preparing for an audit or program review april 17, 2011 © 2011 global financial aid services 1

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Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

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Page 1: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

Preparing for an Audit or Program Review

April 17, 2011

© 2011 Global Financial Aid Services 1

Page 2: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

Agenda

» Types of Audits » What to Expect During an Audit?» What will Auditors Request?» Resolving Findings & Corrective Action» How to Prepare?» Common Findings

© 2011 Global Financial Aid Services 2

Page 3: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

How to Prepare?

© 2011 Global Financial Aid Services 3

What types of audits are there?

Page 4: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

Types of Audits/Reviews

» A-133» Public & Non-Profit Institutions» Single Audit Act» OMB Circular A-133

» FSA Audit» All other Institutions (For-Profit)» Audit Guide

» Federal Program Review

© 2011 Global Financial Aid Services 4

Page 5: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

Compliance Audit

» Compliance Audit

» Annual audit of the school’s compliance with the laws and regulations that are applicable to the FSA programs in which the school participates

© 2011 Global Financial Aid Services 5

Page 6: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

Financial Statement Audit

» Financial Statement Audit

» Annual audit of the school’s financial statements

© 2011 Global Financial Aid Services 6

Page 7: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

How to Prepare?

© 2011 Global Financial Aid Services 7

What should I expect during an audit?

Page 8: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

The Audit Process

» Entrance Conference» Auditors Analysis» Exit Conference» Final Report» Corrective Action Plan

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Page 9: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

Before They Arrive

» Notify Leadership & Relevant Depts.» Retrieve & Send Requested

Information!» Set Expectations» Notify IT if Access to SIS is Required

» Ensure Auditors will have Access Timely» Set Access Appropriately

» Designate a “Point Person”

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Page 10: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

Entrance Conference

» Include Relevant Departments» Financial Aid, Student Accounts, IT» Registrar, Admissions, Student

Employment

» Introduce the “Point Person”» Designate a quiet work area» Train on the Student Info System

» Provide Instructions» Explain File Retrieval Process

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Page 11: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

How to Prepare?

© 2011 Global Financial Aid Services 11

What documents willthe auditors request?

Page 12: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

Document Requests

» Policies & Procedures Manual» Sample FSA Forms» Catalog» Cost of Attendance Budgets» FISAP» SAP Policy» Pell Account Information

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Page 13: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

Document Requests

» Refund Policy» Return to Title IV Process» ISIRs for Sample» Documentation of Cash Management» PPA & ECAR» Latest Accreditation» Software Used» Campus Security Report

© 2011 Global Financial Aid Services 13

Page 14: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

How to Prepare?

© 2011 Global Financial Aid Services 14

What will the auditors ask?

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Anticipate Common Questions

» Who monitors disbursements?» Who tracks withdrawals?» Who tracks changes in Enrollment Status? » Who performs Return to Title IV?» Who updates the Policies & Procedures?» Who ensures aid is properly disbursed?» Who ensures Verification is complete?

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Page 16: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

Exit Conference

» Include Relevant Departments»Financial Aid»Student Accounts»Registrar»Student Employment» IT etc.

» Listen to Results» Ensure All Findings are Discussed» Ask Questions to Prepare for Response

» Discuss Next Steps and Timing© 2011 Global Financial Aid Services 16

Page 17: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

Respond to Findings

» Do you Agree with the Finding?

» If Yes, take Corrective Action» Resolve findings as quickly as possible» Modify P&P Manual as needed» Communicate to Affected Departments» Conduct Training on Changes

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Page 18: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

Respond to Findings

» Do you Disagree with the Finding?

» It is Okay to Disagree» Check the Regulations» Consult with Trusted Peers» Respond with your position

» Include details outlining your issue» Include reference to Regulations

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Page 19: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

Corrective Action Plan

» Written Plan» Outlines steps to resolve issues» Identify the Finding & Resolution

» Follow the CAP» Develop/Refine Procedures» Assign Responsible Parties

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Page 20: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

How to Prepare?

© 2011 Global Financial Aid Services 20

How to Prepare?

Page 21: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

How to Prepare

» Good Inter-Office Communication

» If Processes, Policies, Systems Change» Set a Meeting, Huddle, Let Everyone Know» Explain the implications of changes

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Page 22: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

How to Prepare

» Keep Your Files Organized & Consistent

» Paper Files» Group by Award Year» Checklist Cover Letter» Notes

» Electronic Files

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Page 23: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

How to Prepare

» Keep Your Policies & Procedures Current

» Schedule Periodic Check Points to Update» Test Procedures to Ensure they Work!» Verify Staff is following Policies

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How to Prepare

» Strengthen Internal Controls

» Assign Responsibilities

» Create Checks and Balances

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Page 25: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

How to Prepare

» Leverage Student Information System» Run Reports» Check for Anomalies» Cross Check with Other Departments

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Page 26: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

How to Prepare

» Invest in your staff» Online Training» Conferences» Workshops» P&P Manual Training» NASFAA CORE» FSA Coach

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Page 27: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

How to Prepare

» Internal Audit» Manage Institutional Risk» Test Compliance Activities» NASFAA Self Evaluation Guide

© 2011 Global Financial Aid Services 27

Page 28: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

How to Prepare?

© 2011 Global Financial Aid Services 28

Most Common Findings?

Page 29: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

10 Most Common Audit Findings

1. R2T4 Calculation Errors2. Pell Overpayment/Underpayment3. Late Return of Title IV Funds4. Verification Violations5. Overaward- Financial Need Exceeded

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Page 30: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

10 Most Common Audit Findings Cont.

6. Return of Title IV Funds Not Made7. Enrollment Status not Verified prior to

Disbursement8. Improper certification of Stafford Loans9. Student Credit Balance Deficiencies10. Ineligible Student- Not Meeting SAP11. Repeat Finding- failure to take

Corrective Action

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10 Most Common Program Review Findings

1. Verification Violations2. Crime Awareness Requirements Not

Met3. Student Credit Balance Deficiencies4. Return to Title IV Calculation Errors5. Return of Title IV Funds Made Late

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Program Review Findings

6. Entrance/Exit Counseling Deficiencies7. Account Records Inadequate/Not

Reconciled8. Information in Student Files

Missing/Inconsistent9. SAP Policy not Adequately

Developed/Monitored10.Pell Overpayment/Underpayment

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Page 33: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

Findings on Both Lists

1. Verification Violations2. Return of Title IV Funds Made Late3. Return of Title IV Calculation Errors4. Pell Grant Over/Underpayments5. Student Credit Balance Deficiencies6. Satisfactory Academic Progress Issues

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Page 34: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

How to Prepare?

© 2011 Global Financial Aid Services 34

Let’s Review

Page 35: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

Let’s Review!

» Types of Audits » What to Expect During an Audit?» What will Auditors Request?» Resolving Findings & Corrective Action» How to Prepare» Common Findings

© 2011 Global Financial Aid Services 35

Page 36: Preparing for an Audit or Program Review April 17, 2011 © 2011 Global Financial Aid Services 1

Jeff ScofieldDirector of Financial AidUniversity of Hawaii- Hilo

[email protected]

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Chesa StanfieldDirector of Solutions

Global Financial Aid [email protected]

© 2011 Global Financial Aid Services 37