Compliance and Audit Practices within the Financial Aid Office

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University Business Article January 30, 2018 2015 Vanderbilt University did an internal audit to better understand the cost of compliance. The cost was $146 million in 2013-2014 The Vanderbilt study also determined that compliance cost in higher education is approximately $27 billion According to the Higher Education Compliance Alliance (HECA) there are an estimated 265 federal statutes for institutions to follow University Business Article January 30, 2018

What are the major compliance sectors in Higher Education Cybersecurity Federal Regulations State Regulations Athletics Who is responsible for ensuring regulations are reviewed and policies and procedures are in place What can the Financial Aid Office do to ensure all I’s are dotted and T’s are crossed Discussion Topics

Identity Theft Red Flag Rules Safeguard Rules Identity Theft Red Flag Rules FERPA State Privacy Laws Cybersecurity Compliance All found on IFAP under cybersecurity compliance

What is PII and SPII How is it relevant to compliance Personally Identifiable Information (PII) Sensitive Personally Identifiable Information (SPII) Schools need to educate students and families on how to send their personal information Schools should have readily available the procedure for sending PII or SPII Q&A on IFAP under FSA Cybersecurity Compliance has an example of how to WinZip information Details on how to encrypt data should be on your website What is PII and SPII How is it relevant to compliance

Federal Compliance Consumer Information Disbursement Rules Awarding Rules SAP R2T4 Verification Reporting Regulations ISIR management rules FERPA Federal Compliance

State Compliance Regulations Reporting for various programs On-time awarding Determination student is eligible for funding Audits State Compliance Regulations

Who is the responsible office to ensure college is in compliance Compliance is an institutional responsibility. Make sure decision makers are aware of all compliance issues Every office on campus shares a piece of the compliance pie Communication and training will ensure compliance issues are addressed and in place Who is the responsible office to ensure college is in compliance

What can the Financial Aid Office do to get the ball rolling Create a committee to review and ensure current regulations are being met Committee should consist of IT, Registrar, Bursar, FA, Campus Security, Admissions, Title IX, Institutional Research and General Council Have regular meetings to review progress and to establish a game plan for new regulations As stated earlier make sure the decision makers are aware of the regulations and your progress Communication Communication Communicatiion What can the Financial Aid Office do to get the ball rolling Y

Make sure your Policies and Procedures are up to date and contain all the required information There are a number of companies that will assist with reviewing and suggestions to make your P&P perfect NASFAA has a great tool to utilize Ask other institutions for assistance Utilize any training on the subject Some Best Practices

Best Practices Cont. Regular Meetings with FA staff Retreats with FA staff with specific topics that deal with compliance Allow as many staff as possible to have access to NASFAA newsletter or other relevant publications Get staff on list servs for their specific jobs Have group reading days to review regulations Encourage training opportunities Use DOE tools available on IFAP Best Practices Cont.

Audits There are many entities that will audit your college Federal, State, NCAA and Accrediting Agencies Audits

Top 10 Federal Audit Findings Repeat Finding – Failure to Take Corrective Action NSLDS Roster Reporting – Inaccurate/Untimely Reporting Return to Title IV (R2T4) Calculation Errors Return to Title IV (R2T4) Funds Made Late Verification Violations 6. Pell Grants - Overpayment/Underpayment 7. Qualified Auditor’s Opinion Cited in Audit 8. Entrance/Exit Counseling Deficiencies 9. Student Credit Balance Deficiencies 10. Improper Origination of Direct Loans Top 10 Federal Audit Findings

Federal Audit Notification Gathering of data Sending required documentation Site Visit Responding to findings Final Determination and any fines or restrictions Federal Audit

FAO role in Federal Audit Organize the group to assist with getting information together Assign tasks Gather and send information Make sure all offices are available for visit FAO role in Federal Audit

How to make things easier if chosen for an audit P&P up to date and correct Consumer Information is on website Processes for administering aid are correct Files are in order Verification is complete How to make things easier if chosen for an audit

Questions