These Are the Actual Final Notes from an Institutional Program Review Held in 2011. The

Compliments of the Training Committee

These are the actual final notes from an institutional program review held in 2011. The names of the school and individuals have been deleted.

TIMELINE:

July 26, 2011: Notified via phone call by the FSA, School Participation Team office that a program review would occur, and who the on-site reviewers would be.

July 27, 2011: Certified mail letter of the Announcement of On-Site Program Review was sent via email, and paper letter mailed to school.

August 10, 2011: Information that was outlined in official Announcement above due to program reviewers.

August 23-25: Program reviewers on-site at school.

September 2011-December 2012: Verbal conversations with the program reviewers regarding the likely outcome of the review.

December 23, 2013: preliminary program review report emailed to school, with paper letter sent via certified mail.

January 23, 2014: Responses to findings due to Director of School Participation Division sent from school, via certified mail.

Final Program Review Report has not yet been received.

PRE-REVIEW PREPARATION:

Information the program reviewers requested, which was due to the reviewers prior to their visit (due August 10, 2011 via email to one of the reviewers). For all requests, the most recent data was sent at the time of the review. This information was conveyed to school in the official Announcement of On-Site Program Review leter.

• Course catalog
• Policies and procedures concerning:
• Admissions, institution and academic programs
• Satisfactory academic progress
• Attendance
• Ability to Benefit
• Incarcerated Students
• Recruited compensation/incentive programs
• Withdrawals, official and unofficial
• Return of Title IV Funds
• Verification
• Awarding of Title IV, HEA program aid
• Selection of Preferred Lender for FFEL Program, if applicable

• Campus security information published and distributed to students and staff, including web links.
• URLs for all financial aid consumer information
• Institutional and financial aid student consumer publications (not included in URLs)
• Examples of institutional forms, applications and worksheets that are used in administering the Title IV, HEA programs
• Accreditation Statement of Affiliation (or equivalent) and any additional accreditation documents that demonstrate the accreditation of the institution and describe the extent of the accreditor’s recognition of the institution (locations, academic programs, restrictions, etc.)
• State agency documents that reflect the institution’s legal authority to provide educational services and describe the extent of the State’s recognition of the institution (locations, academic programs, restrictions, etc.)
• An organizational chart of the institution’s administrative offices with individual names and titles along with a list of all employees currently employed by the institution and their occupations. Also, please include a list of all external recruiters.
• Total current enrollment and percentage receiving Title IV HEA program aid
• List of Title IV recipients for the period under review who meet one or more of the following criteria:
• Withdrew or ceased attendance for any reason other than graduation
• Were selected for verification (including those selected for verification but not verified under the 30% option, if applicable)
• Received all non-passing (0 GPA) for any term within this period. This includes any student who failed to pass at least one class and/or earn any credit during any payment period or term. This also includes students who withdrew from all courses in a payment period or term.
• Photocopy or electronic copy of the original complete student file for at least one student on the above list of students.
• Withdrew or ceased attendance for any reason other than graduation
• Were selected for verification (including those selected for verification but not verified under the 30% option, if applicable)
• Received all non-passing (0 GPA) for any term within this period. This includes any student who failed to pass at least one class and/or earn any credit during any payment period or term. This also includes students who withdrew from all courses in a payment period or term.

To provide the above information, the school was given specific instructions on how to transmit the data without compromising the identify ot he students (Protection of Personally Identifiable Information).

Other items for preparation for their visit:

• Manuals or instructions for software programs used by our institution
• Contracts with third parties concerning the administration of Title IV, HEA program funds, or the delivery of educational services for which the institution received Title IV, HEA program funds.
• Be prepared to provide all records on-site at the visit.
• Make arrangements for the review team to access (view only and print capability) to the databases.
• Provide access to administrative staff and students.
• Provide a secure location for the review team to work.
• Provide access to a copier.

School responded and sent the requested information to the Program Review team by August 4, 2011. We had to contact our HR Office, Fiscal Office, Financial Aid Office, Campus Security, Registrar’s Office, Academic Office (Provost’s Office) and Admissions Office about our visit.

REVIEW:

As far as we know, the actual review went as smoothly as possible. In addition, we requested that the Registrar’s Office, Admissions Office, Academic Office and Fiscal/Business Office be in attendance at an entrance interview conducted on day 1 of the on-site review. There were two reviewers on-site, and they were here for 3 days total.

POST-REVIEW FOLLOW UP AND REPORT:

There were multiple follow-up questions through email and phone to the schools prior Financial Aid Director. At some point he was unofficially informed of what the findings would be. In the meantime, we knew we had a few things to refine in our procedures, so we went ahead and implemented these changes.

Upon receipt of the preliminary program review report, received December 26, 2013 we had to prepare responses to each of the findings, We had three findings:

1. Ineligible Federal Pell Grant Program Disbursements Not Returned Timely
2. Annual Fire Safety Report (AFSR) Not Developed or Disseminated
3. Crime Awareness Requirements Not Met-Inadequate Policy Statements, Emergency Response and Evacuation Procedures and Missing Persons Notification

Finding #1: We were audited on 15 students; the reviewers used these 15 students to look at all aspects of their files. Verification, COA, packaging, R2T4, etc. On one student, we calculated a ‘0’ GPA R2T4 return incorrectly. This is the finding that occurred.

Result of Finding #1: We do not yet know the liability for this finding. We do know that we will need to return the amount of the Pell calculation that was done erroneously on one student. Fortunately it was a small amount, but we do not yet know if there will be fines associated with it as well.

Changes made due to Finding #1: Since we knew from conversations we had with the program reviewers that this was an issue, we immediately reviewed and revised our R2T4 procedures, implementing a system of checks and balances. Now, every R2T4 calculation has a quality control check at the time of the calculation. In addition, we revised our participation verification on students that earned F’s or withdrew from courses.

Finding #2: AFSR, Clery Act Compliance. It was clear that we were out of compliance, as we had not yet done an AFSR.

Result of Finding #2: We have been given the opportunity to demonstrate to the DOE that we have corrected this. In our response, we clearly demonstrated that changes have been made, and that we have been in compliance since the 2011 year. Again, we do not have the final report, so we do not yet know if there will be fines.

Changes made due to Finding #2: We also knew prior to the report that this was an issue. Our first ASFAR was published on October 1, 2011 with the required information. We have subsequently published our ASFR every year on the required deadlines, and can show the DOE the methods of distribution. Our response to the finding showed evidence of our compliance since the initial review.

Finding #3: Annual Security Report, Clery Act. Again, it was obvious we were deficient in this report. We have been doing the ASR since 1992, but there were sections that were deficient.

Result of Finding #3: Likely the AFSR above, the DOE has given us the opportunity to correct the oversights of our crime reporting, etc.

Changes made due to Finding #3: We were informed of this oversight verbally before the actual report. Therefore, we were able to implement the required updates with our Campus Security the publication of our ASR. Specifically, we were not fully compliant with the missing person policy and the emergency response and evacuation regulations. Once we were aware of these deficiencies, we updated our ASR with the changes and have been in compliance since the 2012 report.