uncovering the hidden liabilities in your office masfaa conference 2008 november 19, 2008 kimberly...
TRANSCRIPT
Uncovering the Hidden Liabilities in Your Office
MASFAA Conference 2008November 19, 2008
Kimberly Tibbetts Jean RickerVP for Compliance Financial Aid ManagerHigher Education Asst. Group Franklin W. Olin College of Engineering
You should leave this session knowing how to
locate tools with which to find the hidden liabilities in your office
put together a Compliance Committee develop your own internal review plan create a corrective action plan
Group Work to get you in the mood FA Forensics at Work
Compliance Committee Identify Areas of Liability Develop a periodic review plan Create an effective Corrective Action Plan
Open Discussion
1) New Academic Programs: Your Academic Department has created a new certificate program and failed to inform Financial Aid. What do you do?
2) Institutional Disclosure Requirements – Your Campus Security Office refuses to send out the annual crime statistic notification. What do you do?
3) SAP- Institutional vs. FA. A student is not making SAP for Financial Aid purposes but the institution is choosing to allow the student to remain enrolled and take courses. What do you do?
4) IT- system upgrades- your institutions integrated system periodically delivers updates/upgrades based on changes in DOE regulation- some FA related some institutionally related. Your IT Dept is behind in the installation of these upgrades which causes institutional vulnerability with regard to compliance. What do you do?
5) Withdrawals- your Registrar has a habit of back dating withdrawals and/or failing to notify FA when a student withdraws from the institution. What do you do?
Put together a Compliance Committee consisting of at least the following members: FAO Registrar Bursar/Student Account Office Admissions Academic Affairs Faculty IT
Meet every other week for the first 6 – 12 months - monthly thereafter
Develop a list of topics to discuss Currently existing issues Upcoming changes to regulations Solicit topics from other departments More topics will emerge as more meetings
take place
Allow time for each department to update the committee about what is going on in his/her area This will be your opportunity to discover what
the other departments are doing and if it will have an impact on the FAO
This opens up the opportunity for discussion and becomes a regulatory training moment
This sets the foundation for future collaboration with other departments
To ensure institutional compliance To kindly remind all departments of their
responsibilities as compliance officers To find any hidden liabilities within your
institution To develop stronger partnerships with
essential departments
Double Review Process
Create a policy and procedure (P&P) to support the following process to be performed every enrollment period
Secondary review of verification prior to disbursement
Secondary review of R2T4 prior to returning aid
To find any hidden problems before they grow exponentially If there is a consistent problem, this provides
you with the opportunity to develop a Corrective Action Plan, adjust your P&P, and retrain your staff
To give the FAO time to correct the problem before the student leaves your institution
If your office is too busy to do a secondary review…
do a mini audit before the end of the enrollment period
Remember…if you begin to find a significant number of problems, it would be best to utilize the Double Review Process
Select a small sampling of verified files Review student eligibility Review verification Review the award Review disbursed aid amounts
Select a small sampling of students who withdrew from the semester or institution Review R2T4 process Review NSLDS reporting
Cure files Alter your P&P to reflect the changes Train FAO personnel
Perform an internal compliance review to determine if there are any errors that can be corrected prior to the A133 review or before the aid year closes Use the list of Common Findings and findings
from your previous A133 reviews to develop a list of areas to review
If you have a Corrective Action Plan in place, be sure to test to ensure that your office is complying with its own plan
To find any hidden problems It is always better to know the areas that may
be problematic in an A133
To give the FAO time to correct the problem and develop a corrective action plan to have ready for the auditors if needed
Late Refund/Returns to Title IV Account Incorrect Return of Title IV Funds Calculation Entrance/Exit Counseling Deficiencies Enrollment Report (SSCR) Issues Repeat Finding-Failure to Take Corrective
Action Auditor Opinion Cited in Audit Student Credit Balance Deficiencies Verification Violations Pell Over/Under Payments
A Corrective Action Plan must describe the corrective action taken or planned in response to findings identified.
Once a problem has been identified, either though an A133 or your own FA Forensics plan, you need to develop a corrective action plan to correct the problem and ensure that it does not occur again.
Identify issues Schedule a meeting
Bring together all the folks who impact or are impacted by the issues
Be sure to include IT if the solution will require utilization of the system
Meet Lay out the problem and explain why it is an
issue Explain the regulation that must be met Brainstorm a solution
Document the solution Implement the solution Test the implemented solution Conduct a follow up meeting if any
tweaking is needed Be sure to test this area in next year’s
annual internal review audit
IFAP website FSA Assessment NASFAA Self Evaluation Guide Annual Auditor Training Conference
Higher Education Assistance Group, Inc Verification Review Form (www.heag.us) Compliance/Efficiency Guide (www.heag.us)
Share your successesWhat have you implement at your school to ensure that your institution is compliant?
How did you create a institution wide compliance team?
Anything you would like to share with the group?
Any problems to bring to the group?
Kimberly Tibbetts (617) 620-5875VP for ComplianceHigher Education Asst. [email protected]
Jean Ricker (781) 292-2343Financial Aid ManagerOlin College of Engineering [email protected]