Insights from a Former Federal Auditor Briget Biernat Jans Director of Financial Aid Compliance DePaul University

Who Does What, Where? Washington, D.C.  FSA headquarters  Establish policies and processes  For regional offices, as well as institutions  Limited amount of processing  Office of General Counsel Regional Offices  School Participation Teams  Carry out policies and processes  Ensure compliance  Address complaints  FOIA requests  Other teams

School Participation Team  Region V Staffing  Area Case Director  Managers  Institutional Improvement Specialists  Financial Analysts  Institutional Review Specialists  Administrative Staff  Trainers

What’s In It for YOU?  Trainers  Institutional Improvement Specialists  Assist schools that are  new to FSA  that may be struggling with some aspect of the regulations  Technical Assistance Duty  Ask questions – (312)

The Hats Worn by Institutional Review Specialists  Commonly known as “auditors”  Variety of tasks  Eligibility Actions  Method of Payment (MOP) Claims  Audit Resolutions*  Program Reviews  Recently, restructured to be more specialized

Eligibility Actions  New school approvals  Re-certifications  E-App updates  Additional locations  Adding new programs  New leadership  President  Aid director  Board members

Eligibility Actions  No matter the eligibility action, always, always, always send copies of:  Institutional accreditation  State authorization  Signature page  Make friends with academic affairs  Keep copies for yourself

Method of Payment (MOP) Claims  Review Specialists must review all claims for payments for schools under the reimbursement payment method.  Schools pay student first  Submit student-specific documentation of eligibility  Specialists review each student before approving or denying payment

Audit Resolutions  You submit via E-Z Audit  Washington reviews for material completeness  Assigns deficient audits to region  Manager assigns to Review Specialist  Not always same person from year to year  Depends on workload

Audit Resolutions  *Within the region, most likely reason to lead to a federal program review  Qualified opinion  material uncertainty exists  Adverse audit report  Institution has significant financial issues

Audit Resolutions  Reviewer builds a case for recommending a program review  Presents it during the full-team meeting  Team votes on whether need exists to do a review

Audit Resolutions  Keep deficient audits from becoming program reviews:  Avoid repeat findings at all costs.  Prepare a thorough management response to any findings.  Discuss sample size with your auditors.  10% error rate = full file review

Program Reviews  Most reviews determined by Washington  Usually focused on a particular concern  Some come from regional concerns  Typically from deficient audits

Program Reviews  What to do when you’re selected  Notify your President and other key offices  Begin gathering requested information IMMEDIATELY  Call with questions ASAP  Not meeting deadline = “lack of administrative capability”

Program Reviews  Make sure others understand importance and need for speed  Findings are typically addressed along the way  Shouldn’t be any surprises at end of week  If you can fix a finding on the spot, hop on it  The goal is an “expedited determination letter”

Questions???