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of Creating and Maintaining a Compliant Policy and Procedure Manual

Presented by: Chyrl R. Ayers, COOGlobal Financial Aid Services, Inc.SASFAA 2013 50th Anniversary ConferenceFebruary 11, 2013, 3:45 5 pmDunwoody AsWELCOME

Learning Objectives

WHYmust a P&P manual be maintained?WHATis required?WHOis responsible to create and maintain?needs access?WHEREto store and methodologies utilized?WHENshould it be reviewed and updated?Why required?Why does a manual make sense?WHY?

Separate manual; orCross-reference to manual(s) already in existence.

Note: You may want to consider using icons to represent different areas for quick reference in your P&P manual.Considering Different ConfigurationsGood PracticeDifferent Types of IconsTipPolicyImportantExceptionDefinition (some prefer a Glossary in this area)ChecklistExampleNEW

What content to include?WHAT?

Federal PellFDSLCampus-based FundingFSEOGFWSFederal PerkinsTeach GrantPackaging Philosophies and ProceduresDo you package loans only up to the direct cost and allow the student to request additional loan funds for living expenses?Do you package for the full annual limits and then reduce if requested by the student?Packaging Philosophies and Procedures ConsiderationsIf packaging for less than a full annual amount, how are students made aware of the maximum amount they can borrow?How do you monitor funds received from other sources (i.e. scholarships, foundation funds, employer payments, state grants, etc.) to ensure student is not overawarded?Packaging Philosophies and Procedures ConsiderationsIf a students Title IV aid package must be reduced due to receipt of a scholarship, how is the student notified?What is your process for packaging:Transfer students in an open loan period?Re-entry students?Students who change programs?Packaging Philosophies and Procedures ConsiderationsP&P Regulatory Citation Related to Federal Pell690.63 Calculation of Federal Pell Grant Awards690.80 Requirements and optional recalculation690.81 Fiscal Records and Disbursement requirementsH.R. 4137 Iraq and Afghanistan Service Grant ProgramRequirements for determination of Federal Pell Grant;What situations require recalculation?Do you recalculate under optional situations?How and when you disburse and report?Procedures for handling and disbursing the Iraq & Afghanistan Service Grant

Basic Federal Pell Considerations685.102(b) Packaging Policies for FDSL685.304 Counseling Borrowers685.306 Payment of refunds or RT4685.309 Administrative and Fiscal ControlP&P Regulatory Citation Related to FDSLOutline the procedures to determine the appropriate award amounts.Do you always award the maximum?Do you consult with the student first in determining the award amounts?Do you package direct and indirect or only direct?How does the student request indirect/living expenses?Basic DL ConsiderationsAwarding ProcessOutline the procedures to determine parents eligibility under the PLUS programHow do you determine the amount?How do you notify they parent of eligibility and/or awarded amount?What is the process if a parent requests online through COD?How do you collection information to document the parents requested amount?How do you provide information to the parent related to PLUS?Basic DL ConsiderationsPLUS (Parent Borrower)Outline the confirmation process for loansActive or passive?Must document how you handle each academic year in which loans are made to studentsBasic DL ConsiderationsConfirmation ProcessLoan Counseling outline your procedures for loan counseling and include entrance and exit processes.Disbursement Notification Letters include your procedures on how and when notifications are made to borrowers when a direct loan occurs.Basic DL Considerations676.10 Selection and Awarding676.19 FSEOG Fiscal Procedures and RecordsP&P Campus-based Funds - FSEOGShould include your procedures for awarding of FSEOGReviewed and maintained for each award year;How students are informed of eligibility and selection criteria for determining award amount.If information is contained in catalog or consumer information, you should still have a written policy on FSEOGBasic FSEOG ConsiderationsAwarding PolicyShould include details on how you meet the institutional matching requirements.

Note: This process should be the same each award year; therefore, one policy may cover several award years. The award years covered by the policy should be noted in the policy.Basic FSEOG ConsiderationInstitutional Match675.10 Selection and Awarding675.20; 675.21; 675.2(b); 675.18(g) Assigning FWS Jobs675.19 Fiscal Procedures and Records675.36 Job Location and Development-Procedures and Records375.49 Work College Program-Procedures and RecordsP&P Campus-based Funds - FWSApplication material;How students are notified of available positions;How hourly wage is determined;How the interviewing and hiring process works; andPolicy on limiting the number of hours worked.Basic Consideration FWSSelection ProcessSelection process for off-campus employers;Written off-campus FWS Agreements:Who is considered the employer for purposes of hiring, terminations and pay rate?Who is responsible for required cost such as nonfederal share social security and workmans compensation?Who is responsible for payroll?Basic Consideration FWSOff-campus EmployersOutline the payroll procedures used for FWS studentsTimesheet process;Frequency of payment;Method used for paying student;Procedures for documenting payroll made by off-campus employers; andHow the required institutional match is made (school or off-campus employer)

Basic Consideration FWSPayroll and Non-federal ShareInclude how community service requirements are met (7% of your allocation with at least one position as a reading tutor or performing family literacy).Basic Consideration FWSCommunity Service674.10 Selection and Awarding674.31 Perkins MPN674.16 Perkins Loan Disclosure674.19 Fiscal Procedures and Records674.33(d) ForbearanceP&P Campus-based Funds Federal Perkins674.38 Deferment674.42 Contact Borrower674.43 Billing674.45 Collection674.46 Litigation674.52 CancellationEligibility requirements;Selection procedures; andCriteria for determining the award amount.Basic Consideration Federal PerkinsAwarding PolicyLoan Counseling - Should include both entrance and exit counseling processes

Cumulative Balance Owed Procedures used to notify student of the cumulative balance owed and the expected payment amount. Must be provided each award year prior to 1st disbursement of a Federal Perkins loan.Basic Consideration Federal PerkinsMaintenance of MPN (fireproof container or cabinet);Procedures for returning MPN to the borrower after loan is satisfied;Storing of loan records deferments, cancellations, forbearances, repayment schedules and other correspondence with borrower; andIf you use e-sign you must document your e-sign procedures.Basic Consideration Federal PerkinsRecordkeepingDisbursement Notification Letters include your procedures on how and when notifications are made to borrowers when a loan occurs.

Red Flag Rules procedures should include how you comply with the FTCs Red Flag RuleBasic Consideration Federal PerkinsOutline confirmation process for loansActive or passive?Must document how you handle each academic year in which loans are made to students.Basic Consideration Federal PerkinsConfirmationThis section should include the processes used in servicing the Federal Perkins loans:Borrower contacts;Billing procedures;Default and collection procedures;Cost assessed to borrowers; andPerkins assignment.Basic Consideration Federal PerkinsServicing ProceduresNote: If you use a server for your Perkins, the servicers efforts in these areas would be included in the P&P manual. You need to outline who is responsible for what and anything shared.Basic Consideration Federal PerkinsServicing Procedures686.10; 686.11 Eligibility Determination686.32 Counseling686.36 Fiscal Control and Funds AccountingP&P Campus-based Funds TEACH GrantExit counseling for student who does not complete counseling on NSLDS website;Any additional counseling you may perform for TEACH Grant recipients; andHow you verify enrollment in an eligible program and verity students GPA to ensure eligibility for TEACH disbursement.Basic Considerations TEACH Grant691.15; 691.16; 691.17 ACG and National SMART Eligibility Requirements668.3; 691.62; 691.2(d); 691.6 Calculating ACG & National SMART691.81 Fiscal Control and Fund AccountingP&P Campus-based Funds ACG/SMART (Not currently funded)Written policy that indicates the following:Time period for student to provide documentation;Consequences of failure to submit;Method used to notify changes of EFC & change to TIV awards;Procedures to follow when it is necessary to correct FAFSA data; and Procedures followed if referral of student to OIG.Verification 668.53This policy must be made available to all students selected for the process of verification.Verification 668.53Requests for PJsHow students are made aware of the availability to be considered for this process;Process by which student applies for PJ; andStandard forms or other documentation required.Professional Judgment (PJ) 479A and 668.5(c) PJs decision How students are notified of the decision and this should include the results of awards being revised based on approval.Professional Judgment (PJ) 479A and 668.5(c) Methods of Monitoring SAPAutomated or manual process?Who monitors SAP?How often is SAP reviewed?How is FA notified of the failure of SAP?Satisfactory Academic Progress (SAP)668.16(e) and 668.34Procedures for FA Warning and ProbationHow are students notified?What are the appeal proceduresWho prepares academic plan and monitors them to ensure student is meeting the requirements of the plan?How are students notified of the SAP policy?Satisfactory Academic Progress (SAP)668.16(e) and 668.34Procedures for posting of disbursements to students accounts timely and accurately including procedures to ensure funds are posted in 3 days.

Procedures for handling credit balances:Monitoring of students with credit balance authorization forms;

Student Accounts668.164For students with credit balance authorization forms; how do you monitor and ensure credit balances are handled within the 14-day requirement of end of loan period (or award year if loans are not awarded), or within 14-day requirement of graduation;Student AccountsFor students that do not authorize the holding of credit balance, how do you monitor the issuance within the 14-day requirement?How does the student rescind authorization to hold credit balance?Who monitors and handles late disbursements that post that might cause a credit balance which may need to be issued within the 14-days?Student AccountsRosters process for completing and returning rosters including the schedule followed.NSLDS ReportingProcess for reporting changes in enrollment status;Who is responsible?How the responsible party receives notification of change.Enrollment Status ChangesProcess for adding a student to monitoring;Who is responsible?How the responsible party receives notification of change.Transfer Student MonitoringSchools refund policy including Return to Title IV (R2T4)Note: School refund policy may change so it is important to note in the P&P the various policies and effective dates.Process of coordination between departments (academics, business office and financial aid).Procedures for return of unearned aid or refunds resulting from school refund policy or R2T4.Withdrawals/TIV Refunds668.22Notification process of resultsRefund calculations;Return to TIV programs;Post Withdrawal Disbursements (PWD)-Process to notify students of eligibility for PWD;Process for tracking PWDs awaiting authorization student or parent;Process for disbursement of PWD; andProcess to notify and deliver credit balance resulting from PWD.Withdrawals/TIV Refunds668.22Updating NSLDS and loan servicer due to enrollment status change.Process for handling Exit Counseling (covered in DL section of P&P)Default Management PlanWithdrawals/TIV Refunds668.22Distribution of Consumer Information 601.11; 601.30; 668.14; 668.41 668.49; 668.164(i)Procedures for meeting requirements for Constitutional DayProcedures for distributing voter registration (if your state has not enacted the vehicle/voter registration provision)Validity of HS Diploma (if issue is raised)MiscellaneousLeave of Absence ProceduresJob Descriptions of Financial Aid Employees & Adequate Staffing 668.16(b)Procedures for G-845 668.135Resolving Conflicting Information 668.16 (f)Resolving Comment Codes (C-Flags)MiscellaneousCost of Attendance for each award year and back up documentation on how the figures are determinedAcademic Year Definition (if more than one used, the section should document this by program)Title IV Formula (if more than one used, the section should document this by program)Programs subject to clock to credit conversionMiscellaneousWho should create manual?Who should update?Who needs access to manual?WHO?

Where to maintain the completed manual?WHERE?

When should it be updated?WHEN?

NASFAAIFAPListServsPeersResourcesLesson Learned

SAPVerificationRefunds & R2T4Selection Criteria for CBFAdmission CriteriaConsumer InformationMost Frequently Requested Polices and Procedures for a Program ReviewContact Information:

Chyrl R. AyersChief Operating OfficerGlobal Financial Aid Servicescayers@globalfas.com228-523-1030

Q & A