Inside a Program Review
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Inside a Program Review. Sharon Abernathy, Columbia College. Amy Hager, Moberly Area Community College. Sarah Bright, Jefferson College. Columbia College’s Timeline.

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Inside a Program Review

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Inside a program review

Inside a Program Review

Sharon Abernathy, Columbia College

Amy Hager, Moberly Area Community College

Sarah Bright, Jefferson College


Inside a program review

Columbia College’s Timeline

  • 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


Inside a program review

Columbia College’s Preparation Plan

  • 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)


Inside a program review

Entrance Conference

August 18, 2014

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


Inside a program review

Exit Conference-8/22/14

President, CFO, CIO, Academic Dean, FA Leadership Staff

Preliminary concerns:

  • R2T4 – Determination date; online student attendance

  • Perkins loan assignment to ED (due diligence on old paper)

  • Credit balances – paper checks within 14 days; holding without authorization

  • SAP – Transfer credit not included in calculation

  • Definition of AY and loan disbursements (refers to 8 week sessions)-more research needed by reviewers and CC

  • Loan periods (overlapping sessions combined into one term)

  • FA shopping sheet – improve access for non-admitted students

  • SEOG policy – set some aside for awarding later in year

  • Undeclared/undecided majors – aid awarded after 60 credit max.


Inside a program review

Exit Conference-8/22/14

President, CFO, CIO, Academic Dean, FA Leadership Staff

Preliminary concerns (cont.):

10. PJs and D/O – internal approval documentation/closing the loop

  • Verification/Inaccurate ISIR transaction

  • COD – AY week discrepancy

  • Online course attendance – reviewers accessed online courses to verify grades & attendance in FAMS; requested continued access after they left

  • Alumni Referral Grant – might be considered an incentive

  • 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”


Inside a program review

Moberly Area Community College’s Timeline

  • 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<<<<<


Inside a program review

Moberly Area Community College’s Preparation Plan

  • 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.


Inside a program review

Moberly Area Community College’s Entrance Conference

  • 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.


Inside a program review

Moberly Area Community College’s

Preliminary 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)


Inside a program review

Moberly Area Community College’s

Preliminary 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


Inside a program review

Moberly Area Community College’s

Preliminary 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.


Inside a program review

Moberly Area Community College’s

Preliminary 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.


Inside a program review

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.


Inside a program review

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.


Inside a program review

Jefferson College’s Timeline

  • 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


  • Inside a program review

    Jefferson College’s Preliminary Findings

    • Inaccurate Direct Loan Awards

    • Fiscal Operations Report and Application to Participate Data Discrepancies/Errors

    • Inadequate Campus-Based Funding Award/Selection Criteria

    • Improper Job Classification- Community Service Employees

    • Improper Payment For Federal Work Study (FWS) Hours Worked

    • Inappropriate FWS Timesheet Certification

    • Failure To Perform Direct Loan Exit Counseling

    • Consumer Information Requirements Not Met

    • National Student Loan Data System (NSLDS) Reporting Incorrect /Untimely

    • Failure To Comply With Drug-Free Schools And Communities Act/Part 86

    • Campus Security Requirements Not Met- Policy and Procedural Deficiencies in Sexual Assault Policies

    • Improper Return of Title IV Funds Calculations

    • Return of Title IV Funds Calculation Errors

    • Late Return of Title IV Funds

    • Improper Return of Title IV Funds Policy

    • Attendance Not Verified Prior to Disbursement

    • Inadequate Monitoring of Title IV, HEA Credit Balances- Un-negotiated Checks

    • Incorrect Calculation of Cost of Attendance

    • Untimely Reconciliation of Title IV Funds

    • Verification Incomplete/Incorrect

    • Failure to Identify Federal Funds

    • Failure to Adequately Document Professional Judgment Decisions


    Inside a program review

    Jefferson College’s File Reconstructions

    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

      Reconstructions

      Collection 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


  • Inside a program review

    Jefferson College’s Positive Outcomes

    • 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


    Inside a program review

    Resources

    • 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


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