You Don’t Have to Dread the Call from ED

Avoid, Resolve, or Prevent Program Review Findings with NASFAA’s Peer Review Services

"Our school had not received a federal program review in over 28 years. As each academic year passed without a phone call from the Department of Education my anxiousness increased. We received clean audit every year, but nothing was like a federal program."

Does this sound like you? It’s been decades since the Department of Education (ED) visited your school, and you wonder if this will be the day you get "the call." You try not to worry about it because you have clean audits, but really, you hold your breath every time the phone rings, and sigh in relief when ED isn’t on the other end of the line.

Rather than wait for the call any longer, this school decided to be proactive by having a NASFAA Standards of Excellence (SOE) Review. NASFAA’s SOE review can identify and provide corrective actions to resolve potential issues regarding administrative capability, and reduce the school’s risk for a program review.

"The SOE review experience prepared us by closely mirroring a federal review, right down to the entrance and exit interviews with our president."

By law (HEA Sec. 498A), ED must prioritize schools for program reviews if they pose a risk for failing to comply with any of the Administrative Capability Regulations (34 CFR 668.16). NASFAA’s SOE review performs a comprehensive compliance review, evaluates the school’s staffing levels, and examines key financial aid policies, such as consumer information disclosures and satisfactory academic progress.

Regulatory Requirements

NASFAA SOE Review

Follow all the laws, regulations, and guidance related to Title IV aid programs.

Complete review of the school’s adherence to all Title IV rules and regulations through a series of questions and interviews, a review of a random selection of student files, and an examination of the school’s website.

Designate an appropriate number of capable individuals to administer the Title IV aid programs. ED looks at the following factors when determining the right number: number and types of financial aid programs, number of aid applicants and recipients, financial aid delivery system, degree of automation, number of financial aid staff, use of third-party servicers.

Evaluate the school’s current staff level using NASFAA’s Staffing Model.

Perform a technical review of the school’s use of the financial aid system to evaluate automation versus manual processes.

Examine the school’s use of third-party servicers and whether it is an effective use of resources.

Administer Title IV programs with adequate checks and balances, including the division of authorizing payments and disbursing/delivering funds.

Ensure the school’s awarding and disbursement procedures occur in separate offices.

Maintain required school and student records.

Determine if the school has access to all relevant school-related records (such as the FISAP and PPA), and whether the student files are accurate and complete.

Establish, publish, and apply reasonable standards to determine whether students meet Satisfactory Academic Progress (SAP).

Analyze the school’s SAP policy to ensure it contains required elements, establishes reasonable standards, and applies the policy accurately.

Review consumer information disclosures to ensure they include these elements, and all other required information.*

Develop and apply adequate systems to identify and resolve conflicting information.

Examine the school’s conflicting information policies and identify any deficiencies.

Make appropriate referrals to the Office of the Inspector General (OIG) for ED.

Confirm the school is aware of the requirements to refer appropriate situations to OIG.

Provide adequate financial aid counseling to students who apply, such as: sources and amounts of aid offered, methods for determining eligibility and disbursing funds, rights and responsibilities of the student regarding enrollment, refunds, return of Title IV funds, and SAP.

Review consumer information disclosures to ensure they include these elements, and all other required information.*

Not otherwise appear to lack the ability to administer Title IV programs.

Identify areas of non-compliance as well as make recommendations to improve efficiency, accuracy, and student service.*

Develop and follow procedures to evaluate the validity of the student’s high school diploma if the school or ED has reason to question its validity.

Examine the school’s high school diploma validity policies and identify any deficiencies.

* Designates areas of administrative capability reviewed in the Consumer Information Assessment, a review focused solely on consumer information disclosure and reporting requirements.

Once the review was complete, the NASFAA SOE peer review team provided the school with an overview of the strengths of the school, the areas where it was not complying with regulation, and recommended improvements to increase efficiency, automation, and student service. As a result, the school was able to make some changes right away, before receiving its formal SOE report from NASFAA.

"Only a few weeks after the NASFAA team left, I received that friendly phone call from my Department of Education Regional Office informing me of the visit to my campus for a program review. For not having a program review for over 28 years, our report from ED was excellent."

NASFAA’s Standards of Excellence Review program can help you not dread the call from ED by reducing your risk for findings during a program review, or even potentially by avoiding one altogether. To learn more about NASFAA’s peer review services, visit nasfaa.org/SOE.

Publication Date: 2/6/2018

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