Inside a Program ReviewSharon Abernathy, Columbia College

Amy Hager, Moberly Area Community College

Sarah Bright, Jefferson College

• July 15, 2014 – Received “the call” from ED of Announced On-site Program Review on 8/18; No previous Title IV program review

• July 20, 2014 – 1st submission of required docs due to ED• August 7, 2014 - 2nd submission of required docs due to ED• August 18, 2014 - Site visit, Additional docs required

First Day of Fall session Auditors also on site

Weekly updates to President

Columbia College’s Timeline

• Met with President, Academic Dean, CFO, and supervisor• Involved Registrar, Bursar, Dean of Students, HR, Office of Compliance,

Institutional Research and “a cast of hundreds” in subsequent planning meetings

• Developed Sharepoint site for coordination of documents/information• Identify and assign responsibility to key stakeholders for requested items

w/deadline dates (ex. Campus Safety reports, Drug and Alcohol disclosures, consumer information, admission policy, etc.)

• Follow-up meetings for progress updates• Room reservation; refreshments; parking pass; key for secure

environment; technology access (wi-fi, printer, copier)

Columbia College’s Preparation Plan

Included all of the key administrative staff; Four program reviewers; no definite timeline for length of stay (one week or more depending on the review)

– Two hour interview with FA Director – Meetings with CFO, Registrar, Director of Admissions– Student file review– Requests for FWS job descriptions/timecards,

attendance policy, community service contracts

Entrance ConferenceAugust 18, 2014

Preliminary concerns:1. R2T4 – Determination date; online student attendance 2. Perkins loan assignment to ED (due diligence on old paper)3. Credit balances – paper checks within 14 days; holding without authorization4. SAP – Transfer credit not included in calculation5. Definition of AY and loan disbursements (refers to 8 week sessions)-more research

needed by reviewers and CC 6. Loan periods (overlapping sessions combined into one term)7. FA shopping sheet – improve access for non-admitted students8. SEOG policy – set some aside for awarding later in year9. Undeclared/undecided majors – aid awarded after 60 credit max.

Exit Conference-8/22/14President, CFO, CIO, Academic Dean, FA Leadership Staff

Preliminary concerns (cont.):

10. PJs and D/O – internal approval documentation/closing the loop 11. Verification/Inaccurate ISIR transaction 12. COD – AY week discrepancy13. Online course attendance – reviewers accessed online courses to verify grades &

attendance in FAMS; requested continued access after they left14. Alumni Referral Grant – might be considered an incentive15. FWS – incomplete job desc., students working during class time, more than 20

hours (outside of policy) Final Report: “Won’t see before first of year”

Exit Conference-8/22/14President, CFO, CIO, Academic Dean, FA Leadership Staff

• April 21, 2014 – Received “the call” from ED of Announced On-site Program Review on May 19, 2014; No previous Title IV program review

• April 29, 2014 – Aid recipient data was submitted to ED • (2012/2013 and 2013/2014 students only)

• May 5, 2014 – 1st submission of required docs due to ED• May 12, 2014 - 2nd submission of required docs due to ED• May 19-23, 2014 - Site visit, Additional docs required • May 29, 2014 – Submitted additional student files and docs requested

by ED• October 9, 2014 – Received follow-up call from reviewer for additional

information >>>>>Have not received response file to date<<<<<

Moberly Area Community College’s Timeline

• Met with President and CFO to prepare plan• Met individually with CIO, Director of Computing Resources,

Registrar, Business Office Manager, Dean of Students, Dean of Off-Campus Programs and Instructional Technology, Director of Instructional Technology, Director of Human Resources, Director of Security, Director of Plant Operations • Informed each division about the review and discussed their part and

responsibilities • Arranged all logistics (work room, parking, keys, technology, copier,

printer, etc)

If interested in documents requested, an example of letter received is available.

Moberly Area Community College’s Preparation Plan

• Four ED staff; lead reviewer and three others• Phone conferences were conducted with Business Office,

Registrar, and Admissions prior to on-site visit. • On May 19, they met with President, VP Instruction, VP

Finance, and other key staff.• Financial Aid interview – included director, assistant director and

coordinator of FA at Columbia campus who is primarily responsible for R2T4.

• Reviewers presented lists of students they chose for review• Staff in Financial Aid, Registrar, and Business Office

collaborated to collect documents.

Moberly Area Community College’s Entrance Conference

Moberly Area Community College’sPreliminary Findings

• Financial Aid Office Issues

• Return of Federal Funds issues – Actual attendance rosters retrieved from faculty were inconsistent with system which is the data used for R2T4 calcs.

• SEOG - Identified students who had award for $1; and a few awarded because Pell was decreased after conflicting information project.

• FWS – Found one case in which student worked during scheduled class. • COA – Did not have sufficient evidence of how the values were determined.• SAP Appeals – Reviewers thought our process lacked integrity because every appeal

they came across was approved. • 16-week Certificate of Specialization aid calculations - • LETC Certificate Program - should be calculated as clock-hour because of of Missouri’s

POST requirements.• NSLC – All students were reported with same dates of attendance (did not specify

special programs with alternate academic calendars)• COD – Pell COA needs to reflect each students individual COA (our system sends out one

COA for all Pell recipients)

Moberly Area Community College’sPreliminary Findings

• Financial Aid Office Issues

• After review team left I was notified we were also going to be cited for requiring loan data sheet. – Electronic Announcement 03/18/2014

Moberly Area Community College’sPreliminary Findings

• Student Services/Admissions/Other Dept. Issues:

• Degree-seeking status – some records not found to document when a student changed degree status

• Admissions Application – some did not support degree-seeking status reported in system

• CLERY – the reviewers noted lack of missing persons, emergency, fire, VOWA policies but we were able to demonstrate before they left we had these policies.

• Drug and Alcohol Policy – we could not demonstrate a biennial review. We had just updated our policy in March, 2014.

Moberly Area Community College’sPreliminary Findings

• Business Office Issues:

• The word “federal” was not on the account in which federal funds were deposited.

• A case in which a refund check was not issued within 14 days• Questionable Escheatment Policy• Questioned an off-campus site address from our audit reports• Questioned our “Notice of Right to Cancel” loan statement.

Moberly Area Community College’s Preliminary Findings

• Final Report: Expected in November• Reviewers needed more time to investigate our

files and review our attendance reports.

• If serious concerns are discovered they may review additional award years.

Moberly Area Community College’s Progress Already Made

• President and Financial Aid Director shared about the experience and presented preliminary results at all-staff meeting in August

• Progress..• Attendance Issues are being addressed with a “heavier hand” to improve faculty’s

efforts of keeping and reporting accurate attendance records• Attendance module has been purchased for online attendance taking.

• Revised how we calculated aid for LETC students and other students in short term programs

• Revised SEOG policy and other policies as needed• Requested SAP committee to be stricter, and 2nd appeals are reviewed by FA

Director, attempting to strengthen the integrity of the process.• Communicated to all FWS supervisors the importance of not allowing students to

work during scheduled classes (even if class is canceled)• Changed name on bank account • Software vendor is helping to address academic calendar issue for accurate

reporting to NSLC/NSLDS• Admissions and Registrar are more aware of tracking and retaining degree-

seeking status; also revising the admissions application to remove conflicting questions.

• May 2012- site visit, previous Title IV program review was 19 years prior• November 2012- received program review report listing findings• December 2012- initial file reconstructions due (within 30 days of report)• January 2013- progress report submitted and first extension granted

– March 2013- next bi-monthly progress report due, granted extension– May 2013- next bi-monthly progress report due, granted extension– July 2013- next bi-monthly progress report due, granted extension

• August 2013- final extension issued• October 2013- submitted response to findings and reconstructed files

• October 2014- awaiting final program review determination letter

Jefferson College’s Timeline

Jefferson College’s Preliminary Findings1. Improper Return of Title IV Funds

Calculations2. Return of Title IV Funds Calculation

Errors3. Late Return of Title IV Funds4. Improper Return of Title IV Funds Policy5. Attendance Not Verified Prior to

Disbursement6. Inadequate Monitoring of Title IV, HEA

Credit Balances- Un-negotiated Checks7. Incorrect Calculation of Cost of

Attendance8. Untimely Reconciliation of Title IV Funds9. Verification Incomplete/Incorrect10. Failure to Identify Federal Funds11. Failure to Adequately Document

Professional Judgment Decisions

12. Inaccurate Direct Loan Awards13. Fiscal Operations Report and Application to

Participate Data Discrepancies/Errors14. Inadequate Campus-Based Funding

Award/Selection Criteria15. Improper Job Classification- Community Service

Employees16. Improper Payment For Federal Work Study (FWS)

Hours Worked17. Inappropriate FWS Timesheet Certification18. Failure To Perform Direct Loan Exit Counseling19. Consumer Information Requirements Not Met20. National Student Loan Data System (NSLDS)

Reporting Incorrect /Untimely21. Failure To Comply With Drug-Free Schools And

Communities Act/Part 8622. Campus Security Requirements Not Met- Policy

and Procedural Deficiencies in Sexual Assault Policies

Jefferson identified by ED as an institution required to take attendance.Attendance Related Findings Dominated:• Attendance Not Verified Prior to Disbursement• Incorrect Calculation of Cost of Attendance• Improper and Late Return of Title IV Funds Calculations• National Student Loan Data System (NSLDS) Reporting Incorrect

ReconstructionsCollection of attendance records (2009-2010, 2010-2011, and 2011-2012)• Over 15,000 students with an F, W, or I• Over 7,800 files rebuilt (31 boxes delivered)

– Spreadsheets: No-Shows, R2T4s, COAs, Un-Cashed Checks, and Verifications

Jefferson College’s File Reconstructions

• Greater Understanding, Value, and Support for Financial Aid• Development of Student Participation System (SPS) and Retention QI

– Two tracking systems (training video)• Face-to-face and Online courses

– SPS ties directly into Banner to list LDAs– Faculty access via web portal– Attendance vs. other participation (academically-related activities)– Blackboard activities

• Attendance Reports for faculty and by faculty and student– Students who fail to begin attendance- financial aid enrollment

adjustments made at the start of each term (16, 14, 8 week, etc.)– Students who have ceased participation in all courses for 14 calendar

days- weekly monitoring to calculate R2T4s based on LDA

Jefferson College’s Positive Outcomes

– 2009 Program Review Guide http://www.ifap.ed.gov/ifap/byYear.jsp?type=programrevguide&year=2009

– FSA Assessments http://www.ifap.ed.gov/qahome/fsaassessment.html

– ED Final Program Review Determinations (FY2013 & FY 2014) https://studentaid.ed.gov/about/data-center/school/program-reviews

Resources