Transcript Getting Ready for Auditors

Getting Ready
for the Auditors
A school’s guide to
preparing for
annual audits
Copyright 2009 National Student
Loan Program
FSA participation requirement
• Annual financial and compliance audits
– conducted by qualified independent auditor
– submitted to ED within six months of school’s
(or servicer’s) fiscal year end
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Audited financial statement
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Most recently completed fiscal year
Detailed description of related entities
Details of related parties
Other documentation as requested
For proprietary schools
– percentage of revenue derived from Title IV
programs
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Compliance audit
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Most recently completed fiscal year
All Title IV transactions in fiscal year
All transactions since last audit
Type of audit depends on school type
– for-profit schools use Inspector General’s
Audit Guide
– public and nonprofit schools use OMB
Circular A-133
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Annual audit waiver
• Annual audit requirement may be waived if
certain criteria met
• If waiver granted, audits not required until
– end of third fiscal year
– end of second fiscal year if recertification
award year is part of third fiscal year
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Questions?
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Preparing for the auditors basics
• Be prepared to explain institutional policies
and procedures
• Make sure all existing policies and
procedures are in writing
• Know who does what at your school
• Have the people who can answer the
questions available to answer questions
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Pre-visit preparation
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Provide list of Title IV recipients to auditor
Reserve a work space / computer
Arrange for access to SIS
Announce visit dates to impacted campus
offices
• Gather standard documents needed
• School P & P Manual should be handy
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Pre-visit preparation (con’t.)
• Review findings (if any) from last year
• Show what was done to improve
• Create documentation for eligibility
application and program summary grids
• Student budgets and award philosophy
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Institutional eligibility and
participation
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Program participation agreement
State authorization to operate
Accreditation documents
Any third party agreements—outsourcing
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Reporting
• Last year’s FISAP
• Pell statement of account
• State reports
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Student eligibility
• Documentation to show;
– regular student in an eligible program
– meeting SAP standards
– not in default / owe repayment
– EFC result—verification completed
– passed federal matches (drug, citizenship,
etc.)
– enrollment status
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Perkins loan
• Final FCC allocation & LOL
• List of recipients with backup to document
their eligibility for this fund
• P-note signed prior to disbursement
• FA awards = business office
disbursements
• Annual/Aggregate limits not exceeded
• Amount used for administration allowance
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SEOG
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Final allocation
List of recipients and their eligibility
Awarded first to Pell eligible students
Annual maximum award not exceeded
Document transfers from FWS/Perkins
Amount used for administration allowance
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FWS
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Final allocation
List of recipients and their eligibility
Proof of hours worked compared to paid amount
Proof of eligibility to work and pay rate
Hours worked not in conflict with class schedule
Transfer of funds to SEOG and administration
allowance
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PELL / ACG / SMART
• Origination and disbursement records
submitted and accepted
• Award amount calculated correctly based
on enrollment
• New/changed awards reported within
timeframes
• General and specific program eligibility
met
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DL / FFELP
• Student eligibility for subsidized and/or
unsubsidized documented
• Submitted properly executed application
and/or P-note to lender / DOE
• Account for receipt of funds and
disbursement
• Lender / DOE notified properly if student
withdraws
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Disbursements
• Campus-based, Pell, Direct Loans;
• Three business day rule
– drawdown compared to disbursement
• Stafford
– generally three days
– thirteen if temporarily ineligible
– forty-five if verification not complete
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Return of Title IV funds
• Provide list of impacted students
• Document:
– last day of attendance
– refund calculation
– show when funds returned
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Administrative capability
• Continual negative findings may lead to a
question of administrative capability
• Could lead to fines or ineligibility
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Close out
• Eventually, DOE will provide a letter to the
Chief Executive Officer accepting the audit
report and closing out that year.
• DOE is getting better in doing this sooner
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Questions?
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Resources
• OMB Circular A-133
http://www.whitehouse.gov/omb/circulars_
a133/
• OIG Audit Guide
http://ifap.ed.gov/aguides/attachments/sfg
d2000.pdf
• OGA Government Auditing Standards
http://www.gao.gov/govaud/govaudhtml/in
dex.html
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Resources (con’t.)
• 2008-2009 Federal Student Aid Handbook
Volume 2 Chapter 12, “Program Integrity”
http://ifap.ed.gov/fsahandbook/attachment
s/0910FSAHbkVol2Ch12Integrity.pdf
• The Blue Book Chapter 8, “Program
Integrity”
http://ifap.ed.gov/bbooks/attachments/100
5BlueBookCh8ProgramIntegrity.pdf
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Contact information
Policy Department
National Student Loan Program
[email protected]
1-800-735-8778 ext. 6873
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