Hands-On: FSA Assessments For Foreign Schools Session #26 Hands-On: FSA Assessments For Foreign Schools Jamie Malone Byron Scott Training Officers U.S. Department of Education

Training Objectives 1 Locate, Navigate, and Review the Foreign School Assessments 2 Learn the Benefits of Using the Foreign School Assessments 3 Provide a Hands-On Experience Our training objectives are you will locate, navigate and begin using the assessments in today’s hands on session. In addition, we will discuss the benefits of using the Foreign School Assessments. We would like to take about 15-20 minutes to review a Power Point session that will introduce the Foreign School Assessments and prepare you to navigate the assessments in the hands on portion of this session.

Why Use the Assessments? Assess compliance Link to Title IV regulations and other resources Track your Action Plan Why Use the Assessments? The Foreign School Assessment is a tool that can assist you with your compliance efforts. It provides easy access to Title IV regulatory links and other resources to help you evaluate your Policies & Procedures and effectiveness of your Title IV operations. The Assessment provides Policies & Procedures templates, activities to evaluate your Title IV operations, and an Action Plan to help you track the progress of areas that you identify that need to be corrected or to make enhancements to areas that require revisions.

Locate IFAP.ED.GOV FOREIGN SCHOOLS INFORMATION PAGE FOREIGN SCHOOL ASSESSMENT Where can you find the Foreign School FSA Assessments? The Assessments are available from the IFAP website. From IFAP, click on the Foreign Schools Information Page, and then select Foreign Schools Assessment. How many of you have viewed the FSA Assessments that are available on IFAP for domestic schools? We used the Domestic Assessments design when developing the Foreign School Assessments. How are they different then the Foreign School Assessments? There are more domestic FSA Assessments, for example domestic schools have requirements for programs such as Campus-Based funds and requirements for Verification that are not applicable to Foreign Schools.

Foreign Schools Assessments Students Student Eligibility Schools Automation Consumer Information Institutional Eligibility Default Prevention & Management Managing Funds Return of Title IV Funds Fiscal Management There are seven Foreign Schools Assessments divided into three categories. Under the Students Category, you will find the Student Eligibility Assessment. Under the Schools Category, you will find the Automation, Consumer Information, Institutional Eligibility, and Default Prevention & Management Assessments. Under the Managing Funds Category, you will find the Return of Title IV Funds and Fiscal Management Assessments. We suggest you have all the staff responsible for each category involved to complete the Assessments. The Assessments are not meant to be used as a checklist, but as an opportunity for you to evaluate your Title IV aid process.

Assessment Design Page Layout Links Action Plan Activity Bar How are the Foreign School Assessments designed? All of the Foreign School Assessments have the same page layout. At the beginning of each assessment you will find links to documents such as At-A-Glance documents. For example, in the Consumer Information Assessment you will find a link to Consumer Information Disclosures At-A-Glance . Some assessments have links to Policies and Procedures Templates. You are also encouraged to view A Guide to Creating a Policies and Procedures Manual that is available in the domestic school assessments. Keep in mind that some of the requirements for domestic schools are not applicable to Foreign schools. The Guide designed for domestic schools provides a template so that you can design policies and procedures applicable to Foreign Schools. You can access this guide from IFAP.ED.GOV. Click Tools For Schools and select FSA Assessments. The Guide to Creating a Policies and Procedures Manual can be found under the Schools Category. You will also find a link to the Action Plan at the beginning of each assessment. We will discuss the Action Plan later in the session. The Activity Bar contains links to all of the Activities that are part of the assessment. Activities assist you with evaluating compliance requirements for the section being reviewed. The next slide will display the chart on the Main Page of the assessments.

Assessment Design Page Layout Topic Regulation Activity The chart on the main page has three columns. It is designed to follow the Code of Federal Regulations. It provides the topic, regulation and when applicable, other links. You will note that the regulations are not linked in the first column. All other links in the first column are hyperlinked to the applicable document. The Regulatory Links applicable to the assessment are found in the second column and they are hyperlinked. You will also note the regulations are listed in numeric order making it easy for you to locate and review the links. The third column provides the Activity that is applicable to each section listed in the first column. In the example above, it shows that Activity 1 covers Method of Disclosure, Financial Assistance Information, Institutional Information, and Availability of Employees for Information Dissemination Purposes.

Completing an Activity BEFORE AFTER The Foreign School Assessments have been designed so that you can enter information into an activity. To get to each area to enter information, you would use the Tab button on your computer. The information entered can be saved to your hard drive. The activities have been protected so that you can enter information but cannot change the content of the Assessments.

Scenario The school provides required Consumer Information disclosures on it’s website but no subsequent notice to students Does this satisfy the regulatory requirements? We can review the requirements by completing the Consumer Information Assessment The school would like to determine if this process is in compliance with the regulatory requirements. Let’s review how a school would use the Assessments. In the scenario, this school provides the required Consumer Information disclosures via its website. The school does not provide any notice to students indicating the disclosures are available on the website and does not provide students with the exact electronic address where the information can be viewed or accessed.

Consumer Information They decided to complete the Consumer Information Assessment. They clicked on Activity 1 – Institutional and Financial Assistance Information for Students.

Consumer Information Activity 1 The school reviewed Consumer Information Activity 1. Here, they confirmed that they needed to provide a Notice to Students, as well as the exact electronic address where students can review the disclosures. They also confirmed that they were not notifying students that paper copies were available upon request.

Corrective Action Consumer Information Improvement area: Consumer Information disclosures Action Plan: Provide web address and notice to students Now, it’s time to Fix the issue identified. The school identified the area of improvement: Consumer Information Disclosures. The Action plan is to update their procedures to provide a notice to students and the electronic web address where the disclosures are located. They also will include the statement that hard copies are available upon request. The school will also send the notice out for the current award year.

Action Plan Complete Implement Review Annually Where do you locate the Action Plan? An Action Plan can be accessed from the Main Page of any assessment you are using. It helps you capture not only the issue, but also to assign staff members responsible for implementing any changes needed. Let’s look at what a completed Action Plan for this issue would like. It is important to complete the Action Plan, Implement it, and then have a process to annually review to ensure that you remain in compliance. Note: You are not required to use an Action Plan, but we recommend you have a process in place to document the issue you identified and the process you used to evaluate and fix the issue.

Here is an example of a completed Action Plan for this issue. You can see that the school has identified the Action item: Write the Notice. Notice must include the web address where the disclosures are located, and that hard copies are available upon request. Notify students that the required Consumer Information Disclosures are available on the website, provide the actual link to the website, and notify students that paper copies are available upon request. The school also developed the Action Plan: Determine how to notify student via school email address, dorm, or home address. First, we send written notice to students who have a school email address. If the student does not have a school email address, we send written notice to dorm. If the student is not in a dorm, written notice is sent to address on file from FAFSA. The school determined that in this case, the offices involved in the Action Plan would be the Financial Aid Office, Registrar and Admissions Offices. As a Foreign School, you most likely have different names and titles for the office functions that are involved . For example, your office that is responsible for administering the Direct Loan Program may be called the Office of Foreign Students. The key is that you will determine the office on your campus that is responsible for addressing any issues identified. The school also identified two lead persons to coordinate the Action Plan. This is a very important part of the Action Plan process. You need to make sure you assign staff to ensure that the Action Plan is completed.

Next, the school determined that this is a Near-Term Enhancement Next, the school determined that this is a Near-Term Enhancement. In other words, this enhancement could be done immediately. They determined the Start Date, Anticipated Completion Date, and the Actual Completion Date. The Final Result of this Action Plan is: The school sent out all written notification. Followed up with all returned mail for non-sufficient address. They investigated the addresses with Registrar and Admissions Office to locate student. The revised policy has been updated, published and shared with staff and students. Their Policies & Procedures Manual was updated to reflect the changes to their Consumer Information Procedures.

Potential Findings Consumer Information Requirements Not Met Drug Abuse Prevention Requirements Not Met This slide shows some potential findings that can occur related to Consumer Information. By implementing their Action Plan and making changes to their Consumer Information Disclosure Procedures, the school prevented the first finding from occurring. There are also activities within the Consumer Information related to other potential findings. The school could also review other activities to be proactive and make any improvements to ensure a reduced likelihood of other Consumer Information findings occurring in the future.

Hands-On Session Now it’s time for you to take your workbook and locate and navigate the Foreign School Assessments. The workbook has been designed to guide you through all the sections of the Assessments. In addition, it will ask you questions to answer to ensure that you are successfully navigating the assessments. If you have any questions during the hands on session, please raise your hand and we will be happy to assist you.

What We Have Learned Find Navigate Enhance IFAP.ED.GOV Select an Assessment Complete the Assessment Navigate Identify areas to fix and complete Action Plan Fix and review annually Enhance What have we learned today? You have learned where to locate and how to navigate the Assessments. You have reviewed an example of how to fix a Consumer Information issue. We encourage you to go back to your school and begin using the Assessments to evaluate your Title IV operations.

Contact Information We appreciate your feedback on the Foreign School Assessments. Please provide comments to: Joseph Smith U.S. Department of Education Email: Joseph.Smith@ed.gov We hope you enjoyed our session today. If you have suggestions for the Foreign School Assessment design, please forward them to Joseph Smith. His contact information is on the slide.