1. Catherine Boscher-Murphy
COMPL ANCE
ACADEM CS
Catherine Boscher-Murphy
NJASFAA Conference 2019

2. Question:
Is the academic side of your campus in compliance with Title IV regulations?
Do they consider how their policies and decisions impact financial aid?
Areas of Compliance

4. Consumer Information Responsibility
Annual disclosures:
Who is responsible for ensuring all required academic information is published and available?
Each academic department? Provost? Legal Counsel?

5. Generally Available – Academic Info
Academic Disclosures
Accreditation and Licensure
Academic Program Information
Gainful Employment
Placement and Retention Rates
Transfer Credit Policies
These are the obvious areas that the academic side will manage and control
Facilities and instructional personnel
Arrangements with other schools
Graduation and transfer-out rates
Graduation or professional education of four-year graduates
These are pretty clear cut.

6. So how does the Academic side fit with Title IV beyond these areas?
Let’s look at several areas where financial aid for a student is impacted by a policy or decision on the academic side

7. SAP
SAP policy must be as strict or stricter than the Academic Standing Policy
Is a 2.0 required?
Does your campus have an academic amnesty policy?
Replace an ‘F’ grade with a better one earned on a retake
There is NO academic amnesty for SAP
Calculate an FA GPA vs. institutional GPA
Let’s begin with the most obvious area
Watch the college academic standard if you want to use a graduated GPA

8. This policy can make a big difference in SAP standing:
Susie has:
Fall term:
BIO 101 = F
ENG 201 = C
MTH 101 = C
Spring term:
BIO 101 = C (college replaces the F grade)
PSY 201 = B
MTH 102 = C
Inst GPA = FA GPA = 1.83
Also applies to that student who attended your institution 20 years ago and the Dean or Provost says ‘We won’t count those courses, it was so long ago…’
While you must include all courses in the calculation of SAP, you can deal with the circumstance through the appeal process.

9. What about other grades?
If a student has an INC, how do you treat that in SAP?
When does faculty have to turn the INC into a grade?
Does it turn into an F automatically? When?
Must revisit SAP status for that student when the grade is finalized
Deadlines to submit grades

10. What about the Academic Plan?
Is the advisor, faculty member helping select the correct courses?
Does your institution have a policy that allows for a reduction in credits to help get a student back on track (e.g. 6 not 12)?
Do the advisors apply that?

11. Enrollment Reporting Definition of full-time for graduate students
Thesis and dissertation
Study Abroad/Consortium
Do you have varying credits for the same class
How does student get the larger credit load?
Do they pay for that?
Forced full-time – can designate a credit load based on amount of work/time spent on the thesis
Place holder for study abroad and consortium

12. Gainful Employment
Must prominently display on the main page for EACH GE program
Department updates to website
Does this information get deleted
Is the system coded correctly and consistently to pull information for submission to USED?
Major, minor, attributes, etc.
Requirement to have appropriate information or URL’s on all promotional information by ( (d) and (e)

13. Gainful Employment
Do you provide all applicants the required disclosures?
Hand delivery in person or direct with only the GE info as content
Must get receipt from
Must include template
Cannot link to URL

14. Disbursement of Aid Federal –
Required to verify student has begun in classes before disbursing aid
How do you do this?
Faculty verification of attendance in at least one class session

15. Disbursement of Aid Federal –
Do you use a census date after which you will not revise enrollment status (frozen date)
Typically after Add/Drop
If so, only the courses that are ‘frozen’ on the census date can be paid
Students who add courses later lose out on those
Do your faculty know this? We have many faculty who will ‘advertise’ a late starting module class on and web…
Does your system handle this? We have a built-in conflict with our attendance verification – updates override

16. Disbursement of Aid Modules –
If a student is enrolled in a Sept. class and a Nov. class, you can disburse aid once the September class begins
You are required to go back at term’s end to make sure the student began that second module
Cannot pay when a student adds a second modular course after the census date
Unless you have multiple census dates in term

17. Scholarships
Are all outside scholarships accounted for as aid or a resource
How are internal scholarships handled
Is there a vetting process
Do these go through a foundation
Processed by financial aid, student accounts, other office
Departmental scholarships
Stipends, waivers, etc.
Scholarships invented by faculty members
One-offs or more common

18. Study Abroad Does not have to be a required part of program but,
Credits earned must apply toward graduation credits at home school
Do you disburse within regulations based on calendar for the Study Abroad program?
Not your regular calendar

19. Study Abroad
Do you check to make sure the credits/grades from the semester abroad are sent to the college?
Must receive the transcript in order for student to keep their aid
What is your deadline for this?
Are you informed if the student totally withdraws from their program?
Must perform an R2T4

20. Consortiums Do you have a written agreement for these?
Blanket with another school
Individual by student
Are courses applicable to degree program?
Include credits in attempted for SAP
34 CFR – written arrangements
Place holder in system? Impact enrollment reporting

21. Admissions Cycle
Have you considered revising your policy related to incoming fall students
With year round Pell, student can matriculate in summer and receive aid
Consider if summer is header or trailer
FAFSA filed within deadline
Transfers, EOF, special programs

22. Website Is your website ADA compliant? Do all pages meet criteria?
Typically belongs to IT or the webmaster
Do all pages meet criteria?
Who has rights to make revisions
50 Colleges Hit With ADA Lawsuits – Inside Higher Ed 12/10/18

23. E-sign and Electronic Notification
Do you annually notify students about how the college will provide information?
Must give students the opportunity to opt out
If they opt out, are you prepared to provide paper notices
How are you informed of this?

24. GLBA/Red Flag - New Emphasis
Program Participation Agreement (PPA) has been updated recently to require that all IHEs be compliant with Gramm-Leach-Bliley Act (GLBA)
Also reflected in the Federal Student Aid Handbook
Act requires “financial institutions” to ensure the security and confidentiality of customers’ personal information
Colleges and Universities are considered financial institutions under the Act
Are you prepared?

25. GLBA/Red Flag - New Emphasis
Will be tested on the FY19 A-133 Audit
Are you prepared?

26. What Happens if Non-Compliant?
ED may perform a program review if it determines the school may be at risk for failing to comply with any Title IV provisions
no published guidance regarding the criteria ED uses to select the initial award year(s) under review and the triggers for expanding that timeframe

27. Are We a Team?
Regardless of role, compliance is everyone’s responsibility

28. How Can We Improve Compliance?
Get buy-in from higher-ups
Map out annual communication plan for planning/future reference
Utilize legal counsel on campus
Work with Faculty Council

29. How Can We Improve Compliance?
Hire a compliance person for office or campus
Assemble a team to meet regularly
Institute cross department meetings with the major partner offices
Deans, Chairs

30. How Can We Improve Compliance?
Identify areas of weakness
Do a self evaluation
Review policies
Educate, educate, educate—and explain the why
Provide information to support your statements/requests
Update other offices in a timely manner about changes

31. Resources to Review NASFAA Self Evaluation Guide
Policies and Procedures Tools
AskRegs and Knowledgebase

32. Other Resources NASFAA SOE Peer Review Federal Program Review Findings

34. Contact Info
Phone: