1. Crafting Your Policies And Procedures
NCASFAA Fall 2013
Rose Mary Stelma

2. What We’ll Talk About Definitions Requirements
Purpose of Policies and Procedures
Good Practices and Tips
Challenges
FSA Resources
Suggested Topics
Samples

3. Who Is Involved? Chief Craftsman - Dean, VP, Chancellor
Approves policies
Artist - Director/Financial Aid Administrator
Responsible for development and maintenance of P&P
Ensure staff follow P&P
Your dean, vice president, chancellor – your administration – they need to approve policies – that may mean that they say “you decide what to do and we support you” –
Are there instances where you want them to establish the policy? (it impacts recruitment and retention, is something new, is a financial aid policy but has to be implemented by another office – like fraud prevention in distance education – one of the suggestions is to see if multiple students are using the same IP address – you cannot do that in the financial aid office, but it may well be a financial aid policy)
Do you have a faculty senate or staff “advisory” committee that works with your office? They may also be “team owners” or involved in recommending and approving policy.
Director/Financial Aid Administrator – he/she is responsible for the play book – for making sure that everyone is playing by the rules – it’s really important you stay on top of this. You’re the “designated authority”

4. Who Is Involved? Supporting Craftsmen - Financial Aid Staff
May be assigned specific responsibilities (like working on procedures!)
Patrons - Others
Federal Student Aid
NCSEAA
Auditors
Financial Aid staff may actually write and enforce various policies and procedures.
They have to follow the rules – you need to periodically check to make sure that everyone understands and is following the p & p
How are other offices involved? – DE fraud example would involve IT staff – business office is involved in disbursement – registrar with SAP – admissions with who is a regular student
The US Dept of Educ, Federal Student Aid – NCSEAA – state auditors – they all want to make sure we’re following the rules.

5. Important Reminder This presentation provides guidance only.
The list of topics is NOT exhaustive – just a guide
Always review statutes, regulations, and other guidelines (like Dear Colleague letters, guidance issued by state agencies, etc.)

6. Resources You Need A commitment to “get it done”
Willingness to use available resources
Financial aid rules, regulations, statutes, guidance (Dear Colleague, etc.)
Coffee, tea, chocolate – whatever gets and keeps you going
Writing tools

7. Policy Definition Noun
A definite course of action adopted for the sake of expediency, facility, etc.
Action or procedure conforming to or considered with reference to prudence or expediency
Synonyms: strategy, principle, rule
Source: Dictionary.reference.com
What is the definition of “policy?”

8. Procedure Definition Noun
An act or a manner of proceeding in any action or process; conduct
A particular course or mode of action
Synonyms: Management, operation, maneuver, transaction
Source: Dictionary.reference.com
Definition of procedure?

9. Federal Perspective
Campus needs to have written policies and procedures for the administration of Title IV student assistance programs
Does not have to be a “manual”
Tools to assist schools in being good stewards in administration of programs and delivery of dollars and services
Always important to keep the federal perspective in mind – it’s their football.

10. The Purpose Of Policies
Help an organization reach its long-term goals
Influence and determine all major decisions and actions
All activities take place within the policy boundaries
Explain the business of financial aid to others on campus
Centralize information
A set of policies are principles, rules, and guidelines formulated or adopted by an organization to reach its long-term goals and typically published in a booklet or other form that is widely accessible.
Policies and procedures are designed to influence and determine all major decisions and actions, and all activities take place within the boundaries set by them.

11. The Purpose Of Procedures
Specific methods
Policies in action
Day-to-day operations of the organization
Prevent an employee from holding your operation hostage
Assist with staff training
Procedures are the specific methods employed to express policies in action in day-to-day operations of the organization. Together, policies and procedures ensure that a point of view held by the governing body of an organization is translated into steps that result in an outcome compatible with that view.

12. Good Practices
Reference applicable federal and state statutes and regulations
Align with organization’s vision, strategic plan, and core processes, and goals
Review at least annually
Peer review process that includes cross-section of individuals
Clearly defined approval process

13. Good Practices Assign the responsibility to maintain
Use a standardized process and format
Easy accessibility for staff
Do periodic “reality checks”
Version the document
Clearly identify current and previous versions
Clearly list effective dates

14. The “Must Do” Items Say what you do and then do what you say!
Verify that everyone is following the policies and procedures!

15. Tips For Writing Procedures
Action oriented
Properly describe the activity to be performed.
Consistency
Use references and terms the same way every time
Following the procedure must ensure consistent results
Complete
No missing information or gaps in steps or logic
To be effective, procedures must be action oriented, grammatically correct, and written in a consistent style and format to ensure usability. These guidelines, along with industry "best practices" that are documented in auditable criteria, can be used to improve your procedures:
Context. Actions must properly describe the activity to be performed.
Consistency. All references and terms are used the same way every time, and the procedure must ensure consistent results.
Completeness. There must be no information, logic, or design gaps.

16. Tips For Writing Procedures
Internal Controls
The document and its described actions demonstrate feedback and control.
Preventive
Detective
Should not be overly cumbersome
Clarity
Easy to read and understand
Control. The document and its described actions demonstrate feedback and control.
Compliance. All actions are sufficient for their intended compliance.
Correctness. The document must be grammatically correct without spelling errors.
Clarity. Documents must be easy to read and understandable.
Preventive controls might also be system edits – the system will not allow you to award a Federal Pell Grant greater than the academic year’s maximum award, for example.

17. Challenges
NO TIME!!!! TOO MUCH CHANGE!!!! Develop a schedule Assign responsibility to write, test, for keeping up with review, and update statutory and regulatory changes
Other challenges and strategies to address those challenges?

18. Risk Not complying with regulations Audit findings Financial liability
What are the risks of not having written policies & procedures or not following your written policies and procedures?

19. FSA Resources Ifap.ed.gov Select Tools for Schools
Select FSA Assessments
Select A Guide to Creating a Policies and Procedures Manual
Go to IFAP.ed.gov – Tools for Schools – FSA Assessments – A Guide to Creating a Policies and Procedures Manual

21. If you select Policies and Procedures Activity 1: Developing or Enhancing Procedures you get this page that will help you determine which areas you want to evaluate

23. Responsibilities: Who will develop and update this section
Definitions: Acronyms or definitions used

24. If there are new requirements, you see an alert

25. Administrative Capability
Qualified person(s) to administer Title IV
Checks and balances/separation of duties
Satisfactory academic progress
Conflicting data
Fiscal reports and financial statements
Financial aid counseling
Purpose and philosophy of the Financial Aid Office
General office administration
Calendar of activities
General office administration might include office hours, accommodations for disabled individuals, etc.

26. Institutional Eligibility
General requirements
Updating application information
Admission policy
State authorization

27. General Provisions Certification Title IV refunds
Compliance audits and audited financial statements
Consumer information
Verification
Professional judgment and dependency overrides

28. General Provisions Misrepresentation Documentation
Secondary confirmation
Ability to benefit

29. Federal Perkins Loan Selection and awarding of students
Master Promissory Note
Loan disclosure
Fiscal procedures and records
Forbearance and deferment
Contact with borrowers
Billing
Collection
Litigation
Cancellation

30. Federal Work Study and Job Location and Development
Selection and awarding of students
Assigning FWS jobs
JLD procedures and records
Work Colleges
Program procedures and records

31. FSEOG Selection and awarding of students
FSEOG fiscal procedures and records

32. ACG and National SMART Programs ended 6/30/2011 Historical information
Student eligibility requirements
Calculating awards
Fiscal control and accounting for the programs

33. Federal Direct Loan Packaging policies 150% subsidy limitation
Counseling borrowers
Payment of a refund
Payment of a Return to Title IV
Administrative and fiscal control

34. Federal Pell Grant Calculating awards Lifetime limit
Required and optional recalculations
Fiscal records and disbursement requirements
Disbursement for books and supplies

35. TEACH Grant Eligibility determination Counseling
Fiscal control and fund accounting

36. Other Federal Programs
Example: Nursing Student Loan
Selection and awarding of students
Fiscal procedures, accounting, and fiscal records
Disbursement requirements
Payment of a refund

37. North Carolina Student Financial Assistance Programs
Selection and awarding of students
Fiscal procedures, accounting, and fiscal records
Withdrawal calculation – worksheet
Adjustments and refunds
Disbursement requirements
Payment of a refund

38. Programs from Other States
Selection and awarding of students
Fiscal procedures, accounting, and fiscal records
Disbursement requirements
Payment of a refund

39. Institutional Student Financial Assistance Programs
Selection and awarding of students
Fiscal procedures, accounting, and fiscal records
Disbursement requirements
Payment of a refund

40. Appendices Acronyms Terms Forms Charts
Example of a Completed Section (Appendix B)
Policies and Procedures at a Glance (Appendix C)

41. Example: Conflicting Data

42. Use this as a checklist, even if you do not use the entire FSA resource to develop or update your P&P

43. Sample Purpose Statement
This manual is intended for the use of Student Financial Aid office staff, campus administration, auditors, and others reviewing the financial aid operation at this campus.

44. Sample Philosophy Statements
This campus will be the “preferred choice” for quality education and training. This campus is dedicated to fulfilling the educational, training, and cultural needs of the community.
The Financial Aid Office supports the campus in fulfilling its vision and mission by providing assistance to students who would otherwise be unable to pursue a postsecondary education because of finances.

45. Sample Procedure Fraud and Abuse: Instructions on Contacting the OIG
Should fraud or abuse be detected or suspected, report it to the Director of Financial Aid. The Director will consult with the school’s legal counsel prior to referring it for investigation to the Office of the Inspector General of the Department of Education or any agency outside the school.
Instructions on Contacting the OIG
Provide information to ……..

46. Procedures May Provide Examples

47. Is Your P & P Manual Up To Date?
150% Subsidy Limit
Lifetime Eligibility for Federal Pell Grant
Gainful Employment
Credit hour definition
Repeating coursework impact on full time student definition
NOT an exhaustive list – just a guide!
Gainful Employment – what, when, how?
When can you include repeated courses in determining student enrollment status
Limits on the amount of a program that can be provided by another school, requires disclosures, etc.

48. Is Your P & P Manual Up To Date?
Written agreements between schools
Incentive compensation
High School diploma validity
R2T4
Misrepresentation
Ability to Benefit
Disbursement of Title IV aid
NOT an exhaustive list – just a guide!
Removes “safe harbor” provisions & new definitions
Clarification when misrepresentation occurs, by whom & possible consequences (institution, not financial aid applicant in this case)
Disbursement to obtain books & supplies

49. Is Your P & P Manual Up To Date?
Net Price Calculator
Verification changes
Satisfactory Academic Progress
State Aid Programs
Preventing and Reporting Fraud
NOT an exhaustive list – just a guide!
Net Price Calculator – who is maintaining? How are you using it/promoting it with your families? How to answer questions raised by prospective and current students?
Verification changes – implications of using or not using the IRS data retrieval tool – all items or only selected items for each student?
SAP changes in policies, probation, warning, etc.
NCLTG & SCSF replaced with new need-based program for students enrolled at private independent colleges & universities in NC
Forgivable Education Loans for Service
Dear Colleague GEN published on 10/20/2011

50. Resources for You
IFAP.ED.GOV
IFAP.ED.GOV/QAHOME
NASFAA.ORG

51. Resources used for this presentation
IFAP.ED.GOV/QAHOME
Dictionary.com
Businessdictionary.com
Technibble.com
Btiworld.com
Chiff.com