Program Reviews
2011 NHASFAA Fall Conference
What is a Program Review?
A review conducted by
the Department of
Education to evaluate
compliance with Title IV
statute and regulations
 Improve future
institutional capabilities
 Identify liabilities owed
for errors
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Why Does FSA Conduct Program
Reviews?
Required by law
 To ensure that funds are
used for the purposes
intended by Congress and
taxpayers
 Schools and FSA have a
fiduciary duty to Congress
and taxpayers
 Program integrity is
important
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Program Reviews In General
Analyze institutional data and records
 Frame required actions and recommendations
to strengthen future compliance
 Quantify harm and identify liabilities, if any
 Refer institutions for administrative action, if
necessary
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Top Program Review Findings
(Ranked by Frequency)
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Verification errors
Return of Title IV funds made
late
Return to Title IV (R2T4)
calculation errors
Student credit balance
deficiencies
Campus crime requirements
not met
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Top Program Review Findings
(Ranked by Frequency)
Account records inadequate/not reconciled
 Inconsistent information in student file
 Independent student status not documented
 Pell overpayment/underpayment
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Top Program Review Findings
(Ranked by Dollars)
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Ineligible program
Inaccurate recordkeeping
Return of Title IV funds not
made
Inconsistent information in
student file
FFEL disbursements attributed
to unattended/incorrect
payment periods
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Top Program Review Findings
(Ranked by Dollars)
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Improper Pell disbursement - prior to
midpoint
Verification errors
Advances used for non-program purposes
Incorrect Pell calculation
Failure to meet factors of financial
responsibility
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Program Review - Background
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Program reviews are generally
conducted on-site
217 program reviews conducted
nationwide in 2009-10 fiscal year
For more information, see The
Program Review Guide for Institutions
2009 which can be found under
publications tab on IFAP
http://www.ifap.ed.gov/ifap/byYear.j
sp?type=programrevguide
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Program Review Guide Topics
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Department preparation for program review
Institution preparation for program review
Entrance conference
ED review of institutional processes and data
ED review of student level information
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Program Review Guide Topics
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Exit conference/status meeting
Referrals
Post review communication and report
Final determination and follow-up
Appendices (definitions and sample information)
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How Schools Are Selected for
Program Reviews
Conducted on a systematic
basis to include all
participating institutions
 Priority for selection
◦ Cohort default rate in excess
of 25% or highest 25% of
default rates
◦ High (top 25%) default rate
in dollar volume
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How Schools Are Selected for
Program Reviews

Priority for selection
◦ Significant fluctuation in Federal Pell Grant or
FFEL/FDL funding levels
◦ Deficiencies reported by state licensing or
accrediting agencies
◦ High annual dropout rates
◦ Other institutions that ED determines pose a
significant risk of non-compliance
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Risk Reduction
Fully resolve audit findings
 Fully address all findings in the
corrective action plan and be
sure you follow through
 Revise policies and procedures to
avoid repeat findings
 Attend training and keep current
on program changes.
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Types of Program Reviews
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General assessment review
◦ Random sampling of files
◦ Broad review of institutional policies and
processes
◦ Generally includes multiple offices on campus
Focused program review
◦ Focused on one or more areas of Title IV
administration
Off-site or on-site
Announced or unannounced
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Notification to School of Review
Telephone notification to
President and Financial Aid
Director
 Written announcement letter
 Specifies information to be
provided prior to review
◦ Student recipient data
◦ Institutional information
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Requirement to Cooperate
Cooperation in conduct of program review
required
 Provide timely access for examination and
copying of records
 Provide reasonable access to personnel
associated with Title IV administration for the
purpose of obtaining relevant information
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Preparing For The Review
Provide requested information by required
deadline
 Inform all administrators at your school about
the review
 Emphasize to staff the review is of the
institution’s compliance
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FSA Research Prior to Review
FSA internal paper and electronic records
◦ EZ Audit
◦ NSLDS
◦ G5
◦ COD
◦ FISAP
◦ Campus Security website
◦ IPEDS
 State and accrediting agency information
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Entrance Conference
President or CEO needs to be present
 All offices with any role in Title IV
administration
◦ Financial Aid
◦ Registrar
◦ Business Office
◦ Admissions
◦ Placement
◦ Campus Security
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Entrance Conference
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Introduction of FSA and school
representatives
Overview of program review process
How Title IV is processed at the
institution
Logistics
Possible scheduling of exit
conference/status meeting
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During the Review
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Provide review team with
secure workspace
Access to computer
records, including print
capability
Access to photocopier
Contact for reviewer
questions
Ensure staff availability
for interviews
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Review of Institutional Processes
and Data
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Institutional and program eligibility
Administrative capability - required policies and
procedures
Refund and withdrawal procedures
Packaging, awarding and disbursing procedures
Campus security
Verification policies and procedures
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Review of Institutional Processes
and Data
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Fiscal records and procedures
Cash management and
reconciliation procedures
FISAP
Student consumer information
Satisfactory Academic Progress
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Staff Interviews
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Reviewers will interview
multiple staff
The institution cannot
dictate who will be
present during
interviews
The institution cannot
tape record staff
interviews
Possible interviews with
third-parties
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FSA Review of Student-level
Information
Sample of student files reviewed
 Review multiple sources of student records
◦ Admission records
◦ Academic records, including current transcript
◦ Financial Aid records
◦ Student account record (ledger)
 Student interviews may be conducted
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Resolution of Findings While OnSite
Possible discussion of findings during the review
 School may attempt to resolve these findings
 Resolved findings still included in Program
Review Report
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Exit Conference
Usually conducted if fieldwork is
substantially complete
 Topics may include
◦ Required Actions
◦ Outstanding items and
submission timeframes
◦ Oral notification of preliminary
findings
◦ Next steps in program review
process
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Status Meeting
Conducted if fieldwork not
completed and/or data has
not been analyzed
 Similar to exit conference
◦ Required Actions
◦ Outstanding items and
submission timeframes
◦ Next steps in program
review process
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Possible Referrals
Within the Department
◦ Administrative Actions and
Appeals Division
◦ Management Improvement
Services
◦ Office of Inspector General
 External referrals
◦ State licensing agency
◦ Accrediting agency
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Post Review Activity
Provide all outstanding documents
requested by the reviewers
 Additional information may be
requested
 Reviewers may return for additional
on-site work
 FSA will complete analysis of data and
issue a written report
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Program Review Report
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Preliminary report of non-compliance
findings
Describes required actions including
file reviews if necessary
Establishes timeframe for institutional
response
List of student files reviewed attached
as appendix
May include recommendations
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Institution Response to Program
Review Report
Contact reviewer with any and all
questions
 Submit all information required in the
requested format by the established
deadline
 Complete required actions
 Request extension of time to respond if
necessary
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Expedited Determination Letter
(EDL)
Serves as preliminary report and final
determination letter
 School is not required to respond
 Usage limited
◦ No findings, or only minor and non-systematic
findings
◦ Any identified findings corrected prior to EDL
issuance
◦ Any liabilities identified were paid/collected
prior to issuance of EDL
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Final Program Review
Determination Letter (FPRD)
Notifies the institution of the Department’s final
determination for each finding
 No further action required – FPRD closes the
review
 Includes copy of Program Review Report and
school response(s) to report
 Issued within 30-60 days of FSA’s receipt of a
complete and final response
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FPRD – School Action Required
Contains original finding,
summary of school response,
Department’s final
determination
 Identifies liabilities, if any, and
instructions for payment
 Appeal rights for monetary
liabilities
 Proof of repayment of liabilities to
loan holders may be required
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Appeal of Monetary Liabilities
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Monetary liabilities may be appealed
within 45 days
Appeal filed with FSA’s
Administrative Actions and Appeals
Division (AAAD)
Collection of liabilities deferred for
appealed amounts
Non-appealed liabilities still have to
be paid
Appeal may be referred to Office of
Hearings and Appeals (OHA)
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FPRD Close-Out
Written letter closes program review
 Issued after school completes actions required
by FPRD
 Not issued of the school is filing an appeal for
any liabilities
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Record Retention
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Retain records until later of review closure or
normal record retention period
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Contact Information
For questions about this session:
Anita Olivencia, Training Officer
Anita.Olivencia@ed.gov
617-289-0130
Please provide any comments regarding this training
or the trainer to:
Thomas Threlkeld, Title IV Training Supervisor
Thomas.Threlkeld@ed.gov
617-289-0144
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Your Boston Regional Training Team
Anita Olivencia, Training Officer
◦ 617-289-0130
◦ Anita.Olivencia@ed.gov
 Pam Gilligan, Training Officer
◦ 617-289-0022
◦ Pam.Gilligan@ed.gov
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