Surviving ED Program ReviewWhat to Expect

“We’ve Been There & Done That”

Jacob PachecoConnie Manzanares

Northern New Mexico College

New Mexico Association of Student Financial Aid Administrators 2014

Our Objective:

To share our recent Program Review experience in an effort to help you successfully prepare and manage the process.

Presentation Outline

• What is a Program Review • What Triggered Our Program Review & What Could Potentially Trigger Yours• You Get “The Call” Preparing for the Visit – Be Ready• The Reviewers Are Here • After the Visit• Be Prepared

Purpose of U.S. Dept. of Educ. Program Review

• Is to evaluate compliance, identify liabilities and improve institutional capabilities

• Authority for Program Review is defined by Congress to provide necessary oversight of Title IV Participants

What Triggers Program Review?

• High default rates – (over 25% cohort rate or dollar volume)

• Significant fluctuation in volume of Direct loans or Pell

• Deficiencies reported by State or Accrediting agencies

What Triggers Program Review?

• High annual dropout rates

• Financial aid program deficiencies

• Financial/Administrative capability compliance risk, Audit Findings

What Triggered Our Review

• Late Audit Submissions!!! Two year’s in a row!

• I started getting calls - from the Department of Education….Yikes!!

We Got “The Call” July 12th

• Typically 2-4 weeks advance notice

• The dates they initially chose were terrible for us

• Negotiated for more suitable visit dates – need a good reason

We Got The “Letter” July 17

We Got “The Letter” cont..

• U.S. DOE letter confirmed visit dates, explained Entrance Conference & requested Pre-Review Submissions

• Specified that all offices involved in financial aid administration would be reviewed

• Also indicated that Campus Security & Drug-Free Schools Act compliance would be reviewed

The “Call” The “Letter” & Bears Ohh My!

• Don’t Panic! It’s not like you have to do a presentation for NMASFAA

• Read the entire letter:-Date of Review - Pre-Review Requirements – It’s a long list

• Begin Notifying campus officials• Contact the lead Program Reviewer

Contact the Lead Reviewer

• Establish a point of contact• Clarify details about the pre-review

documents - format (electronic or paper)• Clarify Scope and Period of Review• Determine what accommodations are

needed? Parking?

Read ED Program Review Guide 2009

Super useful prep tool

• Reviewers use it• Sample file and policy review checklists• Sample Student/Staff Interview Questions• http://www.ifap.ed.gov/programrevguide/20

09ProgramReviewGuide.html

Preparation Begins

• Set meeting/s with the key players- Fiscal; Academic; Registrar; Admissions, IT (Banner), Security

• Ensure that everyone understands the significance of ED Program Review“Sorry, but no vacation for you Mr. Provost”

Preparation Begins Cont…

• Prepare Resource Room

- Secure a nice working space for Reviewers- Work with IT to provide access to databases- Provide organized copies of all Pre-Review

info- Make arrangements for copying

List of Pre-Submission Items

Pre-Visit Submission Items

• Recipient Data Spreadsheet

- Specific Award Year: Unduplicated list of TIV recipients in Excel and/or Access.

- Used to confirm expenditures and to select a review sample

Pre-Visit Submission ItemsRecipient Data Spreadsheet

Pre-Visit Submission Items

• Consumer Information Attachment – 18 pgs - provide URL’s, title, page #’s, etc. - Policies and Procedures - Consumer Information Publications- Disclosures- Campus Security Reports- Catalogs

Pre-Visit Submission Items• Request for Student Files (7)

- Copy of Admissions File- Copy of Financial Aid File- Academic Transcript- Student Account Ledger- R2T4 calculation worksheet, evidence of return- If Work-Study-time sheets, class schedule,

payroll records

Reviewers Are On Campus

Entrance Conference

• Everybody Should Attend – President, Vice Pres., CFO, Registrar, Deans, Chairs, Security

• Reviewers will explain:- Purpose - Scope- Timeframe which will include scheduling the

Exit Conference (Don’t assume everybody pays attention)

Entrance Conference, cont.

• Introduce the school team• Reviewers did most of the talking – explained

the reason for the review and the scope• Discuss staff interviews – Schedule created

after entrance• Opportunity to ask questions

Staff Interviews

• Ensure staff members are available – They have to know the importance of being available.

• Use and share the Program Review Guide for interview prep

• Many of the questions concerned consumer information and campus security

Problems are Found

• Reviewers find an issue with R2T4- Liability: have to send $$ back to the DOE

• Consumer Information- not all requirements adequately met- some info not easy to find- some links did not work- Clery Act (Do we have dorms or not?)

Problems are Found cont..

• Verification

– We were verifying too many files– Asking for documentation that was not necessary

Exit Conference

• Reviewers praised Northern! – Let us know that findings were minimal & we were doing a good job

• Reviewers discussed findings• Framed required actions to strengthen our

compliance• This is a time to ask questions and seek clarity

on what happens next

Relief!!

Program Review Report

• We are waiting – It’s been over 6 months• Clery Act finding is reviewed by a Department

in Washington D.C.• When report arrives we will provide

institutional response by a due date specified in letter.

Be Prepared

• Policies & Procedures- Verification, Refunds, R2T4, Awarding, SAP,

Professional Judgment- Admissions- Fiscal- Academic- Enrollment- Campus Security

• Don’t get caught not implementing your own policy

Be Prepared

• Staff should be current on FSA requirements and engaged with professional community.- Conferences (Annual FSA, NMASFAA, etc.)- Training sessions – online

• Use Assessment Tools (FSA, NASFAA)

Questions?

Contact Information:

Jacob PachecoFinancial Aid DirectorNorthern New Mexico College505-747-2122jpacheco@nnmc.edu

Connie ManzanaresAssistant Director, Financial AidNorthern New Mexico College505-747-2124conniem@nnmc.edu