1. The Auditors are coming! OH My! Help me prepare!
Shannon Crossland-Texas Tech University
Delisa Falks-Texas A&M University
Texas Association of Student Financial Aid Administrators

2. Topics Types of Audits and Reviews Possible Triggers
How to proactively prepare
What to do when you have been selected
What to expect
You are not alone!
Texas Association of Student Financial Aid Administrators

3. Types of Audits
Audit of federal programs (Pell, Supplemental Opportunity Grant, Direct Loans etc..)
Program Review-completed by The Department Of Education
A-133 Circular Audit-completed by State Auditor’s Office or an independent audit company
Audits can be a full scope or a limited scope audit, or particular to one specific aid program
Texas Association of Student Financial Aid Administrators

4. Other Audits
Audit of state programs (Texas Grant, Texas College Work Study etc..) the auditors will be with the Texas Higher Education Coordinating Board-THECB)
Audit of Veteran benefits(Federal-Veteran Affairs Office, Hazelwood- Texas Veterans Commission
NCAA Audit-conducted by NCAA staff
Audits performed by your university audit team
Texas Association of Student Financial Aid Administrators

5. Type of Audit What is a full scope audit?
What is a limited or focused audit?
Texas Association of Student Financial Aid Administrators

6. Commonalities amongst all audits
Notifications sent to the university-any one or both of the following:
Director of Financial Aid
President of the University
University Audit Office
These notifications can be a letter in the mail, or an and in some instances the initial contact can be a phone call.
Texas Association of Student Financial Aid Administrators

7. Possible Triggers
Significant changes in Direct loan or Pell grant volume
Significant increase in professional judgments
Deficiencies reported by state licensing or accrediting agencies
High withdrawal rates
Repeat findings or recurrent problems
Complaints from students
Have not had a review in a number of years
For many schools in Texas, an A 133 audit will happen each year due to the Department of Education regulations regarding audits
Texas Association of Student Financial Aid Administrators

8. How do we begin to prepare?
Know any new regulations and/or changes in regulations and implement those changes when they come out
Always ensure that all Policies and Procedures are up to date
Establish a timeline and stick to it for review of all policies annually
Ensure that the financial aid staff is aware of all policies and procedures and follows them exactly
Train your staff-conferences, regional trainings, web based training, workshops
Procedures manuals
Texas Association of Student Financial Aid Administrators

9. Documentation is Key!
Ensure there is proper documentation for a students file
Ensure staff follows procedures established in the office
Incorporate internal reviews to ensure processes are documented
Texas Association of Student Financial Aid Administrators

10. Quality Checks in our office annually
Randomly have files pulled for review for errors
This could save you from audit findings
We are all busy, however a little prevention goes a long way
What to review
Did your team member follow procedures?
Is all required documentation in the student’s file?
Are all forms signed?
Can you determine what was done and why by the team member?
Establish some reports to help you?-EX: students who have no Pell but have an FSEOG award
Example quality checks
Texas Association of Student Financial Aid Administrators

11. Preparing!
Auditor(s) will send in advance information that you need to provide them prior to their arrival.
Provide space where the auditors can work while on site
In some cases you may need to provide computers
Request access to computer systems they will need in advance of their arrival
Financial Aid Management System
Imaging System
Begin pulling files they have requested, review what you have pulled to see if there is any potential findings they may uncover
Whoever pulls the files and reviews should report any issues they find to the Director immediately
Texas Association of Student Financial Aid Administrators

12. Things you need to have ready!
Always ensure your Program Participation Agreement(PPA) and Eligibility and Certification Approval Report(ECAR) is update to date and you have a copy available
Review prior audits
Corrective actions plans from prior audit, did you take the corrective steps
What procedures are in place?
Texas Association of Student Financial Aid Administrators

13. Resources available to help you!
Ifap.ed.gov
Ed.gov
Nasfaa.org
Finaid.org
Texas Association of Student Financial Aid Administrators

14. Additional tools! Federal Student Aid Handbook Dear Colleague Letters
Federal Registrars
Code of Federal Regulations
Federal Student Aid Assessment Tools
NASFAA Self-Evaluation Guides
NASFAA Policy Builder
NASFAA Compliance Engine
Texas Association of Student Financial Aid Administrators

15. When you get selected! Do not panic!
Auditors are there ultimately help
Read anything they send to you carefully
Notify senior campus officials immediately
Discuss with your team
Texas Association of Student Financial Aid Administrators

16. When you get selected! Sample checklist
Notify Clearinghouse of Audit dates
Book Conference Room
Disclosure One-Pager (Staff changes; known issues, etc)
Reserve Work Space
Notify Pertinent Parties
Chief Auditor, Dr. Logan, Registrar, SBS, Accounting Services
Notify Staff
See Prior Year Notices in
IT Support
FAMS Access
Login
Parking
Detail and Demo Application Controls sample for all involved prior to arrival of SAO on campus.
Entrance Conference
Exit Conference
Guest Wireless Account
Texas Association of Student Financial Aid Administrators

17. Who needs to know that an audit is scheduled on your campus?
The President of the University
The University Audit Office
The Director of Financial Aid
The Financial Aid Staff
Registrar Office
Bursar Office
University Accounting
Texas Association of Student Financial Aid Administrators

18. Documents you will most likely provide
Policies and Procedures manual
Specific policies requested
Cost of Attendance(budgets)
Organizational charts for Financial Aid, Admissions, Registrar
Risk management document
PPA and eCAR
FISAP
Third Party contracts
Disclosures
Texas Association of Student Financial Aid Administrators

19. Entrance Meeting
Typically occurs the first date the auditor(s) are on site
Purpose is to understand what will be taking place
Invite all those who will be working with the auditor(s) while they are on site and possibly after they have completed their on site work
Director of Financial Aid
Registrar
Student Business Services(Bursar)
Individual(s) responsible for G5-draw downs
University Internal Audit
Texas Association of Student Financial Aid Administrators

20. Entrance meeting content
Auditors will typically provide an agenda
Introduce their team members and the areas that each of their team members will be reviewing:
Audit objective and scope
Planned Audit work
Audit timeline
Possible finding classifications
Other matters pertinent to the audit
Questions on fraud
Texas Association of Student Financial Aid Administrators

21. What is it like working with an auditor?
Expect a lot of questions.
Questions do not automatically mean something is wrong
When the auditor send you something to review
Take your time and review what they are asking
Make sure you have thoroughly reviewed what they sent you, review your policy and be ready to answer their questions
When you have the explanation get back to the auditor
What if they find something?
Review and ensure it is a finding.
If it is acknowledge and if you can resolve it immediately do so
Texas Association of Student Financial Aid Administrators

22. What is it REALLY like!
Texas Association of Student Financial Aid Administrators

23. Samples they will most likely want
Return of Title IV
Verification
Satisfactory Academic Progress
NSLDS – Enrollment Reporting
COD – Pell and Direct Loan
Reconciliations
Texas Association of Student Financial Aid Administrators

24. During the Audit or Review
Listen to what you are being asked
Understand what you are being asked
Respond
Be Cooperative
Be Honest
You may have findings that you disagree with, that is okay
Explain why you disagree and provide documentation to support your disagreement
Texas Association of Student Financial Aid Administrators

25. Most Common Findings
Enrollment Reporting (outside of reporting time frames)
Return of Title IV (use of incorrect dates, miss entering of dates, late return of funds)
Verification (transposition of numbers, including household members who should not be in the HH, unsigned documents, incorrect documentation used per your policy)
Not following your written policies and procedures
Repeat findings or failure to take corrective action from previous audits
Texas Association of Student Financial Aid Administrators

26. Exit Conference! It’s over!
Listen to the debriefing to ensure you understand what findings they have
Do you agree or disagree with the findings?
Include the offices in which the findings are in relation to
See clarification where needed
Ensure they have disclosed all findings they have at time of the Exit Conference
Ask questions if you need to
Establish the timeframe in which you would like status updates
Determine next steps
Next stats update
Responding to findings
Review of your policies in procedures for updates needed
Establish corrective action plan and how, when to implement
Texas Association of Student Financial Aid Administrators

27. Responding to a finding
Read and fully understand the finding
Respond with action that will be taken and when as well as who is the responsible person for that particular finding (could be the Director of Financial Aid and the Registrar)
Ensure internally you make necessary changes as soon as possible
If you do not believe there is a finding, indicate the schools position
Include finding, issue being disputed and include regulatory citation
Remember they are not always right
Make use of your university or colleges internal audit office or legal counsel if you need to
they can review the findings and review your responses before you send them to the auditor
Know your appeal rights if necessary
Texas Association of Student Financial Aid Administrators

28. Make sure you take action!
If you have findings-make sure you follow your corrective action plan
What can help you in the future?
Training-conferences, workshops, webinars
Review of NASFAA daily updates(if you are a member)
IFAP!
Network!
Texas Association of Student Financial Aid Administrators

29. You are not alone! Reach out to your colleagues!
There are many of us that have gone through MANY audits and program reviews.
We can help!
Texas Association of Student Financial Aid Administrators

30. Texas Association of Student Financial Aid Administrators

31. Thank you! Shannon Crossland-Shannon.Crossland@ttu.edu
Delisa