FSA Program Review “Not Such a Rocky Road” Jacob Pacheco Northern New Mexico College New Mexico Association of Student Financial Aid Administrators 2015

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

Presentation Outline What is a Program Review What triggered our Program Review & What could trigger yours Preparing for the visit – Be ready The reviewers are here After the visit – Review Report

Purpose of U.S. Dept. of Educ. Program Review To evaluate compliance, identify liabilities and improve institutional capabilities Authority for Program Review is defined by Law to provide necessary oversight of Title IV Participants Section 498A of the HEA, 20 U.S.C. § 1099c

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

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

Top Program Review Findings R2T4 calculation errors Verification violations Entrance/Exit counseling deficiencies Crime awareness requirements not met Student credit balance deficiencies Satisfactory Academic Progress policy not adequately developed/monitored 8

Top Program Review Findings R2T4 funds made late Pell Grant overpayments/underpayments Account records inadequate/not reconciled Inaccurate recordkeeping Lack of administrative capability Information in student files missing/inconsistent 9

We Got “The Call” (July 12 th ) Advance notice of arrival (We had one month) The dates they initially chose were terrible for us (First week of fall term) Negotiated for more suitable visit date – 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! 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 at your institution Clarify details about the pre-review documents - format (electronic or paper) Clarify Scope and Period of Review Determine what accommodations are needed?

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

Campus 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 – provide URL’s, title, page #’s, etc. -Policies and Procedures -Consumer Information Publications - Disclosures -Campus Security Reports -Catalogs

Consumer Information Attachment

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 question concerned consumer information and campus security

Problems are Found 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 This is a time to ask questions and seek clarity on what happens next.

Program Review Report (This is when the fun really began!!) Report arrived exactly one year after the Program Review!! Required institutional response to findings within 30 days -Had to request a 15 day extension

Program Review Report cont… Clery Act finding is reviewed separately by a Department in Washington D.C. – Still have not received this.

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 regulatory requirements - Conferences: Annual FSA, NASFAA, NMASFAA - Training sessions – online Use Assessment Tools (FSA, NASFAA) − FSA COACH − FSA Assessments

Resources – 37 My IFAP What’s New Tools for Schools Publications Handbooks Letters & Announcements Training and Conferences

FSA Assessments Self-assessment tool designed to assist schools in evaluating their financial aid policies, processes, and procedures Includes assessment modules regarding Students, Schools, and Campus-Based Programs tml 38

FSA Assessments 39

Questions?

Contact Information: Jacob Pacheco Financial Aid Director Northern New Mexico College