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!