preparing for an audit or program review april 17, 2011 © 2011 global financial aid services 1
TRANSCRIPT
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
How to Prepare?
© 2011 Global Financial Aid Services 3
What types of audits are there?
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
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
Financial Statement Audit
» Financial Statement Audit
» Annual audit of the school’s financial statements
© 2011 Global Financial Aid Services 6
How to Prepare?
© 2011 Global Financial Aid Services 7
What should I expect during an audit?
The Audit Process
» Entrance Conference» Auditors Analysis» Exit Conference» Final Report» Corrective Action Plan
© 2011 Global Financial Aid Services 8
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”
© 2011 Global Financial Aid Services 9
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
© 2011 Global Financial Aid Services 10
How to Prepare?
© 2011 Global Financial Aid Services 11
What documents willthe auditors request?
Document Requests
» Policies & Procedures Manual» Sample FSA Forms» Catalog» Cost of Attendance Budgets» FISAP» SAP Policy» Pell Account Information
© 2011 Global Financial Aid Services 12
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
How to Prepare?
© 2011 Global Financial Aid Services 14
What will the auditors ask?
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?
© 2011 Global Financial Aid Services 15
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
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
© 2011 Global Financial Aid Services 17
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
© 2011 Global Financial Aid Services 18
Corrective Action Plan
» Written Plan» Outlines steps to resolve issues» Identify the Finding & Resolution
» Follow the CAP» Develop/Refine Procedures» Assign Responsible Parties
© 2011 Global Financial Aid Services 19
How to Prepare?
© 2011 Global Financial Aid Services 20
How to Prepare?
How to Prepare
» Good Inter-Office Communication
» If Processes, Policies, Systems Change» Set a Meeting, Huddle, Let Everyone Know» Explain the implications of changes
© 2011 Global Financial Aid Services 21
How to Prepare
» Keep Your Files Organized & Consistent
» Paper Files» Group by Award Year» Checklist Cover Letter» Notes
» Electronic Files
© 2011 Global Financial Aid Services 22
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
© 2011 Global Financial Aid Services 23
How to Prepare
» Strengthen Internal Controls
» Assign Responsibilities
» Create Checks and Balances
© 2011 Global Financial Aid Services 24
How to Prepare
» Leverage Student Information System» Run Reports» Check for Anomalies» Cross Check with Other Departments
© 2011 Global Financial Aid Services 25
How to Prepare
» Invest in your staff» Online Training» Conferences» Workshops» P&P Manual Training» NASFAA CORE» FSA Coach
© 2011 Global Financial Aid Services 26
How to Prepare
» Internal Audit» Manage Institutional Risk» Test Compliance Activities» NASFAA Self Evaluation Guide
© 2011 Global Financial Aid Services 27
How to Prepare?
© 2011 Global Financial Aid Services 28
Most Common Findings?
10 Most Common Audit Findings
1. R2T4 Calculation Errors2. Pell Overpayment/Underpayment3. Late Return of Title IV Funds4. Verification Violations5. Overaward- Financial Need Exceeded
© 2011 Global Financial Aid Services 29
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
© 2011 Global Financial Aid Services 30
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
© 2011 Global Financial Aid Services 31
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
© 2011 Global Financial Aid Services 32
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
© 2011 Global Financial Aid Services 33
How to Prepare?
© 2011 Global Financial Aid Services 34
Let’s Review
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
Jeff ScofieldDirector of Financial AidUniversity of Hawaii- Hilo
© 2011 Global Financial Aid Services 36
Chesa StanfieldDirector of Solutions
Global Financial Aid [email protected]
© 2011 Global Financial Aid Services 37