Inside a Program Review

1. Inside a Program Review Sharon Abernathy, Columbia College Amy Hager, Moberly Area Community College Sarah Bright, Jefferson College

2. Columbia College’s Timeline • July 15, 2014 – Received “the call” from ED of Announced On-site Program Review on 8/18; No previous Title IV program review • July 20, 2014 – 1st submission of required docs due to ED • August 7, 2014 - 2nd submission of required docs due to ED • August 18, 2014 - Site visit, Additional docs required • First Day of Fall session • Auditors also on site Weekly updates to President

3. Columbia College’s Preparation Plan • Met with President, Academic Dean, CFO, and supervisor • Involved Registrar, Bursar, Dean of Students, HR, Office of Compliance, Institutional Research and “a cast of hundreds” in subsequent planning meetings • Developed Sharepoint site for coordination of documents/information • Identify and assign responsibility to key stakeholders for requested items w/deadline dates (ex. Campus Safety reports, Drug and Alcohol disclosures, consumer information, admission policy, etc.) • Follow-up meetings for progress updates • Room reservation; refreshments; parking pass; key for secure environment; technology access (wi-fi, printer, copier)

4. Entrance Conference August 18, 2014 Included all of the key administrative staff; Four program reviewers; no definite timeline for length of stay (one week or more depending on the review) • Two hour interview with FA Director • Meetings with CFO, Registrar, Director of Admissions • Student file review • Requests for FWS job descriptions/timecards, attendance policy, community service contracts

5. Exit Conference-8/22/14 President, CFO, CIO, Academic Dean, FA Leadership Staff Preliminary concerns: • R2T4 – Determination date; online student attendance • Perkins loan assignment to ED (due diligence on old paper) • Credit balances – paper checks within 14 days; holding without authorization • SAP – Transfer credit not included in calculation • Definition of AY and loan disbursements (refers to 8 week sessions)-more research needed by reviewers and CC • Loan periods (overlapping sessions combined into one term) • FA shopping sheet – improve access for non-admitted students • SEOG policy – set some aside for awarding later in year • Undeclared/undecided majors – aid awarded after 60 credit max.

6. Exit Conference-8/22/14 President, CFO, CIO, Academic Dean, FA Leadership Staff Preliminary concerns (cont.): 10. PJs and D/O – internal approval documentation/closing the loop • Verification/Inaccurate ISIR transaction • COD – AY week discrepancy • Online course attendance – reviewers accessed online courses to verify grades & attendance in FAMS; requested continued access after they left • Alumni Referral Grant – might be considered an incentive • FWS – incomplete job desc., students working during class time, more than 20 hours (outside of policy) Final Report: “Won’t see before first of year”

7. Moberly Area Community College’s Timeline • April 21, 2014 – Received “the call” from ED of Announced On-site Program Review on May 19, 2014; No previous Title IV program review • April 29, 2014 – Aid recipient data was submitted to ED • (2012/2013 and 2013/2014 students only) • May 5, 2014 – 1st submission of required docs due to ED • May 12, 2014 - 2nd submission of required docs due to ED • May 19-23, 2014 - Site visit, Additional docs required • May 29, 2014 – Submitted additional student files and docs requested by ED • October 9, 2014 – Received follow-up call from reviewer for additional information >>>>>Have not received response file to date<<<<<

8. Moberly Area Community College’s Preparation Plan • Met with President and CFO to prepare plan • Met individually with CIO, Director of Computing Resources, Registrar, Business Office Manager, Dean of Students, Dean of Off-Campus Programs and Instructional Technology, Director of Instructional Technology, Director of Human Resources, Director of Security, Director of Plant Operations • Informed each division about the review and discussed their part and responsibilities • Arranged all logistics (work room, parking, keys, technology, copier, printer, etc) If interested in documents requested, an example of letter received is available.

9. Moberly Area Community College’s Entrance Conference • Four ED staff; lead reviewer and three others • Phone conferences were conducted with Business Office, Registrar, and Admissions prior to on-site visit. • On May 19, they met with President, VP Instruction, VP Finance, and other key staff. • Financial Aid interview – included director, assistant director and coordinator of FA at Columbia campus who is primarily responsible for R2T4. • Reviewers presented lists of students they chose for review • Staff in Financial Aid, Registrar, and Business Office collaborated to collect documents.

10. Moberly Area Community College’s Preliminary Findings • Financial Aid Office Issues • Return of Federal Funds issues– Actual attendance rosters retrieved from faculty were inconsistent with system which is the data used for R2T4 calcs. • SEOG- Identified students who had award for $1; and a few awarded because Pell was decreased after conflicting information project. • FWS– Found one case in which student worked during scheduled class. • COA – Did not have sufficient evidence of how the values were determined. • SAP Appeals– Reviewers thought our process lacked integrity because every appeal they came across was approved. • 16-week Certificate of Specialization aid calculations - • LETC Certificate Program - should be calculated as clock-hour because of of Missouri’s POST requirements. • NSLC– All students were reported with same dates of attendance (did not specify special programs with alternate academic calendars) • COD – Pell COA needs to reflect each students individual COA (our system sends out one COA for all Pell recipients)

11. Moberly Area Community College’s Preliminary Findings • Financial Aid Office Issues • After review team left I was notified we were also going to be cited for requiring loan data sheet. • Electronic Announcement 03/18/2014

12. Moberly Area Community College’s Preliminary Findings • Student Services/Admissions/Other Dept. Issues: • Degree-seeking status – some records not found to document when a student changed degree status • Admissions Application– some did not support degree-seeking status reported in system • CLERY – the reviewers noted lack of missing persons, emergency, fire, VOWA policies but we were able to demonstrate before they left we had these policies. • Drug and Alcohol Policy – we could not demonstrate a biennial review. We had just updated our policy in March, 2014.

13. Moberly Area Community College’s Preliminary Findings • Business Office Issues: • The word “federal” was not on the account in which federal funds were deposited. • A case in which a refund check was not issued within 14 days • Questionable Escheatment Policy • Questioned an off-campus site address from our audit reports • Questioned our “Notice of Right to Cancel” loan statement.

14. Moberly Area Community College’s Preliminary Findings • Final Report: Expected in November • Reviewers needed more time to investigate our files and review our attendance reports. • If serious concerns are discovered they may review additional award years.

15. Moberly Area Community College’s Progress Already Made • President and Financial Aid Director shared about the experience and presented preliminary results at all-staff meeting in August • Progress.. • Attendance Issues are being addressed with a “heavier hand” to improve faculty’s efforts of keeping and reporting accurate attendance records • Attendance module has been purchased for online attendance taking. • Revised how we calculated aid for LETC students and other students in short term programs • Revised SEOG policy and other policies as needed • Requested SAP committee to be stricter, and 2nd appeals are reviewed by FA Director, attempting to strengthen the integrity of the process. • Communicated to all FWS supervisors the importance of not allowing students to work during scheduled classes (even if class is canceled) • Changed name on bank account • Software vendor is helping to address academic calendar issue for accurate reporting to NSLC/NSLDS • Admissions and Registrar are more aware of tracking and retaining degree-seeking status; also revising the admissions application to remove conflicting questions.

16. Jefferson College’s Timeline • May 2012- site visit, previous Title IV program review was 19 years prior • November 2012- received program review report listing findings • December 2012- initial file reconstructions due (within 30 days of report) • January 2013- progress report submitted and first extension granted • March 2013- next bi-monthly progress report due, granted extension • May 2013- next bi-monthly progress report due, granted extension • July 2013- next bi-monthly progress report due, granted extension • August 2013- final extension issued • October 2013- submitted response to findings and reconstructed files • October 2014- awaiting final program review determination letter

17. Jefferson College’s Preliminary Findings • Inaccurate Direct Loan Awards • Fiscal Operations Report and Application to Participate Data Discrepancies/Errors • Inadequate Campus-Based Funding Award/Selection Criteria • Improper Job Classification- Community Service Employees • Improper Payment For Federal Work Study (FWS) Hours Worked • Inappropriate FWS Timesheet Certification • Failure To Perform Direct Loan Exit Counseling • Consumer Information Requirements Not Met • National Student Loan Data System (NSLDS) Reporting Incorrect /Untimely • Failure To Comply With Drug-Free Schools And Communities Act/Part 86 • Campus Security Requirements Not Met- Policy and Procedural Deficiencies in Sexual Assault Policies • Improper Return of Title IV Funds Calculations • Return of Title IV Funds Calculation Errors • Late Return of Title IV Funds • Improper Return of Title IV Funds Policy • Attendance Not Verified Prior to Disbursement • Inadequate Monitoring of Title IV, HEA Credit Balances- Un-negotiated Checks • Incorrect Calculation of Cost of Attendance • Untimely Reconciliation of Title IV Funds • Verification Incomplete/Incorrect • Failure to Identify Federal Funds • Failure to Adequately Document Professional Judgment Decisions

18. Jefferson College’s File Reconstructions Jefferson identified by ED as an institution required to take attendance. Attendance Related Findings Dominated: • Attendance Not Verified Prior to Disbursement • Incorrect Calculation of Cost of Attendance • Improper and Late Return of Title IV Funds Calculations • National Student Loan Data System (NSLDS) Reporting Incorrect Reconstructions Collection of attendance records (2009-2010, 2010-2011, and 2011-2012) • Over 15,000 students with an F, W, or I • Over 7,800 files rebuilt (31 boxes delivered) • Spreadsheets: No-Shows, R2T4s, COAs, Un-Cashed Checks, and Verifications

19. Jefferson College’s Positive Outcomes • Greater Understanding, Value, and Support for Financial Aid • Development of Student Participation System (SPS) and Retention QI • Two tracking systems (training video) • Face-to-face and Online courses • SPS ties directly into Banner to list LDAs • Faculty access via web portal • Attendance vs. other participation (academically-related activities) • Blackboard activities • Attendance Reports for faculty and by faculty and student • Students who fail to begin attendance- financial aid enrollment adjustments made at the start of each term (16, 14, 8 week, etc.) • Students who have ceased participation in all courses for 14 calendar days- weekly monitoring to calculate R2T4s based on LDA

20. Resources • 2009 Program Review Guide http://www.ifap.ed.gov/ifap/byYear.jsp?type=programrevguide&year=2009 • FSA Assessments http://www.ifap.ed.gov/qahome/fsaassessment.html • ED Final Program Review Determinations (FY2013 & FY 2014) https://studentaid.ed.gov/about/data-center/school/program-reviews