Preparing for a Federal Program Review

Val MeyersAssociate Director

Michigan State University

Program Review vs. A-133 Audit

• A-133 is an audit required of non-profits who spend more than $500,000 in federal funding.

• Generally done by an internal auditor and/or a contracted third-party auditor.

• Must be done for each year in which you spend more than 0.5m in fed funds

• Requirements published by the Office of Management and Budget, federal government

The A-133 is…

• Routine: generally you work with the same auditors and they generally ask the same questions and want the same data– Do you have any new federal aid programs? (ACG,

SMART, TEACH have been recent replies)– For this selected population – send packages,

ISIRs, NSLDS printouts– Give us a copy of your FISAP for the audited year

Program Review

In contrast, a Program Review is anything but routine --– Program Review originates with Dept of ED– Selection for review at ED’s discretion (could be years or

decades between reviews)– Short window from notification to the review process– Focused on financial aid processes and regulations in HEOA– May target a few specific processesYou don’t know what to expect or what will be requested

ahead of time – so you need to be thoroughly prepared to answer questions about your institutional practices!

The Timeline of a Program Review

• MSU notified February 18, 2010 of program review (by phone call and letter)

• Letter listed documentation to be sent to reviewers within 2 weeks

• Reviewer visit approximately 1 month after notification date

• Reviewers on campus three days• Findings notification received approximately 3

weeks later (April 15, 2010)

The Information

Information request includes both aid office and other offices’ information including:

• Academic catalogs (degree programs, courses offered, class start/end dates, location of sites of instruction)

• Admissions policies and procedures (including ability to benefit policies and procedures, recruiter compensation or incentive pay)

• Attendance policy

Other information required

• Satisfactory Academic Progress policy & procedure• Verification• Withdrawals, official and unofficial• Return of Title IV• Campus security information• Financial Aid consumer information• Accreditation Statement of Affiliation• State agency documents showing the state’s

recognition of the institution (public schools)

More information required

Organizational charts for financial aid, admissions, registrar, bursar/controller

Data sample for reviewed year of all students who– Were selected for verification– Withdrew or ceased attendance for any reason

other than graduation– Received all non-passing grades in any term of the

review year

Form a Task Force

• If selected for a program review, your first step should be forming a committee of affected offices

• Much of the requested data will not be in control of the aid office

• Find out who knows or is responsible, particularly about required consumer information

Next Steps

• Call on members of the Task Force to help you assemble needed data and documentation

• Appoint a point person in Financial Aid to mail, email, or fax data appropriately and keep a list to ensure everything is submitted on time

• Prepare for the in-person visit

The Visit

• You may have fielded questions during the data submission phase, but be prepared for many questions during the visit

• Reviewers will request an entrance interview/meeting with key players from campus

• During the entrance interview, they explain the process and request a point person as their contact

The Visit p.2

• As point person, you will– Set up workspace, including access to information

and equipment required by the reviewers– Pull files (print records) for students they select for

in-depth review– Research and respond to questions as files are

reviewed– Schedule one-on-one interviews with selected staff

(e.g., director of admissions, financial aid, bursars)

Records Review

• Fifteen records were selected from the list MSU supplied prior to the visit– Reviewers then checked the verification data,

R2T4 calculations, and/or documentation of walk-away withdrawal dates to ensure proper changes/calculations

– Any questions in process or procedure, proof of return of funds, etc., were then researched and answered

Questions asked– Rationale for our SAP policy

• GPA monitoring, maximum timeframe, and MSU-specific criteria such as maximum number of withdrawals allowed

– Proof that the Clery (campus crime report) was sent to all staff and students – by whom – what method – what date

– Separation of duties (awarding vs. disbursement of aid)– Security access to COD and NSLDS and

policy/procedure for terminating access when a staff member leaves

Questions asked

• Policy on refunding – MSU begins refunding at earliest possible date (10 days before first class date). Reviewers asked about our process if the student fails to attend class, drops credits, etc. – how do we track this, and what do we do to reverse or modify aid awards/disbursements if this happens

Final Steps in Visit

• At the end of the visit, the reviewers ask to schedule an exit interview with the same attendees as at the entrance interview

• Reviewers discuss in general terms any findings or concerns they have at the time

• This is preliminary and reviewers explain that the official letter will be sent to the institution within 30-45 days

Official Notification

• If there are findings:– A letter is issued listing problems identified.– The institution has 30 or 45 days to respond,

depending upon the number and complexity of the findings.

– After review of the institution’s response, the Department issues a final letter.

– If there are findings requiring repayment and/or penalties, the final letter will outline the school’s financial responsibility.

Notification p.2

• If there are no findings, the institution may receive an Expedited Final Determination Letter.– An Expedited Letter means that the process is

complete. No problems have been found, so the institution doesn’t need to respond and the review is considered “closed”.

Follow Up

• If there were findings, your Task Force members should review and change policies and procedures to bring your institution into compliance

• If there were suggestions for improvement, you may wish to discuss and decide if your institution wants to make changes

Implementing Changes

• Any changes must include rewritten policies and/or procedures, web sites, and publications

• Changes mean training! Schedule training sessions to inform your staff on new policies and procedures – and be sure they understand why the change is being made

Questions?