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Compliance Anywhere within the box, but never outside of the box.
Policy & Procedure Manual • Keep it current, review and update annually • Training tool as well as a reference for auditors • Are you following your written policies? Procedures? • Use links to federal regulations (check them regularly) • Be as vaguely detailed as possible
Policy & Procedure Manual Being compliant, not complacent! No reason to reinvent the wheel… • NASFAA • IFAP • Bing.com (over 13million sites popped up, including several schools) • Step by step • Including screen shots • Overview with generalizations • Basic nuts & bolts
Our challenges Communication Return To Title IV Satisfactory Academic Progress Verification Gainful Employment
Communication • University community • Upward, downward, inward and outward • Students • Not just the award/offer letter • Department of Education • Clarification, comments, compliments & issues • Within the aid office • “Did you really just say that?”
R2T4 • Changes for schools that offer blocks or modules • Attendance taking school • Last date of attendance is based on the roster • Non-attendance taking school • How do you confirm when they ceased attending? • Distance learning • Not just when they last logged/signed in • Must be an active participant
SAP • Warning versus Probation • What we measure: • Quantitative • Credits attempted versus credits earned • Maximum timeframe (150%) • Qualitative • Grade Point Average requirement • When we measure: • Annually or at the end of every semester • Why we measure • Required to do so, but more importantly, to help the student
Verification • The importance of getting it right. • Allow time to focus and pay attention to the details. • QA schools- will remain the same 2012-2013 • Once selected for verification, the ISIR will indicate which data elements must be verified. • There are more than 300 SAR comment codes. Remember, you have the right to question any data element that seems odd, just be sure that you are doing it for the right reasons.
Professional Judgment (PJ) • If not selected for verification, are you required to complete verification prior to doing a PJ? • With the elimination of subsidized student loans for graduate and professional students, are you required to do verification on this group of students? • What happens if the ISIR you did the PJ on comes back as selected for verification?
Gainful Employment • Certification programs (less than 2 years in length) • Title IV eligible programs, however you must report all students, not just those receiving Title IV funding • Institutional charges, balance owed when the student ceased to attend, did they receive alternative loans? • Data from 2006-2007 through 2009-2010 • Due by July 1, 2011 (extended) • Data from 2010-2011 due by November 15, 2011
Communication • Tell them • Tell them what you just said • Tell them what you just told them that you said • Tell them what you just said that you told them what you said • And say it all again! • Then ask if they have any questions… • You know they will have questions • Generally, about what you just told them! Repeat after me…….I love financial aid. Financial aid is my life. I love financial aid.
Resources • IFAP.ed.gov • ED.gov • NSLDS.ed.gov • NASFAA.org • Colleagues • Smart Sessions webinar (Great Lakes), Thanks Michiale! • Mom