Preparing for a Federal Program Review

1. Preparing for a Federal Program Review Val Meyers Associate Director Michigan State University

2. Program Review vs. A-133 Audit • A-133 is an audit required of non-profits who spend more than $500,000 in federal funding. • Generally done by an internal auditor and/or a contracted third-party auditor. • Must be done for each year in which you spend more than 0.5m in fed funds • Requirements published by the Office of Management and Budget, federal government

3. The A-133 is… • Routine: generally you work with the same auditors and they generally ask the same questions and want the same data • Do you have any new federal aid programs? (ACG, SMART, TEACH have been recent replies) • For this selected population – send packages, ISIRs, NSLDS printouts • Give us a copy of your FISAP for the audited year

4. Program Review In contrast, a Program Review is anything but routine -- • Program Review originates with Dept of ED • Selection for review at ED’s discretion (could be years or decades between reviews) • Short window from notification to the review process • Focused on financial aid processes and regulations in HEOA • May target a few specific processes You don’t know what to expect or what will be requested ahead of time – so you need to be thoroughly prepared to answer questions about your institutional practices!

5. The Timeline of a Program Review • MSU notified February 18, 2010 of program review (by phone call and letter) • Letter listed documentation to be sent to reviewers within 2 weeks • Reviewer visit approximately 1 month after notification date • Reviewers on campus three days • Findings notification received approximately 3 weeks later (April 15, 2010)

6. The Information Information request includes both aid office and other offices’ information including: • Academic catalogs (degree programs, courses offered, class start/end dates, location of sites of instruction) • Admissions policies and procedures (including ability to benefit policies and procedures, recruiter compensation or incentive pay) • Attendance policy

7. Other information required • Satisfactory Academic Progress policy & procedure • Verification • Withdrawals, official and unofficial • Return of Title IV • Campus security information • Financial Aid consumer information • Accreditation Statement of Affiliation • State agency documents showing the state’s recognition of the institution (public schools)

8. More information required Organizational charts for financial aid, admissions, registrar, bursar/controller Data sample for reviewed year of all students who • Were selected for verification • Withdrew or ceased attendance for any reason other than graduation • Received all non-passing grades in any term of the review year

9. Form a Task Force • If selected for a program review, your first step should be forming a committee of affected offices • Much of the requested data will not be in control of the aid office • Find out who knows or is responsible, particularly about required consumer information

10. Next Steps • Call on members of the Task Force to help you assemble needed data and documentation • Appoint a point person in Financial Aid to mail, email, or fax data appropriately and keep a list to ensure everything is submitted on time • Prepare for the in-person visit

11. The Visit • You may have fielded questions during the data submission phase, but be prepared for many questions during the visit • Reviewers will request an entrance interview/meeting with key players from campus • During the entrance interview, they explain the process and request a point person as their contact

12. The Visit p.2 • As point person, you will • Set up workspace, including access to information and equipment required by the reviewers • Pull files (print records) for students they select for in-depth review • Research and respond to questions as files are reviewed • Schedule one-on-one interviews with selected staff (e.g., director of admissions, financial aid, bursars)

13. Records Review • Fifteen records were selected from the list MSU supplied prior to the visit • Reviewers then checked the verification data, R2T4 calculations, and/or documentation of walk-away withdrawal dates to ensure proper changes/calculations • Any questions in process or procedure, proof of return of funds, etc., were then researched and answered

14. Questions asked • Rationale for our SAP policy • GPA monitoring, maximum timeframe, and MSU-specific criteria such as maximum number of withdrawals allowed • Proof that the Clery (campus crime report) was sent to all staff and students – by whom – what method – what date • Separation of duties (awarding vs. disbursement of aid) • Security access to COD and NSLDS and policy/procedure for terminating access when a staff member leaves

15. Questions asked • Policy on refunding – MSU begins refunding at earliest possible date (10 days before first class date). Reviewers asked about our process if the student fails to attend class, drops credits, etc. – how do we track this, and what do we do to reverse or modify aid awards/disbursements if this happens

16. Final Steps in Visit • At the end of the visit, the reviewers ask to schedule an exit interview with the same attendees as at the entrance interview • Reviewers discuss in general terms any findings or concerns they have at the time • This is preliminary and reviewers explain that the official letter will be sent to the institution within 30-45 days

17. Official Notification • If there are findings: • A letter is issued listing problems identified. • The institution has 30 or 45 days to respond, depending upon the number and complexity of the findings. • After review of the institution’s response, the Department issues a final letter. • If there are findings requiring repayment and/or penalties, the final letter will outline the school’s financial responsibility.

18. Notification p.2 • If there are no findings, the institution may receive an Expedited Final Determination Letter. • An Expedited Letter means that the process is complete. No problems have been found, so the institution doesn’t need to respond and the review is considered “closed”.

19. Follow Up • If there were findings, your Task Force members should review and change policies and procedures to bring your institution into compliance • If there were suggestions for improvement, you may wish to discuss and decide if your institution wants to make changes

20. Implementing Changes • Any changes must include rewritten policies and/or procedures, web sites, and publications • Changes mean training! Schedule training sessions to inform your staff on new policies and procedures – and be sure they understand why the change is being made

21. Questions?