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