of Creating and Maintaining a Compliant Policy and Procedure Manual Presented by: Chyrl R. Ayers, COO Global Financial Aid Services, Inc. SASFAA 2013 50 th Anniversary Conference February 11, 2013, 3:45 5 pm
WELCOME
Learning Objectives WHY must a P&P manual be maintained? WHAT is required? is responsible to create and maintain? needs access? WHO WHERE to store and methodologies utilized? WHEN should it be reviewed and updated?
WHY? Why required? Why does a manual make sense?
Considering Different Configurations Separate manual; or Cross-reference to manual(s) already in existence. Note: You may want to consider using icons to represent different areas for quick reference in your P&P manual.
Different Types of Icons Good Practice Tip Policy Important Exception Definition (some prefer a Glossary in this area) Checklist Example NEW
WHAT? What content to include?
Packaging Philosophies and Procedures Federal Pell FDSL Campus-based Funding FSEOG FWS Federal Perkins Teach Grant
Packaging Philosophies and Procedures Considerations Do you package loans only up to the direct cost and allow the student to request additional loan funds for living expenses? Do you package for the full annual limits and then reduce if requested by the student?
Packaging Philosophies and Procedures Considerations If packaging for less than a full annual amount, how are students made aware of the maximum amount they can borrow? How do you monitor funds received from other sources (i.e. scholarships, foundation funds, employer payments, state grants, etc.) to ensure student is not overawarded?
Packaging Philosophies and Procedures Considerations If a student s Title IV aid package must be reduced due to receipt of a scholarship, how is the student notified? What is your process for packaging: Transfer students in an open loan period? Re-entry students? Students who change programs?
P&P Regulatory Citation Related to Federal Pell 690.63 Calculation of Federal Pell Grant Awards 690.80 Requirements and optional recalculation 690.81 Fiscal Records and Disbursement requirements H.R. 4137 Iraq and Afghanistan Service Grant Program
Basic Federal Pell Considerations Requirements for determination of Federal Pell Grant; What situations require recalculation? Do you recalculate under optional situations? How and when you disburse and report? Procedures for handling and disbursing the Iraq & Afghanistan Service Grant
P&P Regulatory Citation Related to FDSL 685.102(b) Packaging Policies for FDSL 685.304 Counseling Borrowers 685.306 Payment of refunds or RT4 685.309 Administrative and Fiscal Control
Basic DL Considerations Awarding Process Outline the procedures to determine the appropriate award amounts. Do you always award the maximum? Do you consult with the student first in determining the award amounts? Do you package direct and indirect or only direct? How does the student request indirect/living expenses?
Basic DL Considerations PLUS (Parent Borrower) Outline the procedures to determine parent s eligibility under the PLUS program How do you determine the amount? How do you notify they parent of eligibility and/or awarded amount? What is the process if a parent requests online through COD? How do you collection information to document the parent s requested amount? How do you provide information to the parent related to PLUS?
Basic DL Considerations Confirmation Process Outline the confirmation process for loans Active or passive? Must document how you handle each academic year in which loans are made to students
Basic DL Considerations Loan Counseling outline your procedures for loan counseling and include entrance and exit processes. Disbursement Notification Letters include your procedures on how and when notifications are made to borrowers when a direct loan occurs.
P&P Campus-based Funds - FSEOG 676.10 Selection and Awarding 676.19 FSEOG Fiscal Procedures and Records
Basic FSEOG Considerations Awarding Policy Should include your procedures for awarding of FSEOG Reviewed and maintained for each award year; How students are informed of eligibility and selection criteria for determining award amount. If information is contained in catalog or consumer information, you should still have a written policy on FSEOG
Basic FSEOG Consideration Institutional Match Should include details on how you meet the institutional matching requirements. Note: This process should be the same each award year; therefore, one policy may cover several award years. The award years covered by the policy should be noted in the policy.
P&P Campus-based Funds - FWS 675.10 Selection and Awarding 675.20; 675.21; 675.2(b); 675.18(g) Assigning FWS Jobs 675.19 Fiscal Procedures and Records 675.36 Job Location and Development- Procedures and Records 375.49 Work College Program-Procedures and Records
Basic Consideration FWS Selection Process Application material; How students are notified of available positions; How hourly wage is determined; How the interviewing and hiring process works; and Policy on limiting the number of hours worked.
Basic Consideration FWS Off-campus Employers Selection process for off-campus employers; Written off-campus FWS Agreements: Who is considered the employer for purposes of hiring, terminations and pay rate? Who is responsible for required cost such as nonfederal share social security and workman s compensation? Who is responsible for payroll?
Basic Consideration FWS Payroll and Non-federal Share Outline the payroll procedures used for FWS students Timesheet process; Frequency of payment; Method used for paying student; Procedures for documenting payroll made by offcampus employers; and How the required institutional match is made (school or off-campus employer)
Basic Consideration FWS Community Service Include how community service requirements are met (7% of your allocation with at least one position as a reading tutor or performing family literacy).
P&P Campus-based Funds Federal Perkins 674.10 Selection and Awarding 674.31 Perkins MPN 674.16 Perkins Loan Disclosure 674.19 Fiscal Procedures and Records 674.33(d) Forbearance 674.38 Deferment 674.42 Contact Borrower 674.43 Billing 674.45 Collection 674.46 Litigation 674.52 Cancellation
Basic Consideration Federal Perkins Awarding Policy Eligibility requirements; Selection procedures; and Criteria for determining the award amount.
Basic Consideration Federal Perkins Loan Counseling - Should include both entrance and exit counseling processes Cumulative Balance Owed Procedures used to notify student of the cumulative balance owed and the expected payment amount. Must be provided each award year prior to 1 st disbursement of a Federal Perkins loan.
Basic Consideration Federal Perkins Recordkeeping Maintenance of MPN (fireproof container or cabinet); Procedures for returning MPN to the borrower after loan is satisfied; Storing of loan records deferments, cancellations, forbearances, repayment schedules and other correspondence with borrower; and If you use e-sign you must document your e-sign procedures.
Basic Consideration Federal Perkins Disbursement Notification Letters include your procedures on how and when notifications are made to borrowers when a loan occurs. Red Flag Rules procedures should include how you comply with the FTC s Red Flag Rule
Basic Consideration Federal Perkins Confirmation Outline confirmation process for loans Active or passive? Must document how you handle each academic year in which loans are made to students.
Basic Consideration Federal Perkins Servicing Procedures This section should include the processes used in servicing the Federal Perkins loans: Borrower contacts; Billing procedures; Default and collection procedures; Cost assessed to borrowers; and Perkins assignment.
Basic Consideration Federal Perkins Servicing Procedures Note: If you use a server for your Perkins, the servicers efforts in these areas would be included in the P&P manual. You need to outline who is responsible for what and anything shared.
P&P Campus-based Funds TEACH Grant 686.10; 686.11 Eligibility Determination 686.32 Counseling 686.36 Fiscal Control and Funds Accounting
Basic Considerations TEACH Grant Exit counseling for student who does not complete counseling on NSLDS website; Any additional counseling you may perform for TEACH Grant recipients; and How you verify enrollment in an eligible program and verity student s GPA to ensure eligibility for TEACH disbursement.
P&P Campus-based Funds ACG/SMART (Not currently funded) 691.15; 691.16; 691.17 ACG and National SMART Eligibility Requirements 668.3; 691.62; 691.2(d); 691.6 Calculating ACG & National SMART 691.81 Fiscal Control and Fund Accounting
Verification 668.53 Written policy that indicates the following: Time period for student to provide documentation; Consequences of failure to submit; Method used to notify changes of EFC & change to TIV awards; Procedures to follow when it is necessary to correct FAFSA data; and Procedures followed if referral of student to OIG.
Verification 668.53 This policy must be made available to all students selected for the process of verification.
Professional Judgment (PJ) 479A and 668.5(c) Requests for PJ s How students are made aware of the availability to be considered for this process; Process by which student applies for PJ; and Standard forms or other documentation required.
Professional Judgment (PJ) 479A and 668.5(c) PJ s decision How students are notified of the decision and this should include the results of awards being revised based on approval.
Satisfactory Academic Progress (SAP) 668.16(e) and 668.34 Methods of Monitoring SAP Automated or manual process? Who monitors SAP? How often is SAP reviewed? How is FA notified of the failure of SAP?
Satisfactory Academic Progress (SAP) 668.16(e) and 668.34 Procedures for FA Warning and Probation How are students notified? What are the appeal procedures Who prepares academic plan and monitors them to ensure student is meeting the requirements of the plan? How are students notified of the SAP policy?
Student Accounts 668.164 Procedures for posting of disbursements to students accounts timely and accurately including procedures to ensure funds are posted in 3 days. Procedures for handling credit balances: Monitoring of students with credit balance authorization forms;
Student Accounts For students with credit balance authorization forms; how do you monitor and ensure credit balances are handled within the 14-day requirement of end of loan period (or award year if loans are not awarded), or within 14-day requirement of graduation;
Student Accounts For students that do not authorize the holding of credit balance, how do you monitor the issuance within the 14-day requirement? How does the student rescind authorization to hold credit balance? Who monitors and handles late disbursements that post that might cause a credit balance which may need to be issued within the 14- days?
NSLDS Reporting Rosters process for completing and returning rosters including the schedule followed.
Enrollment Status Changes Process for reporting changes in enrollment status; Who is responsible? How the responsible party receives notification of change.
Transfer Student Monitoring Process for adding a student to monitoring; Who is responsible? How the responsible party receives notification of change.
Withdrawals/TIV Refunds 668.22 Schools refund policy including Return to Title IV (R2T4) Note: School refund policy may change so it is important to note in the P&P the various policies and effective dates. Process of coordination between departments (academics, business office and financial aid). Procedures for return of unearned aid or refunds resulting from school refund policy or R2T4.
Withdrawals/TIV Refunds 668.22 Notification process of results Refund calculations; Return to TIV programs; Post Withdrawal Disbursements (PWD)- Process to notify students of eligibility for PWD; Process for tracking PWD s awaiting authorization student or parent; Process for disbursement of PWD; and Process to notify and deliver credit balance resulting from PWD.
Withdrawals/TIV Refunds 668.22 Updating NSLDS and loan servicer due to enrollment status change. Process for handling Exit Counseling (covered in DL section of P&P) Default Management Plan
Miscellaneous Distribution of Consumer Information 601.11; 601.30; 668.14; 668.41 668.49; 668.164(i) Procedures for meeting requirements for Constitutional Day Procedures for distributing voter registration (if your state has not enacted the vehicle/voter registration provision) Validity of HS Diploma (if issue is raised)
Miscellaneous Leave of Absence Procedures Job Descriptions of Financial Aid Employees & Adequate Staffing 668.16(b) Procedures for G-845 668.135 Resolving Conflicting Information 668.16 (f) Resolving Comment Codes (C-Flags)
Miscellaneous Cost of Attendance for each award year and back up documentation on how the figures are determined Academic Year Definition (if more than one used, the section should document this by program) Title IV Formula (if more than one used, the section should document this by program) Programs subject to clock to credit conversion
WHO? Who should create manual? Who should update? Who needs access to manual?
WHERE? Where to maintain the completed manual?
WHEN? When should it be updated?
Resources NASFAA IFAP ListServs Peers
Lesson Learned
Most Frequently Requested Polices and Procedures for a Program Review SAP Verification Refunds & R2T4 Selection Criteria for CBF Admission Criteria Consumer Information
Contact Information: Chyrl R. Ayers Chief Operating Officer Global Financial Aid Services cayers@globalfas.com 228-523-1030
Q & A
5 W s of Creating and Maintaining a Compliance Policy and Procedure Manual