What to Expect, when you’re
An Audit
What you should expect today!
Private, SUNY, and CUNY Perspective
Federal Title IV and NYS TAP Reviews & Audits
Top 10 findings
Negotiating the results
Preventive Planning to Minimize Potential for
Q and A
Federal Program Review
• Usually conducted by Regional Office Program
Review Specialists
• Can be conducted by the US ED. Office of
Inspector general
• Review office procedures and student
financial aid, bursar, and registrar records
• Disallowances based directly on findings
State Audits
• Conducted by NYS Comptroller's Office
• Review College academic, bursar and registrar
• Comprehensive review of college academic
policies as they relate toward financial aid
• Disallowances are based on the sample
population findings and calculated over all
The potential liability from State
Audits is usually much higher than
the potential liability from Federal
Program Reviews
Federal Audits Top 10 Findings
• 1. R2T4 calculation errors
• 2. R2T4 late refunds –(SUNY)
• 3. Commencement of Attendance proof
• 4. SAP (SUNY)
• 5. Pell grant Payments overpayment
• 6. FWS time sheet errors
• 7. NSLD reporting errors late or missing grad date
• 8. Verifications errors
• 9. Entrance or Exit interviews missions
• 10. Conflicting Information
SUNY Audit Findings
• R2T4 - Timely return of funds
• FWS - No signed contract for off-campus employment
• Loan Disbursement Notification - Timely “Notice of Disbursement”
and right to cancel the loan for both Perkins and DL Notification must be
done for all disbursements
• Loan Reconciliation - Reconciliation not performed monthly
• SAP - No SAP policy for professional school that does not use letter
• Reporting to clearinghouse -Did not report student status changes within
60 day time allowance
NYS TAP Audit – TOP 10 Findings
1. Ineligible program
2. Course not applicable toward the degree
3. Satisfactory Academic Progress
4. Ability to Benefit
5. Refunds not made in timely fashion
6. Missing folders or documents
7. Not a NYS resident
8. Not a HS graduate
9. Undeclared major
10. Funds not applied to account properly
Preparing for an Audit
• Ask the entity performing the audit for the scope
and timeframe
• Meet with academic, financial, and legal counsel
staff to discuss audit
• Review appropriate contact individual(s) from
each office
• Review how information will be shared
• Identify space for auditors
During Audit
• Stay CALM!!!!!!!
• Remember the auditors are only doing their job they
are not out to “get you”
• Provide records to auditors as quickly as possible
• Take your time when answering questions
• Never GUESS, if unsure – do research
• Reach out to colleagues if you have questions
• Do Not blindly trust!! – Verify
• Ask for regulation citation for finding
• Keep in mind the auditor may be mistaken
• Dispute findings during audit
Final Meeting
• Do not admit to anything!!
• If something is missing - search for it
• If a timeline was missed – double check that it
• If a policy is not in writing – put it in writing
• Ask for timeframe for submitting additional
responses and for receiving preliminary and final
• Seek legal advise before you agree to anything
What Should I Do Now
• Review and update Financial Aid Office
procedures manual
• Review college bulletin to assure accuracy of
information and compliance with regulations
• Review Middle States and other accreditation
• Review NYS Education Department “Inventory
of Registered Programs” to assure all college
offerings are approved
If a college practice or procedure
does not look correct than you
need to speak up
Ultimately the College President
and Administration are Responsible
There is no substitute for a GOOD