By Linda Conard, NASFAA
Originally published in NASFAA Now, October 2018
Twenty years ago, the Standards of Excellence (SOE) Review Program grew out of a beautifully simple idea: Currently practicing financial aid administrators would perform reviews to help their peers improve their financial aid operations. NASFAA's 1996-97 Board of Directors and SOE Task Force brought that idea to life with the launch of SOE, a unique and powerful service for both identifying challenges and achieving excellence in financial aid administration.
The Board and Task Force envisioned offering institutions far more than the evaluations already available through basic audits, federal program reviews, or consultant-led options. SOE's peer reviews had to be comprehensive, confidential, objective, supportive, and voluntary—all while maintaining NASFAA's extremely high standards. Reviews would need to help both seasoned financial aid leaders and new directors find hidden threats to compliance, improve customer service, make the best use of available resources, and even make the case for additional resources to improve operations. And, to really stand out, SOE reviews would need to provide a nonpunitive, peer-to-peer experience as well as highlight best practices and ultimately help raise the standards of financial aid operations among all NASFAA member institutions.
To achieve this mammoth challenge, the Task Force turned to Vernetta Fairley, then-director of financial aid at the University of Southern Mississippi. Fairley took the lead in creating the comprehensive peer review program from scratch. Working with Joan Crissman and Connie McCormick from the NASFAA staff, Fairley assembled a team of four talented reviewers and writers—Bob Collins, Pam Fowler, Susan Luhman, and Micki Roemer—representing financial aid offices of different sizes and types from across the nation.
"We essentially had a panel of experienced thinkers to help get the program off to a good start," explained Fairley. "We tweaked and went back to the drawing board several times, but the initial review process worked well. Reviewers felt a sort of ownership of the program's success and would offer suggestions to make it better."
In fall 1998, Fairley and her four-member SOE review team performed the first three pilot reviews that led to the program's full launch in January 1999. Today, SOE is not only celebrating its 20th anniversary but also the positive impact of the 250 SOE reviews performed across the country since the program began.
SOE reviews have always remained on the cutting edge of regulatory changes and paradigm shifts in higher education administration. However, the program's core, peer-centered approach has changed very little over the years.
"SOE uses a time-tested formula for helping schools achieve financial aid excellence," explained Mandy Sponholtz, NASFAA's current SOE program administrator. "Our review items may change, but not the overall program. SOE is just as valuable now as it was envisioned 20 years ago—even more so, given the additional regulatory burden financial aid administrators face today," she said.
SOE's unique approach covers far more than annual audits. "We often find significant issues the auditors completely missed," said SOE Reviewer Chuck Knepfle.
By design, audits focus solely on compliance, and auditors generally lack a working knowledge of financial aid. Full SOE reviews examine compliance within the bigger picture of customer service, workflow, technology use, interdepartmental cooperation, and more, through the program's comprehensive, in-person evaluations.
"SOE reviews are a great opportunity for schools to address issues before an audit or program review, reducing the potential that compliance issues will be found and liabilities assessed," said SOE Reviewer Brad Barnett.
"It's a great way to uncover compliance challenges without involving a visit from our friends in the Department of Education," said SOE Reviewer Phil Asbury.
In spring 2017, SOE launched its new Consumer Information (CI) Assessment, which delivers the consumer information portion of the full SOE review as a separate, more economical review conducted off campus. The CI Assessment helps address an alarming trend noted by SOE reviewers: Increasingly, schools are failing to meet all the disclosure and reporting rules.
"Almost every review now has at least five to 10 consumer information findings," said Knepfle.
These findings not only mean families miss out on important consumer information, but they also put the school at risk for heavy fines and bad press. For example, a single Clery Act violation carries a maximum fine of $54,789*. That's about 15 times more than the cost of an SOE review. Between 2010 and 2017, the U.S. Department of Education (ED) assessed 45 schools Clery Act fines ranging from $5,000 to $2.4 million, with an average of $360,000. Beyond campus security (e.g., items such as IPEDS nonsubmission or incentive compensation), ED assessed 27 institutions fines averaging over $1.2 million per school. Using a CI Assessment, schools can quickly discover and resolve such missing pieces in their consumer information compliance.
The exclusive use of peers as reviewers sets SOE apart from all other audits and reviews. Before beginning a review, Sponholtz hand selects the right team leader to work directly with the institution's staff, and that team leader chooses the best review team to fit the school's unique needs.
Every reviewer and team leader is a financial aid professional currently working in a financial aid office. "We know the challenges schools face; it's likely we have faced them as well," Asbury said. "We aren't consultants whose job is to simply provide advice or information. Peer reviewers spend their time working in their own offices ... because of this, our knowledge is much more current."
"Reviewers bring a wealth of experience and knowledge with them from their own financial aid careers," Barnett added. "Staff at schools have the opportunity to engage in discussions with SOE reviewers about much more than just regulatory issues, and they benefit from the reviewers' process experiences."
The collegial nature of SOE reviews also allows staff to be more forthcoming with reviewers, which helps reveal potential challenges and allows solutions to be found before they grow into larger problems. "It's a nonpunitive way to measure the effectiveness of your office," Asbury said.
"We have experienced your struggles firsthand and can make recommendations for improvement and point to compliance exceptions that many auditors wouldn't notice," said Mark Diestler, an SOE reviewer who previously served as a federal program reviewer. He added, "I don't think you can get more bang for your buck anywhere else."
Institutional eligibility for federal student aid funds extends far beyond the aid office. SOE reviews can help distinct divisions on campus recognize their shared responsibilities and build collaborations. For Kim Lamborn, a new financial aid director at University of Western States, building those collaborations was among the top reasons she sought a review. "I wanted to raise awareness, create buy-in, and foster relationships with other departments," she said.
SOE's external perspective can also help institutional executives better understand the needs of the financial aid office. "One of the biggest challenges facing some of the schools we review is not having the institutional support to make needed changes," said Alison Rabil, who first had an SOE review as a new director and later joined the SOE team as a reviewer. "An SOE review gives you institutional traction because someone from outside is evaluating and making suggestions for improvement," she said.
SOE's 20 years of success clearly demonstrates the program's strength and longevity. But both the reviewers and reviewed schools know the best reason to celebrate is SOE's impact on helping schools achieve their goals for their financial aid operations.
"Receiving a formal SOE review report allowed us to approach management for support in rectifying the situations we had. It demonstrated that we were being proactive, had a ‘road map' for the fixes and implementations, and had a realistic assessment of what we were facing," said Patrick Scott, director of financial aid at Cuesta College.
"Having been with this program for years, I know we have helped countless aid offices avoid trouble with the Department of Education, shown them a better way to do things, pointed out staff issues and problems, and become mentors to their aid directors," said Pam Fowler, an SOE reviewer who helped shape the original program in 1998 and has performed reviews throughout SOE's 20-year history.
Barnett added, "I've been on reviews where you can see the staff are hungry for help, very appreciative for us being there, and willing to engage in some fantastic conversations about how to improve what they are doing. When I see the smiles on their faces after they feel an issue has been solved and hear the relief they express about having some direction, well ... I know when I go home that I've made a positive difference."
To learn more about SOE and submit a Peer Review Information Request, visit nasfaa.org/SOE.