Compliance Across Campus Catherine Boscher-Murphy NJASFAA Conference March 2018

Goals of this Session Who are your campus partners? What are the most common compliance issues across campus? What areas of Title IV regulations intersect with other areas on campus? How do you communicate with other offices about TIV?

Campus Partners Obvious ones: Bursar/Student Accounts Admissions Registrar EOP Athletics Security/Campus Police

Campus Partners Less obvious ones: Advising Residence Life Provost Professional Faculty Residence Life Provost Foundation Office IT and Institutional Research

Most Common Compliance Issues Audit findings: #2: R2T4 calculation errors #3: Missed R2T4 deadlines #4: Inaccurate/untimely student enrollment reporting #6: TIV Credit balance deficiencies

Most Common Compliance Issues Program Review findings: #1: Crime Awareness requirements not met #3: R2T4 calculations errors #5: TIV Credit balance deficiencies #6: SAP policy not developed/monitored #7: Missed R2T4 deadlines #8: Lack of administrative capability #10:R2T4 refunds not made #13:Consumer information requirements not met

How Do We Intersect? Who do we have to play nicely with in the sandbox?

R2T4 calculations Who identifies the students to calculate? Identify on system? Provide list? Registrar Student Affairs IT department Who has responsibility for the calculation? Bursar Financial Aid What tool do you use? Federal refund formula System provided module Test your system against the federal one If you use the federal one, reduces likelihood of being cited for a calculation error If the calculation is done by a different office, who revises the financial aid awards Who returns the funds?

R2T4 calculations If the Financial Aid Office is not responsible, is the other office aware of the timeline and deadline requirements?

Enrollment Reporting Who has responsibility? What tool do you use? Registrar Financial Aid What tool do you use? Clearinghouse NSLDS reporting Is this automated? Are you using the correct stat us codes?

TIV Credit Balances Who has responsibility? Student Accounts Finance Financial Aid Are the deadlines being met? Disbursement Credit balance calculations Refunds to students How do you do this? Direct Deposit Paper check Debit card Non-compliant holding of Title IV balances – during year; at end of year

Crime Awareness Who has responsibility? Campus Police Student Affairs/Student Life Financial Aid IT/Communications Have you defined your geography/property? Are the statistics being kept? Crime Log Fire events Crime Statistics Emergency warnings Missing student policy Do you get input from local jurisdictions for adjacent properties?

Crime Awareness Is your campus correctly identifying the type of crimes on campus Number and type of incidence New definitions VAWA Do you collect information from local agencies? Are the necessary security report notifications being sent? Email notification Paper copies available Discrepancies between what is posted on website vs. what is submitted to ED

SAP Who has responsibility? Do you have policies? Financial Aid Registrar Advising Do you have policies? Do you follow your policies? How do you identify students? Lists from IT Does your policy cover all the required components? qualitative quantitative progression max. time frame Do you address repeat courses? Probation? Appeals? No academic amnesty for SAP

SAP Who notifies student? Who collects appeals? Who approves appeals? Financial Aid Registrar Advising Who collects appeals? Who approves appeals? Single person Financial Aid Office Committee with members from campus Who develops the Academic Plans? Faculty advisors

Administrative Capability Individual responsible for aid programs Adequate number of qualified persons Institutional offices communicate Establish and maintain records System to identify and resolve discrepancies Written procedures Checks and balances Ensure separation of duties 1. Is there an individual responsible for administering and coordinating all financial aid programs 2. Does the institution employ an adequate number of qualified persons to administer the Title IV programs? 3. Do institutional offices communicate any information that has bearing on a student’s eligibility for Title IV aid? Waivers Scholarships 4. Do you establish and maintain records required under Title IV program regulations? 5. Do you have an adequate system to identify and resolve discrepancies in information received from different sources with respect to a student’s application for Title IV aid? Do you have mechanisms in place to obtain and review appropriate information 6. Written procedures that indicate the responsibilities of each office regarding the approval, disbursement, and delivery of Title IV assistance, and the preparation and submission of reports to ED? 7. Do you have adequate checks and balances within your system of internal controls? 8. Ensure no one individual or office has responsibility for both authorizing and disbursing or delivering Title IV funds? Family members on both sides of the aisle?

Administrative Capability Policies in place to contact ED’s Office of Inspector General (OIG) Provide adequate financial aid counseling to eligible students Employees available to assist enrolled and prospective students in obtaining institutional and financial aid information Prohibit bonuses, commissions, or other incentive payment Demonstrate a level of competency 9. Do you have policies and procedures in place to contact ED’s Office of Inspector General (OIG) when necessary? 10. Do you provide adequate financial aid counseling to eligible students who apply for assistance from the Title IV programs 11. Do you have one or more employees available to assist enrolled and prospective students in obtaining institutional and financial aid information? 12. Do you prohibit bonuses, commissions, or other incentive payment? 13. Do you demonstrate a level of competency necessary to administer the Title IV programs 14. Do you regularly reconcile Title IV funds?

Consumer Information Who has responsibility? Is reporting being done? Are deadlines being met? Are students being notified? How? Consumer Information & School Reports – FSA Handbook, School Eligibility, Ch. 6

Consumer Information General disclosures for enrolled or prospective students Annual security report and annual fire safety report Report on athletic program participation rates and financial support data (Equity in Athletics Data or EADA) FERPA information Financial aid available Academic programs, facilities, costs, etc. Withdrawal procedures Accreditation and licensure Disability services and facilities Transfer credit policies Copyright infringement Student Activities, diversity Net Price Calculator Shopping Sheet Completion, graduation, retention and transfer rates GE disclosures Campus Crime and Safety Drug and Alcohol Abuse Prevention Athletics Textbooks Loan Counseling Private educational loans Misrepresentation Anti-Lobbying Voter Registration (Family Educational Rights and Privacy Act of 1974, discussed in Chapter 7). Document dissemination of disclosures

Other Areas to Consider NCAA Reporting Gainful Employment Reporting FISAP Surveys Tier I and II arrangements Stale checks – non-escheatment of funds

How Can We Improve Compliance? Hire a compliance person for office or campus Identify areas of weakness Do a self evaluation before the feds come to visit Get buy-in from supervisors in other areas e.g. attendance from faculty – Provost Utilize legal counsel on campus

Communication Across Campus Be cooperative Provide information to support your statements/requests Update other offices in a timely manner about changes Institute cross department meetings with the major partner offices Communications group from across campus of the student touching offices Systems User Group Get buy-in from Provost or President (usually have to talk the money aspect here) How do you connect with other offices?

Resources to Review NASFAA Self Evaluation Guide Policies and Procedures Tools AskRegs and Knowledgebase Clery Reporting https://www2.ed.gov/admins/lead/safety/handbook.pdf

Other Resources NASFAA SOE Peer Review Federal Program Review Findings https://studentaid.ed.gov/sa/about/data-center/school/program-reviews Clery specific PR Findings https://studentaid.ed.gov/sa/about/data-center/school/clery-act-reports

Contact Info Email: boschermurpc@mail.montclair.edu Phone: 973-655-7014