Uncovering the Hidden Liabilities in Your Office MASFAA Conference 2008 November 19, 2008 Kimberly TibbettsJean Ricker VP for ComplianceFinancial Aid Manager Higher Education Asst. GroupFranklin W. Olin College of Engineering

 You should leave this session knowing how to  locate tools with which to find the hidden liabilities in your office  put together a Compliance Committee  develop your own internal review plan  create a corrective action plan

 Group Work to get you in the mood  FA Forensics at Work  Compliance Committee  Identify Areas of Liability  Develop a periodic review plan  Create an effective Corrective Action Plan  Open Discussion

 1) New Academic Programs: Your Academic Department has created a new certificate program and failed to inform Financial Aid. What do you do?  2) Institutional Disclosure Requirements – Your Campus Security Office refuses to send out the annual crime statistic notification. What do you do?  3) SAP- Institutional vs. FA. A student is not making SAP for Financial Aid purposes but the institution is choosing to allow the student to remain enrolled and take courses. What do you do?  4) IT- system upgrades- your institutions integrated system periodically delivers updates/upgrades based on changes in DOE regulation- some FA related some institutionally related. Your IT Dept is behind in the installation of these upgrades which causes institutional vulnerability with regard to compliance. What do you do?  5) Withdrawals- your Registrar has a habit of back dating withdrawals and/or failing to notify FA when a student withdraws from the institution. What do you do?

 Put together a Compliance Committee consisting of at least the following members:  FAO  Registrar  Bursar/Student Account Office  Admissions  Academic Affairs  Faculty  IT

 Meet every other week for the first 6 – 12 months - monthly thereafter  Develop a list of topics to discuss  Currently existing issues  Upcoming changes to regulations  Solicit topics from other departments  More topics will emerge as more meetings take place

 Allow time for each department to update the committee about what is going on in his/her area  This will be your opportunity to discover what the other departments are doing and if it will have an impact on the FAO  This opens up the opportunity for discussion and becomes a regulatory training moment  This sets the foundation for future collaboration with other departments

 To ensure institutional compliance  To kindly remind all departments of their responsibilities as compliance officers  To find any hidden liabilities within your institution  To develop stronger partnerships with essential departments

 Double Review Process  Create a policy and procedure (P&P) to support the following process to be performed every enrollment period  Secondary review of verification prior to disbursement  Secondary review of R2T4 prior to returning aid

 To find any hidden problems before they grow exponentially  If there is a consistent problem, this provides you with the opportunity to develop a Corrective Action Plan, adjust your P&P, and retrain your staff  To give the FAO time to correct the problem before the student leaves your institution

 If your office is too busy to do a secondary review… do a mini audit before the end of the enrollment period  Remember…if you begin to find a significant number of problems, it would be best to utilize the Double Review Process

 Select a small sampling of verified files  Review student eligibility  Review verification  Review the award  Review disbursed aid amounts  Select a small sampling of students who withdrew from the semester or institution  Review R2T4 process  Review NSLDS reporting  Cure files  Alter your P&P to reflect the changes  Train FAO personnel

 Perform an internal compliance review to determine if there are any errors that can be corrected prior to the A133 review or before the aid year closes  Use the list of Common Findings and findings from your previous A133 reviews to develop a list of areas to review  If you have a Corrective Action Plan in place, be sure to test to ensure that your office is complying with its own plan

 To find any hidden problems  It is always better to know the areas that may be problematic in an A133  To give the FAO time to correct the problem and develop a corrective action plan to have ready for the auditors if needed

 Late Refund/Returns to Title IV Account  Incorrect Return of Title IV Funds Calculation  Entrance/Exit Counseling Deficiencies  Enrollment Report (SSCR) Issues  Repeat Finding-Failure to Take Corrective Action  Auditor Opinion Cited in Audit  Student Credit Balance Deficiencies  Verification Violations  Pell Over/Under Payments

 A Corrective Action Plan must describe the corrective action taken or planned in response to findings identified.  Once a problem has been identified, either though an A133 or your own FA Forensics plan, you need to develop a corrective action plan to correct the problem and ensure that it does not occur again.

 Identify issues  Schedule a meeting  Bring together all the folks who impact or are impacted by the issues  Be sure to include IT if the solution will require utilization of the system  Meet  Lay out the problem and explain why it is an issue  Explain the regulation that must be met  Brainstorm a solution

 Document the solution  Implement the solution  Test the implemented solution  Conduct a follow up meeting if any tweaking is needed  Be sure to test this area in next year’s annual internal review audit

 IFAP website  FSA Assessment  NASFAA Self Evaluation Guide  Annual Auditor Training Conference  Higher Education Assistance Group, Inc  Verification Review Form (  Compliance/Efficiency Guide (

Share your successes What have you implement at your school to ensure that your institution is compliant? How did you create a institution wide compliance team? Anything you would like to share with the group? Any problems to bring to the group?

Kimberly Tibbetts(617) VP for Compliance Higher Education Asst. Group Jean Ricker (781) Financial Aid Manager Olin College of Engineering