A POLICIES AND PROCEDURES MANUAL

NYSFAAA Annual ConferenceJohn ViewDirector of EOP and Financial Aid Compliance officerOctober 2015

Quiz -?• Section 668.3 of the Title IV Regulations stipulates every

school who participates in title IV aid Must have a Policy and procedures manual.

• True or False

Answer is????

•False

A Policies and Procedures Manual is NOT:

• The FSA Handbook• A copy of the Code of Federal Regulations• A list of “things to do”

Why a Policies and Procedures Manual?

• A set of written policies and procedures to guide and manage a Financial Aid Office.

• Not required by ED, recommended

• Federal regulations require schools to have, maintain, and disclose certain policies in writing.

Why is it Important?

• Compliance requirements• External Audits and Internal Audits• Program reviews – Federal and State• Administrative capability 668.16; 668.34• Staff training• Consistency • Equity

Today’s Agenda

Evaluate what should be included Identify the differences between a policy

and a procedure Create a comprehensive manual Develop a systematic way to track and

incorporate regulatory changes

Getting Started

Policies: Required or Optional

• Federal• State• Institutional

Policies and Procedures Components

Table of contentsOrganizational chart−Institutional−Office General office information

− Mission and vision− Location and hours

Eligibility and Certification Approval Report (ECAR)Program Participation Agreement (PPA)

Policies and Procedures Components (continued)

• Accreditation Entities• Identification of programs in which your

institution participates− Federal− State − Private− Institutional

Individual policies and procedures

Broad Categories to Consider• Aid programs• Consumer Information

• Cost of Attendance• Packaging Philosophy

• Professional Judgment

• Return of Title IV Funds

Broad Categories to Consider(continued)

• Satisfactory Academic Progress

• Transfer Monitoring • Verification • Technical Considerations

• Forms• Fraud and abuse

Definition of Policy

Policies identify “why”

Explain the purpose or value− Increases understanding

Identify the applicable law or regulation Identify federal, state, institutional

Definition of ProceduresProcedures identify “how”

Identify new regulations and changes in school policies

Provide consistency Explain the process so it is understood both

by seasoned staff as well as any new staff in your office or the profession

Use Screen shots as visual aids Consider the impact to other offices’

procedures

Sample Templates – NASFAA/ED

Sample - NASFAA

Sample - NASFAA

Sample - NASFAA

Sample – ED – found on IFAP

Sample – ED from IFAP

Due Diligence Track the new regulatory

requirements throughout the year Know the implementation date Verify interpretation with colleagues

−Seek guidance from ED if necessary Take advantage of available tools

Due Diligence(continued)

• Follow the Notices of Proposed Rulemaking (NPRM) for a better understanding of the intent of any changes

− Comments − Summaries− Effective dates

Best Practices

Get a Jump Start• Gather related items

− Old manuals− Memoes− Cheat sheets− Forms− School catalog and other publications

• Beg, borrow and use existing templates or P&P manuals that a colleague may share with you

• Start simple

Getting Help • Templates and guidance

− Information for Financial Aid Professionals

− NASFAA− Google

• Be consistent• Use them as operating guides

Develop an Implementation Plan

• What • Who’s responsible• Due dates (draft and final)• Final approval• When next review

Select Format• Outline format• Columns• Paragraphs/narrative• Combination

Keep It Simple• Use common language (not FA legalise)• Spell out acronyms• Glossary of acronyms and common terms

• Not a copy and paste of the Code of Federal Regulations, FSA Handbook, or other resource materials−Make it school-specific− Include the applicable law or regulation for

quick reference, when appropriate

Divide Up The Tasks• Ask staff to take sections relative to their areas

• Set deadline and stick to them• Review portions of it at different times of the year to make it more manageable

Share the Work Load and Responsibility

• Business office• Registrar• Admissions• Processing staff• Student services• Directors• Middle management staff• Institutional Technology• Academic Governance – New programs• Others

Questions to Ask & Answer• Why add a policy or make changes?

• Who does the policy impact and in what ways?

• When is the implementation date?

• Which staff and departments should be consulted?

Ask Questions• Who has the final authority to implement or make changes?

• Are there exceptions to the policy?• What are the related forms?• How do the additions or changes “fit” with other policies? Are there any conflicts to be resolved?

• How should policies/changes be provided to other administrators?

• What campus mechanism is in place to alert FAO that a policy change may need to occur?

Assessment

Continually Evaluate Your P&P Manual……

• Provide your staff with current policies and procedures that pertain to eligibility for federal, state, and institutional programs

• Deliver general and specific responsibilities to the staff, and other departments

Does Your P&P Manual…..

• Provide general office procedures ensuring a systematic and consistent approach in the operation of all programs

• Provide quick references • Facilitate the orientation and training of personnel both In-House and Outside – (Professional Training Opportunities)

Identify Responsibilities

• Determine who will ultimately be responsible as the coordinator −Designate staff that needs to participate−Delegate assignments based upon areas of

expertise−Establish a team with members from all

relevant offices • Borrow, share, and steal from

colleagues• Include appropriate levels of

management and departments for review and approvals

Remember……..• Doesn’t need to be complicated to be effective

• Don’t be caught not following your own policies and procedures

Next Steps

Stay on Top of Updates• Review annually at a minimum• Identify who has access to both review and update

• Track regulatory changes− Ifap.ed.gov− Federal Register/ NASFAA News

• Read the comments and summary as well as the regulations

• Check student files through internal file reviews

• Follow your own procedures

Tips of the Trade-From our Colleagues

Be sure to: Make sure your policies are consistent with

federal and state regulations; compliance is huge

Review them with staff Update them continually with corrections or

when regulations change Start working on them well before you need

(yesterday) Delegate the updates

Final Developments• Make the review a part of your annual calendar

• Implement a user-friendly, easy-to-read format

• Make hard copies or electronic back-up of old P&Ps

• Share with all relevant employees• Post online/file share

Questions and Thank you!