of Creating and Maintaining a Compliant Policy and Procedure Manual

1. 5 ‘s of Creating and Maintaining a Compliant Policy and Procedure Manual Presented by: Chyrl R. Ayers, COO Global Financial Aid Services, Inc. SASFAA 2013 50th Anniversary Conference February 11, 2013, 3:45 – 5 pm Dunwoody A

2. WELCOME

3. Learning Objectives WHY must a P&P manual be maintained? WHAT is required? WHO is responsible to create and maintain? needs access? WHERE to store and methodologies utilized? WHEN should it be reviewed and updated?

4. WHY? • Why required? • Why does a manual make sense?

5. Considering Different Configurations • Separate manual; or • Cross-reference to manual(s) already in existence. Note: You may want to consider using icons to represent different areas for quick reference in your P&P manual.

6. Different Types of Icons • Good Practice • Tip • Policy • Important • Exception • Definition (some prefer a Glossary in this area) • Checklist • Example • NEW

7. WHAT? • What content to include?

8. Packaging Philosophies and Procedures • Federal Pell • FDSL • Campus-based Funding • FSEOG • FWS • Federal Perkins • Teach Grant

9. Packaging Philosophies and Procedures Considerations • Do you package loans only up to the direct cost and allow the student to request additional loan funds for living expenses? • Do you package for the full annual limits and then reduce if requested by the student?

10. Packaging Philosophies and Procedures Considerations • If packaging for less than a full annual amount, how are students made aware of the maximum amount they can borrow? • How do you monitor funds received from other sources (i.e. scholarships, foundation funds, employer payments, state grants, etc.) to ensure student is not overawarded?

11. Packaging Philosophies and Procedures Considerations • If a student’s Title IV aid package must be reduced due to receipt of a scholarship, how is the student notified? • What is your process for packaging: • Transfer students in an open loan period? • Re-entry students? • Students who change programs?

12. P&P Regulatory Citation Related to Federal Pell • 690.63 Calculation of Federal Pell Grant Awards • 690.80 Requirements and optional recalculation • 690.81 Fiscal Records and Disbursement requirements • H.R. 4137 Iraq and Afghanistan Service Grant Program

13. Basic Federal Pell Considerations • Requirements for determination of Federal Pell Grant; • What situations require recalculation? • Do you recalculate under optional situations? • How and when you disburse and report? • Procedures for handling and disbursing the Iraq & Afghanistan Service Grant

14. P&P Regulatory Citation Related to FDSL • 685.102(b) Packaging Policies for FDSL • 685.304 Counseling Borrowers • 685.306 Payment of refunds or RT4 • 685.309 Administrative and Fiscal Control

15. Basic DL Considerations Awarding Process Outline the procedures to determine the appropriate award amounts. • Do you always award the maximum? • Do you consult with the student first in determining the award amounts? • Do you package direct and indirect or only direct? • How does the student request indirect/living expenses?

16. Basic DL Considerations PLUS (Parent Borrower) Outline the procedures to determine parent’s eligibility under the PLUS program • How do you determine the amount? • How do you notify they parent of eligibility and/or awarded amount? • What is the process if a parent requests online through COD? • How do you collection information to document the parent’s requested amount? • How do you provide information to the parent related to PLUS?

17. Basic DL Considerations Confirmation Process Outline the confirmation process for loans • Active or passive? • Must document how you handle each academic year in which loans are made to students

18. Basic DL Considerations • Loan Counseling – outline your procedures for loan counseling and include entrance and exit processes. • Disbursement Notification Letters – include your procedures on how and when notifications are made to borrowers when a direct loan occurs.

19. P&P Campus-based Funds - FSEOG • 676.10 Selection and Awarding • 676.19 FSEOG Fiscal Procedures and Records

20. Basic FSEOG Considerations Awarding Policy Should include your procedures for awarding of FSEOG • Reviewed and maintained for each award year; • How students are informed of eligibility and selection criteria for determining award amount. • If information is contained in catalog or consumer information, you should still have a written policy on FSEOG

21. Basic FSEOG Consideration Institutional Match Should include details on how you meet the institutional matching requirements. Note: This process should be the same each award year; therefore, one policy may cover several award years. The award years covered by the policy should be noted in the policy.

22. P&P Campus-based Funds - FWS • 675.10 Selection and Awarding • 675.20; 675.21; 675.2(b); 675.18(g) Assigning FWS Jobs • 675.19 Fiscal Procedures and Records • 675.36 Job Location and Development-Procedures and Records • 375.49 Work College Program-Procedures and Records

23. Basic Consideration FWS Selection Process • Application material; • How students are notified of available positions; • How hourly wage is determined; • How the interviewing and hiring process works; and • Policy on limiting the number of hours worked.

24. Basic Consideration FWS Off-campus Employers • Selection process for off-campus employers; • Written off-campus FWS Agreements: • Who is considered the employer for purposes of hiring, terminations and pay rate? • Who is responsible for required cost such as nonfederal share social security and workman’s compensation? • Who is responsible for payroll?

25. Basic Consideration FWS Payroll and Non-federal Share Outline the payroll procedures used for FWS students • Timesheet process; • Frequency of payment; • Method used for paying student; • Procedures for documenting payroll made by off-campus employers; and • How the required institutional match is made (school or off-campus employer)

26. Basic Consideration FWS Community Service Include how community service requirements are met (7% of your allocation with at least one position as a reading tutor or performing family literacy).

27. P&P Campus-based Funds – Federal Perkins • 674.10 Selection and Awarding • 674.31 Perkins MPN • 674.16 Perkins Loan Disclosure • 674.19 Fiscal Procedures and Records • 674.33(d) Forbearance • 674.38 Deferment • 674.42 Contact Borrower • 674.43 Billing • 674.45 Collection • 674.46 Litigation • 674.52 Cancellation

28. Basic Consideration Federal Perkins Awarding Policy • Eligibility requirements; • Selection procedures; and • Criteria for determining the award amount.

29. Basic Consideration Federal Perkins Loan Counseling - Should include both entrance and exit counseling processes Cumulative Balance Owed – Procedures used to notify student of the cumulative balance owed and the expected payment amount. Must be provided each award year prior to 1st disbursement of a Federal Perkins loan.

30. Basic Consideration Federal Perkins Recordkeeping • Maintenance of MPN (fireproof container or cabinet); • Procedures for returning MPN to the borrower after loan is satisfied; • Storing of loan records – deferments, cancellations, forbearances, repayment schedules and other correspondence with borrower; and • If you use e-sign you must document your e-sign procedures.

31. Basic Consideration Federal Perkins Disbursement Notification Letters – include your procedures on how and when notifications are made to borrowers when a loan occurs. Red Flag Rules – procedures should include how you comply with the FTC’s Red Flag Rule

32. Basic Consideration Federal Perkins Confirmation Outline confirmation process for loans • Active or passive? • Must document how you handle each academic year in which loans are made to students.

33. Basic Consideration Federal Perkins Servicing Procedures This section should include the processes used in servicing the Federal Perkins loans: • Borrower contacts; • Billing procedures; • Default and collection procedures; • Cost assessed to borrowers; and • Perkins assignment.

34. Basic Consideration Federal Perkins Servicing Procedures Note: If you use a server for your Perkins, the servicers’ efforts in these areas would be included in the P&P manual. You need to outline who is responsible for what and anything shared.

35. P&P Campus-based Funds – TEACH Grant • 686.10; 686.11 Eligibility Determination • 686.32 Counseling • 686.36 Fiscal Control and Funds Accounting

36. Basic Considerations TEACH Grant • Exit counseling for student who does not complete counseling on NSLDS website; • Any additional counseling you may perform for TEACH Grant recipients; and • How you verify enrollment in an eligible program and verity student’s GPA to ensure eligibility for TEACH disbursement.

37. P&P Campus-based Funds – ACG/SMART (Not currently funded) • 691.15; 691.16; 691.17 ACG and National SMART Eligibility Requirements • 668.3; 691.62; 691.2(d); 691.6 Calculating ACG & National SMART • 691.81 Fiscal Control and Fund Accounting

38. Verification – 668.53 Written policy that indicates the following: • Time period for student to provide documentation; • Consequences of failure to submit; • Method used to notify changes of EFC & change to TIV awards; • Procedures to follow when it is necessary to correct FAFSA data; and • Procedures followed if referral of student to OIG.

39. Verification – 668.53 This policy must be made available to all students selected for the process of verification.

40. Professional Judgment (PJ) – 479A and 668.5(c) Requests for PJ’s • How students are made aware of the availability to be considered for this process; • Process by which student applies for PJ; and • Standard forms or other documentation required.

41. Professional Judgment (PJ) – 479A and 668.5(c) PJ’s decision – How students are notified of the decision and this should include the results of awards being revised based on approval.

42. Satisfactory Academic Progress (SAP)668.16(e) and 668.34 Methods of Monitoring SAP • Automated or manual process? • Who monitors SAP? • How often is SAP reviewed? • How is FA notified of the failure of SAP?

43. Satisfactory Academic Progress (SAP)668.16(e) and 668.34 Procedures for FA Warning and Probation • How are students notified? • What are the appeal procedures • Who prepares academic plan and monitors them to ensure student is meeting the requirements of the plan? How are students notified of the SAP policy?

44. Student Accounts668.164 Procedures for posting of disbursements to students’ accounts timely and accurately including procedures to ensure funds are posted in 3 days. Procedures for handling credit balances: • Monitoring of students with credit balance authorization forms;

45. Student Accounts • For students with credit balance authorization forms; how do you monitor and ensure credit balances are handled within the 14-day requirement of end of loan period (or award year if loans are not awarded), or within 14-day requirement of graduation;

46. Student Accounts • For students that do not authorize the holding of credit balance, how do you monitor the issuance within the 14-day requirement? • How does the student rescind authorization to hold credit balance? • Who monitors and handles late disbursements that post that might cause a credit balance which may need to be issued within the 14-days?

47. NSLDS Reporting Rosters – process for completing and returning rosters including the schedule followed.

48. Enrollment Status Changes • Process for reporting changes in enrollment status; • Who is responsible? • How the responsible party receives notification of change.

49. Transfer Student Monitoring • Process for adding a student to monitoring; • Who is responsible? • How the responsible party receives notification of change.

50. Withdrawals/TIV Refunds668.22 Schools refund policy including Return to Title IV (R2T4) Note: School refund policy may change so it is important to note in the P&P the various policies and effective dates. Process of coordination between departments (academics, business office and financial aid). Procedures for return of unearned aid or refunds resulting from school refund policy or R2T4.