NYSFAAA Leadership Preparation Program Reviews October 16, 2015 Thomas J. Dalton Assistant Vice-President, Enrollment Management Excelsior College

What is a Federal Program Review?  Method of oversight  Evaluates compliance with Title IV, HEA statute and regulations  Examination of financial aid, fiscal and academic records  Interviews with institutional staff and students  Review of consumer information requirements  Identifies errors in compliance and liabilities owed  Tool to improve future institutional capabilities

How Are Institutions Selected? 20 U.S.C. 1099c -1 (a)(2): (The Secretary) shall give priority for program review to institutions of higher education that are institutions with:  High cohort default rate or dollar volume of default (25%+)  Significant fluctuations in Federal Pell Grant or loan volume  Reported deficiencies or financial aid problems by state or accrediting agency  High annual dropout rates, or  Any other institution the Department determines may pose significant risk of failure to comply with administrative capability or financial responsibility requirements

Institution Preparation for Program Review  Receiving Notification of Program Review  Advance Notice Review  Short Notice Review  Third-Party Servicer Notification  Responding to Announcement Letter 4

Excelsior's Federal Program Review Timeline  February 10, 2015 – Notification from DoE  Required Deadlines:  February 17, 2015 – Consumer Information and Disclosures  February 18, 2015 – Data Requests  February 23, 2015 – Outstanding Items  March 2, 2015 – Records and Documentation available for Review

Entrance Meeting  Introductions  DoE will explain the process  Issue the sample to be reviewed  15 – 20 students in FY 2014  15 – 20 students in FY 2015  Review will look at ALL areas of the College – will last 5 days 6

Areas of Focus During the Review Specific to Excelsior College  The regular and substantive interactions between faculty and students  Dropout rate  Return of Title IV  Student time of Enrollment  The Flow of Money 7

Review of Institutional Processes and Data  Review Institutional Documents Collected Catalog/Brochure/Handbook Policies and Procedures Published Campus Security Information Student Consumer Publications Online Student Consumer Information Institutional Forms, Applications and Worksheets 8

Review of Institutional Processes and Data  Review of Institutional Critical Elements Eligible Institution Administrative Capability Program Eligibility Consumer Information Campus Security Financial Responsibility Fiscal Review FISAP 9

Review of Institutional Processes and Data  Staff Interviews Academic/Registrar Admissions Financial Aid Student Accounts/Bursar/Fiscal Office Placement Campus Security 10

Review of Student Level Information  Review of Student Critical Elements Student Eligibility Attendance Cost of Attendance Credit Balances Enrollment Status Dependency Overrides/Professional Judgment Return of Title IV Satisfactory Academic Progress Verification Calculations/Disbursements 11

Review of Student Level Information  Records Reviewed in Student Files  Admissions  Academic  Financial Aid  Student Account Ledger  Student Records Compared to Department Data  NSLDS  COD  CPS  Student and Staff Interviews

Exit Meeting  Same representation as Entrance Meeting  DoE will present any “Findings”  Typically they won’t tell you what you do well!  DoE will identify any outstanding items  DoE will describe the process for appeal  DoE may request additional information 13

What happens after the onsite visit?  DoE will issue a “Final Determination Letter” in 3 to 6 months  Your institution will have 30 days to appeal any finding  If your institution agrees with the findings – you will have 30 days to submit a “Corrective Action Plan” and repay Federal funds back if they are due 14

Final Program Review Determination Letter (FPRD)  Department’s final determination for each finding  Identifies liabilities and provides payment instructions  Closes Program Review, if appropriate  State authorizing and accrediting agencies receive copies  Subject to FOIA  Two types:  No further action required  Further action required 15

Final Program Review Determination Letter (FPRD)  Standard sections Cover page Table of Contents Institutional Information Scope of Review and Disclaimer Findings and Final Determinations Summary of Liabilities Repayment Instructions Appendices and Enclosures Sample template in Program Review Guide

Top Audit Findings 1.Repeat Finding – Failure to Take Corrective Action 2.NSLDS Roster Reporting – Inaccurate/Untimely Reporting 3.Return of Title IV (R2T4) Calculation Errors 4.R2T4 Made Late 5.Verification Violations 17

Top Audit Findings 6.Pell Overpayment/Underpayment 7.Student Credit Balance Deficiencies 8.Entrance/Exit Counseling Deficiencies 9.Qualified Auditor’s Opinion Cited in Audit 10.G5 Expenditures Untimely/Incorrectly Reported 18

Top Program Review Findings 1.Verification Violations 2.Return of Title IV (R2T4) Calculation Errors 3.Student Credit Balance Deficiencies 4.Entrance/Exit Counseling Deficiencies 5.Crime Awareness Requirements Not Met 6.Satisfactory Academic Progress Policy Not Adequately Developed/Monitored

Top Program Review Findings 7.NSLDS Roster Reporting – Inaccurate/Untimely Reporting 8.Inaccurate Record Keeping 9.Drug Abuse Prevention Program 10.Requirements Not Met 11.Consumer Information Requirements Not Met 12.Return of Title IV (R2T4) Made Late

Findings on Both Lists 1.R2T4 Calculation Errors 2.Student Status – Inaccurate/Untimely Reporting 3.R2T4 Made Late 4.Verification Violations 5.Student Credit Balance Deficiencies 6.Entrance/Exit Counseling Deficiencies 21

Resources on IFAP  amReviewGuide.html amReviewGuide.html 22

QUESTIONS? 23