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Why Does FSA Conduct Program Reviews

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					Program Reviews
2011 NHASFAA Fall Conference
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


                                             2
Why Does FSA Conduct Program
Reviews?
 Required by law
 To 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

                               3
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




                                                     4
Top Program Review Findings
(Ranked by Frequency)


   Verification errors
   Return of Title IV funds made
    late
   Return to Title IV (R2T4)
    calculation errors
   Student credit balance
    deficiencies
   Campus crime requirements
    not met

                                    5
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




                                              6
Top Program Review Findings
(Ranked by Dollars)

                       Ineligible program
                       Inaccurate recordkeeping
                       Return of Title IV funds not
                        made
                       Inconsistent information in
                        student file
                       FFEL disbursements attributed
                        to unattended/incorrect
                        payment periods


                                                        7
Top Program Review Findings
(Ranked by Dollars)

 Improper Pell disbursement - prior to
  midpoint
 Verification errors
 Advances used for non-program purposes
 Incorrect Pell calculation
 Failure to meet factors of financial
  responsibility




                                           8
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




                                          9
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




                                                   10
Program Review Guide Topics

 Exit conference/status meeting
 Referrals
 Post review communication and report
 Final determination and follow-up
 Appendices (definitions and sample information)




                                                    11
How Schools Are Selected for
Program Reviews
 Conducted 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

                                    12
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


                                                        13
Risk Reduction
 Fully resolve audit findings
 Fully 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.



                                      14
Types of Program Reviews
 General assessment review
  ◦ Random sampling of files
  ◦ Broad review of institutional policies and
    processes
  ◦ Generally includes multiple offices on campus
 Focused program review
  ◦ Focused on one or more areas of Title IV
    administration
 Off-site or on-site
 Announced or unannounced



                                                    15
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



                                   16
Requirement to Cooperate
 Cooperation in conduct of program review
  required
 Provide timely access for examination and
  copying of records
 Provide reasonable access to personnel
  associated with Title IV administration for the
  purpose of obtaining relevant information




                                                    17
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




                                                   18
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

                                              19
Entrance Conference
 President or CEO needs to be present
 All offices with any role in Title IV
  administration
  ◦ Financial Aid
  ◦ Registrar
  ◦ Business Office
  ◦ Admissions
  ◦ Placement
  ◦ Campus Security

                                          20
Entrance Conference

 Introduction of FSA and school
  representatives
 Overview of program review process
 How Title IV is processed at the
  institution
 Logistics
 Possible scheduling of exit
  conference/status meeting



                                       21
During the Review
 Provide review team with
  secure workspace
 Access to computer
  records, including print
  capability
 Access to photocopier
 Contact for reviewer
  questions
 Ensure staff availability
  for interviews

                              22
Review of Institutional Processes
and Data
 Institutional and program eligibility
 Administrative capability - required policies and
  procedures
 Refund and withdrawal procedures
 Packaging, awarding and disbursing procedures
 Campus security
 Verification policies and procedures



                                                      23
Review of Institutional Processes
and Data
          Fiscal records and procedures
          Cash management and
           reconciliation procedures
          FISAP
          Student consumer information
          Satisfactory Academic Progress




                                            24
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
                                                25
FSA Review of Student-level
Information
 Sample of student files reviewed
 Review multiple sources of student records
  ◦ Admission records
  ◦ Academic records, including current transcript
  ◦ Financial Aid records
  ◦ Student account record (ledger)
 Student interviews may be conducted



                                                     26
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




                                                       27
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

                                                 28
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



                                            29
Possible Referrals
  Within the Department
   ◦ Administrative Actions and
     Appeals Division
   ◦ Management Improvement
     Services
   ◦ Office of Inspector General
  External referrals
   ◦ State licensing agency
   ◦ Accrediting agency


                                   30
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



                                           31
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


                                            32
Institution Response to Program
Review Report
 Contact reviewer with any and all
  questions
 Submit all information required in the
  requested format by the established
  deadline
 Complete required actions
 Request extension of time to respond if
  necessary


                                            33
Expedited Determination Letter
(EDL)
 Serves as preliminary report and final
  determination letter
 School is not required to respond
 Usage 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
                                                     34
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


                                                       35
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

                                         36
Appeal of Monetary Liabilities
 Monetary liabilities may be appealed
  within 45 days
 Appeal 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)

                                           37
FPRD Close-Out
 Written letter closes program review
 Issued after school completes actions required
  by FPRD
 Not issued of the school is filing an appeal for
  any liabilities




                                                     38
Record Retention
 Retain records until later of review closure or
  normal record retention period




                                                    39
Contact Information
For questions about this session:
  Anita Olivencia, Training Officer
  Anita.Olivencia@ed.gov
  617-289-0130


Please provide any comments regarding this training
or the trainer to:
   Thomas Threlkeld, Title IV Training Supervisor
   Thomas.Threlkeld@ed.gov
   617-289-0144

                                                      40
Your Boston Regional Training
Team
 Anita Olivencia, Training Officer
  ◦ 617-289-0130
  ◦ Anita.Olivencia@ed.gov
 Pam Gilligan, Training Officer
  ◦ 617-289-0022
  ◦ Pam.Gilligan@ed.gov




                                      41

				
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