Inside a Program Review
Sharon Abernathy, Columbia College
Amy Hager, Moberly Area Community College
Sarah Bright, Jefferson College
Columbia College’s Timeline
• July 15, 2014 – Received “the call” from ED of Announced Onsite Program Review on 8/18; No previous Title IV program
review
• July 20, 2014 – 1st submission of required docs due to ED
• August 7, 2014 - 2nd submission of required docs due to ED
• August 18, 2014 - Site visit, Additional docs required
 First Day of Fall session
 Auditors also on site
Weekly updates to President
Columbia College’s Preparation Plan
• Met with President, Academic Dean, CFO, and supervisor
• Involved Registrar, Bursar, Dean of Students, HR, Office of Compliance,
Institutional Research and “a cast of hundreds” in subsequent planning
meetings
• Developed Sharepoint site for coordination of documents/information
• Identify and assign responsibility to key stakeholders for requested items
w/deadline dates (ex. Campus Safety reports, Drug and Alcohol
disclosures, consumer information, admission policy, etc.)
• Follow-up meetings for progress updates
• Room reservation; refreshments; parking pass; key for secure
environment; technology access (wi-fi, printer, copier)
Entrance Conference
August 18, 2014
Included all of the key administrative staff; Four program
reviewers; no definite timeline for length of stay (one week or
more depending on the review)
– Two hour interview with FA Director
– Meetings with CFO, Registrar, Director of Admissions
– Student file review
– Requests for FWS job descriptions/timecards,
attendance policy, community service contracts
Exit Conference-8/22/14
President, CFO, CIO, Academic Dean, FA Leadership Staff
Preliminary concerns:
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R2T4 – Determination date; online student attendance
Perkins loan assignment to ED (due diligence on old paper)
Credit balances – paper checks within 14 days; holding without authorization
SAP – Transfer credit not included in calculation
Definition of AY and loan disbursements (refers to 8 week sessions)-more research
needed by reviewers and CC
Loan periods (overlapping sessions combined into one term)
FA shopping sheet – improve access for non-admitted students
SEOG policy – set some aside for awarding later in year
Undeclared/undecided majors – aid awarded after 60 credit max.
Exit Conference-8/22/14
President, CFO, CIO, Academic Dean, FA Leadership Staff
Preliminary concerns (cont.):
10. PJs and D/O – internal approval documentation/closing the loop
11. Verification/Inaccurate ISIR transaction
12. COD – AY week discrepancy
13. Online course attendance – reviewers accessed online courses to verify grades &
attendance in FAMS; requested continued access after they left
14. Alumni Referral Grant – might be considered an incentive
15. FWS – incomplete job desc., students working during class time, more than 20
hours (outside of policy)
Final Report: “Won’t see before first of year”
Moberly Area Community College’s
Timeline
• April 21, 2014 – Received “the call” from ED of Announced On-site
Program Review on May 19, 2014; No previous Title IV program
review
• April 29, 2014 – Aid recipient data was submitted to ED
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(2012/2013 and 2013/2014 students only)
May 5, 2014 – 1st submission of required docs due to ED
May 12, 2014 - 2nd submission of required docs due to ED
May 19-23, 2014 - Site visit, Additional docs required
May 29, 2014 – Submitted additional student files and docs
requested by ED
• October 9, 2014 – Received follow-up call from reviewer for
additional information
>>>>>Have not received response file to date<<<<<
Moberly Area Community College’s
Preparation Plan
• Met with President and CFO to prepare plan
• Met individually with CIO, Director of Computing Resources,
Registrar, Business Office Manager, Dean of Students, Dean of
Off-Campus Programs and Instructional Technology, Director
of Instructional Technology, Director of Human Resources,
Director of Security, Director of Plant Operations
• Informed each division about the review and discussed their part and
responsibilities
• Arranged all logistics (work room, parking, keys, technology, copier,
printer, etc)
If interested in documents requested, an example of letter received is available.
Moberly Area Community College’s
Entrance Conference
• Four ED staff; lead reviewer and three others
• Phone conferences were conducted with Business Office,
Registrar, and Admissions prior to on-site visit.
• On May 19, they met with President, VP Instruction, VP
Finance, and other key staff.
• Financial Aid interview – included director, assistant director and
coordinator of FA at Columbia campus who is primarily responsible for
R2T4.
• Reviewers presented lists of students they chose for review
• Staff in Financial Aid, Registrar, and Business Office
collaborated to collect documents.
Moberly Area Community College’s
Preliminary Findings
• Financial Aid Office Issues
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Return of Federal Funds issues – Actual attendance rosters retrieved from
faculty were inconsistent with system which is the data used for R2T4 calcs.
SEOG - Identified students who had award for $1; and a few awarded
because Pell was decreased after conflicting information project.
FWS – Found one case in which student worked during scheduled class.
COA – Did not have sufficient evidence of how the values were determined.
SAP Appeals – Reviewers thought our process lacked integrity because every
appeal they came across was approved.
16-week Certificate of Specialization aid calculations LETC Certificate Program - should be calculated as clock-hour because of of
Missouri’s POST requirements.
NSLC – All students were reported with same dates of attendance (did not
specify special programs with alternate academic calendars)
COD – Pell COA needs to reflect each students individual COA (our system
sends out one COA for all Pell recipients)
Moberly Area Community College’s
Preliminary Findings
• Financial Aid Office Issues
• After review team left I was notified we were also going to be
cited for requiring loan data sheet.
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Electronic Announcement 03/18/2014
Moberly Area Community College’s
Preliminary Findings
• Student Services/Admissions/Other Dept. Issues:
• Degree-seeking status – some records not found to document when a
student changed degree status
• Admissions Application – some did not support degree-seeking status
reported in system
• CLERY – the reviewers noted lack of missing persons, emergency, fire,
VOWA policies but we were able to demonstrate before they left we
had these policies.
• Drug and Alcohol Policy – we could not demonstrate a biennial
review. We had just updated our policy in March, 2014.
Moberly Area Community College’s
Preliminary Findings
• Business Office Issues:
• The word “federal” was not on the account in which federal funds
were deposited.
• A case in which a refund check was not issued within 14 days
• Questionable Escheatment Policy
• Questioned an off-campus site address from our audit reports
• Questioned our “Notice of Right to Cancel” loan statement.
Moberly Area Community College’s
Preliminary Findings
• Final Report: Expected in November
• Reviewers needed more time to investigate our
files and review our attendance reports.
• If serious concerns are discovered they may
review additional award years.
Moberly Area Community College’s
Progress Already Made
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President and Financial Aid Director shared about the experience and presented
preliminary results at all-staff meeting in August
Progress..
• Attendance Issues are being addressed with a “heavier hand” to improve faculty’s
efforts of keeping and reporting accurate attendance records
• Attendance module has been purchased for online attendance taking.
• Revised how we calculated aid for LETC students and other students in short term
programs
• Revised SEOG policy and other policies as needed
• Requested SAP committee to be stricter, and 2nd appeals are reviewed by FA
Director, attempting to strengthen the integrity of the process.
• Communicated to all FWS supervisors the importance of not allowing students to
work during scheduled classes (even if class is canceled)
• Changed name on bank account
• Software vendor is helping to address academic calendar issue for accurate
reporting to NSLC/NSLDS
• Admissions and Registrar are more aware of tracking and retaining degreeseeking status; also revising the admissions application to remove conflicting
questions.
Jefferson College’s Timeline
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May 2012- site visit, previous Title IV program review was 19 years prior
November 2012- received program review report listing findings
December 2012- initial file reconstructions due (within 30 days of report)
January 2013- progress report submitted and first extension granted
– March 2013- next bi-monthly progress report due, granted extension
– May 2013- next bi-monthly progress report due, granted extension
– July 2013- next bi-monthly progress report due, granted extension
• August 2013- final extension issued
• October 2013- submitted response to findings and reconstructed files
• October 2014- awaiting final program review determination letter
Jefferson College’s Preliminary Findings
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Improper Return of Title IV Funds
Calculations
Return of Title IV Funds Calculation
Errors
Late Return of Title IV Funds
Improper Return of Title IV Funds Policy
Attendance Not Verified Prior to
Disbursement
Inadequate Monitoring of Title IV, HEA
Credit Balances- Un-negotiated Checks
Incorrect Calculation of Cost of
Attendance
Untimely Reconciliation of Title IV Funds
Verification Incomplete/Incorrect
Failure to Identify Federal Funds
Failure to Adequately Document
Professional Judgment Decisions
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Inaccurate Direct Loan Awards
Fiscal Operations Report and Application to
Participate Data Discrepancies/Errors
Inadequate Campus-Based Funding
Award/Selection Criteria
Improper Job Classification- Community Service
Employees
Improper Payment For Federal Work Study (FWS)
Hours Worked
Inappropriate FWS Timesheet Certification
Failure To Perform Direct Loan Exit Counseling
Consumer Information Requirements Not Met
National Student Loan Data System (NSLDS)
Reporting Incorrect /Untimely
Failure To Comply With Drug-Free Schools And
Communities Act/Part 86
Campus Security Requirements Not Met- Policy
and Procedural Deficiencies in Sexual Assault
Policies
Jefferson College’s File Reconstructions
Jefferson identified by ED as an institution required to take attendance.
Attendance Related Findings Dominated:
• Attendance Not Verified Prior to Disbursement
• Incorrect Calculation of Cost of Attendance
• Improper and Late Return of Title IV Funds Calculations
• National Student Loan Data System (NSLDS) Reporting Incorrect
Reconstructions
Collection of attendance records (2009-2010, 2010-2011, and 2011-2012)
• Over 15,000 students with an F, W, or I
• Over 7,800 files rebuilt (31 boxes delivered)
– Spreadsheets:
No-Shows, R2T4s, COAs, Un-Cashed Checks, and Verifications
Jefferson College’s Positive Outcomes
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Greater Understanding, Value, and Support for Financial Aid
Development of Student Participation System (SPS) and Retention QI
– Two tracking systems (training video)
• Face-to-face and Online courses
– SPS ties directly into Banner to list LDAs
– Faculty access via web portal
– Attendance vs. other participation (academically-related activities)
– Blackboard activities
Attendance Reports for faculty and by faculty and student
– Students who fail to begin attendance- financial aid enrollment
adjustments made at the start of each term (16, 14, 8 week, etc.)
– Students who have ceased participation in all courses for 14 calendar
days- weekly monitoring to calculate R2T4s based on LDA
Resources
– 2009 Program Review Guide
http://www.ifap.ed.gov/ifap/byYear.jsp?type=program
revguide&year=2009
– FSA Assessments
http://www.ifap.ed.gov/qahome/fsaassessment.html
– ED Final Program Review Determinations (FY2013 & FY
2014) https://studentaid.ed.gov/about/datacenter/school/program-reviews