Surviving a Federal Program Review Presented By: Mary Blizzard and Stephany Harper

Why Me? High cohort default rate Significant changes in Direct Loan or Pell volume Late refunds Deficiencies reported by state licensing or accrediting agencies Financial responsibility standards High withdrawal rates Significant audit findings Repeat findings or recurrent problems Significant risk of noncompliance with administrative capability Complaints from students or adverse publicity Institutions that haven’t had a review in a number of years Frequent change in financial aid leadership

How Will I Be Notified? There are two basic types of notification Short Notice -Program Reviewers Show Up at Your School Advanced Notice -A Phone Call is made to the President’s Office You typically get a week to provide requested information Program Reviewers may do an on-site visit or conduct the review remotely

What Are the Main Differences? On-Site Program Review • Introductions • Reason for Program Review and Scope • Overview of Program Review Process • Title IV Processing/Staff Responsibilities • Required Documents and Time Frames • Schedule Exit Conference Off-Site Program Review • Conference Call • Usually Limited Scope

What Is the Timeline? 2-4 weeks advanced notice (but sometimes shorter notice, especially in cases of serious complaints or adverse media) Typically 1 week on-campus Written report 1-6 months later School response due in 30-60 days Final Determination Letter (or, in cases of few or no findings, an expedited Determination Letter) Appeal process

How Can I Prepare? Review the Program Review Guide: https://ifap.ed.gov/ifap/byYear.jsp?type=programrevguide&year=2009 Rally the Troops- Notify Administration and Conduct an Internal Meeting Prior to the Visit Appoint a Point Person to Be the Main Point of Contact Make Certain Tasks Are Assigned and Completed

What Will I Need to Provide? Policies and Procedures Manual Sample FSA forms Cost of Attendance Budgets Pell Electronic Statement of Account (ESOA) Information Return to Title IV (R2T4) worksheets Documentation of cash requests/refunds/returns Default management plan, if required FISAP Satisfactory Academic Program and refund policies

What Will I Need to Provide? ISIRs Latest accreditation status Third party servicer contracts Administrative software utilized Program Participation Agreement (PPA) and Eligibility and Certification Approval Report (ECAR) Financial statements for past two years Campus security report Catalog Consumer information

Helpful Hints Ask for requests in writing or confirm understanding in writing for clarity Keep copies of everything provided: you will look at it again (and again) Provide a comfortable place for reviewers to work Respond promptly to requests Do not answer the “unasked” question Challenge findings

Most Frequent Findings Verification Crime awareness reporting R2T4 errors Entrance/Exit Counseling SAP Student Credit Balance Deficiencies Missing or inconsistent information in student files Pell Over/Under payments Consumer information deficiencies Lack of administrative capabilities Some Additional Recent Findings: FWS students paid for time they were scheduled for class OR Documenting Pell recipients’ initial attendance and/or documenting dropping a class and reducing Pell accordingly

Next Steps When discussing findings, ask questions if you are unclear You will have a good sense of what will be shared at the exit interview - prepare those who will attend no matter how negative the findings – it is much better to hear it from you first than in a group setting with the reviewers During review ask for regulatory/statutory citations and make sure you understand how they apply to the findings Make sure you keep all reviewed materials together to ensure you know what reviewers saw at the time of the review Prepare your answers to the findings Create priority list for implementation of correcting findings Create an implementation timeline

Contact Information Mary Blizzard mary.blizzard@wvhepc.edu Stephany Harper Stephany.Harper@glenville.edu