5of Creating and Maintaining a Compliant Policy

and Procedure Manual

Presented by: Chyrl R. Ayers, COOGlobal Financial Aid Services, Inc.

SASFAA 2013 50th Anniversary ConferenceFebruary 11, 2013, 3:45 – 5 pm

Dunwoody A

‘s

WELCOME

Learning Objectives

WHYmust a P&P manual be maintained?

WHATis required?

WHO is responsible to create and maintain?needs access?

WHERE to store and methodologies utilized?

WHEN should it be reviewed and updated?

• Why required?• Why does a manual make sense?

WHY?

• Separate manual; or• Cross-reference to manual(s) already in

existence.

Note: You may want to consider using icons to represent different areas for quick reference in your P&P manual.

Considering Different Configurations

• Good Practice

Different Types of Icons

• Tip• Policy• Important• Exception• Definition (some prefer a Glossary in this area)• Checklist• Example• NEW

• What content to include?

WHAT?

• Federal Pell• FDSL• Campus-based Funding

– FSEOG– FWS– Federal Perkins

• Teach Grant

Packaging Philosophies and Procedures

• Do you package loans only up to the direct cost and allow the student to request additional loan funds for living expenses?

• Do you package for the full annual limits and then reduce if requested by the student?

Packaging Philosophies and Procedures Considerations

• If packaging for less than a full annual amount, how are students made aware of the maximum amount they can borrow?

• How do you monitor funds received from other sources (i.e. scholarships, foundation funds, employer payments, state grants, etc.) to ensure student is not overawarded?

Packaging Philosophies and Procedures Considerations

• If a student’s Title IV aid package must be reduced due to receipt of a scholarship, how is the student notified?

• What is your process for packaging:– Transfer students in an open loan period?– Re-entry students?– Students who change programs?

Packaging Philosophies and Procedures Considerations

P&P Regulatory Citation Related to Federal Pell

• 690.63 Calculation of Federal Pell Grant Awards

• 690.80 Requirements and optional recalculation

• 690.81 Fiscal Records and Disbursement requirements

• H.R. 4137 Iraq and Afghanistan Service Grant Program

• Requirements for determination of Federal Pell Grant;

• What situations require recalculation?• Do you recalculate under optional

situations?• How and when you disburse and report?• Procedures for handling and disbursing the

Iraq & Afghanistan Service Grant

Basic Federal Pell Considerations

• 685.102(b) Packaging Policies for FDSL• 685.304 Counseling Borrowers• 685.306 Payment of refunds or RT4• 685.309 Administrative and Fiscal Control

P&P Regulatory Citation Related to FDSL

Outline the procedures to determine the appropriate award amounts.

• Do you always award the maximum?• Do you consult with the student first in

determining the award amounts?• Do you package direct and indirect or only direct?• How does the student request indirect/living

expenses?

Basic DL ConsiderationsAwarding Process

Outline the procedures to determine parent’s eligibility under the PLUS program

• How do you determine the amount?• How do you notify they parent of eligibility and/or awarded

amount?• What is the process if a parent requests online through

COD?• How do you collection information to document the

parent’s requested amount?• How do you provide information to the parent related to

PLUS?

Basic DL ConsiderationsPLUS (Parent Borrower)

Outline the confirmation process for loans• Active or passive?• Must document how you handle each academic

year in which loans are made to students

Basic DL ConsiderationsConfirmation Process

• Loan Counseling – outline your procedures for loan counseling and include entrance and exit processes.

• Disbursement Notification Letters – include your procedures on how and when notifications are made to borrowers when a direct loan occurs.

Basic DL Considerations

• 676.10 Selection and Awarding• 676.19 FSEOG Fiscal Procedures and

Records

P&P Campus-based Funds - FSEOG

Should include your procedures for awarding of FSEOG

• Reviewed and maintained for each award year;• How students are informed of eligibility and

selection criteria for determining award amount.• If information is contained in catalog or

consumer information, you should still have a written policy on FSEOG

Basic FSEOG ConsiderationsAwarding Policy

Should include details on how you meet the institutional matching requirements.

Note: This process should be the same each award year; therefore, one policy may cover several award years. The award years covered by the policy should be noted in the policy.

Basic FSEOG ConsiderationInstitutional Match

• 675.10 Selection and Awarding• 675.20; 675.21; 675.2(b); 675.18(g) Assigning

FWS Jobs• 675.19 Fiscal Procedures and Records• 675.36 Job Location and Development-

Procedures and Records• 375.49 Work College Program-Procedures and

Records

P&P Campus-based Funds - FWS

• Application material;• How students are notified of available

positions;• How hourly wage is determined;• How the interviewing and hiring process

works; and• Policy on limiting the number of hours

worked.

Basic Consideration FWSSelection Process

• Selection process for off-campus employers;

• Written off-campus FWS Agreements:– Who is considered the employer for purposes

of hiring, terminations and pay rate?– Who is responsible for required cost such as

nonfederal share social security and workman’s compensation?

– Who is responsible for payroll?

Basic Consideration FWSOff-campus Employers

Outline the payroll procedures used for FWS students

• Timesheet process;• Frequency of payment;• Method used for paying student;• Procedures for documenting payroll made by off-

campus employers; and• How the required institutional match is made

(school or off-campus employer)

Basic Consideration FWSPayroll and Non-federal Share

Include how community service requirements are met (7% of your allocation with at least one position as a reading tutor or performing family literacy).

Basic Consideration FWSCommunity Service

• 674.10 Selection and Awarding

• 674.31 Perkins MPN• 674.16 Perkins Loan

Disclosure• 674.19 Fiscal

Procedures and Records

• 674.33(d) Forbearance

P&P Campus-based Funds – Federal Perkins

• 674.38 Deferment• 674.42 Contact

Borrower• 674.43 Billing• 674.45 Collection• 674.46 Litigation• 674.52 Cancellation

• Eligibility requirements;• Selection procedures; and• Criteria for determining the award amount.

Basic Consideration Federal PerkinsAwarding Policy

Loan Counseling - Should include both entrance and exit counseling processes

Cumulative Balance Owed – Procedures used to notify student of the cumulative balance owed and the expected payment amount. Must be provided each award year prior to 1st disbursement of a Federal Perkins loan.

Basic Consideration Federal Perkins

• Maintenance of MPN (fireproof container or cabinet);• Procedures for returning MPN to the borrower after loan

is satisfied;• Storing of loan records – deferments, cancellations,

forbearances, repayment schedules and other correspondence with borrower; and

• If you use e-sign you must document your e-sign procedures.

Basic Consideration Federal PerkinsRecordkeeping

Disbursement Notification Letters – include your procedures on how and when notifications are made to borrowers when a loan occurs.

Red Flag Rules – procedures should include how you comply with the FTC’s Red Flag Rule

Basic Consideration Federal Perkins

Outline confirmation process for loans• Active or passive?• Must document how you handle each

academic year in which loans are made to students.

Basic Consideration Federal PerkinsConfirmation

This section should include the processes used in servicing the Federal Perkins loans:

• Borrower contacts;• Billing procedures;• Default and collection procedures;• Cost assessed to borrowers; and• Perkins assignment.

Basic Consideration Federal PerkinsServicing Procedures

Note: If you use a server for your Perkins, the servicers’ efforts in these areas would be included in the P&P manual. You need to outline who is responsible for what and anything shared.

Basic Consideration Federal PerkinsServicing Procedures

• 686.10; 686.11 Eligibility Determination• 686.32 Counseling• 686.36 Fiscal Control and Funds

Accounting

P&P Campus-based Funds – TEACH Grant

• Exit counseling for student who does not complete counseling on NSLDS website;

• Any additional counseling you may perform for TEACH Grant recipients; and

• How you verify enrollment in an eligible program and verity student’s GPA to ensure eligibility for TEACH disbursement.

Basic Considerations TEACH Grant

• 691.15; 691.16; 691.17 ACG and National SMART Eligibility Requirements

• 668.3; 691.62; 691.2(d); 691.6 Calculating ACG & National SMART

• 691.81 Fiscal Control and Fund Accounting

P&P Campus-based Funds – ACG/SMART (Not currently funded)

Written policy that indicates the following:• Time period for student to provide documentation;• Consequences of failure to submit;• Method used to notify changes of EFC & change

to TIV awards;• Procedures to follow when it is necessary to

correct FAFSA data; and • Procedures followed if referral of student to OIG.

Verification – 668.53

This policy must be made available to all students selected for the process of verification.

Verification – 668.53

Requests for PJ’s• How students are made aware of the

availability to be considered for this process;• Process by which student applies for PJ; and• Standard forms or other documentation

required.

Professional Judgment (PJ) – 479A and 668.5(c)

PJ’s decision – How students are notified of the decision and this should include the results of awards being revised based on approval.

Professional Judgment (PJ) – 479A and 668.5(c)

Methods of Monitoring SAP• Automated or manual process?• Who monitors SAP?• How often is SAP reviewed?• How is FA notified of the failure of SAP?

Satisfactory Academic Progress (SAP)668.16(e) and 668.34

Procedures for FA Warning and Probation• How are students notified?• What are the appeal procedures• Who prepares academic plan and monitors

them to ensure student is meeting the requirements of the plan?

How are students notified of the SAP policy?

Satisfactory Academic Progress (SAP)668.16(e) and 668.34

Procedures for posting of disbursements to students’ accounts timely and accurately including procedures to ensure funds are posted in 3 days.

Procedures for handling credit balances:• Monitoring of students with credit balance

authorization forms;

Student Accounts668.164

• For students with credit balance authorization forms; how do you monitor and ensure credit balances are handled within the 14-day requirement of end of loan period (or award year if loans are not awarded), or within 14-day requirement of graduation;

Student Accounts

• For students that do not authorize the holding of credit balance, how do you monitor the issuance within the 14-day requirement?

• How does the student rescind authorization to hold credit balance?

• Who monitors and handles late disbursements that post that might cause a credit balance which may need to be issued within the 14-days?

Student Accounts

Rosters – process for completing and returning rosters including the schedule followed.

NSLDS Reporting

• Process for reporting changes in enrollment status;

• Who is responsible?• How the responsible party receives

notification of change.

Enrollment Status Changes

• Process for adding a student to monitoring;

• Who is responsible?• How the responsible party receives

notification of change.

Transfer Student Monitoring

Schools refund policy including Return to Title IV (R2T4)

Note: School refund policy may change so it is important to note in the P&P the various policies and effective dates.

Process of coordination between departments (academics, business office and financial aid).

Procedures for return of unearned aid or refunds resulting from school refund policy or R2T4.

Withdrawals/TIV Refunds668.22

Notification process of results• Refund calculations;• Return to TIV programs;• Post Withdrawal Disbursements (PWD)-

– Process to notify students of eligibility for PWD;– Process for tracking PWD’s awaiting authorization

student or parent;– Process for disbursement of PWD; and– Process to notify and deliver credit balance resulting

from PWD.

Withdrawals/TIV Refunds668.22

Updating NSLDS and loan servicer due to enrollment status change.

Process for handling Exit Counseling (covered in DL section of P&P)

Default Management Plan

Withdrawals/TIV Refunds668.22

Distribution of Consumer Information 601.11; 601.30; 668.14; 668.41 – 668.49; 668.164(i)

 Procedures for meeting requirements for Constitutional Day

 Procedures for distributing voter registration (if your state has not enacted the vehicle/voter registration provision)

 Validity of HS Diploma (if issue is raised)

Miscellaneous

Leave of Absence Procedures

Job Descriptions of Financial Aid Employees & Adequate Staffing 668.16(b)

Procedures for G-845 668.135

Resolving Conflicting Information 668.16 (f)

Resolving Comment Codes (C-Flags)

Miscellaneous

Cost of Attendance for each award year and back up documentation on how the figures are determined

Academic Year Definition (if more than one used, the section should document this by program)

Title IV Formula (if more than one used, the section should document this by program)

Programs subject to clock to credit conversion 

Miscellaneous

• Who should create manual?• Who should update?• Who needs access to manual?

WHO?

• Where to maintain the completed manual?

WHERE?

• When should it be updated?

WHEN?

• NASFAA• IFAP• ListServs• Peers

Resources

Lesson Learned

• SAP• Verification• Refunds & R2T4• Selection Criteria for CBF• Admission Criteria• Consumer Information

Most Frequently Requested Polices and Procedures for a Program Review

Contact Information:

Chyrl R. AyersChief Operating Officer

Global Financial Aid Servicescayers@globalfas.com

228-523-1030

Q & A