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STUDENT FRAUD: A PROBLEM YOU CAN’T IGNORE!
Prepared for WCET’s 24th Annual Meeting (November 1-3, 2012)
STUDENT FRAUD A PROBLEM YOU CAN’T IGNORE
Moderator Mollie McGill, Deputy Director for Programs and Membership,
WICHE Cooperative for Educational Technologies – WCET
Presenters Kishia Brock, Vice President of Student Affairs and Advancement,
Rio Salado College
Audra Barrett, Associate Vice President of Instruction, Dallas County Community College District – Dallas TeleCollege Online
Ryan Chase, Associate Dean of Student Affairs, Rio Salado College
STUDENT FRAUD: A PROBLEM YOU CAN’T IGNORE
Understanding and Addressing the Problem
Institutional Perspectives Dallas TeleCollege Online Rio Salado College
COMMON FRAUD SCHEMES
Pell Runners The Chronicle for Higher Education, April 2
8, 2012 USA Today, April 30, 2012 Community College Spotlight, May 12, 201
2
Fraud Rings US Department of Education, IG Report, Se
ptember 26, 2011 US Department of Education, Dear Colleag
ue Letter, October 20, 2011 EDUCAUSE, September 19, 2012
A REAL LIFE FRAUD!!
HALTON FRAUD RING CASE Ring leader engaged 4 individuals to help recruit
people to participate in the scheme to apply for financial aid through distance education programs
Applicants were neither active students nor did they intend to become active students
Participants kicked back a portion of those funds to the ringleaders and her conspirators in amounts ranging from $500-$1,500
Individuals received more than $538,000
FRAUD RING CHARACTERISTICS Schemes typically target online and the less-expensive and/or two-
year “entry level” programs
Fraud “Ring Leader” recruits participants enticing them with an opportunity for free money
Scheme participants typically target vulnerable populations (e.g. younger persons and/or in economically depressed areas)
Most participants never graduated high school or completed a GED program but falsify admissions
Ring Leader often sets student accounts up with one or a few common addresses/phone numbers/emails
FRAUD RING CHARACTERISTICS
Participants provide personal info to Ring Leader, who will register for school, apply for federal student aid, and “do all of the homework” to maintain attendance until the funds are disbursed
Once funds are disbursed, Ring Leader and participant split the
funds, stop attending, and the student is not heard from again
Scheme ring leaders often attend school themselves as well as helping recruits to attend fraudulently
Ring leaders will also set up student accounts with stolen identities to avoid having to split the proceeds
FINANCIAL AID FRAUD TODAY
ED’s Office of Inspector, NASFAA Conference, Chicago, July 2012
Fraud ring investigations currently constitute about 17% of all open OIG cases
As of August 2011, OIG has opened 100 investigations and have been evaluating 49 additional complaints
One referral from a large for-profit institution includes 600 different potential fraud rings involving over 10,000 participants
Due to the sheer volume of referrals, finite resources, and other case work, we cannot investigate all of the referrals we receive concerning distance education fraud rings.
WE NEED YOUR HELP!!
INSTITUTIONAL REQUIREMENTS
US Department of Education > Standards of Administrative Capability > Resolving Conflicting Data
C.F.R § 668.16(f) – an institution must develop and apply an adequate system to identify and resolve discrepancies in the information that the institution receives from different sources with respect to a student's application for financial aid under Title IV, HEA programs…
C.F.R § 668.16(g) – an institution has an obligation to refer to the Office of the Inspector General of the Department of Education for investigation any credible information indicating that an applicant for Title IV may have engaged in fraud or other criminal conduct…
ADDRESSING THE PROBLEMFORMULATING AN INSTITUTIONAL PLAN
Define and Communicate Staff Expectations What activity constitutes suspicion? How do we apply a fair and equitable standard? Risk = Legal, e.g. Office of Civil Rights (OCR)Complaints
Collaborate with Institutions Lansing Community College Apollo Group/University of Phoenix
Implement Strategically Student Success Driven Student Conduct Driven Admissions Driven NOT Financial Aid Driven
RIO SALADO COLLEGE - CURRENT INITIATIVES
More proactive fraud prevention approach College-wide effort instead of a “financial aid problem” Student Code of Conduct
Embedded into Student Success initiatives Realign student flow All incoming students seeking a degree or certificate Authenticate identity Authenticate prior education Referrals Report analytics
Establish new organizational responsibilities Judicial Affairs Office Academic Integrity Team
RIO SALADO COLLEGEPROCESS OVERVIEW
•Students seeking a degree or certificate at Rio Salado College•Students supplementing coursework
•Authenticate identity •Authenticate prior education •Verify authenticity of any submission provided throughout the enrollment process
When Suspicious •Referrals Process•Academic Integrity •Judicial Affairs
RIO SALADO COLLEGE -STRATEGIC PLAN
Year 1 Prevention
Degree/Certificate Seeking Students
Supplemental Students
Authentication Organizational
ChangeOrientation Phase I
Year 2 Prevention
Orientation Phase II
Advisement
Mandatory Placement Testing
Identification & Reporting
ParticipationAcademic Integrity
Faculty and Staff Reporting
DCCCD – DALLAS TELECOLLEGE ONLINEINSTITUTIONAL PROFILE
Seven independently accredited colleges (BHC, CVC, EFC, ECC, MVC, NLC, RLC)
DTCO serves all campuses with mirror online sections, student support/advising
Since 1965, has served more than 1.5 million people Average enrollment Fall 85,000 credit, CE 25,000 Average DL enrollment 18% (most combo of F2F and online) $45 per credit hour tuition for Dallas residents 29% of credit students receive financial aid Centralized Financial Aid operations in 2011 Outsourced verification process to Global
STEPS TO AWARD
Application Registration Apply for FA Orientation Attend classes (online/F2F) Instructor certification of attendance
DCCCD – DALLAS TELECOLLEGE ONLINEFRAUD PREVENTION PRACTICES
FA disbursement takes place in phases
FA student responsibility videos – training
DOE procedure – a student attending two or more institutions
DCCCD does not separate online from on ground in terms of FA
Lock dates and flex term courses
AWARDS PROCESS
AID BASICS FOR STUDENTS
STUDENT RESOURCES
STUDENT RESOURCES
DCCCD – DALLAS TELECOLLEGE ONLINEFRAUD PREVENTION PRACTICES
DCCCD separation of duties Admissions: authenticate identity Enrollment: must be enrolled to receive financial aid Financial Aid: Awards Management and Financial Services
Colleague duplicate scan and FAFSA matching database
DCCCD verification documents if information on ISR changes
Global Contracted Services Audit
DCCCD – DALLAS TELECOLLEGE ONLINECASE STUDY
Instance of FA/VA Problem Investigation requested by College management Discrepancies in certifications made by VA coordinator Violation of Federal regulations
VA coordinator who was also a student, was certifying his own enrollment using an access code assigned to someone else
VA coordinator certified fictitious courses in order to maintain the proper enrollment
VA coordinator terminated, and information provided to the VA Regional Office in Waco, TX
RIO SALADO COLLEGE - INSTITUTIONAL PROFILE
Low cost tuition of $76 per credit hour in state and $215 per credit hour out of state
Approximately 70,000 total student headcount
Approximately 14,000 financial aid recipients
Rapid enrollment growth
PeopleSoft school
RIO SALADO COLLEGE - PROCESS OVERVIEW
•Students seeking a degree or certificate at Rio Salado College•Students supplementing coursework
•Authenticate identity •Authenticate prior education •Verify authenticity of any submission provided throughout the enrollment process
When Suspicious •Referrals Process•Academic Integrity •Judicial Affairs
RIO SALADO COLLEGE - FRAUD PREVENTION Pull Report of Newly Declared Program Seeking Students
Check for documentation of identity submitted
Check for evidence of prior education submitted
Apply AUTH Checklist as needed AUTH Checklist
Admissions and Records Authenticate Identity Checklist Item Admissions and Records Authenticate Prior Education Checklist Item Financial Aid Additional Information Required
Admissions and Records evaluates submissions Removes checklist items for authentic submissions Refers falsified, altered or forged submissions to Judicial Affairs for violating the
college’s Student Code of Conduct
RIO SALADO COLLEGE - NEXT STEPS
Comprehensively study and evaluate effectiveness Effects on enrollment Catch rate Instances of Return of Title IV Funds Overall college debt
Incorporate additional reporting currently used by University of Phoenix Duplicate demographic report Duplicate direct deposit (DD) report Reverse look-up report DD-fraud-match report Incarcerated student report Death Master File report
Changes to Federal Verification 2013-2014 Dear Colleague Letter GEN-12-11 Issued July 17,2012
CONTACT INFORMATION
Kishia Brock Vice President of Student Affairs Rio Salado College 480-517-8567 [email protected]
Audra Barrett Associate Vice President of Instruction Dallas TeleCollege Online 972-669-6406 [email protected]
Ryan Chase Associate Dean of Student Affairs Rio Salado College 480-517-8314 [email protected]
