Program Reviews 2011 NHASFAA Fall Conference

What is a Program Review? A review conducted by the Department of Education to evaluate compliance with Title IV statute and regulations Improve future institutional capabilities Identify liabilities owed for errors 2

Why Does FSA Conduct Program Reviews? Required by law To ensure that funds are used for the purposes intended by Congress and taxpayers Schools and FSA have a fiduciary duty to Congress and taxpayers Program integrity is important 3

Program Reviews In General Analyze institutional data and records Frame required actions and recommendations to strengthen future compliance Quantify harm and identify liabilities, if any Refer institutions for administrative action, if necessary 4

Top Program Review Findings (Ranked by Frequency) Verification errors Return of Title IV funds made late Return to Title IV (R2T4) calculation errors Student credit balance deficiencies Campus crime requirements not met 5

Top Program Review Findings (Ranked by Frequency) Account records inadequate/not reconciled Inconsistent information in student file Independent student status not documented Pell overpayment/underpayment 6

Top Program Review Findings (Ranked by Dollars) Ineligible program Inaccurate recordkeeping Return of Title IV funds not made Inconsistent information in student file FFEL disbursements attributed to unattended/incorrect payment periods 7

Top Program Review Findings (Ranked by Dollars) Improper Pell disbursement - prior to midpoint Verification errors Advances used for non-program purposes Incorrect Pell calculation Failure to meet factors of financial responsibility 8

P Program Review - Background Program reviews are generally conducted on-site 217 program reviews conducted nationwide in fiscal year For more information, see The Program Review Guide for Institutions 2009 which can be found under publications tab on IFAP sp?type=programrevguide sp?type=programrevguide 9

Program Review Guide Topics  Department preparation for program review  Institution preparation for program review  Entrance conference  ED review of institutional processes and data  ED review of student level information 10

Program Review Guide Topics  Exit conference/status meeting  Referrals  Post review communication and report  Final determination and follow-up  Appendices (definitions and sample information) 11

How Schools Are Selected for Program Reviews Conducted on a systematic basis to include all participating institutions Priority for selection ◦ Cohort default rate in excess of 25% or highest 25% of default rates ◦ High (top 25%) default rate in dollar volume 12

How Schools Are Selected for Program Reviews Priority for selection ◦ Significant fluctuation in Federal Pell Grant or FFEL/FDL funding levels ◦ Deficiencies reported by state licensing or accrediting agencies ◦ High annual dropout rates ◦ Other institutions that ED determines pose a significant risk of non-compliance 13

Risk Reduction Fully resolve audit findings Fully address all findings in the corrective action plan and be sure you follow through Revise policies and procedures to avoid repeat findings Attend training and keep current on program changes. 14

Types of Program Reviews General assessment review ◦ Random sampling of files ◦ Broad review of institutional policies and processes ◦ Generally includes multiple offices on campus Focused program review ◦ Focused on one or more areas of Title IV administration Off-site or on-site Announced or unannounced 15

Notification to School of Review Telephone notification to President and Financial Aid Director Written announcement letter Specifies information to be provided prior to review ◦ Student recipient data ◦ Institutional information 16

Requirement to Cooperate Cooperation in conduct of program review required Provide timely access for examination and copying of records Provide reasonable access to personnel associated with Title IV administration for the purpose of obtaining relevant information 17

Preparing For The Review Provide requested information by required deadline Inform all administrators at your school about the review Emphasize to staff the review is of the institution’s compliance 18

FSA Research Prior to Review FSA internal paper and electronic records ◦ EZ Audit ◦ NSLDS ◦ G5 ◦ COD ◦ FISAP ◦ Campus Security website ◦ IPEDS State and accrediting agency information 19

Entrance Conference President or CEO needs to be present All offices with any role in Title IV administration ◦ Financial Aid ◦ Registrar ◦ Business Office ◦ Admissions ◦ Placement ◦ Campus Security 20

Entrance Conference Introduction of FSA and school representatives Overview of program review process How Title IV is processed at the institution Logistics Possible scheduling of exit conference/status meeting 21

During the Review Provide review team with secure workspace Access to computer records, including print capability Access to photocopier Contact for reviewer questions Ensure staff availability for interviews 22

Review of Institutional Processes and Data Institutional and program eligibility Administrative capability - required policies and procedures Refund and withdrawal procedures Packaging, awarding and disbursing procedures Campus security Verification policies and procedures 23

Review of Institutional Processes and Data Fiscal records and procedures Cash management and reconciliation procedures FISAP Student consumer information Satisfactory Academic Progress 24

Staff Interviews Reviewers will interview multiple staff The institution cannot dictate who will be present during interviews The institution cannot tape record staff interviews Possible interviews with third-parties 25

FSA Review of Student-level Information Sample of student files reviewed Review multiple sources of student records ◦ Admission records ◦ Academic records, including current transcript ◦ Financial Aid records ◦ Student account record (ledger) Student interviews may be conducted 26

Resolution of Findings While On- Site Possible discussion of findings during the review School may attempt to resolve these findings Resolved findings still included in Program Review Report 27

Exit Conference Usually conducted if fieldwork is substantially complete Topics may include ◦ Required Actions ◦ Outstanding items and submission timeframes ◦ Oral notification of preliminary findings ◦ Next steps in program review process 28

Status Meeting Conducted if fieldwork not completed and/or data has not been analyzed Similar to exit conference ◦ Required Actions ◦ Outstanding items and submission timeframes ◦ Next steps in program review process 29

Possible Referrals Within the Department ◦ Administrative Actions and Appeals Division ◦ Management Improvement Services ◦ Office of Inspector General External referrals ◦ State licensing agency ◦ Accrediting agency 30

Post Review Activity Provide all outstanding documents requested by the reviewers Additional information may be requested Reviewers may return for additional on-site work FSA will complete analysis of data and issue a written report 31

Program Review Report Preliminary report of non-compliance findings Describes required actions including file reviews if necessary Establishes timeframe for institutional response List of student files reviewed attached as appendix May include recommendations 32

Institution Response to Program Review Report Contact reviewer with any and all questions Submit all information required in the requested format by the established deadline Complete required actions Request extension of time to respond if necessary 33

Expedited Determination Letter (EDL) Serves as preliminary report and final determination letter School is not required to respond Usage limited ◦ No findings, or only minor and non-systematic findings ◦ Any identified findings corrected prior to EDL issuance ◦ Any liabilities identified were paid/collected prior to issuance of EDL 34

Final Program Review Determination Letter (FPRD) Notifies the institution of the Department’s final determination for each finding No further action required – FPRD closes the review Includes copy of Program Review Report and school response(s) to report Issued within days of FSA’s receipt of a complete and final response 35

FPRD – School Action Required Contains original finding, summary of school response, Department’s final determination Identifies liabilities, if any, and instructions for payment Appeal rights for monetary liabilities Proof of repayment of liabilities to loan holders may be required 36

Appeal of Monetary Liabilities Monetary liabilities may be appealed within 45 days Appeal filed with FSA’s Administrative Actions and Appeals Division (AAAD) Collection of liabilities deferred for appealed amounts Non-appealed liabilities still have to be paid Appeal may be referred to Office of Hearings and Appeals (OHA) 37

FPRD Close-Out Written letter closes program review Issued after school completes actions required by FPRD Not issued of the school is filing an appeal for any liabilities 38

Record Retention Retain records until later of review closure or normal record retention period 39

Contact Information For questions about this session: Anita Olivencia, Training Officer Please provide any comments regarding this training or the trainer to: Thomas Threlkeld, Title IV Training Supervisor

Your Boston Regional Training Team Anita Olivencia, Training Officer ◦ ◦ Pam Gilligan, Training Officer ◦ ◦ 41