1. Policy and Procedure Manual
2018 MSFAA Summer conference
Bernice Lindke

2. Why Record Policies/Procedures?
Administrative Capability
Regulatory Compliance
Financial Aid Offices must document how federal regulations are implemented
Reviewed during audits
Establishes history
Reference for practices

3. Office Benefits of a Policy & Procedure Manual
Provides consistency and clarity of functions
Improves accountability
Reduces burden on management
Encourages independence for staff to do their jobs
Helps with training new staff

4. Policy Statement General Brief
Explains why you have the rule/regulation
Identifies who is affected by the regulation
When the rule is applied
What happens if the rule isn’t followed

5. Procedure Elements Explains the actions
What position performs the actions
Timing of the actions
How the actions are applied
Provides examples
Gives specificity
Allows others to understand process and follow steps to perform the function

6. Policy Statement Example
Crystal Mountain College, as a participant in federal loan programs, is required to have a code of conduct applicable to the institution’s officers, employees, and agents. The code of conduct requirements are set forth in the Higher Education Opportunity Act (HEOA) signed into law on August 14, The Code of Conduct Related to Student Loan Activities is a requirement specific to certain transactions and activities related to financial aid matters. In addition, the law includes requirements related to publication of the code and annual disclosures.

7. Procedure Example Code of Conduct
Crystal Mountain College hereby adopts the following provisions from the HEOA, Section 493 as its Code of Conduct Related to Student Loan Activities and will annually inform all institutional officers, employees, and agents with responsibilities for student loan activities and decisions of the provisions of this code.
 (1) Ban on Revenue-Sharing Arrangements  
  (A) Prohibition -- The institution shall not enter into any revenue-sharing arrangement with any lender.
  (B) Definition -- For purposes of this paragraph, the term 'revenue-sharing arrangement’ means an arrangement between an institution and a lender under which –
….Continues on with more specificity

8. Policy Statement Example
Michigan Competitive Scholarship
MCS is available to undergraduate students pursuing their first degrees at an approved Michigan postsecondary institution. The scholarship is based on both financial need and merit.

9. Procedure Example Awarding Procedures:
Prior to the start of the fall semester a batch award is placed for the Fall and Winter semesters for each student that is eligible for MCS. Log into MiSSG. Select MiSSG/Reports/Eligible Students Report. Select the appropriate academic year. Select Michigan Competitive Scholarship for Aid Program then select how you would like the student’s to be displayed. Click “Generate Report”. Save the report as an excel file.
Filter report by Total Award column (smallest to largest). Any student receiving less than the maximum amount ($1000) will need to be manually awarded for each student. Everyone else can be batch awarded for Fall and Winter. For batch awarding to work each SSN will need to be converted to a student ID#.

10. P&P’s Typically Requested in a Program Review
Satisfactory Academic Progress (SAP)
Admissions
Refunds
Return of Title IV Funds
Consumer Information
Verification
Perkins Loan Selection and Awarding of Students
FWS Selection and Awarding of Students
FSEOG Selection and Awarding of Students
*Per FSA “A Guide to Creating a Policies & Procedures Manual”

11. How to Get the Manual Completed
Assign Topics to Staff based on
Job responsibilities
Or, use a team approach
Policy and Procedure Templates on the Web
FSA Assessment for Schools
A Guide to Creating a Policies & Procedures Manual
NASFAA Compliance Tool
Step by step guidelines
Contains Title IV regulation references
Kept in secure place for future updates

12. Don’t Reinvent the Wheel!
Many examples of great policies/procedures available on the web
These are public documents that can be used to develop your Policies/Procedures
Examples:
Student Loan Code of Conduct
Satisfactory Academic Progress Policy
Just edit for your campus’ unique practices and reflect how the policies are enforced
When in doubt, ask permission

13. Formats Used
Paper
Website
Shared Network
Other

14. Words of Wisdom
If you have a written Policy and Procedure, you must follow it.
If you’re doing something else, stop it, or
change your P&P.

15. Caution
Potential problems if you don’t follow your Policy and Procedures
Audit and/or program review findings
Fines and penalties assessed to your institution
Bad press, depending upon severity of the issue
Lower student enrollment
Loss of Title IV eligibility (in very severe cases)

16. Questions?