FSA Program Review“Not Such a Rocky Road”

Jacob Pacheco

Northern New Mexico College

New Mexico Association of Student Financial Aid Administrators 2015

Our Objective:

To share our recent Program Review experience in an effort to help you successfully prepare for and manage the federal review process.

Presentation Outline

• What is a Program Review • What triggered our Program Review & What could trigger yours• Preparing for the visit – Be ready• The reviewers are here • After the visit – Review Report

Purpose of U.S. Dept. of Educ. Program Review

• To evaluate compliance, identify liabilities and improve institutional capabilities

• Authority for Program Review is defined by Law to provide necessary oversight of Title IV Participants

Section 498A of the HEA, 20 U.S.C. § 1099c

What Triggers Program Review?

• High default rates – (over 25% cohort rate or dollar volume)

• Significant fluctuation in volume of Direct loans or Pell

• Deficiencies reported by State or Accrediting agencies

What Triggers Program Review?

• High annual dropout rates

• Financial aid program deficiencies

• Financial/Administrative capability compliance risk

What Triggered Our Review

• Late Audit Submissions!!! Two year’s in a row!

• I started getting calls - from the Department of Education….Yikes!!

Top Program Review Findings

• R2T4 calculation errors• Verification violations• Entrance/Exit counseling deficiencies• Crime awareness requirements not met• Student credit balance deficiencies• Satisfactory Academic Progress policy not

adequately developed/monitored

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Top Program Review Findings

• R2T4 funds made late • Pell Grant

overpayments/underpayments • Account records inadequate/not

reconciled• Inaccurate recordkeeping• Lack of administrative capability• Information in student files

missing/inconsistent

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We Got “The Call” (July 12th)

• Advance notice of arrival (We had one month)

• The dates they initially chose were terrible for us (First week of fall term)

• Negotiated for more suitable visit date – need a good reason

We Got The “Letter” July 17

We Got “The Letter” cont..

• U.S. DOE letter confirmed visit dates, explained Entrance Conference & requested Pre-Review Submissions

• Specified that all offices involved in financial aid administration would be reviewed

• Also indicated that Campus Security & Drug-Free Schools Act compliance would be reviewed

Contact the Lead Reviewer

• Establish a point of contact at your institution

• Clarify details about the pre-review documents - format (electronic or paper)

• Clarify Scope and Period of Review

• Determine what accommodations are needed?

Read ED Program Review Guide 2009

Super useful prep tool:

• Reviewers use it• Sample file and policy review checklists• Sample Student/Staff Interview Questions• http://www.ifap.ed.gov/programrevguide/200

9ProgramReviewGuide.html

Campus Preparation Begins

• Set meeting/s with the key players- Fiscal; Academic; Registrar; Admissions, IT (Banner), Security

• Ensure that everyone understands the significance of ED Program Review“Sorry, but no vacation for you Mr. Provost”

Preparation Begins Cont…

Prepare Resource Room

• Secure a nice working space for Reviewers• Work with IT to provide access to databases• Provide organized copies of all Pre-Review info• Make arrangements for copying

List of Pre-Submission Items

Pre-Visit Submission Items

• Recipient Data Spreadsheet- Specific Award Year: Unduplicated list of TIV

recipients in Excel and/or Access.

- Used to confirm expenditures and to select a review sample

Pre-Visit Submission ItemsRecipient Data Spreadsheet

Pre-Visit Submission Items

• Consumer Information Attachment – provide URL’s, title, page #’s, etc. -Policies and Procedures -Consumer Information Publications- Disclosures-Campus Security Reports-Catalogs

Consumer Information Attachment

Pre-Visit Submission Items

• Request for Student Files (7)

- Copy of Admissions File- Copy of Financial Aid File- Academic Transcript- Student Account Ledger- R2T4 calculation worksheet, evidence of return- If Work-Study: time sheets, class schedule, payroll records

Reviewers Are On Campus!!

Entrance Conference

• Everybody Should Attend – President, Vice Pres., CFO, Registrar, Deans, Chairs, Security

• Reviewers will explain:- Purpose - Scope- Timeframe which will include scheduling the

Exit Conference (Don’t assume everybody pays attention!)

Entrance Conference, cont.

• Introduce the school team• Reviewers did most of the talking – explained

the reason for the review and the scope• Discuss staff interviews – Schedule created

after entrance• Opportunity to ask questions

Staff Interviews

• Ensure staff members are available – They have to know the importance of being available.

• Use and share the Program Review Guide for interview prep

• Many of the question concerned consumer information and campus security

Problems are Found

• Issue with R2T4- Liability: have to send $$ back to the DOE

• Consumer Information- not all requirements adequately met- some info not easy to find- some links did not work- Clery Act (Do we have dorms or not?)

Problems are Found cont..

• Verification

– We were verifying too many files– Asking for documentation that was not necessary

Exit Conference

• Reviewers praised Northern! – Let us know that findings were minimal & we were doing a good job.

• Reviewers discussed findings• This is a time to ask questions and seek clarity

on what happens next.

Program Review Report

(This is when the fun really began!!)

• Report arrived exactly one year after the Program Review!!

• Required institutional response to findings within 30 days-Had to request a 15 day extension

Program Review Report cont…

• Clery Act finding is reviewed separately by a Department in Washington D.C. – Still have not received this.

Be Prepared

• Policies & Procedures- Verification, Refunds, R2T4, Awarding, SAP,

Professional Judgment- Admissions- Fiscal- Academic- Enrollment- Campus Security

• Don’t get caught not implementing your own policy

Be Prepared

• Staff should be current on FSA regulatory requirements

- Conferences: Annual FSA, NASFAA, NMASFAA- Training sessions – online

• Use Assessment Tools (FSA, NASFAA)− FSA COACH− FSA Assessments

Resources – www.ifap.ed.gov

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My IFAPWhat’s NewTools for SchoolsPublicationsHandbooksLetters & Announcements

Training and Conferences

FSA Assessments

• Self-assessment tool designed to assist schools in evaluating their financial aid policies, processes, and procedures

• Includes assessment modules regarding Students, Schools, and Campus-Based Programs

http://ifap.ed.gov/qahome/fsaassessment.html

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FSA Assessments

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Questions?

Contact Information:

Jacob PachecoFinancial Aid Director

Northern New Mexico College505-747-2122jpacheco@nnmc.edu