Orientation to the Foreign Schools Participation Division & Orientation to the FSA Conference

1. Session 42 Orientation to the Foreign Schools Participation Division & Orientation to the FSA Conference David Bartlett and Marcia Fediw | Dec. 2013 U.S. Department of Education 2013 FSA Training Conference for Financial Aid Professionals

2. Suggested Sessions • All General Sessions • Foreign Schools Session Track (Sessions 43-50) • Session 4 • Loan Counseling Tools • Session 8 • Title IV Reconciliation: What You Need to Know • Session 9 • PLUS Processing A to Z • Session 11 • Direct Loan Processing Tips & Troubleshooting

3. Suggested Sessions • Session 21 • Return of Title IV Funds – Basic Training for FAAs New to R2T4 • Session 28 • What FAAs Must Know About 150% Direct Subsidized Loan Limits • Session 7 • Federal Loan Servicing Update • Session 15 • NSLDS Enrollment Reporting

4. Foreign Schools Participation Division • Agenda • U.S. Department of Education Structure and Roles • Institution Participation Data • Key Functions of Foreign Schools Participation Division • Eligibility • Technical Assistance • Financial Analysis • Compliance Audit Resolution • Method of Payment • Program Review • Contacting us

5. U.S. Department of Education • http://www2.ed.gov/about/offices/or/index.html

6. Federal Student Aid An OFFICE of the U.S. DEPARTMENT of EDUCATION • Chief Operating Officer (James Runcie) appointed by President of the United States. • Policy Liaison • Technology • Finance • Performance Management • Customer Experience • Risk Management • Administrative Services • Acquisitions • Business Operations • Federal Loan School Support Team • Program Compliance • Foreign Schools Participation Division

7. Foreign Participation Data • 410 Institutions • 33 Countries • 25,000+ Students • $1 Billion USD annually • Foreign CDRs (Sector rates) • FY2011 (2-yr): 2.7% • FY2009 (3-yr): 7.3% * *origination data based on each institution’s 2012 fiscal year end data

8. School Participation Data • Participating Institutions • Domestic 5831 • Foreign 410 • 2011-2012 Award Year Funding • Domestic $143 Billion • Foreign $1 Billion • Foreign Funding by School Type • For-Profit 52% • Non-Profit 16% • Public 32%

9. Institutional and Program Eligibility • Eligibility Applications • Primary Application Types: • Initial Certification • Recertification • Reinstatement • Eligibility Only • Voluntary Withdrawal • Updates • Mergers • Change in Ownership • eligcert.ed.gov

10. Institutional and Program Eligibility • Legal Authorization & Degree Granting Authority • Academic Catalog, Programs & Locations, Partnerships • School Policies • Admissions • Refund Policy • SAP • R2T4 • Special requirements for Medical, Veterinary, and Nursing Programs • Outcome Documents

11. Technical Assistance • Institutional Assistance Services • Self-Paced On-Line Tools • Foreign Schools Assessments • FSA Coach for Foreign Schools • One-on-One Assistance • Referral to Subject Matter Experts in the Division

12. Financial Analysis • Assessment of institutional financial viability and health using financial ratios that are weighted & combined into a single composite score of financial responsibility. • Composite scores range from negative 1.0 through positive 3.0. Less than 1.5 is a failing score, but some schools may qualify for “zone” if score at least 1.0.

13. Financial Analysis • Other considerations • Past performance (including timely submission of acceptable compliance audits and audited financial statements). • Going concern statements. • Qualified, Adverse, Disclaimed Auditor Opinions. • Failure to repay Title IV, HEA program liabilities owing to U.S. Department of Education.

14. Financial Analysis • In general, “No news is good news.” • For Currently Participating Institutions, if a problem:Zone Alternative (Score 1.0 – 1.4, not exceed 3 consecutive years), Zone reporting requirements, Restricted Method of Payment HCM1 & audit attestation. Provisional Certification10% LOC (minimum), Provisional certification, Zone reporting requirements, Restricted Method of Payment HCM1 or HCM2, audit attestation. Letter of Credit only 50% LOC (minimum), can be considered financially responsible. No “Zone” reporting, no Method of Payment restrictions, no audit attestation. • New / Reinstatement Institutions Letter of Credit onlyas above.

15. Method of Payment • “Method of Payment” refers to the way an institution receives Title IV, HEA program funds. • The Secretary of Education has the sole discretion to determine the method under Title IV, HEA program funds are provided to an institution. • Types: • Advanced Payment • Heightened Cash Monitoring 1 (HCM1) • Heightened Cash Monitoring 2 (HCM2)/ Reimbursement • HCM1, HCM2 and Reimbursement used to mitigate risk and protect the federal interest in Title IV, HEA funds.

16. Compliance Audit Resolution • Compliance Audit Resolution is a process that normally occurs after an institution submits an acceptable compliance audit report. • Compliance audits ensure that Title IV, HEA funds have been expended correctly, but auditors may identify weaknesses and errors in Title IV, HEA program administration. • School are expected to implement corrective action for each finding of non-compliance to prevent recurrence. • Compliance audit reports containing more serious findings are flagged for additional resolution by Foreign Schools Participation Division.

17. Compliance Audit Resolution • Final Audit Determination Letter completes compliance audit resolution process. • Letter may assess a monetary liability to recover unauthorized costs incurred by the U.S. Department of Education or borrower due to incorrect administration of Title IV, HEA programs. Liabilities are not punitive and they are not fines. • School may appeal liabilities, if any, if it has evidence to indicate that the auditor’s finding was incorrect or if Department of Education’s determination was incorrect. • Letter provides payment instruction and appeal instruction, if liabilities asserted.

18. Program Review • Similar to Compliance Audit process, but also differences. • Differences: • Department of Education employees conduct on-site or off-site program review. • May be narrowly focused on a particular issue or set of issues or have a general scope. • Similarities: • Expanded file study may be required. • School has opportunity to respond to Program Review Report. • Department considers response in Final Program Review Determination. • Liabilities, if any, not punitive. May appeal.

19. Other Activities • SAIG enrollment verification process • Coordinating new school onboarding (Federal Loan School Support Team) • Electronic Announcements and updates to Foreign Schools Information Page on IFAP.ed.gov • International Schools Page on StudentAid.gov • Data, data analysis and consultation with policy-makers, auditors and others (e.g. NCFMEA, OPE, OIG, GAO) • Consulting in projects to modernize FSA computer systems

20. Contacting us • E-mail: FSA.Foreign.Schools.Team@ed.gov • Phone: 202-377-3168 • Fax: 202-377-3486 • Snail mail: U.S. Department of Education Foreign Schools Participation Division Union Center Plaza, 7th Floor 830 First Street, NE Washington DC, 20202 (20002 if overnight/courier)

21. QUESTIONS?