Schools How-to Guide to Vendor Oversight

A little about CMU 4 year, public university in Grand Junction, CO 10,660 students – 77% traditional & full-time ≈40% Pell Eligible 3 collection phases: Current student education – 99% collection Internal collections – 27% collection External collections – 10.2% collection 4 third-party collection agencies, tax off-sets, rotate agencies each year

Step 1: Preform Due Diligence on Yourself Concept: Due Diligence: Reasonable steps taken by a person in order to satisfy a legal requirement, especially in buying or selling something. Gather information from conferences, watch compliance webinars, read through law summaries. The more you understand and know, the better you’ll be able to monitor your agencies. How-to: Takes some time Research & maintain lists of all higher education compliance organizations. Start with the Compliance Handout

Step 2: Establish Contracts with Compliance Obligations Concept: Contracting = RFP > Thoroughly Review Responses >Interview top candidates > Select best fit > Contract RFP – your chance to set the precedence of the relationship RFP language = Contract language

Step 2: Establish Contracts with Compliance Obligations How-to RFP: The Basics Be Clear! Take time to be sure you have all the pieces Always check with your purchasing department and any state or attorney requirements 2 main sections – Administrative Information and actual RFP RFP Example: Ask for: Training manual Description of “best efforts” of collection Describe customer service philosophy Complaints, process to resolve Examples of standard letters/communication Pending lawsuits against the company References Strong Compliance Language

Compliance Language Examples Pursuant to C.R.S. 12-14-115 through 118 as amended, Offeror must be licensed to conduct business as a professional collection agency in the State of Colorado. Offeror must submit proof of licensure in the State of Colorado with their bid response. Offeror shall acknowledge the privacy rights of educational accounts which are expressed in the Gramm-Leach-Bliley Act, the Federal Family Educational Rights and Privacy Act, the Red Flag Rule and any other applicable State or Federal law related to communications and collections of delinquent accounts. Offeror shall not, under any circumstances, violate any applicable State or Federal law, including Fair Debt Collection Practices Act or violate any guidelines established by the Federal Trade Commission. Bid response shall provide evidence of compliance with: 1) Family Education Rights and Privacy Act, 2) Fair Debt Collection Practices Act, 3) Gramm-Leach-Bliley, 4) Red Flag Rules 5) Applicable State and Federal laws. Provide information on agency requirements for the University to adhere to laws and policies surrounding University provided account cell phone numbers.

Step 3: Maintain up-to-date copies of service provider policies and procedures Your RFP and contract should have a clause requiring any major changes to be communicated. How do you monitor changes?

Step 4: Appoint a Relationship Manager All big questions, complaints, process improvements, and performance analysis goes through Relationship Manager Example: Collections team = Financial Counseling Manager Others may upload and compute debt verifications Deputy Controller Financial Counseling Manager Bursar Financial Counselors University Cashiers

Step 5: Monitor … Daily Communication Answering Debt Verifications within 24hrs Giving clear information when placing accounts Quarterly meetings – see example Meeting Agenda

Monthly Collections Collections Rate Step 5: and Analyze… Establish solid, consistent reporting numbers to measure performance Each agency may report their collection numbers differently. For example: Monthly Collections Placement Inventory Collections Rate

Step 5: and Analyze… What do you want to know? Can you use the reports the agencies give you? Goal = ensure consistency across all agencies you work with.

Step 5: and Analyze… Analyze performance “score card” Use Excel! It’s Magical. Considerations: Math Total Dollars on all placements vs breaking out 1st/2nd etc. Giving all statistics to all agencies

Step 6: Tier your service providers What do you consider “successful”? Consider a score card? Collection Performance in total – with considerations Collection performance in 1st placements, 2nd placements, etc – with considerations Number of complaints

Step 6: Tier your service providers Is competition a good thing? Our first quarterly meeting was the first week of July 2015 What else can happen when competition is increased?

Step 7: Conduct Regular Audits Concept: Monitor conduct Use your gut – all this communication is to lead to a good understanding of the company Ask for: Your data In-person meeting? Training manual Description of “best efforts” of collection Describe customer service philosophy Complaints, process to resolve Examples of standard letters/communication Pending lawsuits against the company References How-to: CMU coming up on 1 year with new contract Intends on conducting a mini-audit

Step 8: Review Service Provider Performance & Hold them Accountable Remember CFPB Service provider rule. Analyze problem and determine severity Performance improvement plan? Adjust and clearly communicate expectations? Involve purchasing department for guidance? Temporarily suspend service until resolved?

Lindsey Manning Colorado Mesa University LManning@coloradomesa.edu Questions? Thank you! Lindsey Manning Colorado Mesa University LManning@coloradomesa.edu