2009 State Compliance Review Process Presented by GSFC Compliance Team March 2009

1. 2009 State Compliance Review ProcessPresented byGSFC Compliance TeamMarch 2009

2. Compliance Mission and Value Statement • You can expect the Compliance Team to be: • Fair & Unbiased • Accountable • Clear, Consistent, & Concise • Honest & Forthcoming

3. Compliance Reviews of the State Scholarships & Grants Programs Agenda • Welcome and Introductions • Compliance Review Procedures Overview • Compliance Review Preparation • On-site Review • Reports • Summary • Questions and Discussion

4. Introduction • Goal – To make you familiar with the process • Materials: • Information packet, or • www.gsfc.org – Click on ‘School & Lender Information’, then scroll to GSFC Compliance Documents • Staff Introductions • Housekeeping

5. Compliance Review Overview

6. Compliance Review Process Goals • Improve Administration of Programs • Identify Training Needs for Institutional Staff • Safeguard Public Funds • Be Clear, Consistent, and Concise

7. Review Process Prior to 2007 • All Institutions Reviewed Annually • Typical Sample Size was 30-40 Files • Review Was Conducted Only on Selected Award Year

8. Current Compliance Review Process • Each Institution to be Reviewed at Least Once Every Three Years • Sample Size is Based on a Statistically Sound Methodology (95% Confidence Level with +/- 10% Margin of Error) • All State Awards for Students in Sample are Examined for Review • Tracking Benchmark Scores Began in 2007

9. Tracking Institutional Progress Through Benchmarking • Benchmarking tracks the progress of Georgia institutions in the proper administration of State Programs • Findings types are assigned a value based on severity • Number of incidents for each finding type are multiplied by the value of each finding to arrive at a finding score

10. Tracking Institutional Progress Through Benchmarking • The finding score is then compared to the sample size, which determines a Benchmark Score • This Benchmark Score is used to determine which institutions will benefit the most by having GSFC efforts directed towards assisting them in the administration of the State Scholarship and Grant Programs

11. Benchmark Values for Finding Types • 5 – Fraud by an institution or False Certification of award • 4 – Administrative problem affecting a significant portion of the population - GPA, Refunds, Invoicing, Residency (Private & Proprietary) • 3 – Administrative errors affecting smaller population - Selective Service, SAP (Private & Proprietary), Citizenship, Default, Book Allowance, Enrollment, Exceeded Hours

12. Benchmark Values for Finding Types • 2 – Missing or Incorrect Documents - Missing Transcript, Missing Application • 1 – Non-Monetary Exceptions - Incorrect Reporting of Data, No Book Allowance authorization

13. Sample Size • Based on number of awards • Number of files required to achieve a 95% confidence level with a +/- 10% margin of error rate • Typically 80-100 files

14. Policies & Procedures • Missing Documentation only to Institutional Officers • Final Report to President • TCSG & BOR institutions provide annual certification by presidents that TCSG or BOR residency and SAP policies are being followed. • Remittance of liabilities not due until after the Final Report is issued • Strict adherence to the review timeline • Multiple year review • Sample selection with a variety of criteria – presence of electronic applications, cancellations, and citizenship status

15. Training Referrals • Training Referrals to GSFC Learning Resource Center • Mandatory Referrals based on type and number of findings.

16. Measuring Our Success • It is the intent of GSFC to demonstrate good stewardship of State Funds. Success with the current review procedures will be measured by: • Improving Benchmark Scores of All Participating Institutions • Improving the confidence level in GSFC

17. Compliance Review Preparation

18. Pre-Review Correspondence and Processes • Review Notification Letter • Selected / Not Selected • Scheduling Review Date • Compliance Review Schedule Request Form • Compliance Review Notification Scheduling Memo • Engagement Letter • Notification Memo – Request for Pre-Review Documentation and Related On-site Review Information

19. Pre-Review Correspondence and Processes (cont’d) • Provide Compliance with Needed Information • Download Files on an Encrypted Disc or Remote Access - Arrange for Compliance to have secured File Transfer Protocol (FTP) access to needed information, downloaded on an encrypted disc or remote access to student database (if applicable) and the institution’s imaging system (if applicable)

20. Pre-Review Correspondence and Processes (cont’d) • Contact Compliance to Schedule 48 Hour Window for Remote Access • Use Notification Memo To Indicate Type of Access • Provide Information at Least Two (2) Weeks Prior to On-site Review

21. Documents to Submit Prior to Review • Administrative Questionnaire • School Catalog & Student Handbook • Current Financial Aid Policies & Procedures • Scholarship & Grant Reconciliation • User Guide for Computer System

22. Sample Lists • Sample list delivery date- Fifteen (15) business days prior to the review • SURFER Verification Form • Notify Compliance if:- Contact person changes; or- Your email is inaccessible

23. SURFER Verification Form

24. On-Site Compliance Review

25. Review of Files • All information must be available before or at the beginning of the on-site review. • Reviewers will have to take certain student information back to GSFC for review off-site (either hard or soft copy). • If files are not available at the beginning of the on-site review, the institution must copy unavailable files and send to GSFC. The institution will have five (5) business days to remit files to GSFC. • If files remain unavailable five (5) business days after the on-site review, those missing files will be considered a Finding with the associated monetary liability.

26. The Entrance Interview Session • Ensure Institutional Participation • Confirm On-site Review Time • Identify the School Contact Person • Review School Security Procedures • Ensure Availability of Documents • Cover Scope of the Review

27. The Entrance Interview Session (con’t) • Provide Packet of Information Including: Compliance Mission and Value Statement  Update to Compliance Review Policies & Procedures Compliance Review Reporting Time Line Missing Documentation Guidance Compliance Review Deficiency Codes  Conflicting Information Scenarios Documentation Guidance  Compliance Review Appeals Policy Contact Information

28. The Exit Interview Session • Verify the Return of all School Documents • Provide Compliance Review Disclosure Statement • Collect SURFER Verification Form • Provide list of students with missing documentation and the type of missing documentation. Schools may submit missing documentation during the 10-day missing documentation grace period. • Discuss ‘Next Step’ in the Review Process - Forty-five (45) days for Deficiency Report to be issued - Forty-five (45) days for school response time • On-site Review Completed

29. Compliance Review Reports

30. Compliance Review Reports • Two reports will be issued as a result of the Compliance Review • The Deficiency Report and the Final Report

31. Deficiency Report • Issued within forty-five (45) days of the on-site review • Sent to Financial Aid Office, Admissions Office, Business Office and Registrars Office

32. Deficiency Report (con’t) • Institution has forty-five (45) days to respond • Institution’s response should include a response to each Finding listed in the Deficiency Report and any documentation in support of disputed Findings • If institution does not respond to the Deficiency Report within the forty-five (45) day response period, the Final Report will be issued to the president at the end of the forty-five (45) day period • Institutions should not remit funds until Final Report is issued

33. Final Report • Issued within thirty (30) days of the institution’s response to the Deficiency Report • Sent to president with copies to institutional officers • Institution has thirty (30) days to respond • Institution’s response should include payment of any monetary liabilities and any Corrective Action Plans due – any additional documentation regarding disputed Findings should also be included

34. Remittance Device

35. Compliance Review Summary

36. State Compliance Review Summary Each institution will: • Be reviewed AT LEAST once every three (3) years • Designate a point of contact for the Compliance Review Team • Receive Compliance Review Checklist and Administrative Questionnaire • Be required to provide all requested documentation within fifteen (15) days of the Notification Memo

37. State Compliance Review Summary (Con’t) • Arrange for Compliance to have secure FTP access to needed information, downloads on an encrypted disc or remote access to student database (if applicable) and the institution’s imaging system (if applicable) at least two (2) weeks prior to the on-site review • Have various institutional offices represented at the Entrance Interview • Be required to repay any funds determined to be incorrectly awarded to any student

38. State Compliance Review Summary (Con’t) • Present complete student files to the Compliance Team at the beginning of the on-site review • Understands no additional files or missing documentation will be accepted by the reviewer after the beginning of the on-site review • Be provided a list of students with missing documentation at the Exit Interview • Have 10-Day Grace Period Available to Provide Missing Documentation • Be issued a Deficiency Letter and Report only to Institutional Officers

39. State Compliance Review Summary (Con’t) • Have a forty-five (45) day appeal period prior to the Final Letter and Report to provide documentation to alleviate monetary liability • Understands even if the documentation is provided, the finding will remain on the Final Report (unless the finding was incorrectly cited then neither the liability nor the finding will be on the Final Report) • Be issued a Final Report to the President, with copies to the Institutional Officers

40. State Compliance Review Summary (Con’t) • Use the Remittance Device provided with the Final Letter and Report to remit required liabilities to GSFC • Have a thirty (30) day response period, during which an institution should respond to the Final Report and remit liabilities • Asked to submit a Survey

41. Questions?

42. Compliance Team Contact Information For Questions Concerning the Compliance Review Process • Email: ComplianceTeam@gsfc.org or richard@gsfc.org • Phone: 770-724-9012 • Address: Compliance Team 2082 East Exchange Place Tucker, GA 30084

43. Program AdministrationContact Information For Questions Concerning Interpretations of State Scholarship and Grant Program Regulations • Email: ProgramAdmin@gsfc.org • Phone: Schools: 1-800-414-3080 (option 3) • Phone: Students: 1-877-813-1327 • Address: Program Administration 2082 East Exchange Place Tucker, GA 30084

44. Learning Resources Contact Information • Email: LearningResources@gsfc.org • Phone: 770-724-9026 • Address: Learning Resources 2082 East Exchange Place Tucker, GA 30084