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Title IV Compliance

Title IV Compliance. Strategies for Success. Nov. 27, 2018. Agenda. Why Title IV Compliance Matters The Successful Compliance Program Program Reviews How Prepared Are You?. Why Compliance Matters. Discussion. Why does compliance matter to you?. Benefits of Compliance.

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Title IV Compliance

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  1. Title IV Compliance Strategies for Success Nov. 27, 2018

  2. Agenda • Why Title IV Compliance Matters • The Successful Compliance Program • Program Reviews • How Prepared Are You?

  3. Why Compliance Matters

  4. Discussion Why does compliance matter to you?

  5. Benefits of Compliance • Your institution retains its eligibility to participate in the Title IV programs. • You avoid actions requiring monetary resolutions that could impact the financial health of the institution, such as repayment of liabilities and fines. • You maintain access to funds without additional requirements imposed that result in a delay in your receipt.

  6. Benefits of Compliance (continued) • You avoid additional financial requirements in order to continue to participate, such as Letters of Credits. • You avoid restrictions placed on your institution’s participation, such as the ability to add new programs and locations that are Title IV eligible. • You avoid the administrative burden associated with having to conduct files reviews and respond to deficient audits and program reviews.

  7. Case Study: Goodall College • Goodall College is a small, rural private college with an enrollment of 700 students. • The school has seen a decline in enrollment for the past five years. • At its optimal enrollment the school had 1,200 students.

  8. Case Study: Goodall College (continued) What potential Title IV compliance issues can you identify?

  9. Case Study: Goodall College (continued)

  10. Case Study: Goodall College (continued)

  11. Top Ten Audit Findings

  12. Top Ten Program Review Findings

  13. Title IV Compliance Data Dashboard

  14. Title IV Compliance Data Dashboard (continued)

  15. The Successful Compliance Program

  16. Describe a Successful Title IV Compliance Program Activity • What are some components of the compliance program at your institution? • What components work well? • What are some areas that you want to change? • How would you describe a successful compliance program? • Discuss these questions at your table. • When you are done, write your answers on the nearest flip chart. • Appoint a spokesperson to speak for your table.

  17. Successful Compliance Programs Require Attention to Details • Audit Requirements • Financial Standards • Limitations • Cohort Default Rates • Reporting and Disclosure Requirements

  18. Attention to Details: Audit Requirements

  19. Attention to Details: Financial Standards

  20. Attention to Details: Limitations

  21. Attention to Details: Cohort Default Rate

  22. The Benefits of a Low 3-Year Cohort Default Rate

  23. Tipping Points • Where are you starting from • CDR > 15% – Lose benefits • CDR > 18% – Urgent • CDR > 30% – Critical

  24. Sanctions

  25. Attention to Details: Reporting and Disclosures

  26. Case Study: Allgood College • Allgood College is a small, rural private college with an enrollment of 1,000 and enrollment is increasing and expected to exceed 1,200 students. • The President plans to retire in three years and has begun to prepare the senior VP/Provost to replace her/him. • The Financial Aid Director has been employed by the school for 10 years and regularly attends the Federal, State, and Regional financial aid conferences. • The Director has trained the Associate Director in all aspects of maintaining the office during her/his absence. • The staff is able to attend state and regional conferences.

  27. Case Study: Allgood College (continued) What Would You Recommend?

  28. Case Study: Allgood College (continued)

  29. Case Study: Allgood College (continued)

  30. Maintaining a Rigorous Compliance Environment • Be knowledgeable about compliance processes • Adhere to strict submission timelines • Keep audit discussion on meeting agenda • Monitor issues through resolution • Audit committee deeply involved in business, finance, and governance

  31. Program Reviews

  32. Program Review Purpose • Evaluate compliance with the Title IV, HEA statute, and regulations • Identify liabilities owed to the Department for errors in compliance • Improve future institutional capabilities

  33. Types of Program Reviews • General Assessment • Focused Assessment • Joint Program Review

  34. What Happens During a Program Review • Review of the institution’s data and records • Interviews with institution staff and/or students • Determine whether institution is in compliance with Title IV of the Higher Education Act (HEA) rules • Determine source of any identified errors for correction • Program Review Report and Expedited Determination Letter (EDL) • Written response from institution

  35. Preparing for the Review • Gather required information • Both electronic and hard copies are acceptable • Prepare requested reports • Protect sensitive and personally identifiable information • Send reports to the reviewers by the due date as directed • Do not submit hard copy originals

  36. What Happens During a Program Review • Review of the institution’s data and records • Interviews with institution staff and/or students • Determine whether institution is in compliance with Title IV of the Higher Education Act (HEA) rules • Determine source of any identified errors for correction • Program Review Report and Expedited Determination Letter (EDL) • Written response from institution

  37. How Prepared Are You?

  38. Case Study: Yourtown College • Yourtown College is a mid-sized private college. • The enrollment is 4,000 and increasing. • The school has added a new program that has garnered national attention. • The college anticipates a boost in enrollment of 250 students by the end of the school year. • The President has been with the college for five (5) years and is developing a strategic plan for the next ten years. • Although, the President has no desire to leave the college, part of the strategic plan addresses the succession of key administrators.

  39. Case Study: Yourtown College (continued) • How well does your institution compare to Yourtown College? • Give yourself 1 point for every point that is true for your institution. • 16 points max

  40. Case Study: Yourtown College (continued)

  41. Case Study: Yourtown College (continued)

  42. Case Study: Yourtown College (continued)

  43. Why Does Compliance Matter to You? • What do you know now that you did not know before you came? • Is there anything you heard that you might consider implementing at your institution?

  44. Question?

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