Federal Aid Program Participation Agreement€¦ · SCCE Higher Education Compliance Conference 1...

SCCE Higher Education Compliance Conference

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Federal Student Aid Program Participation Agreement

A Work‐Plan for Compliance Officers

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David Galloway, Director, Office of Audit, Compliance, and EthicsKimberly Fearney, Director of Compliance/Ethics Liaison

University of Connecticut

Federal Student Financial Aid and Grants

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Agree to comply with…

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Title IX

Drug Free Schools/Workplace Acts

Clery Crime Statistics/Emergency

Procedures

Sa

nct

ion

s C

he

cks

Gain

ful

Em

plo

ymen

t R

ule

s

Voter Registration

FTC

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• Institutional eligibility• Code of conduct• Processing procedures such

as needs analysis, eligibility, etc.

• Financial responsibility and administrative capability

• Disclosures to students• Information reporting

requirements • State authorization• Accreditation• Definitions: academic year,

credit hour, etc.• Records retention

requirements• Financial aid counseling• No incentive payments


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What else?

• Drug Free Schools Act

• Drug Free Workplace Act

• Clery Act

• Title IV of the Civil rights Act of 1964 (race, color or national origin)

• Title IX of the Education Amendments of 1972 (sex discrimination)

• FERPA

• §504 of the Rehabilitation Act of 1973 (accessibility)

• Age Discrimination Act of 1975

• Safeguarding Customer Information (GLBA)

• Financial Aid Regulations

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What else?

• Administrative Capability

• Financial Responsibility

• Provide Information (IPEDS+)

• Athletic Participation Disclosures

• Gainful Employment Provisions

• Copyright and DMCA Compliance Programs

• Voter Registration Program

• Lobbying

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Six‐year Cycle

Recertification

Compliance w/

Statute and

Regulations

Core Elements…

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3

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Core Elements…• Ninety days to submit a new PPA for recertification.

• Signed by the President

• May be given “provisional” status.

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Core Elements

• Covers all locations

• May be sanctions(1) An emergency action.

(2) The imposition of a fine.

(3) The limitation, suspension, or termination of the participation of the institution in a Title IV, HEA program.

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What next?

• Use the PPA to identify key areas for compliance work plan

• Assess the key areas

• Develop action plan to address improvements

• Implement the action plan

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Broad Compliance Structure:Representative Schools

1. Academic Programs2. Asses Management3. Athletics4. Campus Security5. Civil Rights

Non‐Discrimination Harassment Diversity Accessibility

6. Communications7. Contracts8. Development/Advancement9. Dining Services10. Disability Services11. Emergency Management12. Environmental Health and Safety13. Employee Welfare Benefit Plan14. Federal and State Disclosure15. Financial Aid16. Fiscal Management17. Governance18. Grants/Research Administration19. Human Resources20. International21. Intellectual Property22. IT/Computing23. Records Management24. Research25. Student Affairs26. Student Health27. Tax28. FTC Broadcast Rules

1. Environmental Health and Safety2. Research Administration3. Human Resources4. Accessibility5. Athletics6. Tax7. Donor Gift Restrictions8. Immigration9. Technology Transfer10. Investments11. Information Security and privacy12. Campus Security13. Student Life14. Financial Controls15. Controlled Substances16. Land Use/Planning17. Biohazards

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HIGHER EDUCATIONCOMPLIANCE ALLIANCE


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Higher Education Compliance Alliance1

1. Academic Programs2. Accounting3. Accreditation4. Admissions5. Athletics6. Auxiliary Services7. Campus Safety8. Contracts & Procurement9. Copyright & Trademark10. Disabilities11. Diversity/Affirmative Action12. Environmental Health and Occupational

Safety13. Ethics14. Export Controls15. Financial Aid16. Fund Raising and Development17. Governance18. Grants Management19. Health Care & Insurance

20. Housing21. Human Resources – Discrimination22. Human Resources – Benefits23. Human Resources – Recruitment, Hiring, Termination24. Human Resources – Retirement25. Human Resources – Unions26. Human Resources – Wages27. Immigration28. Information Technology29. Intellectual Property and Technology Transfer30. International Activities and Programs31. Lobbying and Political Activity32. Privacy and Information Security33. Program Integrity Rules34. Research35. Sexual Misconduct36. Tax

131 http://www.higheredcompliance.org/

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So, what do I tell the president…?

• Reasonable assurance• Evidence of compliance


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PPA Evaluation – Drug‐Free Schools/Workplace

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PPA Evaluation – Drug‐Free Schools/Workplace


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Process Compliance processes are

unstructured with no

deliberate effort to enable

compliance via

operational processes.

Some compliance processes

are defined and

documented. Ad hoc

efforts are made to identify

potential compliance

enablers in operational

processes.

Core compliance processes

are documented and well

defined with some

integration of effort across


Compliance processes are

repeatable and consistent,

with compliance enablers

integrated within


Compliance processes are

continuously optimized

and innovation

encouraged.

Organization No formal compliance

structure exists. Ad hoc,

compliance roles are

scattered throughout in

the organization with little

or no collaboration.

A compliance structure has

been formally implemented

and role/responsibilities

have been identified.

Informal or ad hoc

collaboration occurs.

A common compliance

structure has been

deployed. Compliance

roles are executed per

defined responsibilities.

Critical decisions are made

via collaboration of similar

roles.

A normalized, integrated

compliance structure has

been fully implemented.

All like roles execute to

commonly defined

performance levels and

within collaborative

communities.

A compliance CDE or

equivalent has been

implemented.

Information Compliance data, metrics

and indicators exist only in

isolated pockets and lack

any formal or common

definition.

Compliance information

policies have been defined

along with formal (if not

common) compliance data,

metrics and indicators.

Commonly defined

compliance data, metrics

and indicators are shared

and have been integrated

into compliance processes.

Internal benchmarking is

performed.

Compliance data, metrics

and indicators are

common across the

business and integrated

into operational processes.

Internal and external

benchmarking is

performed.

Information drives

decision‐making at all

levels.

Technology Little to no automation

support is available for

compliance activities.

Partial or sporadic

automation of compliance

activities has been

implemented, with no

significant integration.

Core compliance activities

have been automated with

use of some common tools.

Little or no integration of

compliance and operations

support technology.

Compliance activities are

fully automated using

common tools integrated

with operations support

technology. Compliance

reporting can be

automatically generated.

An automated, real‐time

compliance dashboard is

available.

Level 1 ‐Initial

Level 2 ‐Repeatable

Level 3 ‐Defined

Level 4 ‐Managed

Level 5 ‐Optimized

Compliance Convergence Maturity Model ©2009 Matthew Pedowitz, used by permission.

Compliance Convergence Maturity Model

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Level 1 ‐Initial


Level 3 ‐Defined

Level 4 ‐Managed


Management Commitment

Management has assigned the responsibility and committed the resources to achieve the compliance objectives.

Identify Requirements

The legal requirements are identified and understood

Define Standards

The applicability of the legal requirements to the institution are understood and accepted

Document Standards

Policies and procedures are in place that, if followed, would help ensure compliance with the legal requirements.

Communicate Standards

The standards, policies, and procedures have been effectively communicated to all who have a compliance responsibility.

Implement Policies

The requirements of the policies and procedures have been implemented in a manner that will help ensure continuity of compliance.

Monitoring and Auditing

Monitoring and audit processes are being conducted to help ensure compliance.

Federal Sentencing Guidelines


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Level 1 ‐Initial


Level 3 ‐Defined

Level 4 ‐Managed


Internal Environment

Objective Setting

Event Identification

Risk Assessment

Risk Response

Control Activities

Information/ Communication

Monitoring

COSO Model (ERM)

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photo by Becky Parker

PPA and the Role of Compliance


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Compliance Partners

– Provost/Chancellor– Financial Aid– IT– Enrollment Management– Athletics– Health & Safety– Research– Diversity & Equity– Human Resources– ………..

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Committees

• What can compliance offer?

– Unique “global” perspective

– Help frame policy, training, etc.

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EDUCATION

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• Employees in the trenches want to comply with the rules– Know how the system works and when there may be a problem

• Using frequently asked questions to create training

• Support from senior administrators

It’s all in the Approach

• Legal/regulatory with Faculty

• Include the “Who” and the “Why”

• Real life examples of consequences of non‐compliance

• Subject matter expertise is a plus

• “We’re here to help”

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Policies

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Use the policy process to address compliance with PPA

• Evaluate existing policies• What makes sense?• Reach out to peers• Fill the gaps

Case Study

2008 Higher Education Opportunities Act

• Professional Resources (ex. NACUA)

• Committee

• www.heoa.uconn.edu

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Resources

• 2014‐2015 Federal Student Aid Handbook, Volume 2 – School Eligibility and Operations (http://ifap.ed.gov/fsahandbook/1415FSAHbkVol2.html)

• Higher Education Compliance Alliance http://www.higheredcompliance.org/

• National Association of College and University Attorneys http://www.nacua.org/

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Federal Student Aid Program Participation Agreement

A Work‐Plan for Compliance Officers

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David Galloway, Director, Office of Audit, Compliance, and EthicsKimberly Fearney, Compliance and Ethics Officer

University of Connecticut

Federal Aid Program Participation Agreement€¦ · SCCE Higher Education Compliance Conference 1...

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