
Do you think that small schools - less than 250 students - should be subject to the same burden of regulatory requirements as larger schools? Schools with larger / multiple campuses typically have corporate compliance staff therby creating a competitive advantage against a smaller school which does not have the resouces for such a staff.
Juliet,
I am not familiar with COMPTA but there are some software solutions geared toward smaller institutions. I may be able to refer you to someone who has familiarity with a variety of solutions that may be of interest to your school. Feel free to send me an email at traci@tracilee.net if I can be of help.
Traci Lee
I think that all schools should be subject to the same regulatory requirements as larger schools. There should be latitude in the way that a smaller school complies with the regulation. We are a small school and one of the things that is difficult to contend with is that there are some really good, yet really expensive administrative software programs that will take care of a lot of the regulatory requirements and do cross checks to make sure that there are no inconcistencies. Our system is made up of internally created forms and excel documents. We must be more vigilant as this type of system doesn't allow for an internal cross check of entries. Does COMTA foresee creating an administrative software for their accredited schools?
Darlene,
You bring up a good point that, although you may outsource these services, internal audit and review is still critical to ensure compliance. I'm glad to hear how helpful they are to you and that you recognize the importance of compliant operations.
Traci Lee
We have used a servicer FAME for years and they have helped us tremendously. We are a small school of approx. 220 students. Even though we have the outside servicer we still have to do internal audits to be sure we are in compliance with Title IV refunds and Pell Grant disbursements. FAME disburses Pell grant money according to what our financial aid officer instructs them to award. FAME has been very informative during their conferences in regards to regulations, and new regulations coming down the pipe. They are very informative about standards of progress and how they should be monitored and what is in compliance and what is not in regards to SAP. They are great for reports during financial audits done by third parties. They keep records of what and to whom disbursements were made and returned to Title IV.
I agree with your comments. Our system also has several branches but instructors and directors from each specialty area (example massage) come together at least 4 times a year to make sure that our rules and regulations, as well as the quality of our program are all compliant.
Compliance standards need to be uniform regardless of school size. I have been at tiny schools where compliance would be easy because there was no outside financial aid to track/refund and we had good teamwork to review catalog/policies/curriculum/website/advertising for consistency. We kept it simple. I am now at a college program with a staff that is out of my authority who will be part of the self-study but they have been through this multiple times for the accrediting agencies of other programs, so the only thing I hear is "Why don't the accrediting agencies use the same forms and timelines?" That is a good question. My only worry here is that if they are undergoing a review by another agency, they may back-burner my requests and I will not submit in a timely way. Just my fear, really unfounded here.
Regulation requirements should be standard regardless of an institutions size. It removes any ambiguity about what may or may not apply to a particuliar institution. Therefore, less confusion ensures for a more successful audit.
Gloria,
I agree that there are benefits of a small school but, it is hard to stay on top of everything for multiple departments and regulations.
Traci Lee
As a school owner / administrator I believe that all schools should be held to the same set of standards. I think that it is easier for a small school such as mine because I personally know and understand each student as well as staff. If there is a problem then I know about it immediately. This helps to keep control of the suitation. It is difficult at times to "wear this many hats" but I believe very neccesary.
I believe that all schools, no matter the size, should be held to the same regulatory requirements. Isn't the main objective of compliance for the benefit of the consumer? When a student attends an accredited school, whether large or small, they should feel secure that there are processes in place to ensure that the school is being held accountable to follow proper protocol.
I think that smaller schools should be held at the same regulatory requirement as larger schools because it creates uniformity across the board instead of having one set of rules for us and another set for them. Different compliance procedures may also create that 'grey area' where some institutions starts to interpret the rules as it relates to them plus because there is always the potential for growth overtime, it seems like the best decision would be to implement one standard rule for every school.
For me, having worked in both small and large schools, I think it is easier for smaller schools to manage the compliance process. Fewer students and a smaller staff allows for everyone involved to know each student and each student's circumstances more intimately. Therefore, the margin of error is naturally going to be lower. So, with that said, smaller schools being subject to the same burden of regulatory requirements shouldn't be difficult at all. The larger schools with multiple campuses need corporate compliance because of sheer numbers and volume! I definitely don't see that as a competitive edge, but a functional necessity. If anything, a smaller school with a knowledgeable well trained staff has the edge in my opinion.
Thanks, Marjorie. I like hearing positive stories where things are working well and that compliance efforts are embraced by the directors.
I work with a school that has many branches of different sizes and each branch has always tried to remain compliant as a branch. I have recently been appointed to direct the compliance issue at all locations, and I was so happy to see how well this concept was embraced by the directors at each branch. I have visited with each location, and there are two things that I agree with: everything should be well documented ("if it's not documented, it didn't happen") and internal audits shoudl be done quarterly.
I agree that even smaller schools with less than 250 students should be subject to the sames rules and regulations. The procedures and policies should be written and well documented to allow uniformity and also ease of transition of new employees.
Internal audits should be done each quarter to ensure compliance for each department. Assistance can be provided by external certified public accountants if needed.
Joyce - thanks for your insight as a school owner. I would be curious to see/hear from others on their experiences with FA servicers. I agree that the school is ultimately responsible but, I see many schools use servicers and many tell me they do it to "sleep better at night" knowing the servicer is watching the compliance side. However, the servicer is relying on data provided by the school. Does anyone out there have any feedback on this topic regarding the pros and/or cons of using an FA servicer?
I have owned a small school for 12 years and I think we should have the same regulations as any other school. The regulations are for the protection of both the consumer and the school. It is a challenge to meet those regulations, but as a small school owner the only option is to do much of the work yourself with the help of a great staff. Outsourcing is expensive for many small schools. I tried hiring a financial aid servicer when we first started in the Title IV program. The owner is held responsible regardless of who is in charge, so it is better to have complete control over the financial operations of the school so that refunds and returns are done timely, and funds from financial aid arrive timely for the students and for the efficient operation of the school.
Even within regulatory entities, reviewers/auditors may interpret requirements differently. I agree that while there are different ways to comply, it is imperative that the schools be prepared to justify/defend their interpretation. Even so, there is risk of being cited but, if a policy has been implemented consistently with a "defendable" interpretation, the risk is typically reduced.