Program Reviews

1. Program Reviews 2011 NHASFAA Fall Conference

2. 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

3. 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

4. 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

5. 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

6. 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

7. 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

8. 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

9. 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

10. 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

11. Program Review Guide Topics • Exit conference/status meeting • Referrals • Post review communication and report • Final determination and follow-up • Appendices (definitions and sample information)

12. 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

13. 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

14. 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.

15. 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

16. 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

17. 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

18. 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

19. 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

20. 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

21. 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

22. 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

23. 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

24. Review of Institutional Processes and Data • Fiscal records and procedures • Cash management and reconciliation procedures • FISAP • Student consumer information • Satisfactory Academic Progress

25. 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

26. 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

27. 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

28. 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

29. 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

30. Possible Referrals • Within the Department • Administrative Actions and Appeals Division • Management Improvement Services • Office of Inspector General • External referrals • State licensing agency • Accrediting agency

31. 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

32. 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

33. 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

34. 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

35. 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

36. 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

37. 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)

38. 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

39. Record Retention • Retain records until later of review closure or normal record retention period

40. 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

41. 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