People with good academic ideas often don’t consult their financial aid officer before beginning their new venture. That oversight can cost the school and the person with the great idea valuable time, money, and wasted effort.
Federal regulations are sometimes ridged, but they are also flexible enough to allow institutions to be creative in developing their programs and methods of delivery. But those regulations must be understood and the great idea must be developed with those regulations in mind.
Any new educational program, therefore, must include at its inception a qualified, experienced financial aid officer who also is not too ridged. If one is not available, advise your administration, seek out a third party consultant, or call a representative of the U.S. Department of Education (DOE) to make sure your institution is on the right track toward a successful program launch.
However, even the most qualified financial aid officer cannot make a successful launch if the institution is receiving negative audits and reviews by the DOE. Do a self-evaluation at the institution level to be sure your school is meeting the standards set in the DOE Federal Student Aid Handbook.
The most common DOE program review findings and the top audit findings are listed below. By identifying and fixing problems before your audit or review, new programs will be easier to pass through the financial aid review process.
These findings were compiled from a 2015 DOE presentation entitled,
“Program Review Essentials and the Top Compliance Findings from Institution Annual Audits”:
- Repeat findings from prior reviews or audits, and failure to take the appropriate corrective action.
- NDSLS roster reporting, also known as enrollment. The findings generally are inaccurate or untimely reporting.
- Return of Title IV (R2T4) calculation errors.
- Return of Title IV (R2T4) funds paid late or not at all.
- Verification Violations and Comment Code Reviews — oversights and missing documentation. Note: this requires much attention to detail and could involve over 30% of your students.
- Pell Grant overpayment/underpayment.
- Student credit balance deficiencies. This involves untimely, or the absence of, providing students their living expense money in a timely manner.
- Entrance/exit counseling deficiencies. This deficiency may be caused by a failure to obtain such documents or using an incorrect or out of date document.
- Qualified auditor’s opinion cited in an audit may cause the DOE to examine further.
- G-5 expenditures untimely/incorrectly reported (G-5 is the DOE agency making funds available.)
- Drug abuse prevention program requirements not met.
- Inaccurate and incomplete recordkeeping of the following:
- Failure to document enrollment status before disbursement
- Failure to determine unofficial withdrawals
- Failure to maintain consistent disbursement records
- Inadequate or mismatched attendance records for schools required to take attendance
- Inaccurate/missing Federal Work Study timesheets.
- Conflicting last dates of attendance (LDA)
- Failure to follow policies and procedures.
- Consumer Information Requirements not met. This is a broad spectrum situation and there are many items which could lead to management concerns,
Be sure to review the complete list of Consumer Information Requirements and additional consumer information in volume 2, chapter 6 of the FSA Handbook.
Functioning in the federal financial aid area known as Title IV of the Higher Education Act takes constant vigilance to avoid making unintentional errors that could endanger the institution. But with diligence and experience, it can be accomplished.
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