Surviving ED Program Review What to Expect “We’ve Been There & Done That” Jacob Pacheco Connie Manzanares Northern New Mexico College New Mexico Association of Student Financial Aid Administrators 2014

Our Objective: To share our recent Program Review experience in an effort to help you successfully prepare and manage the process.

Presentation Outline What is a Program Review What Triggered Our Program Review & What Could Potentially Trigger Yours You Get “The Call” Preparing for the Visit – Be Ready The Reviewers Are Here After the Visit Be Prepared

Purpose of U.S. Dept. of Educ. Program Review Is to evaluate compliance, identify liabilities and improve institutional capabilities Authority for Program Review is defined by Congress to provide necessary oversight of Title IV Participants

What Triggers Program Review? High default rates – (over 25% cohort rate or dollar volume) Significant fluctuation in volume of Direct loans or Pell Deficiencies reported by State or Accrediting agencies

What Triggers Program Review? High annual dropout rates Financial aid program deficiencies Financial/Administrative capability compliance risk, Audit Findings

What Triggered Our Review Late Audit Submissions!!! Two year’s in a row! I started getting calls - from the Department of Education….Yikes!!

We Got “The Call” July 12th Typically 2-4 weeks advance notice The dates they initially chose were terrible for us Negotiated for more suitable visit dates – need a good reason

We Got The “Letter” July 17

We Got “The Letter” cont.. U.S. DOE letter confirmed visit dates, explained Entrance Conference & requested Pre-Review Submissions Specified that all offices involved in financial aid administration would be reviewed Also indicated that Campus Security & Drug- Free Schools Act compliance would be reviewed

The “Call” The “Letter” & Bears Ohh My! Don’t Panic! It’s not like you have to do a presentation for NMASFAA Read the entire letter: -Date of Review - Pre-Review Requirements – It’s a long list Begin Notifying campus officials Contact the lead Program Reviewer

Contact the Lead Reviewer Establish a point of contact Clarify details about the pre-review documents - format (electronic or paper) Clarify Scope and Period of Review Determine what accommodations are needed? Parking?

Read ED Program Review Guide 2009 Super useful prep tool Reviewers use it Sample file and policy review checklists Sample Student/Staff Interview Questions 9ProgramReviewGuide.html 9ProgramReviewGuide.html

Preparation Begins Set meeting/s with the key players - Fiscal; Academic; Registrar; Admissions, IT (Banner), Security Ensure that everyone understands the significance of ED Program Review “Sorry, but no vacation for you Mr. Provost”

Preparation Begins Cont… Prepare Resource Room - Secure a nice working space for Reviewers - Work with IT to provide access to databases - Provide organized copies of all Pre-Review info - Make arrangements for copying

List of Pre-Submission Items

Pre-Visit Submission Items Recipient Data Spreadsheet - Specific Award Year: Unduplicated list of TIV recipients in Excel and/or Access. - Used to confirm expenditures and to select a review sample

Pre-Visit Submission Items Recipient Data Spreadsheet

Pre-Visit Submission Items Consumer Information Attachment – 18 pgs - provide URL’s, title, page #’s, etc. - Policies and Procedures - Consumer Information Publications - Disclosures - Campus Security Reports - Catalogs

Pre-Visit Submission Items Request for Student Files (7) - Copy of Admissions File - Copy of Financial Aid File - Academic Transcript - Student Account Ledger - R2T4 calculation worksheet, evidence of return - If Work-Study-time sheets, class schedule, payroll records

Reviewers Are On Campus

Entrance Conference Everybody Should Attend – President, Vice Pres., CFO, Registrar, Deans, Chairs, Security Reviewers will explain: - Purpose - Scope - Timeframe which will include scheduling the Exit Conference (Don’t assume everybody pays attention)

Entrance Conference, cont. Introduce the school team Reviewers did most of the talking – explained the reason for the review and the scope Discuss staff interviews – Schedule created after entrance Opportunity to ask questions

Staff Interviews Ensure staff members are available – They have to know the importance of being available. Use and share the Program Review Guide for interview prep Many of the questions concerned consumer information and campus security

Problems are Found Reviewers find an issue with R2T4 - Liability: have to send $$ back to the DOE Consumer Information - not all requirements adequately met - some info not easy to find - some links did not work - Clery Act (Do we have dorms or not?)

Problems are Found cont.. Verification – We were verifying too many files – Asking for documentation that was not necessary

Exit Conference Reviewers praised Northern! – Let us know that findings were minimal & we were doing a good job Reviewers discussed findings Framed required actions to strengthen our compliance This is a time to ask questions and seek clarity on what happens next

Relief!!

Program Review Report We are waiting – It’s been over 6 months Clery Act finding is reviewed by a Department in Washington D.C. When report arrives we will provide institutional response by a due date specified in letter.

Be Prepared Policies & Procedures - Verification, Refunds, R2T4, Awarding, SAP, Professional Judgment - Admissions - Fiscal - Academic - Enrollment - Campus Security Don’t get caught not implementing your own policy

Be Prepared Staff should be current on FSA requirements and engaged with professional community. - Conferences (Annual FSA, NMASFAA, etc.) - Training sessions – online Use Assessment Tools (FSA, NASFAA)

Questions?

Contact Information: Jacob Pacheco Financial Aid Director Northern New Mexico College Connie Manzanares Assistant Director, Financial Aid Northern New Mexico College