A POLICIES AND
PROCEDURES MANUAL
NYSFAAA Annual Conference
John View
Director of EOP and Financial Aid
Compliance officer
October 2015
Quiz -?
• Section 668.3 of the Title IV Regulations stipulates every
school who participates in title IV aid Must have a Policy
and procedures manual.
• True or False
Answer is????
•False
A Policies and Procedures
Manual is NOT:
• The FSA Handbook
• A copy of the Code of Federal Regulations
• A list of “things to do”
Why a Policies and Procedures
Manual?
• A set of written policies and procedures to
guide and manage a Financial Aid Office.
• Not required by ED, recommended
• Federal regulations require schools to have,
maintain, and disclose certain policies in
writing.
Why is it Important?
• Compliance requirements
• External Audits and Internal Audits
• Program reviews – Federal and State
• Administrative capability 668.16; 668.34
• Staff training
• Consistency
• Equity
Today’s Agenda




Evaluate what should be included
Identify the differences between a policy
and a procedure
Create a comprehensive manual
Develop a systematic way to track and
incorporate regulatory changes
Getting Started
Policies: Required or Optional
• Federal
• State
• Institutional
Policies and Procedures Components
Table of contents
Organizational chart
− Institutional
− Office
 General office information
− Mission and vision
− Location and hours
Eligibility and Certification Approval Report (ECAR)
Program Participation Agreement (PPA)
Policies and Procedures
Components
(continued)
• Accreditation Entities
• Identification of programs in which your
institution participates
− Federal
− State
− Private
− Institutional
Individual policies and procedures
Broad Categories to Consider
• Aid programs
• Consumer Information
• Cost of Attendance
• Packaging Philosophy
• Professional Judgment
• Return of Title IV
Funds
Broad Categories to Consider
(continued)
• Satisfactory Academic
Progress
• Transfer Monitoring
• Verification
• Technical
Considerations
• Forms
• Fraud and abuse
Definition of Policy
Policies identify “why”

Explain the purpose or value
− Increases understanding


Identify the applicable law or regulation
Identify federal, state, institutional
Definition of Procedures
Procedures identify “how”





Identify new regulations and changes in
school policies
Provide consistency
Explain the process so it is understood both
by seasoned staff as well as any new staff in
your office or the profession
Use Screen shots as visual aids
Consider the impact to other offices’
procedures
Sample Templates – NASFAA/ED
Sample - NASFAA
Sample - NASFAA
Sample - NASFAA
Sample – ED – found on IFAP
Sample – ED from IFAP
Due Diligence



Track the new regulatory
requirements throughout the year
Know the implementation date
Verify interpretation with colleagues
− Seek guidance from ED if necessary

Take advantage of available tools
Due Diligence
(continued)
• Follow the Notices of Proposed
Rulemaking (NPRM) for a better
understanding of the intent of any
changes
− Comments
− Summaries
− Effective dates
Best Practices
Get a Jump Start
• Gather related items
−
−
−
−
−
Old manuals
Memoes
Cheat sheets
Forms
School catalog and other publications
• Beg, borrow and use existing templates or P&P manuals
that a colleague may share with you
• Start simple
Getting Help
• Templates and guidance
− Information for Financial Aid Professionals
− NASFAA
− Google
• Be consistent
• Use them as operating guides
Develop an Implementation Plan
• What
• Who’s responsible
• Due dates (draft and final)
• Final approval
• When next review
Select Format
• Outline format
• Columns
• Paragraphs/narrative
• Combination
Keep It Simple
• Use common language (not FA legalise)
• Spell out acronyms
• Glossary of acronyms and common terms
• Not a copy and paste of the Code of
Federal Regulations, FSA Handbook, or
other resource materials
− Make it school-specific
− Include the applicable law or regulation for
quick reference, when appropriate
Divide Up The Tasks
• Ask staff to take sections relative to their
areas
• Set deadline and stick to them
• Review portions of it at different times of
the year to make it more manageable
Share the Work Load and Responsibility
• Business office
• Registrar
• Admissions
• Processing staff
• Student services
• Directors
• Middle management staff
• Institutional Technology
• Academic Governance – New programs
• Others
Questions to Ask & Answer
•
Why add a policy or make changes?
•
Who does the policy impact and in what
ways?
•
When is the implementation date?
•
Which staff and departments should be
consulted?
Ask Questions
• Who has the final authority to implement or make
•
•
•
•
•
changes?
Are there exceptions to the policy?
What are the related forms?
How do the additions or changes “fit” with other
policies? Are there any conflicts to be resolved?
How should policies/changes be provided to other
administrators?
What campus mechanism is in place to alert FAO that a
policy change may need to occur?
Assessment
Continually Evaluate Your P&P
Manual……
• Provide your staff with current policies
and procedures that pertain to eligibility
for federal, state, and institutional
programs
• Deliver general and specific
responsibilities to the staff, and other
departments
Does Your P&P Manual…..
• Provide general office procedures
ensuring a systematic and consistent
approach in the operation of all programs
• Provide quick references
• Facilitate the orientation and training of
personnel both In-House and Outside –
(Professional Training Opportunities)
Identify Responsibilities
• Determine who will ultimately be
responsible as the coordinator
− Designate staff that needs to participate
− Delegate assignments based upon areas of
expertise
− Establish a team with members from all
relevant offices
•
•
Borrow, share, and steal from colleagues
Include appropriate levels of
management and departments for review
and approvals
Remember……..
• Doesn’t need to be complicated to be
effective
• Don’t be caught not following your own
policies and procedures
Next Steps
Stay on Top of Updates
• Review annually at a minimum
• Identify who has access to both review and
update
• Track regulatory changes
− Ifap.ed.gov
− Federal Register/ NASFAA News
• Read the comments and summary as well as
the regulations
• Check student files through internal file
reviews
• Follow your own procedures
Tips of the TradeFrom our Colleagues
Be sure to:
Make sure your policies are consistent with
federal and state regulations; compliance is
huge
 Review them with staff
 Update them continually with corrections or
when regulations change
 Start working on them well before you need
(yesterday)
 Delegate the updates

Final Developments
• Make the review a part of your annual
calendar
• Implement a user-friendly, easy-to-read
format
• Make hard copies or electronic back-up of
old P&Ps
• Share with all relevant employees
• Post online/file share
Questions and Thank you!