1. Surviving a Federal Program Review
Presented By:
Mary Blizzard and Stephany Harper

2. Why Me? High cohort default rate
Significant changes in Direct Loan or Pell volume
Late refunds
Deficiencies reported by state licensing or accrediting agencies
Financial responsibility standards
High withdrawal rates
Significant audit findings
Repeat findings or recurrent problems
Significant risk of noncompliance with administrative capability
Complaints from students or adverse publicity
Institutions that haven’t had a review in a number of years
Frequent change in financial aid leadership

3. How Will I Be Notified? There are two basic types of notification
Short Notice -Program Reviewers Show Up at Your School
Advanced Notice -A Phone Call is made to the President’s Office
You typically get a week to provide requested information
Program Reviewers may do an on-site visit or conduct the review remotely

4. What Are the Main Differences?
On-Site Program Review • Introductions • Reason for Program Review and Scope • Overview of Program Review Process • Title IV Processing/Staff Responsibilities • Required Documents and Time Frames • Schedule Exit Conference Off-Site Program Review • Conference Call • Usually Limited Scope

5. What Is the Timeline?
2-4 weeks advanced notice (but sometimes shorter notice, especially in cases of serious complaints or adverse media)
Typically 1 week on-campus
Written report 1-6 months later
School response due in days
Final Determination Letter (or, in cases of few or no findings, an expedited Determination Letter)
Appeal process

6. How Can I Prepare? Review the Program Review Guide:
Rally the Troops- Notify Administration and Conduct an Internal Meeting Prior to the Visit
Appoint a Point Person to Be the Main Point of Contact
Make Certain Tasks Are Assigned and Completed

7. What Will I Need to Provide?
Policies and Procedures Manual
Sample FSA forms
Cost of Attendance Budgets
Pell Electronic Statement of Account (ESOA) Information
Return to Title IV (R2T4) worksheets
Documentation of cash requests/refunds/returns
Default management plan, if required
FISAP
Satisfactory Academic Program and refund policies

8. What Will I Need to Provide?
ISIRs
Latest accreditation status
Third party servicer contracts
Administrative software utilized
Program Participation Agreement (PPA) and Eligibility and Certification Approval Report (ECAR)
Financial statements for past two years
Campus security report
Catalog
Consumer information

9. Helpful Hints
Ask for requests in writing or confirm understanding in writing for clarity
Keep copies of everything provided: you will look at it again (and again)
Provide a comfortable place for reviewers to work
Respond promptly to requests
Do not answer the “unasked” question
Challenge findings

10. Most Frequent Findings
Verification
Crime awareness reporting
R2T4 errors
Entrance/Exit Counseling
SAP
Student Credit Balance Deficiencies
Missing or inconsistent information in student files
Pell Over/Under payments
Consumer information deficiencies
Lack of administrative capabilities
Some Additional Recent Findings: FWS students paid for time they were scheduled for class OR Documenting Pell recipients’ initial attendance and/or documenting dropping a class and reducing Pell accordingly

11. Next Steps When discussing findings, ask questions if you are unclear
You will have a good sense of what will be shared at the exit interview - prepare those who will attend no matter how negative the findings – it is much better to hear it from you first than in a group setting with the reviewers
During review ask for regulatory/statutory citations and make sure you understand how they apply to the findings
Make sure you keep all reviewed materials together to ensure you know what reviewers saw at the time of the review
Prepare your answers to the findings
Create priority list for implementation of correcting findings
Create an implementation timeline

12. Contact Information
Mary Blizzard
Stephany Harper