Transcript Surviving a Program Review

Surviving a Program Review
• Intro of Audit History at LTU
– Internal, External, State CB, VA, Program
Review
• Not an expert - don’t play one on TV
• Not providing secrets how to fool an
auditor, a recent survivor, that’s all
• LTU still waiting for final report from
Denver Case Management Team
Presentation Scope
• Who (Internal, External/Independent,
State, Guaranty Agency, DOE, VA,
Institutional Partners, etc.)
• What (FA records only? – Not)
• Where (Onsite, Offsite, Electronic)
• When (When they say)
• How (As painless as possible)
Who
• Internal Auditors
• External/Independent Auditors
– A-133
• State
– Campus Based
– State Programs
– Loan Programs
• Title IV Program Review
– Schools with 25% cohort default rate higher priority
– Highest 25% of defaulted loan volume school higher
priority
Who (Program Review)
• Higher priority schools
– 25% cohort default rate higher priority
– Highest 25% of defaulted loan volume schools
– Schools with high fluctuation in Stafford loans or Pell
Grant
– Schools reported by state agency or accrediting
agency
– School with high drop out rates
– School determined to pose significant risk of failing to
comply with administrative capability or financial
responsibility
Who’s Involved at Institution
• Institutional Partners
– Registrar
– Business Office
•
•
•
•
–
–
–
–
–
–
–
VP of Finance
Controller
Student Accounting
Accounts Payable
Career Services
IT Staff
Associate Provost Enrollment Mgt (FA Director Reports To)
Admissions Director
President
Campus Safety
Marketing Staff
What
• List was provided of all T4 recipients for last 3 years not
including current year
• Catalog
• Program Participation Agreement
• Third Party Servicer Agreements
• A-133 and copy of independent audit
• FISAP
• Campus Based Statement of Accounts
• Policy & Procedures (provide what you have)
• Admissions and Registration/Transcript Data
• Campus Security Report
• See handout (request from reviewer)
What To Expect from Program
Review
• Written Notice
• Entrance Interview and Explanation to Campus
Attendees
• Extensive Review and Requests
• Exit Interview
• Provide Follow Up Information
• Written Report Within Approx. 60 Days
• Appeal Final Audit Determination Letter (FADL)
or Final Program Review Determination Letter
(FPRD)
Where
• You know they’re watching
– Case Management Team is watching your electronic
activity and independent audits
– Pre-review activity in Denver
– Onsite for actual review
• Seems to be a big push for Program Reviews in
Michigan
• LTU had State CB, Merit, TIP audit offsite (2004)
– Had to ship student data and reports (transcripts,
ISIRs, Award Package Worksheet, Employment
Records, etc.)
When
• Be ready at all times
• Could be unannounced - written request for review is
required but could be provided when arrive to school
• I received call from Denver Case Management Team on
November 16th
– Week of December 12th Program Review
– Needed data file of unduplicated T4 recipients by December 2nd
– Called all necessary campus partners together for prep (& pep)
meeting immediately
– Updated policy & procedure documentation immediately
• Provided everything on checklist in neat format to the
“Resource” room day before review
How (We Prepared)
• Updated web and printed materials
– Consumer information
– Policy & procedures
• Labeled and organized requested
materials in binders, logically categorized
• Printed student data from information
system on request (not much advanced
notice the first day of the review)
Discussion & Examples
• Sample Letter to President Announcing
Program Review and List of Requested
Items
• Program Review Guide
– http://www.ifap.ed.gov/IFAPWebApp/currentIposGuidancePag.jsp
• Sample Institutional Responsibility Guide
• NASFAA Self Evaluation Guide
– http://www.nasfaa.org/publications/2005/selfeval21.asp (for members)
Discussion & Examples
• Additional References
– IFAP
– SFA Handbook
• Section on Administrative Capability is very
important
• 25% of annual refund amount may be required as
a Letter of Credit
– Federal Registers
– Compilation of Federal Regulations
– NASFAA Encyclopedia
Recommendations
• Be honest and forthright
• Be prepared (know FSA Handbook in & out)
– Provide and organize all requested material
• Be polite and hospitable
– Provide a comfortable setting
– But don’t cross the line (don’t offer food or drink)
• Be responsive
– Make sure staff within and without OFA are available
– If you get a request, provide response with 24 hours
– Your program reviewers have jobs too, and they are
reviewed for their results, the more successful you
make them, the better they will treat you.
Recommendations (continued)
• Start preparing now
– LTU is developing a semi-annual self evaluation process
•
See reference material mentioned earlier
– Work with NASFAA Peer Evaluation Process
– Review all consumer information and requirements
• We reviewed print and web material prior to review
• Every day, every decision should be made with the idea that the
results of that decision could end up in the hands of an auditor for
review
– Stress this to staff (internal and external to OFA)
– Keep files neat and orderly (no chance to organize upon request)
– Be prepared to print student data from Information System (FA,
Registration, Admissions, Student Accounting, etc.)
• Really pay attention to R2T4 and SAP
• Communicate extensively with departments outside of OFA
Recommendations (continued)
• Make sure other departments appreciate why
they do the things they do (withdrawal
notification, update Clearinghouse, Campus
Security Report, etc.)
• Ask the auditor for “best practice” advice
– They are there to help as well
– Advice may be vague, but it shows a willingness to
improve
• Challenge external auditor finding because
these findings can end up on A-133 which is
reviewed by Case Management Team Member
(Institutional Review Specialist)
Recommendations
• Example of a challenge at LTU
– Independent auditor found that our enrollment
status changes were not getting to NSLDS
within 30 days.
• Found that as long as we are on a schedule of
updates every 60 days, the ad hoc reporting
requirement of 30 days is not in effect
– Was challenged on BBAY and offering
additional loan funds for Summer (3rd
semester)