A POLICIES AND PROCEDURES MANUAL NYSFAAA Annual Conference John View Director of EOP and Financial Aid Compliance officer October 2015

Quiz -? Section of the Title IV Regulations stipulates every school who participates in title IV aid Must have a Policy and procedures manual. True or False

Answer is???? False

A Policies and Procedures Manual is NOT: The FSA Handbook A copy of the Code of Federal Regulations A list of “things to do”

Why a Policies and Procedures Manual? A set of written policies and procedures to guide and manage a Financial Aid Office. Not required by ED, recommended Federal regulations require schools to have, maintain, and disclose certain policies in writing.

Why is it Important? Compliance requirements External Audits and Internal Audits Program reviews – Federal and State Administrative capability ; Staff training Consistency Equity

Today’s Agenda Evaluate what should be included Identify the differences between a policy and a procedure Create a comprehensive manual Develop a systematic way to track and incorporate regulatory changes

Getting Started

Policies: Required or Optional Federal State Institutional

Policies and Procedures Components Table of contents Organizational chart − Institutional − Office General office information − Mission and vision − Location and hours Eligibility and Certification Approval Report (ECAR) Program Participation Agreement (PPA)

Policies and Procedures Components (continued) Accreditation Entities Identification of programs in which your institution participates − Federal − State − Private − Institutional Individual policies and procedures

Broad Categories to Consider Aid programs Consumer Information Cost of Attendance Packaging Philosophy Professional Judgment Return of Title IV Funds

Broad Categories to Consider (continued) Satisfactory Academic Progress Transfer Monitoring Verification Technical Considerations Forms Fraud and abuse

Definition of Policy  Policies identify “why” Explain the purpose or value −Increases understanding Identify the applicable law or regulation Identify federal, state, institutional

Definition of Procedures  Procedures identify “how” Identify new regulations and changes in school policies Provide consistency Explain the process so it is understood both by seasoned staff as well as any new staff in your office or the profession Use Screen shots as visual aids Consider the impact to other offices’ procedures

Sample Templates – NASFAA/ED

Sample - NASFAA

Sample – ED – found on IFAP

Sample – ED from IFAP

Due Diligence Track the new regulatory requirements throughout the year Know the implementation date Verify interpretation with colleagues − Seek guidance from ED if necessary Take advantage of available tools

Due Diligence (continued) Follow the Notices of Proposed Rulemaking (NPRM) for a better understanding of the intent of any changes −Comments −Summaries −Effective dates

Best Practices

Get a Jump Start Gather related items −Old manuals −Memoes −Cheat sheets −Forms −School catalog and other publications Beg, borrow and use existing templates or P&P manuals that a colleague may share with you Start simple

Getting Help Templates and guidance −Information for Financial Aid Professionals −NASFAA −Google Be consistent Use them as operating guides

Develop an Implementation Plan What Who’s responsible Due dates (draft and final) Final approval When next review

Select Format Outline format Columns Paragraphs/narrative Combination

Keep It Simple Use common language (not FA legalise) Spell out acronyms Glossary of acronyms and common terms Not a copy and paste of the Code of Federal Regulations, FSA Handbook, or other resource materials −Make it school-specific −Include the applicable law or regulation for quick reference, when appropriate

Divide Up The Tasks Ask staff to take sections relative to their areas Set deadline and stick to them Review portions of it at different times of the year to make it more manageable

Share the Work Load and Responsibility Business office Registrar Admissions Processing staff Student services Directors Middle management staff Institutional Technology Academic Governance – New programs Others

Questions to Ask & Answer Why add a policy or make changes? Who does the policy impact and in what ways? When is the implementation date? Which staff and departments should be consulted?

Ask Questions Who has the final authority to implement or make changes? Are there exceptions to the policy? What are the related forms? How do the additions or changes “fit” with other policies? Are there any conflicts to be resolved? How should policies/changes be provided to other administrators? What campus mechanism is in place to alert FAO that a policy change may need to occur ?

Assessment

Continually Evaluate Your P&P Manual…… Provide your staff with current policies and procedures that pertain to eligibility for federal, state, and institutional programs Deliver general and specific responsibilities to the staff, and other departments

Does Your P&P Manual….. Provide general office procedures ensuring a systematic and consistent approach in the operation of all programs Provide quick references Facilitate the orientation and training of personnel both In-House and Outside – (Professional Training Opportunities)

Identify Responsibilities Determine who will ultimately be responsible as the coordinator −Designate staff that needs to participate −Delegate assignments based upon areas of expertise −Establish a team with members from all relevant offices Borrow, share, and steal from colleagues Include appropriate levels of management and departments for review and approvals

Remember…….. Doesn’t need to be complicated to be effective Don’t be caught not following your own policies and procedures

Next Steps

Stay on Top of Updates Review annually at a minimum Identify who has access to both review and update Track regulatory changes −Ifap.ed.gov −Federal Register/ NASFAA News Read the comments and summary as well as the regulations Check student files through internal file reviews Follow your own procedures

Tips of the Trade- From our Colleagues  Be sure to: Make sure your policies are consistent with federal and state regulations; compliance is huge Review them with staff Update them continually with corrections or when regulations change Start working on them well before you need (yesterday) Delegate the updates

Final Developments Make the review a part of your annual calendar Implement a user-friendly, easy-to-read format Make hard copies or electronic back-up of old P&Ps Share with all relevant employees Post online/file share

Questions and Thank you!