NYSFAAA Leadership Preparation

Program Reviews October 16, 2015Thomas J. Dalton

Assistant Vice-President, Enrollment Management

Excelsior College

What is a Federal Program Review?

Method of oversight Evaluates compliance with Title IV, HEA statute

and regulations Examination of financial aid, fiscal and academic

records Interviews with institutional staff and students Review of consumer information requirements

Identifies errors in compliance and liabilities owed

Tool to improve future institutional capabilities

How Are Institutions Selected?

20 U.S.C. 1099c -1 (a)(2): (The Secretary) shall give priority for program review to institutions of higher education that are institutions with:

High cohort default rate or dollar volume of default (25%+) Significant fluctuations in Federal Pell Grant or loan volume Reported deficiencies or financial aid problems by state or

accrediting agency High annual dropout rates, or Any other institution the Department determines may pose

significant risk of failure to comply with administrative capability or financial responsibility requirements

Institution Preparation for Program Review

Receiving Notification of Program Review

Advance Notice Review

Short Notice Review

Third-Party Servicer Notification

Responding to Announcement Letter

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Excelsior's Federal Program Review Timeline

February 10, 2015 – Notification from DoE Required Deadlines:

February 17, 2015 – Consumer Information and Disclosures

February 18, 2015 – Data Requests February 23, 2015 – Outstanding Items March 2, 2015 – Records and Documentation

available for Review

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Entrance Meeting

Introductions DoE will explain the process Issue the sample to be reviewed

15 – 20 students in FY 2014 15 – 20 students in FY 2015

Review will look at ALL areas of the College – will last 5 days

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Areas of Focus During the Review Specific to Excelsior College

The regular and substantive interactions between faculty and students

Dropout rate Return of Title IV Student Authentication @ time of

Enrollment The Flow of Money

Review of Institutional Processes and Data

Review Institutional Documents Collected• Catalog/Brochure/Handbook• Policies and Procedures• Published Campus Security Information• Student Consumer Publications• Online Student Consumer Information• Institutional Forms, Applications and

Worksheets

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Review of Institutional Processes and Data

Review of Institutional Critical Elements• Eligible Institution• Administrative Capability• Program Eligibility• Consumer Information• Campus Security• Financial Responsibility• Fiscal Review• FISAP

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Review of Institutional Processes and Data

Staff Interviews• Academic/Registrar• Admissions• Financial Aid• Student Accounts/Bursar/Fiscal Office• Placement• Campus Security

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Review of Student Level Information

Review of Student Critical Elements• Student Eligibility• Attendance• Cost of Attendance• Credit Balances• Enrollment Status• Dependency Overrides/Professional Judgment• Return of Title IV• Satisfactory Academic Progress• Verification• Calculations/Disbursements

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Review of Student Level Information

Records Reviewed in Student Files Admissions Academic Financial Aid Student Account Ledger

Student Records Compared to Department Data NSLDS COD CPS

Student and Staff Interviews

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Exit Meeting

Same representation as Entrance Meeting DoE will present any “Findings” Typically they won’t tell you what you do

well! DoE will identify any outstanding items DoE will describe the process for appeal DoE may request additional information

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What happens after the onsite visit?

DoE will issue a “Final Determination Letter” in 3 to 6 months

Your institution will have 30 days to appeal any finding

If your institution agrees with the findings – you will have 30 days to submit a “Corrective Action Plan” and repay Federal funds back if they are due

Final Program Review DeterminationLetter (FPRD)

Department’s final determination for each finding Identifies liabilities and provides payment

instructions Closes Program Review, if appropriate State authorizing and accrediting agencies

receive copies Subject to FOIA Two types:

No further action required Further action required

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Final Program Review Determination Letter (FPRD)

Standard sections• Cover page• Table of Contents• Institutional Information• Scope of Review and Disclaimer• Findings and Final Determinations• Summary of Liabilities• Repayment Instructions• Appendices and Enclosures

• Sample template in Program Review Guide

Top Audit Findings

1. Repeat Finding – Failure to Take Corrective Action

2. NSLDS Roster Reporting – Inaccurate/Untimely Reporting

3. Return of Title IV (R2T4) Calculation Errors

4. R2T4 Made Late

5. Verification Violations

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Top Audit Findings

6. Pell Overpayment/Underpayment

7. Student Credit Balance Deficiencies

8. Entrance/Exit Counseling Deficiencies

9. Qualified Auditor’s Opinion Cited in Audit

10.G5 Expenditures Untimely/Incorrectly Reported

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Top Program Review Findings

1. Verification Violations

2. Return of Title IV (R2T4) Calculation Errors

3. Student Credit Balance Deficiencies

4. Entrance/Exit Counseling Deficiencies

5. Crime Awareness Requirements Not Met

6. Satisfactory Academic Progress Policy Not Adequately Developed/Monitored

Top Program Review Findings

7. NSLDS Roster Reporting – Inaccurate/Untimely Reporting

8. Inaccurate Record Keeping

9. Drug Abuse Prevention Program

10.Requirements Not Met

11.Consumer Information Requirements Not Met

12.Return of Title IV (R2T4) Made Late

Findings on Both Lists

1. R2T4 Calculation Errors

2. Student Status – Inaccurate/Untimely Reporting

3. R2T4 Made Late

4. Verification Violations

5. Student Credit Balance Deficiencies

6. Entrance/Exit Counseling Deficiencies

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Resources on IFAP

http://ifap.ed.gov/programrevguide/2009ProgramReviewGuide.html

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QUESTIONS?

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