions Office, Business Office and Admissions Office, Business Office and Registrars OfficeRegistrars Office

- Reference to the regulation to which - Reference to the regulation to which the finding relatesthe finding relates

- Findings outside of the review year- Findings outside of the review year

Page 24: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

2424

Preliminary ReportPreliminary Report

Institution has 30 days to respondInstitution has 30 days to respond Institution’s response should include a Institution’s response should include a

response to each finding listed in the response to each finding listed in the Preliminary Report and any documentation Preliminary Report and any documentation in support of disputed findingsin support of disputed findings

Institution may request a15 day extensionInstitution may request a15 day extension If institution does not either respond to the If institution does not either respond to the

Preliminary Report or request an extension Preliminary Report or request an extension in writing during the 30 day appeal period, in writing during the 30 day appeal period, the Final Report will be issued to the the Final Report will be issued to the President at the end of the 30 day periodPresident at the end of the 30 day period

Institutions should not remittance of funds Institutions should not remittance of funds until Final Report is issueduntil Final Report is issued

Page 25: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

2525

Final ReportFinal Report

Issued within 30 days of the institution’s Issued within 30 days of the institution’s response to the Preliminary Reportresponse to the Preliminary Report

Sent to President with copies to Institutional Sent to President with copies to Institutional OfficersOfficers

Institution has 30 days to respond – must contact Institution has 30 days to respond – must contact lead reviewer if additional time is neededlead reviewer if additional time is needed

Institution’s response should include payment of Institution’s response should include payment of any monetary liabilities and any Corrective Action any monetary liabilities and any Corrective Action Plans due - any additional documentation Plans due - any additional documentation regarding disputed findings should also be regarding disputed findings should also be includedincluded

Page 26: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

2626

To be used for remittance of monetary findings from State Program Reviews ONLY

STATE PROGRAM REVIEW REMITTANCE DEVICE Notice of Returned Funds

School Name:_________________________________________ Total Amount Paid: __________________

Lead Reviewer:________________________________________ Check Number: _____________________

School Code:_________________________________________ Make check payable to: Georgia Student Finance Commission

Date:________________________________________________ Send check to: Georgia Student Finance CommissionAttn: Accounting Department2082 East Exchange PlaceTucker, GA 30084

NAME SSNFISCAL YEAR

AWARD YEAR TERM PROGRAM

HOURS ENROLLED TUITION FEES BOOKS

TOTAL RETURNED

Example: John Doe 123-45-6789 1999 1998-99 Fall 98 HOPE Scholarship 13 $1,500.00 $1,500.00

For GSFC Use Only: Approved for Posting by: _______________________________________ Date: __________________(Compliance Officer)

Posted in Accounting by: ______________________________________ Date: __________________

Page 27: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

2727

Assuming no 15 day Assuming no 15 day extensionextension

Preliminary Response and

documentation due from the school (Day 60)

Final Letter and Report Issued

(Day 90)

School has 30 days to respond

Possible Scenario # 2

Payment/Corrective Action Plan(s) due from school

(Day 120)

School has 30 days to respond

Possible Scenario # 1

Payment/Corrective Action Plan(s) due from school and/or documentation of disputed findings

(Day 120)

Response to Final Report issued by GSFC.

(Day 150)

Possible Scenario # 3

No Response from School (Day 120)

Closure Letter issued by GSFC

(Day 180)

Letter issued by GSFC President

(Day 150)

Payment/Corrective Action Plan(s) due from school

(Day 165)

School has 15 days to respond

Payment/Corrective Action Plan(s) due from school

(Day 165)

Closure Letter issued by GSFC

(Day 150)

GSFC has 15 days to respond

Closure Letter issued by GSFC

(Day 180)

GSFC has 30 days to respond

Preliminary Letter and Report Issued

(Day 30)

GSFC has 30 days to respond

Page 28: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

2828

2008 State Program 2008 State Program Review SummaryReview Summary

Each institution:Each institution:– Will be reviewed AT LEAST once every 3 yearsWill be reviewed AT LEAST once every 3 years– Design a point of contact for the program Design a point of contact for the program

reviewreview– Receive Program Review Checklist and Receive Program Review Checklist and

Administrative Questionnaire Administrative Questionnaire – Will be required to provide all requested Will be required to provide all requested

documentation within 15 days of the documentation within 15 days of the notificationnotification

– Have various institutional offices represented at Have various institutional offices represented at the Entrance and Exit Interviewsthe Entrance and Exit Interviews

Page 29: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

2929

2008 State Program 2008 State Program Review SummaryReview SummaryContinuedContinued– Will be required to repay any funds Will be required to repay any funds

determined to be incorrectly awarded to any determined to be incorrectly awarded to any student, even if awarded outside the student, even if awarded outside the selection yearselection year

– Present complete student files to the Present complete student files to the Compliance Team at the Entrance InterviewCompliance Team at the Entrance Interview

– Understands no additional files or Understands no additional files or documentation will be accepted by the documentation will be accepted by the reviewer after the Entrance Interviewreviewer after the Entrance Interview

– Will be provided preliminary list of findings at Will be provided preliminary list of findings at the Exit Interviewthe Exit Interview

Page 30: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

3030

2008 State Program 2008 State Program Review SummaryReview SummaryContinuedContinued– Will be issued a Preliminary Letter and Will be issued a Preliminary Letter and

Report only to Institutional Officers Report only to Institutional Officers – Have a 30 day appeal period prior to the Have a 30 day appeal period prior to the

Final Letter and Report to provide Final Letter and Report to provide documentation to alleviate monetary documentation to alleviate monetary liabilityliability

– Understands even if the documentation is Understands even if the documentation is provided, the finding will remain on the provided, the finding will remain on the Final Report (unless the finding was Final Report (unless the finding was incorrectly cited then neither the liability incorrectly cited then neither the liability nor the finding will be on the Final Report)nor the finding will be on the Final Report)

Page 31: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

3131

2008 State Program 2008 State Program Review SummaryReview SummaryContinuedContinued– Will be issued a Final Report to the Will be issued a Final Report to the

President, with copies to the Institutional President, with copies to the Institutional OfficersOfficers

– Will use the Remittance Device provided Will use the Remittance Device provided with the Final Letter and Report to remit with the Final Letter and Report to remit required liabilities to GSFCrequired liabilities to GSFC

– Will have a 30 day appeal period, during Will have a 30 day appeal period, during which an institution should respond to the which an institution should respond to the Final Report and remit liabilitiesFinal Report and remit liabilities

Page 32: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

3232

Compliance Mission Compliance Mission and Value Statement and Value Statement

You can expect the Compliance Team You can expect the Compliance Team to be:to be:– Fair & UnbiasedFair & Unbiased– AccountableAccountable– Clear, Consistent, & ConciseClear, Consistent, & Concise– Honest & ForthcomingHonest & Forthcoming

SurveySurvey

Page 33: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

3333

Questions?Questions?

Page 34: 1 2008 State Program Review Process Presented by GSFC Compliance Team.

3434

Compliance Team Compliance Team Contact InformationContact Information

Email:Email: [email protected]@gsfc.org

Phone: Phone: 770-724-9041770-724-9041

Address:Address: Compliance TeamCompliance Team

2082 East Exchange Place 2082 East Exchange Place Tucker, GA 30084Tucker, GA 30084