Policy and Procedure Manual 2018 MSFAA Summer conference Bernice Lindke

Why Record Policies/Procedures? Administrative Capability Regulatory Compliance Financial Aid Offices must document how federal regulations are implemented Reviewed during audits Establishes history Reference for practices

Office Benefits of a Policy & Procedure Manual Provides consistency and clarity of functions Improves accountability Reduces burden on management Encourages independence for staff to do their jobs Helps with training new staff

Policy Statement General Brief Explains why you have the rule/regulation Identifies who is affected by the regulation When the rule is applied What happens if the rule isn’t followed

Procedure Elements Explains the actions What position performs the actions Timing of the actions How the actions are applied Provides examples Gives specificity Allows others to understand process and follow steps to perform the function

Policy Statement Example Crystal Mountain College, as a participant in federal loan programs, is required to have a code of conduct applicable to the institution’s officers, employees, and agents. The code of conduct requirements are set forth in the Higher Education Opportunity Act (HEOA) signed into law on August 14, 2008. The Code of Conduct Related to Student Loan Activities is a requirement specific to certain transactions and activities related to financial aid matters. In addition, the law includes requirements related to publication of the code and annual disclosures.

Procedure Example Code of Conduct Crystal Mountain College hereby adopts the following provisions from the HEOA, Section 493 as its Code of Conduct Related to Student Loan Activities and will annually inform all institutional officers, employees, and agents with responsibilities for student loan activities and decisions of the provisions of this code.  (1) Ban on Revenue-Sharing Arrangements     (A) Prohibition -- The institution shall not enter into any revenue-sharing arrangement with any lender.   (B) Definition -- For purposes of this paragraph, the term 'revenue-sharing arrangement’ means an arrangement between an institution and a lender under which – ….Continues on with more specificity

Policy Statement Example 3.4.1.4 Michigan Competitive Scholarship MCS is available to undergraduate students pursuing their first degrees at an approved Michigan postsecondary institution. The scholarship is based on both financial need and merit.

Procedure Example Awarding Procedures: Prior to the start of the fall semester a batch award is placed for the Fall and Winter semesters for each student that is eligible for MCS. Log into MiSSG. Select MiSSG/Reports/Eligible Students Report. Select the appropriate academic year. Select Michigan Competitive Scholarship for Aid Program then select how you would like the student’s to be displayed. Click “Generate Report”. Save the report as an excel file. Filter report by Total Award column (smallest to largest). Any student receiving less than the maximum amount ($1000) will need to be manually awarded for each student. Everyone else can be batch awarded for Fall and Winter. For batch awarding to work each SSN will need to be converted to a student ID#.

P&P’s Typically Requested in a Program Review Satisfactory Academic Progress (SAP) Admissions Refunds Return of Title IV Funds Consumer Information Verification Perkins Loan Selection and Awarding of Students FWS Selection and Awarding of Students FSEOG Selection and Awarding of Students *Per FSA “A Guide to Creating a Policies & Procedures Manual”

How to Get the Manual Completed Assign Topics to Staff based on Job responsibilities Or, use a team approach Policy and Procedure Templates on the Web FSA Assessment for Schools A Guide to Creating a Policies & Procedures Manual NASFAA Compliance Tool Step by step guidelines Contains Title IV regulation references Kept in secure place for future updates

Don’t Reinvent the Wheel! Many examples of great policies/procedures available on the web These are public documents that can be used to develop your Policies/Procedures Examples: Student Loan Code of Conduct Satisfactory Academic Progress Policy Just edit for your campus’ unique practices and reflect how the policies are enforced When in doubt, ask permission

Formats Used Paper Website Shared Network Other

Words of Wisdom If you have a written Policy and Procedure, you must follow it. If you’re doing something else, stop it, or change your P&P.

Caution Potential problems if you don’t follow your Policy and Procedures Audit and/or program review findings Fines and penalties assessed to your institution Bad press, depending upon severity of the issue Lower student enrollment Loss of Title IV eligibility (in very severe cases)

Questions?