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New Mexico Association of Student Financial Aid Administrators 2014. Surviving ED Program Review What to Expect “We’ve Been There & Done That”. Jacob Pacheco Connie Manzanares Northern New Mexico College. Our Objective:.
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New Mexico Association of Student Financial Aid Administrators 2014 Surviving ED Program Review What to Expect “We’ve Been There & Done That” Jacob PachecoConnie Manzanares Northern New Mexico College
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” 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/2009ProgramReviewGuide.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
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 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
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
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)
Contact Information: Jacob Pacheco Financial Aid Director Northern New Mexico College 505-747-2122 jpacheco@nnmc.edu Connie Manzanares Assistant Director, Financial Aid Northern New Mexico College 505-747-2124 conniem@nnmc.edu