Transcript Getting “Buy-In” with Regulatory compliance

Val Meyers
Associate Director
Michigan State University
MASFAA – October 2011
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Unlike many other offices on campus, Financial
Aid units know we have to watch what is
going on in Washington
Congress can give us Legislative changes,
including adding new programs (or ending
them), changing funding of existing programs,
or changing the way existing programs work
The Department of Education, interpreting
legislation, gives us Regulatory changes
The process of formulating
regulation is complex and
time-consuming
If you keep up on proposed
regulatory changes, you’ll be
more prepared when it
comes time to implement
If you see upcoming changes
that will affect other offices,
you will have time to prepare
those offices to meet their
new responsibilities
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The simple fact is that Financial Aid offices are
used to monitoring legislative and regulatory
changes, and other campus offices generally
are not…
A great deal of our work is dealing with
changes. Most other offices do not regularly
change their policies and procedures.
Other offices don’t know about federal changes
or know if one affects them.
So it is up to us to know about (and pass along)
information about changes.
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Monitors legislative and regulatory action for
your office (and the institution)
Analyzes proposed rule changes to see how
they will affect your policies and procedures
Writes summary analysis documents to
administrators about the requirements
Does your office have a designated compliance
officer?
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If regulatory changes require only changes to
Financial Aid policies and practices, making it
happen is (relatively) easy, but -If regulatory changes involve other areas, you
need to have help
REMEMBER – Regulatory requirements are
imposed upon the institution, not just the
Financial Aid office, and the institution needs
to care about complying with them!
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Monitored as the regulations went from
Negotiated Rulemaking through Proposed,
then Final
Wrote a 3-page summary of changes in the
regulations
Tried to attach affected offices/units to each
regulatory change
Sent “upward” to my director, who pushed it
up to the Associate Provost
Effects of New Department of Education Regulation
All regulations go into effect on July 1, 2011 unless otherwise noted
Admissions
 Under no circumstances can MSU take into account success in recruiting
when determining compensation of all Admissions staff, including the
Director. Merit compensation may be made on other criteria but this one
may not be included. This prohibition applies to recruiters in any part of
the university, including recruiting admits for individual colleges or
programs. (CFR 34 – 668.14)
 If the Office of Admissions were to employ third-party recruiters, they
may not be paid based upon the number of students who apply or
matriculate to the institution.
 If the Secretary of the Dept of ED or the institution have reason to doubt
the validity of a student’s high school diploma, the school now MUST
verify the validity of the diploma. The Dept of ED will begin collecting the
student’s high school on the FAFSA, and a flag will be sent to the school
with the electronic FAFSA record if the Dept of ED cannot verify the
validity of the high school. MSU must then validate the diploma. (OFA
will communicate this information to OA). (CFR 34 – 668.16)
Controller’s Office and Registrar
Modifies the criteria under which a student is considered withdrawn to include a student who
enrolls in a number of modules (courses which do not extend for the full length of the standard
semester) to consider a student withdrawn if he or she does not complete all courses for which
he or she is enrolled. This will significantly impact summer enrollment processing, as this is
the term when students are most likely to enroll in sequential rather than concurrent
coursework.
Registrar will need to modify reports to the Controller’s Office to include these students.
Controller staff will need to perform Title IV Refund Calculations on those with federal
financial aid. (CFR 34- 668.22)
Career Services, Affected Colleges, and Office of Planning & Budgets
Non-degree programs will require additional reporting to the Department of Education.
Students in certificate programs that are aid-eligible (Agriculture Technology and Veterinary
Technology) must have data sent regarding the placement rates and debt to income ratio of
those enrolled in the programs. It may be that some or all of the above offices and departments
will need to be involved in gathering and transmitting data, along with OFA as the source of
student loan debt information. See CFR 34 – 668.6 for detail of reporting requirements.
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You must make a case that compliance is
beyond the scope of Financial Aid alone
You need to get word up to a level where there
is some control over the affected units
You need to facilitate relationships that will get
the work done
Request the formation of a Task Force
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Using the first memo with tentative
assignments of unit responsibility, request
formation of a task force
Ask each Director, Dean, etc. to select
representative(s) of their unit to serve
Look for other needed representation such as
General Counsel and the Institutional Data
Reporting Unit
As the group meets, it may identify other
helpful participants
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Began with representatives from
Office of Financial Aid
 Office of Admissions
 Registrar’s Office
 Controller’s Office (Bursar)
 Career Services (Placement)
 General Counsel
 Office of Planning and Budget (Data Reporting)
 Later added representatives from two colleges
affected by Gainful Employment regulation
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Discuss what needs to be done and which
office(s) are in the best position to do them
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This is where having good partnerships helps
Having sanction from upper levels helps offices
cooperate if your relationship with them wouldn’t be
enough
With several topics, such as in Program
Integrity, agree to form subgroups for each task
In some cases, a single office has responsibility
and control, so that office can handle alone
6. Gainful Employment – Existing or new programs that are Title IV eligible, and have
new students enrolling on or after 7/1/11. These are non-degree programs only,
and graduate programs are excluded. (Registrar, Career Services, OFA,
Institutional Data Reporting, and colleges)
a. Disclosure (information advertising programs on web, promotional
materials). (Agriculture and Vet Medicine)
b. Reporting – Information for award years 2006-07 through 2009-10 due by
10/1/11.
c. New programs (established after 7/1/11) must be approved by the Dept if
aid is offered.
7. Definition of a Credit Hour – Appears MSU is in compliance, but RO should review.
8. Agreements between institutions – n/a. Applies to private institutions only
9. Verification – delayed implementation until 7/1/12. OFA only.
10. Satisfactory Academic Progress – largely in compliance. OFA, UN and GR Deans,
Academic Advisors and UUD
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Develop a web site or internal folder(s) with reference
materials
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Federal Registers
Dear Colleague Letters
Internal memos, emails, and reports
MSU has a site on Angel to post documents,
reports, internal memos
Roster of MSU participants and stakeholders
Agency or Association Definitions
Correspondence - Internal MSU emails, etc.
Governing Board - Michigan State University
News from Professional Organizations, Publications and the MSU Washington Office
Regulations - includes Federal Register
Program Integrity - also includes the 14 categories listed below
1. High School Diploma
2. Ability to Benefit
3. Misrepresentation
4. Incentive Compensation
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Keep the tasks on everyone’s radar
Volunteer to sit in on or chair meetings of
subgroups
Remind the whole group periodically of the
current status of tasks
Establish a calendar of deadline dates
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You cannot assume that things are “being
handled”. If you do, you will find out (at the
last minute) that they are not.
You need to stay involved until the routine is
established, and even then, check in
periodically to ensure it.
Be willing to go back to the beginning and start
over when it is needed – task force members
leave or become unavailable
Thank you!
Val Meyers
Michigan State University
[email protected]