Transcript Preparing for an ISAC Program Review

In Pursuit of Excellence
Preparing for an
ISAC
Program Review
Presented by: Kim Eck,
Illinois Student Assistance Commission
March 31, 2011
In Pursuit of Excellence
General Information
Oversight of schools is handled by ISAC’s
Compliance Department, Program Services &
Operations Division
 Most reviews are conducted at ISAC’s Deerfield
location
Purpose of the Program Review
 Evaluate compliance with state and federal rules and
and regulations
 Identify liabilities that may be owed to ISAC
 Assist in improving operations and services
 Noncompliance is generally the result of
misunderstandings or misinterpretations of rules
and regulations
In Pursuit of Excellence
Specific Objectives
To analyze the school’s data and records and identify
any areas of weakness in the school’s procedures and
recordkeeping activities
To ensure that proper internal controls, processes,
procedures, tracking and recordkeeping activities have
been established
To verify student eligibility and the documentation used
to establish eligibility
To ensure that aid does not exceed cost of attendance
and is properly credited
Provide recommendations that will strengthen the
school’s compliance with federal and state rules
and regulations
In Pursuit of Excellence
School Review Process
Responsibilities are defined by ISAC
Administrative Rules
 Part 2700, General Provisions
Announcement of review
Entrance Conference
Review of school documents, transcripts and
student records
Exit Conference
 Review of findings
 Next steps
Final Report
The Rules
In Pursuit of Excellence
Section 2700.60 Audits and Investigations
4/13/2015
 a) ISAC shall audit participating institutions of higher
learning. Postsecondary institutions participating in ISAC
gift assistance programs shall be audited once every three
years (schedule permitting) unless more frequent audits
appear to be necessary due to circumstances such as:
substantial increases in student enrollment, evidence that
the institution is experiencing difficulty meeting the
requirements of ISAC's rules or federal regulations, or
discrepancies in past audits conducted by ISAC. Secondary
institutions may be audited when ISAC has a complaint
indicating an audit is appropriate. Audits shall usually be
announced, but ISAC reserves the right to make
unannounced audits.
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In Pursuit of Excellence
Frequency of Reviews
School reviews are conducted on a threeyear cycle
 Rotating schedule
 Schedule permitting
May be scheduled more frequently due to
certain circumstances
 Evidence that the school is experiencing
difficulties meeting state and/or federal
requirements
 Default rate 20% or higher
Notification
In Pursuit of Excellence
Announcement letter is sent to the school’s financial aid
director via e-mail
 Approximately two months prior to review date
 If situation warrants, review may be scheduled on shorter notice
or without notice
Letter will include details on
 Review dates
 Academic years
 ISAC programs to be reviewed
 Materials that should be sent to ISAC in advance
 Due dates for the program review materials
Follow-up phone call will be made to
 Confirm dates of the review
 Or reschedule as needed
 Address questions or concerns
Entrance Conference
In Pursuit of Excellence
Conducted via conference call
 Should include staff members from financial aid office, registrar
and business office
 Important to have person(s) who understands school’s SAP
policy available
 May be held at the institution for on-site reviews
Explain purpose and scope of the program review
Discuss school’s population and financial aid programs
and policies
Discuss how financial aid office maintains files
Identify staff members who will be available to answer
questions
The Rules
In Pursuit of Excellence
Section 2700.60 Audits and Investigations
4/13/2015
 b) ISAC shall have access to all records related
to ISAC programs. These records include, but
are not limited to: admission records,
financial records, registration records,
attendance and enrollment records, financial
aid transcripts, grades, academic transcripts
and records maintained in accordance with
ED verification procedures.
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Documents Required for the Review
In Pursuit of Excellence
ISAC Program Review Questionnaire
 Due to ISAC: two weeks after the
Announcement Letter
School Materials
 Samples/copies of various school documents
 Due to ISAC: three weeks after the
Announcement Letter
Student Records
 For those selected in audit sample groups
 Due to ISAC: two weeks from the audit
start date
Submitting Required Materials
In Pursuit of Excellence
ISAC Program Review Questionnaire
 Intended to provide information on the
school’s financial aid operations and
procedures as they relate to the
administration of ISAC and Title IV programs
 Important to complete every question
If there are separate policies for different
programs, be sure to provide all of them for each
year being reviewed
Can be submitted via mail or e-mail
Submitting Required Materials
In Pursuit of Excellence
Program Review Questionnaire Sections
 General Information
 Recordkeeping & Administrative Capability
 Satisfactory Academic Progress (SAP) Standards
 Illinois Residency Verification
 Verification Process
 Gift Assistance Programs Payment Processing
and Reconciliation
 MAP Paid Credit Hours Monitoring
 Refunds Processing for Students
 FFELP Procedures (if appropriate)
Submitting Required Materials
In Pursuit of Excellence
School Materials
 Detailed list includes items such as:
 School catalogs
 Consumer information
 Policies and procedures for awarding, verification, refunds,
withdrawals
 If separate policies or budgets for different programs, be sure to
provide all of them
 Documentation from College Zone or College Illinois is not
acceptable; must be detailed and school-specific
 Attendance and Leave of Absence policies
 MAP institutional reports
 Items should be shipped to ISAC rather
than sent electronically
Submitting Required Materials
In Pursuit of Excellence
School Materials
 Organize to correspond to numbered list
For example:
 2. School catalogs
 3. Consumer Information
Package each category of items bundled together
with an index tab or label for easy identification
 Links to electronic documents are not
acceptable
Must print and send hard copies for review
Because the audit is for previous year, may
not be able to access old links
Submitting Required Materials
In Pursuit of Excellence
Student Records
 For selected audit samples
Academic transcripts
SAP monitoring documents
Award letters
Verification documents
 Details are included in an e-mail sent to
the school indicating the documents that
should be provided for each student
sample group
Submitting Required Materials
For example: #1: MAP Sample
In Pursuit of Excellence
Documents
Instructions
Academic Transcripts and any
Alphabetical order to match the
other documents used to report sample
grades
MAP & IIA Reconciliation
Institutional Reports
Please do not send copies of MAPnet
reports. Provide explanation of
institutional reports, and state how the
reports are used.
Withdrawal Reports
Policies and Procedures should have
the name of the institution,
department and title.
MAP & IIA Reconciliation
Procedures
Policies and Procedures should have
the name of the institution,
department and title.
SAP Probation & Appeals
Any student listed on the sample that
had SAP issues.
Sample Size
Submitting Required Materials
For example: #4: Verification Samples - MAP & IIA
In Pursuit of Excellence
Documents
Instructions
Sample Size
Copies of the 2010-11 ISIRs
Verification Worksheet
Federal Income Tax documents
(student and/or parent)
Additional pertinent verification
documents collected from the
students that support this process.
For example: #6: IVG Sample
Documents
Instructions
Academic Transcripts and any other
documents used to report grades
Alphabetical order to match the
sample
Reconciliation Procedures
Please do not send My Zone
Payment Reports
Sample Size
In Pursuit of Excellence
Submitting Required Materials
Carefully read and follow the instructions
provided for submitting materials
 Important to send requested materials to
ISAC in a timely manner
 Some requested materials can be submitted
via school’s FTP site
 Others must be sent through the mail
Clearly identify materials and samples
to correspond to the items requested
in the instructions
In Pursuit of Excellence
Submitting Required Materials
An e-mail will be sent to provide
information and instructions about audit
samples (student records) being requested
 Audit samples are sent in an Excel format and
the files are placed in the school’s MAPnet
“FTP” folder
Electronic documents sent to ISAC must be
password-protected if SSNs are included
 If sending screen prints from school
systems, be sure to protect/remove SSNs
In Pursuit of Excellence
Preparing for the Review
Advise appropriate staff of review
dates and times to ensure availability
Ensure that all applicable records will
be readily accessible during the review
 Complete student files are not required
 Unofficial transcripts are acceptable
Establish a work area for the reviewers
if the review is on-site
The Rules
In Pursuit of Excellence
Section 2700.60 Audits and Investigations
4/13/2015
 c) ISAC audits shall be conducted in
accordance with generally accepted audit
standards as promulgated by the U.S. General
Accounting Office publication "Standards for
Audit of Governmental Organizations,
Program Activities and Functions," where
applicable.
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In Pursuit of Excellence
The Review
A thorough examination of materials and audit
samples is conducted to identify:
 Discrepancies or violations of policies and procedures
 Suggestions for improvement
 Required corrective action
Findings that could result in liabilities being
assessed
 Ineligible loan or grant award
 Required refund not made or calculated incorrectly
 Incorrect student status resulting in an ineligible
payment
4/13/2015
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The Rules
In Pursuit of Excellence
Section 2700.60 Audits and Investigations
4/13/2015
 d) The institution shall be extended an
opportunity to review and comment on the
auditor's preliminary findings before the final
audit report is submitted to the institution's
chief executive officer. Audit findings may be
appealed in accordance with Section 2700.70,
Appeal Procedures.
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The Rules
In Pursuit of Excellence
Section 2700.60 Audits and Investigations
4/13/2015
 e) If an audit identifies gift assistance funds
which were claimed on behalf of ineligible
students, the funds shall be repaid to ISAC by
the institution.
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Concluding the Review
Exit Conference
In Pursuit of Excellence
 Oral report provides a summary of tentative findings
 Address next steps in the process
 Schools have five days to submit additional documentation
Preliminary Program Review Report
 Issued 14 business days after the Exit Conference
 Cites findings, regulations, requirements and liabilities
 Responses must be submitted within 21 days
Final Program Review Report
 Issued 14 business days after the response
period for the Preliminary Program Review
Report has ended
4/13/2015
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Exit Conference
Informal report on
In Pursuit of Excellence
 Findings
 Suggestions for improvement
 Discrepancies and recommended or required
corrective actions
 Amount of any liabilities assessed
 Time schedule for completing corrective action
 Tentative follow-up review date, if needed
 Format and procedure for submitting final report
 Any disputes by the school in regard to the findings
Not intended to be an in-depth discussion
or debate of the findings
Preliminary Program Review Report
In Pursuit of Excellence
Allows schools to:
 Review exceptions noted by ISAC
 Submit any documentation which may have been
overlooked or previously unavailable
Consists of
 Program Review Digest
 Findings Summary
 Verification Process
 Observations
 MAP & IIA Findings Categories
 Preliminary Summary of Liabilities
4/13/2015
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School Responsibilities
In Pursuit of Excellence
If report cites any findings:
 The school must take the required corrective
action on all findings immediately
 The school must respond to ISAC within
timeframe specified in the report, explaining
the action taken for each finding
 The school must make immediate payment
if a liability is assessed
Audit findings may be appealed in
accordance with ISAC Rules
In Pursuit of Excellence
School Response to Findings
4/13/2015
Responses or comments on findings must
be well-documented
If school agrees with findings and liabilities
assessed, a refund check is required prior
to the final report being issued
Once the findings make it to the
preliminary report, it’s too late to appeal
 Will carry forward to Final Report
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In Pursuit of Excellence
Final Program Review Report
Sent to school president and financial aid
director
Presents the final review determination and
closes the review
Includes
 Scope of Review
 Program Review Digest
 Findings Summary
 Verification Process
 Observations/Recommendations
 Summary of Liabilities
In Pursuit of Excellence
Final Procedures
ISAC reviews school’s response to
determine if corrective action was
taken.
When findings are adequately resolved,
ISAC will notify the school that the audit
is closed.
 ISAC will also notify ED’s Division of Audit
and Program Review that the audit is
closed.
The Rules
In Pursuit of Excellence
Section 2700.60 Audits and Investigations
4/13/2015
 f) ISAC may visit institutions to conduct
investigations related to fraud and abuse of its
programs. Campus administrators and/or
campus security police may be consulted as
part of any ongoing investigation
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In Pursuit of Excellence
Most Common Review Findings
Approved MAP and IIA Award Letter
Language not being used
Illinois residency not verified
MAP reconciliation issues
Overbilling
Satisfactory Academic Progress
policy either not in compliance or
not monitored
Award Letters
In Pursuit of Excellence
Schools are required to
4/13/2015
 Announce MAP awards to the eligible
students enrolled at their institutions
 Clearly identify MAP on their award
notifications as: State of IL MAP Grant (Est)
 Include required MAP language on the
school-issued award letter
 Notify applicants of changes in their
eligibility status.
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In Pursuit of Excellence
4/13/2015
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In Pursuit of Excellence
Award Letters
4/13/2015
For 2010-11, ISAC is sending an
Acknowledgement Letter upon receipt of each
student application
 A copy of the MAP Rights & Responsibilities form is
also sent with each letter.
In 2011-12, ISAC will send only Ineligible Award
Acknowledgements that include the reason for
ineligibility
 Since only ineligible applicants will receive the letter,
schools may want to provide students with a link to
the MAP Rights & Responsibilities form or to
CollegeIllinois.org
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In Pursuit of Excellence
4/13/2015
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In Pursuit of Excellence
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Award Letters
In Pursuit of Excellence
Electronic award letters
4/13/2015
 Links to electronic versions are not
acceptable for review purposes
 Must send hard copies or screen prints
If not available, then must send the template
used to program the electronic award letter
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Illinois Residency
ISAC Rules -- Sections 2700.20 and 2735.20
In Pursuit of Excellence
 Verification guidance -- Section 2700.50
4/13/2015
Recipients of MAP must be residents of the
State of Illinois.
It is the college or university’s responsibility to
ensure that all MAP recipients meet the
Illinois residency requirements.
If a student is selected for verification for
federal student assistance, the student’s
information must also be verified to
determine MAP eligibility, even if the student
is ineligible for federal student assistance.
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In Pursuit of Excellence
Illinois Residency
4/13/2015
Because ED verification procedures do not include procedures for
verifying a student as a resident of Illinois, the following
provisions shall be followed by the institution.
 1) Residency status shall be verified if the institution has any
information that indicates the applicant may not be a resident of IL.
 2) Residency status shall be verified for each applicant who is
selected for verification and has changed dependency status to
become an independent student.
 3) Residency verification shall not be required for an applicant who
received payment of a MAP award during the previous academic
year.
 4) Residency verification shall not be required for an applicant who
was enrolled in an ISAC-approved MAP institution or an ISACapproved Illinois high school (see Section 2700.30) for the preceding
consecutive 12 months prior to the start of the academic year for
which assistance is requested.
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In Pursuit of Excellence
Illinois Residency
4/13/2015
For a dependent student, the parent who is
required to complete the FAFSA must physically
reside in Illinois and Illinois must be his/her true,
fixed, and permanent home.
For an independent student, s/he must have
physically resided in Illinois at the time of
application and for 12 continuous full months
immediately prior to the start of the academic
year for which assistance is requested, and Illinois
must be his/her true, fixed, and permanent
home.
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Illinois Residency
In Pursuit of Excellence
Key Issues
 Any conflicting data must be resolved
 Important to communicate and coordinate
with admissions/records office
e.g. in-state tuition charge does not necessarily
equal Illinois residency for ISAC programs
 When school certifies payment request,
it is also certifying that the student is an
eligible Illinois student
In Pursuit of Excellence
Illinois Residency
4/13/2015
Non-Illinois students will come up in
audit samples
 Social Security Numbers are one way to
monitor
SSNs starting with 318 – 361 were issued in
Illinois
 http://www.ssa.gov/employer/stateweb.htm
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Reconciliation
In Pursuit of Excellence
Section 2735.40 m) 2) Institutional Processing of Payments
4/13/2015
 Institutions are required to reconcile payments received through
MAP and, as applicable, submit all necessary corrections to student
records on a timely basis. Any payments received by the institution
that are determined in the reconciliation to be refunds payable to
ISAC are to be processed and returned to ISAC no later than 60 days
following the end of the academic term unless ISAC has already
deducted outstanding refunds from institutional payment requests
during the applicable fiscal year. Refunds may be caused by billing
errors, retroactive withdrawals and other miscellaneous reasons.
Refunds showing as owed to ISAC must be remitted within 30 days
after the end of the institution's regular school year. Should the
payment arrive after the end of the regular school year, the
institution will have 60 days following receipt of payment to
complete the reconciliation process and return any refunds
due.
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In Pursuit of Excellence
Reconciliation
Will review records to verify that
reconciliation was completed in a timely
manner
 Using information from Comptroller showing
when money was released, when check was
cashed and when reconciliation (credits and
adjustments) took place
Important to reconcile at the end of every
term, not just at the end of the year
 Not only is it a requirement, it also results
in more accurate records
4/13/2015
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In Pursuit of Excellence
Overbilling
4/13/2015
Common issue is when credit hours
billed is greater than the enrollment
records justify
 Caused by add/drop, program changes, etc.
Student records are checked to ensure
 Appropriate adjustments were made
 There were no conflicting grants or
scholarships
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Satisfactory Academic Progress
In Pursuit of Excellence
ISAC Rules define SAP as:
4/13/2015
 An institutional policy that establishes
minimum standards of academic performance.
For purposes of ISAC-administered programs,
the standards must be at least as stringent as
those required by ED pursuant to section 484
of the HEA (20 USC 1091).
Policy must be consistently applied to all
identifiable groups
Must be as strict or stricter than school’s
standard for non-aid students
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Satisfactory Academic Progress
In Pursuit of Excellence
Audit samples should include grades
4/13/2015
 If necessary, include screen prints from
systems (e.g. Banner)
Areas reviewed include:
 Grade point averages
 Completion requirements
 Consistency in monitoring SAP at the end of
specified intervals
 Appeal process
 Communication process
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Satisfactory Academic Progress
In Pursuit of Excellence
Common SAP problem areas:
4/13/2015
 Periods of enrollment for which the student did not
receive financial aid not being counted
 Lapses in attendances
 Development courses
 Course of study changes
 Pass/fail courses
 Transfer credit policy
 Repeat courses
 Ineligible courses
 Noncredit courses
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In Pursuit of Excellence
Compliance & Fiscal Services Department
4/13/2015
Staff
 Johan Brown, Assistant Director, Compliance
and Fiscal Services
 Sharon Bankston, Compliance Examiner
 Tony Morris, Compliance Examiner
Conducts 30 – 35 reviews within a cycle
 July 1 – June 30
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Recommended Resources
In Pursuit of Excellence
FSA Assessments
 www.ifap.ed.gov
Tools for Schools
 Policies & Procedures Templates
 A Guide to Creating a Policies & Procedures
Manual
NASFAA
 www.nasfaa.org
Professional Practice Tools
 Formulating Policies & Procedures
 Self-Evaluation Guide
 Award Letter Self-Assessment Guide
4/13/2015
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Future Discussions
In Pursuit of Excellence
Compliance Webinar
 Q & A with Compliance Staff
 Summer 2011
Satisfactory Academic Progress Workshops
 Regional
 To discuss new ED rules that go into effect July
1, 2011
Financial Aid 201 Workshops
 Offered quarterly
4/13/2015
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In Pursuit of Excellence
What has worked
well for you?
Suggestions?
Questions?