DE-DC-MD CONFERENCE HOW TO PREPARE FOR AN AUDIT 11/9/2011 Dawn Y. Mosisa, Director, University Financial Aid Compliance Johns Hopkins University

Perspective is critical Manage the audit/review process carefully Ensure your office is in good shape How to Prepare for An Audit or Program Review?

Annual Audit General Assessment Reviews Focused Reviews Types of Audits and Reviews

Independent Auditors The U.S. Department of Education Office of the Inspector General (OIG) Others Who performs Audits & Reviews?

Independent Auditors The Dept of Education Other Agencies Coordinated onsite reviews Do They Speak To Each Other?

Annual Audit General Assessment Program Review Focused Program Review Recertification What is the Typical Focus of an Audit/Program Review?

High CDR Deficiencies reported by state, accrediting, or other agency Significant changes in Pell or Loan volume Late refunds High withdrawal rates Significant Audit Findings Repeat Findings or recurrent problems Complaints from students or adverse publicity Haven’t had a review in a number of years What are Some Possible Triggers for a Program Review?

Typically you work with your auditors to identify a mutually agreeable timeframe. The Department of Education generally provides 2-4 weeks notice for a general assessment program review. Timing for an Audit or Review?

Complaints from law enforcement agencies Serious, credible complaints from students OIG complaints Negative reports from state or accrediting agencies Adverse articles in the media Information from employees (current or prior) Possible fraud and abuse Factors That Could Result In Short Notice For a Review

R2T4 calculation errors Pell overpayment / underpayment Late return of TIV funds Verification errors Overawards R2T4 not made Enrollment status not verified prior to disbursement Improper certification of loans Credit balances not refunded in a timely manner Ineligible students – not meeting SAP Repeat finding – failure to take corrective action Common Audit Findings

Verification errors Crime Awareness requirements not met Credit balances not refunded in timely manner R2T4 calculation errors R2T4 done late Entrance/exit counseling deficiencies Account Records inadequate / not reconciled Missing/inconsistent information in files SAP policy not adequately developed and/or monitored Pell overpayment / underpayment Enrollment report (SSCR) issues Repeat findings or failure to take corrective action Common Program Review Findings

Verification errors R2T4 calculation errors R2T4 performed late Pell Grant underpayment / overpayment Credit balances not refunded in timely manner SAP issues Repeat finding / failure to take corrective action What is on both lists?

Involves more than just the financial aid office More than student eligibility and the management of Title IV funds Institutional compliance with TIV laws What Should You Know About the Audit Process?

What is the level of knowledge of your auditor/reviewer? Do you think it is better to have a more knowledgeble auditor? Or less? Who Is Your Auditor / Reviewer?

Letter Request for Information Onsite Visit Entrance Interview Audit / Review is conducted Exit Interview – usually with preliminary findings Initial Letter of Findings Institutional Response with Corrective Action Plans (CAP) as appropriate Final Report of Findings Snapshot of the Typical Audit

Be calm! Listen and understand what is being asked Be cooperative, responsive, and honest Be direct in your responses and to the point Do not answer the “unasked” question Say you don’t know if you don’t know (find out the answer) Document what was said, and any outcome or action items Ask for requests in writing, or confirm in writing for clarity Keep copies of anything you provide to them During the Onsite Visit…..

Who is conducting the audit / review? What is their focus and how were you selected? What type of information will they request and will you be able to easily provide it? Are your student files organized and by AY? Who should you involve? Notify leadership and relevant offices, including IT. Select a “point person” for the auditor/reviewer to work with. Designate a quiet work area for your auditor. How Do You Prepare for An Upcoming Onsite Audit / Review?

Policy and Procedure Manual Cost of Attendance Budgets SAP Policy Pell and Loan account information R2T4 Policy and process List of enrolled students, and withdrawals ISIRs and student files Access to documents/SIS SSCR documentation Other What Documents Are Typically Requested?

Ongoing due diligence Ensure previous audit findings are corrected Ensure new laws and regulations are implemented Have safety nets in place in your operations Don’t ignore repeat questions/issues raised by students & staff - they could indicate a weak area or gap Ensure your staff is properly trained ongoingly Meet regularly with your staff Ensure your student files are organized, and that actions and decisions are documented Keep your P&P updated How to Prepare for Audits and General Assessment Reviews

Internal Audits Mock Program Review by outside consultant NASFAA Self-Evaluation Guide Program Review Guide for Institutions on IFAP FSA Assessments on IFAP What Else?

On IFAP under Tools Developed in collaboration with FA Professionals Purpose is to help schools with compliance and with making improvements What is FSA Assessments?

It has 3 main topic areas, with several sections under each, and several specific topics/sub-sections under each section. These main topic areas are: Students School Campus-based There’s an FAQ page with guidance on how to navigate and begin using! What Does FSA Assessments Offer?

The “Students” main topic includes 3 sections: Student Eligibility Satisfactory Academic Progress Verification FSA Assessments - “Students”

The “School” main topic area includes 7 sections: Guide to create a P&P Automation Consumer Information Default Prevention and Management Fiscal Management Institutional Eligibility R2T4 FSA Assessments - “School”

The“Campus-based” main topic includes 3 sections: FSEOG FWS Perkins FSA Assessments – “Campus-based”

Provides guidance on which sections and/or activities to complete based on your current situation, such as: Deficient Audit Recertification Fiscal Reconciliation Program Review Deficiencies No Action or Deficiencies 2 Assessments per AY is recommended FSA Assessments Chart

15 sub-sections – with 3 activities Student eligibilityCitizenship Academic QualificationSAP FA HistoryValid SSN Selective ServiceACG/SMART Drug-related offensesTEACH Grant TelecommunicationsStudy Abroad Financial NeedVerification Regular Student in Eligible Program FSA Assessments – Student – Student Eligibility

9 sub-sections – with 5 activities RecertificationPPA Gainful EmploymentConsumer Information Financial ResponsibilityPreferred Lender Lists Accred/State ApprovalWritten Arrangements Program Eligibility/AY Requirements FSA Assessments – School – Institutional Eligibility

No Surprises Know the scope, perspective, and reason for the audit/review An institutional review Select a “point person” Be organized Always be professional, responsive, and direct Document In Summary

Questions??? Good Luck!!!