1. Schools How-to Guide to Vendor Oversight

2. A little about CMU 4 year, public university in Grand Junction, CO
10,660 students – 77% traditional & full-time
≈40% Pell Eligible
3 collection phases:
Current student education – 99% collection
Internal collections – 27% collection
External collections – 10.2% collection
4 third-party collection agencies, tax off-sets, rotate agencies each year

3. Step 1: Preform Due Diligence on Yourself
Concept:
Due Diligence: Reasonable steps taken by a person in order to satisfy a legal requirement, especially in buying or selling something.
Gather information from conferences, watch compliance webinars, read through law summaries.
The more you understand and know, the better you’ll be able to monitor your agencies.
How-to:
Takes some time
Research & maintain lists of all higher education compliance organizations.
Start with the Compliance Handout

4. Step 2: Establish Contracts with Compliance Obligations
Concept:
Contracting = RFP > Thoroughly Review Responses >Interview top candidates > Select best fit > Contract
RFP – your chance to set the precedence of the relationship
RFP language = Contract language

5. Step 2: Establish Contracts with Compliance Obligations
How-to RFP: The Basics
Be Clear!
Take time to be sure you have all the pieces
Always check with your purchasing department and any state or attorney requirements
2 main sections – Administrative Information and actual RFP
RFP Example:
Ask for:
Training manual
Description of “best efforts” of collection
Describe customer service philosophy
Complaints, process to resolve
Examples of standard letters/communication
Pending lawsuits against the company
References
Strong Compliance Language

6. Compliance Language Examples
Pursuant to C.R.S through 118 as amended, Offeror must be licensed to conduct business as
a professional collection agency in the State of Colorado. Offeror must submit proof of licensure in the
State of Colorado with their bid response.
Offeror shall acknowledge the privacy rights of educational accounts which are expressed in the Gramm-Leach-Bliley Act, the Federal Family Educational Rights and Privacy Act, the Red Flag Rule and any other applicable State or Federal law related to communications and collections of delinquent accounts. Offeror shall not, under any circumstances, violate any applicable State or Federal law, including Fair Debt Collection Practices Act or violate any guidelines established by the Federal Trade Commission.
Bid response shall provide evidence of compliance with:
1) Family Education Rights and Privacy Act,
2) Fair Debt Collection Practices Act,
3) Gramm-Leach-Bliley,
4) Red Flag Rules
5) Applicable State and Federal laws.
Provide information on agency requirements for the University to adhere to laws and policies surrounding University provided account cell phone numbers.

7. Step 3: Maintain up-to-date copies of service provider policies and procedures
Your RFP and contract should have a clause requiring any major changes to be communicated.
How do you monitor changes?

8. Step 4: Appoint a Relationship Manager
All big questions, complaints, process improvements, and performance analysis goes through Relationship Manager
Example: Collections team = Financial Counseling Manager
Others may upload and compute debt verifications
Deputy Controller
Financial Counseling Manager
Bursar
Financial Counselors
University Cashiers

9. Step 5: Monitor … Daily Communication
Answering Debt Verifications within 24hrs
Giving clear information when placing accounts
Quarterly meetings – see example Meeting Agenda

10. Monthly Collections Collections Rate
Step 5: and Analyze…
Establish solid, consistent reporting numbers to measure performance
Each agency may report their collection numbers differently.
For example:
Monthly Collections
Placement Inventory
Collections Rate

11. Step 5: and Analyze… What do you want to know?
Can you use the reports the agencies give you?
Goal = ensure consistency across all agencies you work with.

12. Step 5: and Analyze… Analyze performance “score card”
Use Excel! It’s Magical.
Considerations:
Math
Total Dollars on all placements vs breaking out 1st/2nd etc.
Giving all statistics to all agencies

13. Step 6: Tier your service providers
What do you consider “successful”?
Consider a score card?
Collection Performance in total – with considerations
Collection performance in 1st placements, 2nd placements, etc – with considerations
Number of complaints

14. Step 6: Tier your service providers
Is competition a good thing?
Our first quarterly meeting was the first week of July 2015
What else can happen when competition is increased?

15. Step 7: Conduct Regular Audits
Concept:
Monitor conduct
Use your gut – all this communication is to lead to a good understanding of the company
Ask for:
Your data
In-person meeting?
Training manual
Description of “best efforts” of collection
Describe customer service philosophy
Complaints, process to resolve
Examples of standard letters/communication
Pending lawsuits against the company
References
How-to:
CMU coming up on 1 year with new contract
Intends on conducting a mini-audit

16. Step 8: Review Service Provider Performance & Hold them Accountable
Remember CFPB Service provider rule.
Analyze problem and determine severity
Performance improvement plan?
Adjust and clearly communicate expectations?
Involve purchasing department for guidance?
Temporarily suspend service until resolved?

17. Lindsey Manning Colorado Mesa University LManning@coloradomesa.edu
Questions? Thank you!
Lindsey Manning
Colorado Mesa University