1. Financial Aid Forensics Top Audit Findings Expose the Hidden Liabilities in Your Institution 44 th Annual EASFAA Conference May 16-19, 2010 Susan ProulxSheri Gonthier Director of FA ComplianceDirector of Financial Aid Community College SystemNHTI-Concord’s Of New HampshireCommunity College

2. Financial Aid Forensics Top Audit Findings  Presentation will be provided electronically on the EASFAA website…

3. Presentation Goals…  Put together a Compliance Committee  Discover tools to help uncover hidden liabilities  Develop your own internal review plan

4. Presentation Goals…  Review top audit findings  Create a corrective action plan

5. Compliance Committee  Put together a Compliance Committee consisting of at least the following members: FAO Registrar Bursar/Student Account Office Admissions Academic Affairs Student Affairs IT

6. Compliance Committee  Meet every other week for the first 6 – 12 months - monthly thereafter  Develop a list of topics to discuss Currently existing issues (including audit findings) Upcoming changes to regulations Solicit topics from other departments Topics will emerge as the group continues to meet

7. Compliance Committee  Allow time for each department to update the committee about what is going on in his/her area Provides an opportunity to discover activities in other departments that may have an impact on Financial Aid Maintains the opportunity for discussion Provides time for regulatory training moments

8. Compliance Committee…also:  Sets the foundation for future collaboration with other departments  Keeps continued focus on Title IV federal requirements  Promotes the institutional responsibility for financial aid

9. Goals of the Compliance Committee  Help ensure institutional compliance  Re-enforce the institutional responsibility of FA – all departments have compliance officers  Uncover hidden liabilities within your institution  Develop stronger partnerships with essential departments

10. Every Enrollment Period  Double Review Process Create a policy and procedure to perform:  Secondary review of verification, prior to disbursement when possible  Secondary review of R2T4 (including NSLDS check) prior to returning aid

11. Secondary Review of Verification

12.  Use FAA Access to CPS On-Line Calculate and Manage your Return of Title IV Funds Secondary Review of R2T4

13. Goals of Enrollment Period Review  To discover issues before they grow exponentially If there is a systemic problem, this provides you with the opportunity to develop a Corrective Action Plan, adjust your policies/procedures, and retrain your staff  To give the FAO time to correct the problem before the student leaves your institution

14. Compliance Department  Performs a sample review of verification and R2T4s  Performs a review of NSLDS  Coordinates corrective action for any audit findings

15. Alternative to Secondary Review  If your office is too busy to do a full secondary review… Perform a mini audit before the end of the enrollment period  Remember…if you begin to find a significant number of issues, it would be best to utilize the Double Review Process

16. Mini Self Audit  Select a small sample of verified files Review student eligibility Review verification Review the award Review disbursed aid amounts  Select a small sample of students who withdrew from the semester or institution Review R2T4 process Review NSLDS reporting  Make corrections to files  Make adjustments to policies and procedures as necessary  Train FAO personnel

17. Annually…  Perform an internal compliance review to determine if there are any errors that can be corrected prior to the A133 review or before the aid year closes Use the list of Common Findings and previous A133 results to develop focus areas If you have a Corrective Action Plan in place, test to ensure that your office is complying

18. Goals of Annual Review  Discover hidden issues Be aware of the areas that may be problematic in an A133  Provide time for the FAO to develop a corrective action plan, correct the problem and be ready for the auditors

19. Common Findings  Late Refund/Return to Title IV Account  Incorrect Return of Title IV Funds Calculation  Entrance/Exit Counseling Deficiencies  Enrollment Report (SSCR) Issues  NSLDS dates – inaccurate/untimely  Repeat Finding-Failure to Take Corrective Action  Auditor Opinion Cited in Audit

20. Common Findings Student Credit Balance Deficiencies Verification Violations Pell Over/Under Payments PPA issues FISAP Cost of Attendance Cod Reporting Student Loan Notification Letters

21. More Common Findings  Crime Awareness Requirements Not Met  Consumer Information Requirements Not Met  Lack of Administrative Capability  Inaccurate Recordkeeping  SAP Policy Not Adequately Developed/Monitored

22. More Common Findings  Improper/Undocumented Dependency Overrides  Ineligible Pell Disbursement  Information in Student Files Missing or Inconsistent  Cash Management/Timeliness of Draw Downs

23. Develop a Corrective Action Plan  A Corrective Action Plan must describe the corrective action taken or planned in response to findings identified and the timeline for correction.  Once an issue has been identified, either though an A133 or your own FA Forensics plan, develop a plan to correct the problem and ensure that it does not occur again.

24. Corrective Action Plan  Schedule a meeting Bring together all who impact or are impacted by the issues Include IT if the solution will require system changes/enhancements  Meet Lay out the problem and explain why it is an issue Explain the regulation that must be met Brainstorm a solution

25. Corrective Action Plan  Document the solution  Implement the solution  Test the implemented solution  Conduct a follow up meeting to make any necessary adjustments  Be sure to test this area in next year’s annual internal review audit

26. Resources  Peers  IFAP website  FSA Assessment  NASFAA Self Evaluation Guide  Office of Inspector General – Specific Guidance for SFA Audits  A-133 Compliance Supplement  Annual Auditor Training Conference, for example:

27. Discussion Share your successes What have you implemented at your school to ensure that your institution is compliant? How did you create an institution-wide compliance team? Anything you would like to share with the group? Any problems/questions to bring to the group?

28. Contact Information Susan Proulx(603) 219-0031 Director of Financial Aid Compliance Community College System of New Hampshire sproulx@ccsnh.edu Sheri Gonthier(603) 271-7136 Director of Financial Aid NHTI – Concord’s Community College sgonthier@ccsnh.edu