Georgia Student Finance Commission Managing a State Program Review & Implementing Regulation Changes FALL 2005 GASFAA Presentation By GSFC Compliance Unit

Managing a State Program Review October 14, 2005 Presenter: Caylee French GSFC Compliance Officer

Agenda Program Review Objectives Program Review Objectives Program Review Policies, Procedures, & Process Program Review Policies, Procedures, & Process Most Common Findings Most Common Findings Conflicting Information Conflicting Information Tips and Pointers Tips and Pointers

Objective & Purpose of the Program Review Objective:  To determine whether the institution is consistently following policies and procedures, and in compliance with the Scholarships and Grants regulations Purpose:  To offer guidance and assistance And,  To raise awareness of problems, concerns, and needs

Program Review Policy Time Frame and Program Groups Time Frame and Program Groups Sample Selection Sample Selection Review Exemption Review Exemption Review Escalation Review Escalation Discretionary Review Discretionary Review Repayment of Funds Repayment of Funds

Program Review Time Frame and Program Groups 1 review per school, per fiscal year 1 review per school, per fiscal year Program Groups include HOPE, GTEG, and LEAP Program Groups include HOPE, GTEG, and LEAP –Other programs may be reviewed as deemed appropriate

Program Review Sample Selection Sample size is based on number of awards for that program group Sample size is based on number of awards for that program group –Less than 20 students awarded, all students reviewed –Between 21 and 2000 awards, 20 students reviewed –More than 2000 awards, 1% of students reviewed

Review Exemption If no findings for two consecutive years, school is exempt from review during the next year If no findings for two consecutive years, school is exempt from review during the next year –After exemption year, school must again achieve two consecutive years without findings to be granted another exemption

Review Escalation If initial review produces a post-appeal error rate of 30% or higher for any one program group (HOPE, GTEG, LEAP), a second review will be conducted with twice the sample size as original review If initial review produces a post-appeal error rate of 30% or higher for any one program group (HOPE, GTEG, LEAP), a second review will be conducted with twice the sample size as original review –If second review produces 30% error rate, school must apply this to all awards or hire outside reviewers to review all awards for that fiscal year

Discretionary Review GSFC may, at its sole discretion, review a school at any time it has reason to believe such a review is warranted GSFC may, at its sole discretion, review a school at any time it has reason to believe such a review is warranted –Changes in school program staffing –Significant changes in the number or types of awards being made –Findings of other departments or agencies –Third-party request for investigation –Reasonable suspicion of program mismanagement

Repayment of Funds If findings occurred in years prior to fiscal year being reviewed, no repayment is required as part of the review If findings occurred in years prior to fiscal year being reviewed, no repayment is required as part of the review If findings occur in years subsequent to fiscal year being reviewed, no repayment is required as part of the review, but finding will be re-examined during the next review If findings occur in years subsequent to fiscal year being reviewed, no repayment is required as part of the review, but finding will be re-examined during the next review If findings occur in year being reviewed, funds must be returned to GSFC If findings occur in year being reviewed, funds must be returned to GSFC

Program Review Process & Procedure The Institution’s Role The Institution’s Role Georgia Student Finance Commission – Compliance Officer’s Role Georgia Student Finance Commission – Compliance Officer’s Role On-site Review Procedure On-site Review Procedure

Program Review Checklist Hand Out

On-site Program Review Process Records Evaluation Records Evaluation –Admission’s –Registrar’s –Student Financial Aid –Fiscal Records/Student Account

Records Evaluation Admission Application Admission Application –Student data must be available State of Residency State of Residency Citizenship Status Citizenship Status Previous Enrollment Information Previous Enrollment Information Parent information, if applicable Parent information, if applicable –Supporting documentation, if applicable

Records Evaluation Registrar’s Office Registrar’s Office –College Transcripts Institutional and Previous College transcripts must be available Institutional and Previous College transcripts must be available –Enrollment Hours –Satisfactory Academic Progress –Grade Point Average Requirements, if applicable –High School/GED Transcript Supporting evidence of residency status Supporting evidence of residency status

Records Evaluation Student Financial Aid Student Financial Aid –FAFSA, E-HOPE or paper HOPE, GTEG, and/or Institutional application State of Residency information State of Residency information Parent information, if applicable Parent information, if applicable Selective Service registration Selective Service registration Citizenship verification Citizenship verification Default/Refund due Default/Refund due Satisfactory Academic Progress Satisfactory Academic Progress –Supporting documentation, if applicable

Fiscal Records/ Student Accounts Award Amount Award Amount –Tuition and Fees –Book Allowance Return of Funds Return of Funds –Title IV and HOPE –HOPE and/ or GTEG only Disbursement of Funds Disbursement of Funds –Verification of enrollment Reconciliation of Funds Reconciliation of Funds –Verification of reported data

Program Review Guide Hand Out Residency Admissions Application - Institutional Financial Aid Application FAFSA - HOPE Application Citizenship IF PRA IF PRA Admissions Application -HOPE Application- FAFSA Copy of Green Card/PRA Card – Date of Issue Copy of Green Card/PRA Card – Date of Issue Selective Service Selective Service Website Confirmation -FAFSA HOPE Application Enrollment Status Transcripts Computer System Access to Registration Records Award Amount Tuition and Fees Schedule for Fiscal Year being reviewed Award Letter, Computer System Access to Financial Aid Management Records Disbursement of Funds Business Records Computer System Access to Student Account Records Grade Point Average Institutional Transcript Previous College Transcripts Copy of Back of One Institutional Transcript HOPE Eligibility Calculation

Conflicting Information Supporting documentation present in student’s file to resolve conflicting or contradictory information Supporting documentation present in student’s file to resolve conflicting or contradictory information –Residency Date –Date of Birth –SSN –Citizenship  Resolving Conflicting Information is a cooperative effort among all campus offices

Common Findings Residency Residency –Not a GA resident for 12 months prior to enrollment –Don’t rely on other offices to make determination for you Citizenship Citizenship –Must be US citizen or Permanent Resident Alien (or other eligible non- citizen) for 12 months prior to awarding –Be sure to retain a copy of Permanent Resident Alien card

Common Findings Student not meeting GPA requirements Student not meeting GPA requirements(Scholarship) –Be sure to include ALL attempted degree hours –Calculate checkpoints using coursework in chronological order Inadequate SAP review procedures or policy is not enforced Inadequate SAP review procedures or policy is not enforced –Develop adequate monitoring system to ensure proper SAP review

Tips and Pointers Start early Start early –Begin the preparation process as soon as receiving notice Be over-prepared Be over-prepared –Have files, computer access, and requested documentation ready Provide adequate workspace Provide adequate workspace –Table or desk with computer access

Clarification of The HOPE Regulations Changes for October 14, 2005 Presenter: Dominic Coles, GSFC Compliance Officer

Agenda  Three-Term (3-T) Checkpoint Clarification  End-of-Spring (EOS) Checkpoint Clarification  Zero Grade Point Average  Zero Credit Hours  HOPE Book Allowance Disbursement  Georgia Tuition Equalization Grant (GTEG) and Military Dependents  Selective Service Registration For Male Under 18 Years of Age

Checkpoints Clarification Recipients must have a HOPE Grade Point Average (GPA) of 3.0 at each checkpoint to continue eligibility: Recipients must have a HOPE Grade Point Average (GPA) of 3.0 at each checkpoint to continue eligibility: - 3-T Checkpoint - EOS Checkpoints - Tier Checkpoints

Checkpoints Clarification The HOPE GPA is a unique calculation used solely for the purpose of determining HOPE Scholarship eligibility at the college level The HOPE GPA is a unique calculation used solely for the purpose of determining HOPE Scholarship eligibility at the college level The HOPE GPA may differ from other GPA calculations The HOPE GPA may differ from other GPA calculations The office which is normally responsible for the institutional GPA evaluation should perform the HOPE GPA evaluation The office which is normally responsible for the institutional GPA evaluation should perform the HOPE GPA evaluation

**Special Note Regarding Diploma Hours** Hours for which a student was enrolled in a diploma or certificate program, even if they are later accepted into a degree program, have no bearing on determining whether a student is subject to 3-T or EOS checkpoints. Hours for which a student was enrolled in a diploma or certificate program, even if they are later accepted into a degree program, have no bearing on determining whether a student is subject to 3-T or EOS checkpoints.

3-T Checkpoint Clarification Only applies to First Tier, part-time students Only applies to First Tier, part-time students Does not apply if the student was ever enrolled for at least 12 hours Does not apply if the student was ever enrolled for at least 12 hours Must have attempted less than 12 hours during each of the student’s first three terms Must have attempted less than 12 hours during each of the student’s first three terms Exit point of eligibility only Exit point of eligibility only

3-T Checkpoint Clarification – Hand Out Freshman Checkpoints Prior to 04-05Summer2004Fall2004Winter2005Spring2005Summer2005 Fall 2005 to Spring 2006 >12PTPTPTPTEOSEOS >12NEPTPTPTEOSEOS >12NENEPTPTEOSEOS >12NENENEPTEOSEOS <12PTPTPT3-TPTEOSEOS <12PTPTNEPT3-TEOS <12PTNENEPTPT3-TEOS <12NEPTPTNEPT3-TEOS <12NEPTNEPTPT3-TEOS <12PTNEPTPT3-TEOS <12PTPTNENEPT3-TEOS <12PTFTPTNEEOSEOS

EOS Checkpoint Clarification Apply to all HOPE Scholarship recipients regardless of Spring 2005 enrollment Apply to all HOPE Scholarship recipients regardless of Spring 2005 enrollment Exception: Freshman who have not yet been enrolled full-time for at least one term Exception: Freshman who have not yet been enrolled full-time for at least one term

EOS Checkpoint Clarification Must have a cumulative 3.0 GPA at the end of each Spring semester/quarter Must have a cumulative 3.0 GPA at the end of each Spring semester/quarter - First Tier recipients must be full-time (12 hrs.) for at least 1 of their first 3 terms at least 1 of their first 3 terms - Second, Third, and Fourth Tier recipients must be reviewed at the end of each Spring term, reviewed at the end of each Spring term, whether full-time, part-time or not enrolled whether full-time, part-time or not enrolled - Exit point of eligibility only

EOS Checkpoint Clarification Example 1: Degree Program Example 1: Degree Program GPA = 2.99 at the end of Spring 2005 GPA = 2.99 at the end of Spring 2005 EOS applies at the end of Spring 2005 EOS applies at the end of Spring 2005 Not eligible for the next term Not eligible for the next term Fall 2003 DegreeSpring2004Degree Summer 2004 Fall2004 Winter 2005 DegreeSpring2005Degree 1212 Not Enrolled NotEnrolled99

EOS Checkpoint Clarification Example 2:Diploma/Certificate Program Example 2:Diploma/Certificate Program 12 diploma hours were accepted into the degree program 12 diploma hours were accepted into the degree program GPA = 2.99 at the end of Spring 2005 GPA = 2.99 at the end of Spring 2005 EOS does not apply EOS does not apply Eligible for the next term Eligible for the next term Fall 2003 DiplomaSpring2004Diploma Summer 2004 Fall2004 Winter 2005 DegreeSpring2005Degree 1212 Not Enrolled 96

Zero Grade Point Average Reach checkpoint but no GPA Reach checkpoint but no GPA –Example – Learning Support Program Not eligible until the next entry point, unless obtained 3.0 GPA for at least one course Not eligible until the next entry point, unless obtained 3.0 GPA for at least one course May request an exception May request an exception –HOPE Regulations offer guidelines to qualify for an exception –If approved, retroactive payment

Zero Credit Hours Courses that appear on a student’s transcript with no course hours will be assigned 3 semester hours or 5 quarter hours for the purpose of determining a student’s Attempted- Hours – –Exception – Courses that carry actual zero credit as published by the institution

HOPE Book Allowance Disbursement Entire amount must be disbursed Entire amount must be disbursed Unused portion that is not disbursed must be returned to GSFC Unused portion that is not disbursed must be returned to GSFC Must apply funds to book charges unless written authorization is obtained from student authorizing the funds to be used for other charges Must apply funds to book charges unless written authorization is obtained from student authorizing the funds to be used for other charges Regulation will be enforced by Winter quarter or Spring semester of 2006 Regulation will be enforced by Winter quarter or Spring semester of 2006

GTEG and Military Dependents Non-resident military dependent can receive GTEG Non-resident military dependent can receive GTEG Applies to all non-resident military dependents Applies to all non-resident military dependents Effective Fall 2005 Effective Fall 2005 No retroactive GTEG for prior years No retroactive GTEG for prior years

GTEG and Military Dependents Student will continue to receive GTEG if parent is no longer Georgia resident Student will continue to receive GTEG if parent is no longer Georgia resident No break in enrollment No break in enrollment Effective Fall 2005 Effective Fall 2005 No retroactive GTEG payment for prior years No retroactive GTEG payment for prior years

Selective Service Registration Male Under 18 Eligible for the term for which student is not required to register Eligible for the term for which student is not required to register School does not have to verify that student registered once he turned 18 during the current award year, but must do so before subsequent award years School does not have to verify that student registered once he turned 18 during the current award year, but must do so before subsequent award years –However, GSFAPPS will prevent disbursement for future terms until student has updated status Not eligible for retroactive disbursement if does not register for the term for which the student is required to comply Not eligible for retroactive disbursement if does not register for the term for which the student is required to comply

QUESTIONS/COMMENTS/ SUGGESTIONS? GSFC Compliance Unit Cindy Abbott, Senior Manager Tammy Tran, Compliance Analyst Caylee French, Compliance Officer Dominic Coles, Compliance Officer Ray Tripp, Compliance Officer