1. Compliance Across Campus
Catherine Boscher-Murphy
NJASFAA Conference
March 2018

2. Goals of this Session Who are your campus partners?
What are the most common compliance issues across campus?
What areas of Title IV regulations intersect with other areas on campus?
How do you communicate with other offices about TIV?

3. Campus Partners Obvious ones: Bursar/Student Accounts Admissions
Registrar
EOP
Athletics
Security/Campus Police

4. Campus Partners Less obvious ones: Advising Residence Life Provost
Professional
Faculty
Residence Life
Provost
Foundation Office
IT and Institutional Research

5. Most Common Compliance Issues
Audit findings:
#2: R2T4 calculation errors
#3: Missed R2T4 deadlines
#4: Inaccurate/untimely student enrollment reporting
#6: TIV Credit balance deficiencies

6. Most Common Compliance Issues
Program Review findings:
#1: Crime Awareness requirements not met
#3: R2T4 calculations errors
#5: TIV Credit balance deficiencies
#6: SAP policy not developed/monitored
#7: Missed R2T4 deadlines
#8: Lack of administrative capability
#10:R2T4 refunds not made
#13:Consumer information requirements not met

7. How Do We Intersect?
Who do we have to play nicely with in the sandbox?

8. R2T4 calculations Who identifies the students to calculate?
Identify on system? Provide list?
Registrar
Student Affairs
IT department
Who has responsibility for the calculation?
Bursar
Financial Aid
What tool do you use?
Federal refund formula
System provided module
Test your system against the federal one
If you use the federal one, reduces likelihood of being cited for a calculation error
If the calculation is done by a different office, who revises the financial aid awards
Who returns the funds?

9. R2T4 calculations
If the Financial Aid Office is not responsible, is the other office aware of the timeline and deadline requirements?

10. Enrollment Reporting Who has responsibility? What tool do you use?
Registrar
Financial Aid
What tool do you use?
Clearinghouse
NSLDS reporting
Is this automated?
Are you using the correct stat us codes?

11. TIV Credit Balances Who has responsibility?
Student Accounts
Finance
Financial Aid
Are the deadlines being met?
Disbursement
Credit balance calculations
Refunds to students
How do you do this?
Direct Deposit
Paper check
Debit card
Non-compliant holding of Title IV balances – during year; at end of year

12. Crime Awareness Who has responsibility?
Campus Police
Student Affairs/Student Life
Financial Aid
IT/Communications
Have you defined your geography/property?
Are the statistics being kept?
Crime Log
Fire events
Crime Statistics
Emergency warnings
Missing student policy
Do you get input from local jurisdictions for adjacent properties?

13. Crime Awareness
Is your campus correctly identifying the type of crimes on campus
Number and type of incidence
New definitions
VAWA
Do you collect information from local agencies?
Are the necessary security report notifications being sent?
notification
Paper copies available
Discrepancies between what is posted on website vs. what is submitted to ED

14. SAP Who has responsibility? Do you have policies?
Financial Aid
Registrar
Advising
Do you have policies?
Do you follow your policies?
How do you identify students?
Lists from IT
Does your policy cover all the required components?
qualitative
quantitative
progression
max. time frame
Do you address repeat courses? Probation? Appeals?
No academic amnesty for SAP

15. SAP Who notifies student? Who collects appeals? Who approves appeals?
Financial Aid
Registrar
Advising
Who collects appeals?
Who approves appeals?
Single person
Financial Aid Office
Committee with members from campus
Who develops the Academic Plans?
Faculty advisors

16. Administrative Capability
Individual responsible for aid programs
Adequate number of qualified persons
Institutional offices communicate
Establish and maintain records
System to identify and resolve discrepancies
Written procedures
Checks and balances
Ensure separation of duties
1. Is there an individual responsible for administering and coordinating all financial aid programs
2. Does the institution employ an adequate number of qualified persons to administer the Title IV programs?
3. Do institutional offices communicate any information that has bearing on a student’s eligibility for Title IV aid?
Waivers
Scholarships
4. Do you establish and maintain records required under Title IV program regulations?
5. Do you have an adequate system to identify and resolve discrepancies in information received from different sources with respect to a student’s application for Title IV aid?
Do you have mechanisms in place to obtain and review appropriate information
6. Written procedures that indicate the responsibilities of each office regarding the approval, disbursement, and delivery of Title IV assistance, and the preparation and submission of reports to ED?
7. Do you have adequate checks and balances within your system of internal controls?
8. Ensure no one individual or office has responsibility for both authorizing and disbursing or delivering Title IV funds?
Family members on both sides of the aisle?

17. Administrative Capability
Policies in place to contact ED’s Office of Inspector General (OIG)
Provide adequate financial aid counseling to eligible students
Employees available to assist enrolled and prospective students in obtaining institutional and financial aid information
Prohibit bonuses, commissions, or other incentive payment
Demonstrate a level of competency
9. Do you have policies and procedures in place to contact ED’s Office of Inspector General (OIG) when necessary?
10. Do you provide adequate financial aid counseling to eligible students who apply for assistance from the Title IV programs
11. Do you have one or more employees available to assist enrolled and prospective students in obtaining institutional and financial aid information?
12. Do you prohibit bonuses, commissions, or other incentive payment?
13. Do you demonstrate a level of competency necessary to administer the Title IV programs
14. Do you regularly reconcile Title IV funds?

18. Consumer Information Who has responsibility? Is reporting being done?
Are deadlines being met?
Are students being notified?
How?
Consumer Information & School Reports – FSA Handbook, School Eligibility, Ch. 6

19. Consumer Information
General disclosures for enrolled or prospective students
Annual security report and annual fire safety report
Report on athletic program participation rates and financial support data (Equity in Athletics Data or EADA)
FERPA information
Financial aid available
Academic programs, facilities, costs, etc.
Withdrawal procedures
Accreditation and licensure
Disability services and facilities
Transfer credit policies
Copyright infringement
Student Activities, diversity
Net Price Calculator
Shopping Sheet
Completion, graduation, retention and transfer rates
GE disclosures
Campus Crime and Safety
Drug and Alcohol Abuse Prevention
Athletics
Textbooks
Loan Counseling
Private educational loans
Misrepresentation
Anti-Lobbying
Voter Registration
(Family Educational Rights and Privacy Act of 1974, discussed in Chapter 7).
Document dissemination of disclosures

20. Other Areas to Consider
NCAA Reporting
Gainful Employment Reporting
FISAP
Surveys
Tier I and II arrangements
Stale checks – non-escheatment of funds

21. How Can We Improve Compliance?
Hire a compliance person for office or campus
Identify areas of weakness
Do a self evaluation before the feds come to visit
Get buy-in from supervisors in other areas
e.g. attendance from faculty – Provost
Utilize legal counsel on campus

22. Communication Across Campus
Be cooperative
Provide information to support your statements/requests
Update other offices in a timely manner about changes
Institute cross department meetings with the major partner offices
Communications group from across campus of the student touching offices
Systems User Group
Get buy-in from Provost or President (usually have to talk the money aspect here)
How do you connect with other offices?

23. Resources to Review NASFAA Self Evaluation Guide
Policies and Procedures Tools
AskRegs and Knowledgebase
Clery Reporting

24. Other Resources NASFAA SOE Peer Review Federal Program Review Findings
Clery specific PR Findings

26. Contact Info
Phone: