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Preparing for a Federal Program Review. Val Meyers Associate 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.

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Preparing for a federal program review

Preparing for a Federal Program Review

Val Meyers

Associate Director

Michigan State University

Program review vs a 133 audit
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
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
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 processes

    You 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
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
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
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
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
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
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
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
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
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
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 asked1
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
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
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
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
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
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