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Georgia Student Finance Commission. Managing a State Program Review & Implementing Regulation Changes FALL 2005 GASFAA Presentation By GSFC Compliance Unit. Managing a State Program Review. October 14, 2005 Presenter: Caylee French GSFC Compliance Officer. Agenda. - PowerPoint PPT Presentation
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Georgia Student Georgia Student Finance CommissionFinance Commission
Managing a State Program ReviewManaging a State Program Review&&
Implementing Regulation Implementing Regulation ChangesChanges
FALL 2005 GASFAA PresentationFALL 2005 GASFAA PresentationBy GSFC Compliance UnitBy GSFC Compliance Unit
Managing a State Managing a State Program ReviewProgram Review
October 14, 2005October 14, 2005Presenter:Presenter:
Caylee FrenchCaylee FrenchGSFC Compliance OfficerGSFC Compliance Officer
AgendaAgenda Program Review ObjectivesProgram Review Objectives Program Review Policies, Program Review Policies,
Procedures, & ProcessProcedures, & Process Most Common FindingsMost Common Findings Conflicting InformationConflicting Information Tips and PointersTips and Pointers
Objective & Purpose of Objective & Purpose of the Program Reviewthe Program Review
Objective:Objective: To determine To determine
whether the whether the institution is institution is consistently consistently following policies following policies and procedures, and procedures, and in compliance and in compliance with the with the Scholarships and Scholarships and Grants regulationsGrants regulations
Purpose:Purpose: To offer guidance To offer guidance
and assistanceand assistanceAnd,And,
To raise To raise awareness of awareness of problems, problems, concerns, and concerns, and needsneeds
Program Review PolicyProgram Review Policy Time Frame and Program GroupsTime Frame and Program Groups Sample SelectionSample Selection Review ExemptionReview Exemption Review EscalationReview Escalation Discretionary ReviewDiscretionary Review Repayment of FundsRepayment of Funds
Program Review Time Program Review Time Frame and Program Frame and Program
GroupsGroups 1 review per school, per fiscal 1 review per school, per fiscal
yearyear Program Groups include HOPE, Program Groups include HOPE,
GTEG, and LEAPGTEG, and LEAP– Other programs may be reviewed as Other programs may be reviewed as
deemed appropriatedeemed appropriate
Program Review Program Review Sample SelectionSample Selection
Sample size is based on number Sample size is based on number of awards for that program groupof awards for that program group– Less than 20 students awarded, all Less than 20 students awarded, all
students reviewedstudents reviewed– Between 21 and 2000 awards, 20 Between 21 and 2000 awards, 20
students reviewedstudents reviewed– More than 2000 awards, 1% of More than 2000 awards, 1% of
students reviewedstudents reviewed
Review ExemptionReview Exemption If no findings for two consecutive If no findings for two consecutive
years, school is exempt from years, school is exempt from review during the next yearreview during the next year– After exemption year, school must After exemption year, school must
again achieve two consecutive years again achieve two consecutive years without findings to be granted without findings to be granted another exemptionanother exemption
Review EscalationReview Escalation If initial review produces a post-appeal If initial review produces a post-appeal
error rate of 30% or higher for any one error rate of 30% or higher for any one program group (HOPE, GTEG, LEAP), a program group (HOPE, GTEG, LEAP), a second review will be conducted with second review will be conducted with twice the sample size as original reviewtwice the sample size as original review– If second review produces 30% error rate, If second review produces 30% error rate,
school must apply this to all awards or hire school must apply this to all awards or hire outside reviewers to review all awards for outside reviewers to review all awards for that fiscal yearthat fiscal year
Discretionary ReviewDiscretionary Review GSFC may, at its sole discretion, review GSFC may, at its sole discretion, review
a school at any time it has reason to a school at any time it has reason to believe such a review is warrantedbelieve such a review is warranted– Changes in school program staffingChanges in school program staffing– Significant changes in the number or types Significant changes in the number or types
of awards being madeof awards being made– Findings of other departments or agenciesFindings of other departments or agencies– Third-party request for investigationThird-party request for investigation– Reasonable suspicion of program Reasonable suspicion of program
mismanagementmismanagement
Repayment of FundsRepayment of Funds If findings occurred in years prior to fiscal If findings occurred in years prior to fiscal
year being reviewed, no repayment is year being reviewed, no repayment is required as part of the reviewrequired as part of the review
If findings occur in years subsequent to If findings occur in years subsequent to fiscal year being reviewed, no repayment is fiscal year being reviewed, no repayment is required as part of the review, but finding required as part of the review, but finding will be re-examined during the next reviewwill be re-examined during the next review
If findings occur in year being reviewed, If findings occur in year being reviewed, funds must be returned to GSFCfunds must be returned to GSFC
Program Review Program Review Process & ProcedureProcess & Procedure
The Institution’s RoleThe Institution’s Role
Georgia Student Finance Georgia Student Finance Commission – Compliance Commission – Compliance Officer’s RoleOfficer’s Role
On-site Review ProcedureOn-site Review Procedure
Program Review Program Review ChecklistChecklistHand OutHand Out
Program Review Program Review ChecklistChecklistHand OutHand Out
On-siteOn-siteProgram Review Program Review
ProcessProcess Records EvaluationRecords Evaluation
– Admission’sAdmission’s– Registrar’sRegistrar’s– Student Financial AidStudent Financial Aid– Fiscal Records/Student AccountFiscal Records/Student Account
Records EvaluationRecords Evaluation Admission ApplicationAdmission Application
– Student data must be availableStudent data must be available State of ResidencyState of Residency Citizenship StatusCitizenship Status Previous Enrollment InformationPrevious Enrollment Information Parent information, if applicableParent information, if applicable
– Supporting documentation, if Supporting documentation, if applicableapplicable
Records EvaluationRecords Evaluation Registrar’s OfficeRegistrar’s Office
– College Transcripts College Transcripts Institutional and Previous College Institutional and Previous College
transcripts must be availabletranscripts must be available– Enrollment HoursEnrollment Hours– Satisfactory Academic ProgressSatisfactory Academic Progress– Grade Point Average Requirements, if Grade Point Average Requirements, if
applicableapplicable– High School/GED TranscriptHigh School/GED Transcript
Supporting evidence of residency statusSupporting evidence of residency status
Records EvaluationRecords Evaluation Student Financial AidStudent Financial Aid
– FAFSA, E-HOPE or paper HOPE, GTEG, FAFSA, E-HOPE or paper HOPE, GTEG, and/or Institutional applicationand/or Institutional application
State of Residency informationState of Residency information Parent information, if applicableParent information, if applicable Selective Service registrationSelective Service registration Citizenship verificationCitizenship verification Default/Refund dueDefault/Refund due Satisfactory Academic ProgressSatisfactory Academic Progress
– Supporting documentation, if applicable Supporting documentation, if applicable
Fiscal Records/Fiscal Records/Student AccountsStudent Accounts
Award AmountAward Amount– Tuition and FeesTuition and Fees– Book AllowanceBook Allowance
Return of FundsReturn of Funds– Title IV and HOPETitle IV and HOPE– HOPE and/ or GTEG onlyHOPE and/ or GTEG only
Disbursement of FundsDisbursement of Funds– Verification of enrollmentVerification of enrollment
Reconciliation of FundsReconciliation of Funds– Verification of reported dataVerification of reported data
Program Review Guide Hand Out
ResidencyResidency Admissions Application - Institutional Financial Aid Admissions Application - Institutional Financial Aid Application Application FAFSA - HOPE ApplicationFAFSA - HOPE Application
Citizenship Citizenship IF PRAIF PRA
Admissions Application -HOPE Application- FAFSAAdmissions Application -HOPE Application- FAFSA Copy of Green Card/PRA Card – Date of IssueCopy of Green Card/PRA Card – Date of Issue
Selective ServiceSelective Service Selective Service Website Confirmation -FAFSASelective Service Website Confirmation -FAFSAHOPE ApplicationHOPE Application
Enrollment StatusEnrollment Status TranscriptsTranscriptsComputer System Access to Registration RecordsComputer System Access to Registration Records
Award AmountAward Amount Tuition and Fees Schedule for Fiscal Year being reviewedTuition and Fees Schedule for Fiscal Year being reviewedAward Letter, Computer System Access to Financial Aid Award Letter, Computer System Access to Financial Aid Management RecordsManagement Records
Disbursement of FundsDisbursement of Funds Business RecordsBusiness RecordsComputer System Access to Student Account RecordsComputer System Access to Student Account Records
Grade Point AverageGrade Point Average Institutional TranscriptInstitutional TranscriptPrevious College TranscriptsPrevious College TranscriptsCopy of Back of One Institutional TranscriptCopy of Back of One Institutional TranscriptHOPE Eligibility Calculation HOPE Eligibility Calculation
Conflicting InformationConflicting Information Supporting documentation present in Supporting documentation present in
student’s file to resolve conflicting or student’s file to resolve conflicting or contradictory informationcontradictory information– Residency DateResidency Date– Date of BirthDate of Birth– SSNSSN– CitizenshipCitizenship
Resolving Conflicting Information is a Resolving Conflicting Information is a cooperative effort among all campus officescooperative effort among all campus offices
Common FindingsCommon Findings ResidencyResidency
– Not a GA Not a GA resident for 12 resident for 12 months prior to months prior to enrollmentenrollment
– Don’t rely on Don’t rely on other offices to other offices to make make determination determination for youfor you
Citizenship Citizenship – Must be US citizen Must be US citizen
or Permanent or Permanent Resident Alien (or Resident Alien (or other eligible non-other eligible non-citizen) for 12 citizen) for 12 months prior to months prior to awardingawarding
– Be sure to retain a Be sure to retain a copy of Permanent copy of Permanent Resident Alien cardResident Alien card
Common FindingsCommon Findings Student not Student not
meeting GPA meeting GPA requirementsrequirements(Scholarship)(Scholarship)– Be sure to include Be sure to include
ALL attempted ALL attempted degree hoursdegree hours
– Calculate Calculate checkpoints using checkpoints using coursework in coursework in chronological orderchronological order
Inadequate SAP Inadequate SAP review procedures review procedures or policy is not or policy is not enforcedenforced
– Develop Develop adequate adequate monitoring monitoring system to system to ensure proper ensure proper SAP reviewSAP review
Tips and PointersTips and Pointers Start early Start early
– Begin the preparation process as Begin the preparation process as soon as receiving noticesoon as receiving notice
Be over-preparedBe over-prepared– Have files, computer access, and Have files, computer access, and
requested documentation readyrequested documentation ready Provide adequate workspace Provide adequate workspace
– Table or desk with computer accessTable or desk with computer access
Clarification of The Clarification of The HOPE Regulations HOPE Regulations
ChangesChangesfor 2005-2006for 2005-2006
October 14, 2005October 14, 2005Presenter:Presenter:
Dominic Coles,Dominic Coles,GSFC Compliance OfficerGSFC Compliance Officer
AgendaAgenda Three-Term (3-T) Checkpoint ClarificationThree-Term (3-T) Checkpoint Clarification End-of-Spring (EOS) Checkpoint ClarificationEnd-of-Spring (EOS) Checkpoint Clarification Zero Grade Point AverageZero Grade Point Average Zero Credit HoursZero Credit Hours HOPE Book Allowance DisbursementHOPE Book Allowance Disbursement Georgia Tuition Equalization Grant (GTEG) Georgia Tuition Equalization Grant (GTEG)
and Military Dependentsand Military Dependents Selective Service Registration For Male Selective Service Registration For Male
Under 18 Years of AgeUnder 18 Years of Age
Checkpoints Checkpoints ClarificationClarification
Recipients must have a HOPE Recipients must have a HOPE Grade Point Average (GPA) of 3.0 Grade Point Average (GPA) of 3.0 at each checkpoint to continue at each checkpoint to continue eligibility:eligibility:- 3-T- 3-T Checkpoint Checkpoint- EOS Checkpoints- EOS Checkpoints- Tier Checkpoints- Tier Checkpoints
Checkpoints Checkpoints ClarificationClarification
The HOPE GPA is a unique calculation The HOPE GPA is a unique calculation used solely for the purpose of used solely for the purpose of determining HOPE Scholarship eligibility determining HOPE Scholarship eligibility at the college levelat the college level
The HOPE GPA may differ from other The HOPE GPA may differ from other GPA calculationsGPA calculations
The office which is normally responsible The office which is normally responsible for the institutional GPA evaluation for the institutional GPA evaluation should perform the HOPE GPA evaluationshould perform the HOPE GPA evaluation
**Special Note **Special Note Regarding Diploma Regarding Diploma
Hours**Hours** Hours for which a student was Hours for which a student was
enrolled in a diploma or enrolled in a diploma or certificate program, even if they certificate program, even if they are later accepted into a degree are later accepted into a degree program, have no bearing on program, have no bearing on determining whether a student is determining whether a student is subject to 3-T or EOS checkpoints.subject to 3-T or EOS checkpoints.
3-T Checkpoint 3-T Checkpoint ClarificationClarification
Only applies to First Tier, part-time Only applies to First Tier, part-time studentsstudents
Does not apply if the student was Does not apply if the student was everever enrolled for at least 12 hoursenrolled for at least 12 hours
Must have attempted less than 12 Must have attempted less than 12 hours during hours during eacheach of the student’s first of the student’s first three termsthree terms
Exit point of eligibility onlyExit point of eligibility only
3-T Checkpoint 3-T Checkpoint Clarification – Hand Clarification – Hand
OutOutFreshman Checkpoints
Prior Prior toto04-0504-05
SummeSummerr20042004
FallFall20042004
WinterWinter20052005
SpringSpring20052005
SummeSummerr20052005
Fall 2005 Fall 2005 to Spring to Spring 20062006
>12>12 PTPT PTPT PTPT PTPT EOSEOS EOSEOS>12>12 NENE PTPT PTPT PTPT EOSEOS EOSEOS>12>12 NENE NENE PTPT PTPT EOSEOS EOSEOS>12>12 NENE NENE NENE PTPT EOSEOS EOSEOS<12<12 PTPT PTPT PTPT 3-T3-T PTPT EOSEOS EOSEOS<12<12 PTPT PTPT NENE PTPT 3-T3-T EOSEOS<12<12 PTPT NENE NENE PTPT PTPT 3-T3-T EOSEOS<12<12 NENE PTPT PTPT NENE PTPT 3-T3-T EOSEOS<12<12 NENE PTPT NENE PTPT PTPT 3-T3-T EOSEOS<12<12 PTPT NENE PTPT PTPT 3-T3-T EOSEOS<12<12 PTPT PTPT NENE NENE PTPT 3-T3-T EOSEOS<12<12 PTPT FTFT PTPT NENE EOSEOS EOSEOS
EOS Checkpoint EOS Checkpoint ClarificationClarification
Apply to all HOPE Scholarship Apply to all HOPE Scholarship recipients regardless of Spring recipients regardless of Spring 2005 enrollment2005 enrollment
Exception:Exception: Freshman who Freshman who have not yet been enrolled have not yet been enrolled full-time for at least one termfull-time for at least one term
EOS Checkpoint EOS Checkpoint ClarificationClarification
Must have a cumulative 3.0 GPA at the Must have a cumulative 3.0 GPA at the end of end of eacheach Spring semester/quarter Spring semester/quarter- First Tier recipients must be full-time (12 hrs.) - First Tier recipients must be full-time (12 hrs.) for for
at least 1 of their first 3 termsat least 1 of their first 3 terms- Second, Third, and Fourth Tier recipients must - Second, Third, and Fourth Tier recipients must bebe
reviewed at the end of each Spring term, reviewed at the end of each Spring term, whether full-time, part-time or not enrolled whether full-time, part-time or not enrolled - Exit point of eligibility only- Exit point of eligibility only
EOS Checkpoint EOS Checkpoint ClarificationClarification
Example 1: Degree ProgramExample 1: Degree Program
GPA = 2.99 at the end of Spring 2005GPA = 2.99 at the end of Spring 2005 EOS applies at the end of Spring 2005EOS applies at the end of Spring 2005 Not eligible for the next termNot eligible for the next term
Fall Fall 20032003
DegreeDegree
Spring Spring 20042004
DegreeDegree
Summer Summer 20042004
FallFall20042004
Winter Winter 20052005
DegreeDegree
SpringSpring20052005
DegreeDegree1212 1212 Not Not
EnrolledEnrolledNotNot
EnrolledEnrolled99 99
EOS Checkpoint EOS Checkpoint ClarificationClarification
Example 2:Example 2: Diploma/Certificate Diploma/Certificate ProgramProgram
12 diploma hours were accepted into the degree 12 diploma hours were accepted into the degree programprogram
GPA = 2.99 at the end of Spring 2005GPA = 2.99 at the end of Spring 2005 EOS does not applyEOS does not apply Eligible for the next termEligible for the next term
Fall Fall 20032003
DiplomDiplomaa
Spring Spring 20042004
DiplomaDiploma
Summer Summer 20042004
FallFall20042004
Winter Winter 20052005
DegreeDegree
SpringSpring20052005
DegreeDegree
1212 1212 Not Not EnrolledEnrolled
Not Not EnrolledEnrolled
99 66
NO
End of Spring Checkpoint (EOS)VS
Three-Term Checkpoint (3TC)
Is the student Tier 1?
YES
EOS
YESNO
EOS
Was the student ever enrolled full-time in a degree
program?
Has the student attended 3 terms
part-time, beginning
Summer 2004?
YESNO
3TC at the end of the 3rd term
Wait until 3rd term part-time for 3TC or if student
attends full-time EOS
Zero Grade Point Zero Grade Point AverageAverage
Reach checkpoint but no GPAReach checkpoint but no GPA– Example – Learning Support ProgramExample – Learning Support Program
Not eligible until the next entry point, unless Not eligible until the next entry point, unless obtained 3.0 GPA for at least one courseobtained 3.0 GPA for at least one course
May request an exceptionMay request an exception– HOPE Regulations offer guidelines to qualify for HOPE Regulations offer guidelines to qualify for
an exceptionan exception– If approved, retroactive paymentIf approved, retroactive payment
Zero Credit HoursZero Credit Hours Courses that appear on a student’s
transcript with no course hours will be assigned 3 semester hours or 5 quarter hours for the purpose of determining a student’s Attempted-Hours– Exception – Courses that carry actual
zero credit as published by the institution
HOPE Book Allowance HOPE Book Allowance DisbursementDisbursement
Entire amount must be disbursed Entire amount must be disbursed Unused portion that is not disbursed Unused portion that is not disbursed
must be returned to GSFCmust be returned to GSFC Must apply funds to book charges Must apply funds to book charges
unless written authorization is unless written authorization is obtained from student authorizing the obtained from student authorizing the funds to be used for other chargesfunds to be used for other charges
Regulation will be enforced by Winter Regulation will be enforced by Winter quarter or Spring semester of 2006quarter or Spring semester of 2006
GTEG and Military GTEG and Military DependentsDependents
Non-resident military dependent Non-resident military dependent can receive GTEGcan receive GTEG
Applies to all non-resident military Applies to all non-resident military dependentsdependents
Effective Fall 2005Effective Fall 2005 No retroactive GTEG for prior No retroactive GTEG for prior
yearsyears
GTEG and Military GTEG and Military DependentsDependents
Student will continue to receive Student will continue to receive GTEG if parent is no longer GTEG if parent is no longer Georgia residentGeorgia resident
No break in enrollmentNo break in enrollment Effective Fall 2005Effective Fall 2005 No retroactive GTEG payment for No retroactive GTEG payment for
prior yearsprior years
Selective Service Selective Service Registration Registration
Male Under 18Male Under 18 Eligible for the term for which student is not Eligible for the term for which student is not
required to registerrequired to register School does not have to verify that student School does not have to verify that student
registered once he turned 18 during the registered once he turned 18 during the current award year, but must do so before current award year, but must do so before subsequent award years subsequent award years – However, GSFAPPS will prevent disbursement for However, GSFAPPS will prevent disbursement for
future terms until student has updated statusfuture terms until student has updated status Not eligible for retroactive disbursement if Not eligible for retroactive disbursement if
does not register for the term for which the does not register for the term for which the student is required to comply student is required to comply
QUESTIONS/COMMENTS/QUESTIONS/COMMENTS/SUGGESTIONS?SUGGESTIONS?
GSFC Compliance UnitGSFC Compliance UnitCindy Abbott, Senior Manager Cindy Abbott, Senior Manager
Tammy Tran, Compliance AnalystTammy Tran, Compliance AnalystCaylee French, Compliance OfficerCaylee French, Compliance OfficerDominic Coles, Compliance OfficerDominic Coles, Compliance Officer
Ray Tripp, Compliance OfficerRay Tripp, Compliance [email protected]@gsfc.org
800-505-4732800-505-4732