1. 1 2008 State Program Review Process Presented by GSFC Compliance Team

2. 2 2008 State Program Review Process Agenda Welcome and Introductions Welcome and Introductions 2008 Program Review Overview 2008 Program Review Overview Program Review Timeline Program Review Timeline Questions and Discussion Questions and Discussion

3. 3 Introduction Goal – To make you familiar with the process Goal – To make you familiar with the process Materials: Materials: –Information packet, or –www.gsfc.org – Click on ‘School & Lender Information’, then scroll to GSFC Compliance Documents www.gsfc.org Staff Introductions Staff Introductions Housekeeping Housekeeping

4. 4 Goals Improve Administration of Programs Improve Administration of Programs Educate and Train Institutional Staff Educate and Train Institutional Staff Safeguard Public Funds Safeguard Public Funds Be Clear, Consistent, and Concise Be Clear, Consistent, and Concise

5. 5 Implementation Began with the 2007 Review Calendar Began with the 2007 Review Calendar Included 40 Institutions Included 40 Institutions Employed a Benchmark Component Employed a Benchmark Component

6. 6 Review Process Prior to 2007 All Institutions Reviewed Annually All Institutions Reviewed Annually Typical Sample Size was 30-40 Files Typical Sample Size was 30-40 Files Length of Review Length of Review Review Was Conducted Only on Selected Award Year Review Was Conducted Only on Selected Award Year

7. 7 Current Review Process Each Institution to be Reviewed at Least Once Every Three Years Each Institution to be Reviewed at Least Once Every Three Years Sample Size is Based on a Statistically Sound Methodology (95% Confidence Level with +/- 10% Margin of Error) Sample Size is Based on a Statistically Sound Methodology (95% Confidence Level with +/- 10% Margin of Error) Review Timeframe is 2 Days Review Timeframe is 2 Days All State Awards for Students in Sample are Examined for Review All State Awards for Students in Sample are Examined for Review

8. 8 Tracking Institutional Progress Through Benchmarking Benchmarking tracks the progress of Georgia institutions in the proper administration of State Programs. Benchmarking tracks the progress of Georgia institutions in the proper administration of State Programs. Findings types are assigned a value based on severity Findings types are assigned a value based on severity Number of incidents for each finding type are multiplied by the value of each finding to arrive at a finding score Number of incidents for each finding type are multiplied by the value of each finding to arrive at a finding score The finding score is then compared to the sample size, which determines a Benchmark Score The finding score is then compared to the sample size, which determines a Benchmark Score This Benchmark Score is used to determine which institutions will benefit the most by having GSFC efforts directed towards assisting them in the administration of the State Scholarship and Grant Programs This Benchmark Score is used to determine which institutions will benefit the most by having GSFC efforts directed towards assisting them in the administration of the State Scholarship and Grant Programs

9. 9 Benchmark Values for Finding Types 5 – Fraud by an institution or False Certification of award 5 – Fraud by an institution or False Certification of award 4 – Administrative problem affecting a significant portion of the population - GPA, Refunds, Invoicing, Residency 4 – Administrative problem affecting a significant portion of the population - GPA, Refunds, Invoicing, Residency 3 – Administrative errors affecting smaller population - Selective Service, SAP, Citizenship, Default, Book Allowance, Enrollment, Exceeded Hours 3 – Administrative errors affecting smaller population - Selective Service, SAP, Citizenship, Default, Book Allowance, Enrollment, Exceeded Hours 2 – Missing or Incorrect Documents - Missing Transcript, Missing Application 2 – Missing or Incorrect Documents - Missing Transcript, Missing Application 1 – Non-Monetary Exceptions - Incorrect Reporting of Data, No Book Allowance authorization 1 – Non-Monetary Exceptions - Incorrect Reporting of Data, No Book Allowance authorization

10. 10 Institution’s Benchmark Score Finding Value / Sample Size = Institution’s Benchmark Score Finding Value / Sample Size = Institution’s Benchmark Score Example: Example: 3 incidences of incorrect determination of Residency (value of 4) will result in a finding rate of 12 (3x4). If 90 files are sampled, the resulting Benchmark Score will be 13.33 3 incidences of incorrect determination of Residency (value of 4) will result in a finding rate of 12 (3x4). If 90 files are sampled, the resulting Benchmark Score will be 13.33

11. 11 Benchmarking Impact Last Year We Reviewed Schools Based on the 2006 Benchmark Scores Last Year We Reviewed Schools Based on the 2006 Benchmark Scores 40 Schools 40 Schools 2006 Benchmark Scores Used Solely for Determining 2007 Review Roster 2006 Benchmark Scores Used Solely for Determining 2007 Review Roster Tracking Benchmark Scores Began in 2007 Tracking Benchmark Scores Began in 2007

12. 12 Institutional Review Roster for 2008 Repeating reviews at a portion of the schools reviewed in 2007 Repeating reviews at a portion of the schools reviewed in 2007 Exempted in 2006 Exempted in 2006 Schools with a 2006 Benchmark Score of zero Schools with a 2006 Benchmark Score of zero

13. 13 Sample Size Based on number of awards Based on number of awards Number of files required to achieve a 95% confidence level with a +/- 10% margin of error rate Number of files required to achieve a 95% confidence level with a +/- 10% margin of error rate Typically 80-90 files Typically 80-90 files

14. 14 Policies & Procedures Preliminary Report to Institutional Officers Preliminary Report to Institutional Officers Final Report to President Final Report to President Remittance of liabilities not due until after the Final Report is issued Remittance of liabilities not due until after the Final Report is issued Strict adherence to the review timeline Strict adherence to the review timeline Multiple year review Multiple year review Sample selection with a variety of criteria – presence of electronic applications, cancellations, and citizenship status Sample selection with a variety of criteria – presence of electronic applications, cancellations, and citizenship status

15. 15 Training Referrals Training Referrals Training Referrals Mandatory Referrals Mandatory Referrals

16. 16 Goals It is the intent of GSFC to demonstrate good stewardship of State Funds. Success with the current review procedures will be measured by: It is the intent of GSFC to demonstrate good stewardship of State Funds. Success with the current review procedures will be measured by: –Improving Benchmark Scores of All Participating Institutions –Developing better relationships with Georgia institutions –Improving the confidence level in GSFC

17. 17 Review Preparation Review Notification Letter -Selected / Not Selected Review Notification Letter -Selected / Not Selected Review Schedule Review Schedule *New – Program Review Schedule Request Form *New – Program Review Schedule Request Form Request for Documentation Request for Documentation

18. 18 Administrative Questionnaire School Catalog & Student Handbook Current Financial Aid Policies & Procedures Scholarship & Grant Reconciliation User Guide for Computer System Documents to Submit Prior to Review

19. 19 Sample Lists Sample list delivery date - 5 business days prior to the review Sample list delivery date - 5 business days prior to the review Notify Compliance if: - Contact person changes; or - Your email is inaccessible Notify Compliance if: - Contact person changes; or - Your email is inaccessible

20. 20 The Entrance Interview Session More School Participation More School Participation Confirm On-site Review Time Confirm On-site Review Time Identify the School Contact Person Identify the School Contact Person Review School Security Procedures Review School Security Procedures Ensure Availability of Documents Ensure Availability of Documents Cover Scope of the Review Cover Scope of the Review Discuss the School’s Last Program Review Discuss the School’s Last Program Review School’s Questions School’s Questions

21. 21 The Exit Interview Session Verify the Return of all School Documents Verify the Return of all School Documents Collect all Review Documents Collect all Review Documents Summarize the Review Findings Summarize the Review Findings Distribute Copies of the Review Findings, Deficiency Code List and Sample Documentation List Distribute Copies of the Review Findings, Deficiency Code List and Sample Documentation List Discuss ‘Next Step’ in the Review Process -30 days, preliminary report -30 days, school response time Discuss ‘Next Step’ in the Review Process -30 days, preliminary report -30 days, school response time Deficiency Resolution Deficiency Resolution On-site Review Completed On-site Review Completed

22. 22 Program Review Reports Two reports will be issued as a result of the program review Two reports will be issued as a result of the program review The Preliminary Report and the Final Report The Preliminary Report and the Final Report

23. 23 Preliminary Report Issued within 30 days of the on-site review Issued within 30 days of the on-site review Changes found in the Preliminary Report Changes found in the Preliminary Report - Sent to Financial Aid Office, Admissions Office, Business Office and Registrars Office - Reference to the regulation to which the finding relates - Findings outside of the review year

24. 24 Preliminary Report Institution has 30 days to respond Institution has 30 days to respond Institution’s response should include a response to each finding listed in the Preliminary Report and any documentation in support of disputed findings Institution’s response should include a response to each finding listed in the Preliminary Report and any documentation in support of disputed findings Institution may request a15 day extension Institution may request a15 day extension If institution does not either respond to the Preliminary Report or request an extension in writing during the 30 day appeal period, the Final Report will be issued to the President at the end of the 30 day period If institution does not either respond to the Preliminary Report or request an extension in writing during the 30 day appeal period, the Final Report will be issued to the President at the end of the 30 day period Institutions should not remittance of funds until Final Report is issued Institutions should not remittance of funds until Final Report is issued

25. 25 Final Report Issued within 30 days of the institution’s response to the Preliminary Report Issued within 30 days of the institution’s response to the Preliminary Report Sent to President with copies to Institutional Officers Sent to President with copies to Institutional Officers Institution has 30 days to respond – must contact lead reviewer if additional time is needed Institution has 30 days to respond – must contact lead reviewer if additional time is needed Institution’s response should include payment of any monetary liabilities and any Corrective Action Plans due - any additional documentation regarding disputed findings should also be included Institution’s response should include payment of any monetary liabilities and any Corrective Action Plans due - any additional documentation regarding disputed findings should also be included

26. 26

27. 27 Assuming no 15 day extension

28. 28 2008 State Program Review Summary Each institution: Each institution: –Will be reviewed AT LEAST once every 3 years –Design a point of contact for the program review –Receive Program Review Checklist and Administrative Questionnaire –Will be required to provide all requested documentation within 15 days of the notification –Have various institutional offices represented at the Entrance and Exit Interviews

29. 29 2008 State Program Review Summary Continued –Will be required to repay any funds determined to be incorrectly awarded to any student, even if awarded outside the selection year –Present complete student files to the Compliance Team at the Entrance Interview –Understands no additional files or documentation will be accepted by the reviewer after the Entrance Interview –Will be provided preliminary list of findings at the Exit Interview

30. 30 2008 State Program Review Summary Continued –Will be issued a Preliminary Letter and Report only to Institutional Officers –Have a 30 day appeal period prior to the Final Letter and Report to provide documentation to alleviate monetary liability –Understands even if the documentation is provided, the finding will remain on the Final Report (unless the finding was incorrectly cited then neither the liability nor the finding will be on the Final Report)

31. 31 2008 State Program Review Summary Continued –Will be issued a Final Report to the President, with copies to the Institutional Officers –Will use the Remittance Device provided with the Final Letter and Report to remit required liabilities to GSFC –Will have a 30 day appeal period, during which an institution should respond to the Final Report and remit liabilities

32. 32 Compliance Mission and Value Statement You can expect the Compliance Team to be: You can expect the Compliance Team to be: –Fair & Unbiased –Accountable –Clear, Consistent, & Concise –Honest & Forthcoming Survey Survey

33. 33 Questions?

34. 34 Compliance Team Contact Information Email:Compliance@gsfc.org Email:Compliance@gsfc.orgCompliance@gsfc.org Phone: 770-724-9041 Phone: 770-724-9041 Address:Compliance Team Address:Compliance Team 2082 East Exchange Place Tucker, GA 30084