S ESSION T ITLE I T ’ S T IME TO L IGHT THE L IGHTS 2016 ILASFAA A NNUAL C ONFERENCE A PRIL 6 – 8, 2016, H ILTON, L ISLE, IL R2T4 E XPERIENCED P AUL S CHMIDT – C OLLEGE OF D U P AGE 2016 ILASFAA A NNUAL C ONFERENCE A PRIL 6 – 8, 2016, H ILTON, L ISLE, IL

Scenes Common Audit Findings What are Modules and do you have them? R2T4 on the Web Hand Calculations Institutional Software for calculations Examples Tips Questions 2016 ILASFAA Annual Conference 2

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Common Audit Findings – FSA Conference 2015 – Session 37 #3 – Return of Title IV Calculation Errors #4 – Return of Title IV Funds Made Late #6 – Pell Grants – Overpayment/Underpayment #10 – G5 Expenditures Untimely/Incorrectly Reported 2016 ILASFAA Annual Conference 4

Top Program Review Findings – FSA Conference 2015 – Session 37 #2 – Return to Title IV Calculation Errors #8 - Inaccurate Recordkeeping #10 - Consumer Information Requirements Not Met Tied with Return to Title IV (R2T4) Funds Made Late 2016 ILASFAA Annual Conference 5

Top Program Review Findings Institutional Charges to Include: Tuition Fees Room and Board (if contracted with the school) Required Course Materials (Books, kits, tools, supplies) 2016 ILASFAA Annual Conference 6

Top Program Review Findings Institutional Charges to Exclude: Charges for required course materials that a school can document a student had a real and reasonable opportunity to purchase elsewhere (FSA Handbook – Volume 5, Page 17) Group Health Insurance Fees Parking/Library fines Athletic or concert tickets Charges for non Title IV eligible course 2016 ILASFAA Annual Conference 7

Top Program Review Findings “Pell 2 Step” Reducing Pell for non-attends prior to R2T4 Making sure award matches enrollment status Double checks!! Direct Loans Master Promissory Note completed? What classes to count? Drop prior to census, non-attend, added late ILASFAA Annual Conference 8

Specifically from the Department of Education Incorrect number of days used in term/payment period Actual clock-hours used instead of scheduled hours Incorrect aid used as “could have been disbursed” Incorrect withdrawal date Mathematical and/or rounding errors 2016 ILASFAA Annual Conference 9

Specifically from the Department of Education Returns not made within 45-day allowable timeframe School’s policy and procedures not followed Inadequate system in place to identify/track official and unofficial withdrawals No system in place to track number of days remaining to return funds 2016 ILASFAA Annual Conference 10

Modules Simply defined – Modules are classes that are offered in any length other than your standard term. Many schools offer 16 week 1 st 8 week sessions 2 nd 8 week session 12 week sessions Combination of all the above 2016 ILASFAA Annual Conference 11

Modules Must be careful to count correct number of days attended and number of days in module Example: Student signs up for 1 st 8 week course that runs 1/23/16 to 3/15/16 and stops attending on 2/1/16 (10 days into class of 53 days) Student signs up for 12 week course that runs 2/15/16 to 5/20/16 and stops attending on 3/5/16 (20 days into class of 89 days) 2016 ILASFAA Annual Conference 12

Modules Student has attended 30 (10 from 1 st 8 wk and 20 from 12 week) days of a possible 112 days (1 st 8 wk overlaps into 12 week – total days to consider are 1/23/16 to 5/20/16 or 112 days). Don’t forget to exclude breaks of 5 days or more! Don’t double count days! 2016 ILASFAA Annual Conference 13

R2T4 on the Web Accessed through FAA Access to CPS Online Must have Read/WRITE access which is granted by your Destination Point person through SAIG Enrollment Does not send any data to Department of Education, only a place to process your records 2016 ILASFAA Annual Conference 14

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R2T4 on the Web Per CPS Tech support – not very intuitive In order of most common use Must setup Institutional charges And School Calendar first 2016 ILASFAA Annual Conference 16

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Hand Calculations 2016 ILASFAA Annual Conference 35

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Institutional Software 2016 ILASFAA Annual Conference 40

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Case Example: Student was enrolled in 4 classes for Spring 1 class spanned full session – 16 weeks 3 classes were 1 st 8 week modules Student withdrew from 16 week course 2/28 Completed all 3 of the 8 week classes. Is this R2T4? Why? 2016 ILASFAA Annual Conference 42

Example Yes, this is R2T4 Count all 4 classes, full 16 weeks Total days attended includes those of 16 week and those of completed 1 st 8 week classes DOE states that because the student did not complete the longest period of enrollment that they were enrolled for, it is R2T ILASFAA Annual Conference 43

Examples in FSA Handbook Volume 5, Chapter ILASFAA Annual Conference 44

Tips Make your Internal Auditor your FRIEND!!! Only evil during audit times How do you identify students? Withdrawal process student takes from office to office? Interoffice communication? Any others? 2016 ILASFAA Annual Conference 45

Tips How do you identify students? 2016 ILASFAA Annual Conference 46

Tips How do you count days? 2016 ILASFAA Annual Conference 47

Tips How do you count days? 2016 ILASFAA Annual Conference 48

Tips Do you have updated policies/procedures? How do you reduce Pell for non-attend classes in relationship to R2T4? Do you have a double check on your process? Do you track the process? 2016 ILASFAA Annual Conference 49

Tip How do you track process? 2016 ILASFAA Annual Conference 50 Round #FAR005 Created FAR005 Review Complete Report Scanned with comments Letters Completed and Sent Returns Completed and Sent to Finance Finance Returned Funds Copy report to share folder 1a2/1/2016N/A 12/8/2016 2/16/20162/9/2016 2/10/20162/16/ /15/2016 2/17/2016 2/26/ /22/20162/24/20162/26/2016 3/15/20162/26/ /29/20163/1/20163/4/2016 3/1/20163/15/20163/4/ /7/20163/10/2016 3/14/20163/10/20163/15/20163/10/ /14/20163/15/2016 3/24/20163/25/2016 3/15/ /21/20163/25/

Closing Credits Questions? 2016 ILASFAA Annual Conference 51

Supporting Cast (References) FSA Handbook – R2T4 – Vol 5 Hand Calculation sheets R2T4 on the Web in FAA Access ILASFAA Annual Conference 52

Supporting Cast (References) 2015 FSA Conference – Session 22 – How Modules Can Affect Title IV Session 34 – R2T4 and Credit Hour Programs Session 37 – Program Review Essentials and the Top 10 Compliance Findings 2016 ILASFAA Annual Conference 53

Supporting Cast (References) Department of Education Training: Online Training Module—Return of Title IV Funds This is an online, self-paced training module on the Return of Title IV Funds (R2T4) calculation, featuring a variety of lessons and resources to assist schools in meeting the R2T4 requirements. This course provides information on elements of the R2T4 regulations that are common to all institutions, discusses considerations for the formulation of school policy, and includes lessons specific to completing R2T4 for clock-hour programs, credit-hour programs, and credit-hour programs with modules. The training is intended for financial aid professionals who are unfamiliar with the R2T4 requirements and other staff who would like to learn more about performing the R2T4 calculation. To access the training, log in to the E-Training website with your username and password. After logging in, select "Training by Topics" from the main menu bar. From the drop-down menu that appears, choose "Return of Title IV Funds" and then select "Enroll Me" to launch the course.log in to the E-Training website Note: If you do not have a username and password for Federal Student Aid E-Training, click on "Create new account" on the homepage and follow the instructions to create a username and password. If you have questions about this training, please Suzanne Scheldt. Suzanne Scheldt 2016 ILASFAA Annual Conference 54

Supporting Cast (References) Regional Drive-In Workshop Series Locations and Dates Attachment to Dear Colleague Letter ANN ILASFAA Annual Conference 55