program reviews 2011 nhasfaa fall conference. what is a program review? a review conducted by the...
TRANSCRIPT
Program Reviews2011 NHASFAA Fall Conference
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What is a Program Review?
A review conducted by the Department of Education to evaluate compliance with Title IV statute and regulations
Improve future institutional capabilities
Identify liabilities owed for errors
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Why Does FSA Conduct Program Reviews?Required by lawTo ensure that funds
are used for the purposes intended by Congress and taxpayers
Schools and FSA have a fiduciary duty to Congress and taxpayers
Program integrity is important
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Program Reviews In General
Analyze institutional data and records Frame required actions and
recommendations to strengthen future compliance
Quantify harm and identify liabilities, if any
Refer institutions for administrative action, if necessary
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Top Program Review Findings(Ranked by Frequency)
Verification errorsReturn of Title IV funds
made lateReturn to Title IV (R2T4)
calculation errorsStudent credit balance
deficienciesCampus crime
requirements not met
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Top Program Review Findings(Ranked by Frequency)
Account records inadequate/not reconciled
Inconsistent information in student file
Independent student status not documented
Pell overpayment/underpayment
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Top Program Review Findings(Ranked by Dollars)
Ineligible programInaccurate recordkeepingReturn of Title IV funds
not madeInconsistent information
in student fileFFEL disbursements
attributed to unattended/incorrect payment periods
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Top Program Review Findings(Ranked by Dollars) Improper Pell disbursement - prior to
midpointVerification errorsAdvances used for non-program
purposesIncorrect Pell calculationFailure to meet factors of financial
responsibility
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Program Review - Background
Program reviews are generally conducted on-site
217 program reviews conducted nationwide in 2009-10 fiscal year
For more information, see The Program Review Guide for Institutions 2009 which can be found under publications tab on IFAP
http://www.ifap.ed.gov/ifap/byYear.jsp?type=programrevguide
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Program Review Guide Topics
Department preparation for program review
Institution preparation for program review
Entrance conference ED review of institutional processes
and data ED review of student level information
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Program Review Guide Topics
Exit conference/status meeting Referrals Post review communication and report Final determination and follow-up Appendices (definitions and sample
information)
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How Schools Are Selected for Program ReviewsConducted on a
systematic basis to include all participating institutions
Priority for selection◦Cohort default rate in
excess of 25% or highest 25% of default rates
◦High (top 25%) default rate in dollar volume
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How Schools Are Selected for Program Reviews
Priority for selection◦Significant fluctuation in Federal Pell
Grant or FFEL/FDL funding levels◦Deficiencies reported by state
licensing or accrediting agencies◦High annual dropout rates◦Other institutions that ED determines
pose a significant risk of non-compliance
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Risk Reduction
Fully resolve audit findingsFully address all findings in
the corrective action plan and be sure you follow through
Revise policies and procedures to avoid repeat findings
Attend training and keep current on program changes.
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Types of Program ReviewsGeneral assessment review
◦Random sampling of files◦Broad review of institutional policies
and processes◦Generally includes multiple offices on
campusFocused program review
◦Focused on one or more areas of Title IV administration
Off-site or on-siteAnnounced or unannounced
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Notification to School of Review
Telephone notification to President and Financial Aid Director
Written announcement letter
Specifies information to be provided prior to review◦Student recipient data◦Institutional information
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Requirement to CooperateCooperation in conduct of program
review requiredProvide timely access for examination
and copying of recordsProvide reasonable access to
personnel associated with Title IV administration for the purpose of obtaining relevant information
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Preparing For The Review
Provide requested information by required deadline
Inform all administrators at your school about the review
Emphasize to staff the review is of the institution’s compliance
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FSA Research Prior to Review
FSA internal paper and electronic records◦EZ Audit◦NSLDS◦G5◦COD◦FISAP◦Campus Security website◦IPEDS
State and accrediting agency information
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Entrance Conference
President or CEO needs to be presentAll offices with any role in Title IV
administration◦Financial Aid◦Registrar◦Business Office◦Admissions◦Placement◦Campus Security
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Entrance Conference
Introduction of FSA and school representatives
Overview of program review process
How Title IV is processed at the institution
LogisticsPossible scheduling of exit
conference/status meeting
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During the Review
Provide review team with secure workspace
Access to computer records, including print capability
Access to photocopierContact for reviewer
questionsEnsure staff availability
for interviews
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Review of Institutional Processes and DataInstitutional and program eligibilityAdministrative capability - required
policies and proceduresRefund and withdrawal proceduresPackaging, awarding and disbursing
proceduresCampus securityVerification policies and procedures
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Review of Institutional Processes and Data
Fiscal records and procedures
Cash management and reconciliation procedures
FISAPStudent consumer
informationSatisfactory Academic
Progress
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Staff Interviews
Reviewers will interview multiple staff
The institution cannot dictate who will be present during interviews
The institution cannot tape record staff interviews
Possible interviews with third-parties
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FSA Review of Student-level Information
Sample of student files reviewedReview multiple sources of student
records◦Admission records◦Academic records, including current
transcript◦Financial Aid records◦Student account record (ledger)
Student interviews may be conducted
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Resolution of Findings While On-Site
Possible discussion of findings during the review
School may attempt to resolve these findings
Resolved findings still included in Program Review Report
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Exit Conference
Usually conducted if fieldwork is substantially complete
Topics may include◦Required Actions◦Outstanding items and
submission timeframes◦Oral notification of
preliminary findings◦Next steps in program
review process
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Status Meeting
Conducted if fieldwork not completed and/or data has not been analyzed
Similar to exit conference◦Required Actions◦Outstanding items and
submission timeframes◦Next steps in program
review process
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Possible Referrals
Within the Department◦Administrative Actions
and Appeals Division◦Management
Improvement Services◦Office of Inspector
GeneralExternal referrals
◦State licensing agency◦Accrediting agency
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Post Review Activity
Provide all outstanding documents requested by the reviewers
Additional information may be requested
Reviewers may return for additional on-site work
FSA will complete analysis of data and issue a written report
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Program Review Report
Preliminary report of non-compliance findings
Describes required actions including file reviews if necessary
Establishes timeframe for institutional response
List of student files reviewed attached as appendix
May include recommendations
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Institution Response to Program Review ReportContact reviewer with any and
all questionsSubmit all information required
in the requested format by the established deadline
Complete required actionsRequest extension of time to
respond if necessary
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Expedited Determination Letter (EDL)Serves as preliminary report and final
determination letterSchool is not required to respondUsage limited
◦No findings, or only minor and non-systematic findings
◦Any identified findings corrected prior to EDL issuance
◦Any liabilities identified were paid/collected prior to issuance of EDL
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Final Program Review Determination Letter (FPRD)
Notifies the institution of the Department’s final determination for each finding
No further action required – FPRD closes the review
Includes copy of Program Review Report and school response(s) to report
Issued within 30-60 days of FSA’s receipt of a complete and final response
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FPRD – School Action Required
Contains original finding, summary of school response, Department’s final determination
Identifies liabilities, if any, and instructions for payment
Appeal rights for monetary liabilities
Proof of repayment of liabilities to loan holders may be required
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Appeal of Monetary LiabilitiesMonetary liabilities may be
appealed within 45 daysAppeal filed with FSA’s
Administrative Actions and Appeals Division (AAAD)
Collection of liabilities deferred for appealed amounts
Non-appealed liabilities still have to be paid
Appeal may be referred to Office of Hearings and Appeals (OHA)
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FPRD Close-OutWritten letter closes program reviewIssued after school completes actions
required by FPRDNot issued of the school is filing an
appeal for any liabilities
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Record RetentionRetain records until later of review
closure or normal record retention period
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Contact Information
For questions about this session:Anita Olivencia, Training [email protected] 617-289-0130
Please provide any comments regarding this training or the trainer to:
Thomas Threlkeld, Title IV Training Supervisor
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Your Boston Regional Training Team
Anita Olivencia, Training Officer◦617-289-0130◦[email protected]
Pam Gilligan, Training Officer◦617-289-0022◦[email protected]