Surviving a Program Review

1
Surviving a Program Review

• Intro of Audit History at LTU
• Internal, External, State CB, VA, Program Review
• Not an expert - dont play one on TV
• Not providing secrets how to fool an auditor, a
  recent survivor, thats all
• LTU still waiting for final report from Denver
  Case Management Team

2
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)

3
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

4
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

5
Whos 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

6
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)

7
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)

8
Where

• You know theyre 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.)

9
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

10
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)

11
Discussion Examples

• Sample Letter to President Announcing Program
  Review and List of Requested Items
• Program Review Guide
• http//www.ifap.ed.gov/IFAPWebApp/currentIposGuida
  ncePag.jsp
• Sample Institutional Responsibility Guide
• NASFAA Self Evaluation Guide
• http//www.nasfaa.org/publications/2005/selfeval21
  .asp (for members)

12
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

13
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 dont cross the line (dont 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.

14
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

15
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)

16
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)