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Discuss the steps a school can take to prevent triggering a program review.
Shawn,
That is a great approach to looking for potential issues. It does not have to require hours of review but you have to review some to ensure compliance with requirements. Great approach!
Sincerely,
Chyrl Ayers
In my office we conduct 15 minutes weekly audits in order to prevent triggering program reviews.
Nichole, You will never be able to prevent a program review as there are so many different reasons why the Department of Education might want to schedule one with your school. However, it is in your power to make sure the program reviewer leaves your school with a confident feeling that you are following all of the rules and regulations that govern Title IV.
Regards,
David McGuffee
We conduct a bi-annual mock program review now to take measures to prevent an actual program review. It tends to make sure that you are actually following your catolog and policies that are set by the institution. We also make sure to stay current on any regulations that have changed to make sure we stay in compliance.
Wendy,
You are correct that this would prevent any issues during a program review; however, it would not necessarily prevent you from having one. There are times that an institution is chosen due to a lengthy period without one. If you have your P&P in place for all departments and are in compliance you should be prepared. Preparation and organization is the key to good experience.
Sincerely,
Chyrl Ayers
I think that as long as you are in compliance with your policies and procedures as well as the federal regualations, that will prevent you from a program review. Checks and balances are always needed and required to help out with the things that you are doing.
Rita,
Knowledge is definitely a key to ensuring that the Program Review is successful. There are triggers for program reviews and it critical that you monitor these items. Also, program reviews will occur due to the lack of one for a lengthy period of time. The best measure is to ensure that your student files are complete and accurate.
Sincerely, Chyrl
I believe adequate training for employees is the most important factor in avoiding a program review. The staff must be knowledgeable and confident in order to provide students sufficient information so that they may make good decisions about their educational and financial futures. Management must make employees aware of the importance of correctly processing students applications for admissions and financial aid and of the consequences of repeat findings, a high default rate and other situations that may trigger a program review. Continuous training and good lines of communication will help reduce the chances.
Michelle,
Consistency and accuracy in the processing and packaging of the students' files are very important. All departments should have Policies and Procedures in place to ensure consistent and accurate processing for all students. If your approach is followed throughout the organization you should never have an issue.
Sincerely, Chyrl
As in dealing with any governmental body, consistency and accuracy will help to avoid being "red-flagged". Strong policy and procedure implimentation from the onset is critical.
Ruth,
I really appreciate your thorough and thoughtful response to this Forum. It is extremely important that one continues to develop their P&P Manual. I recommend that you evaluate it at least once a year and be mindful of some changes that cannot wait. Also, I encourage the P&P development process to be handle by a team that reviews at least once a year.
Sincerely, Chyrl
I really like the language you chose in describing the Policy & Procedure manual. "a living, breathing organism". I have found they are an ongoing process.
Our procedures manual was written several years ago and has not since been updated. My idea on the subject, is for the person actually doing the work to periodically update their procedures to reflect current practices. Over time, even if the external requirements do not change, there are always changes in the way things are actually done. The person responsible for that area is usually the best one to make updates, but they should be reviewed for clarity (understanding) and for preventable problems that may arise from individual changes (checks and balances that might be overlooked or regulatory or legal issues of which the current person in that position might not be aware).
I think it best to review the written document at least annually and document that the review took place. Procedural changes take place anytime there is a change in personnel or regulatory requirements. A suggestion might be for everyone to keep a list of little changes made in their daily operations. Then when the review process comes up, they can have constructive input into changes in the manual. A check/balance for this would include everyone with similar duties "comparing notes" as well as supervisory positions reviewing the information from a different perspective.
I like the idea of a number of participants in the Policies and Procedures review process so that the result includes all of the current policy requirements as well as all of the actual procedures currently in use.
Carmen,
All of your thoughts on this area were interesting. Great approaches to insure your are prepared and not surprised by an audit or program review.
Keep up the good work. Best wishes, Chyrl
I agree that a Policy and Procedure manual is an excellent tool. Just be sure that your actual practice reflects these policies and procedures - that is one sure-fire way to an audit finding: you're not doing what your manual says you should be doing. Definitely a preventable "ouchie."
Treat the manual as a living, breathing organism that requires periodic attention. Change it when needed. If your procedures change, make sure your manual is changed commensurate with that new procedure.
Keep in mind that a new pair of eyes can be a huge help with doing a reality check on your P&P manual. If it makes sense to a lay person, then it is probably on target.
Jeannette,
These are good thoughts; however, do you have any specific approaches or techniques that you use to accomplish this. Do you or your team perform mini-program reviews of your files or maybe have different staff members review different people work. I am sure that you have some ideas that you could share with all of us on the postings.
Best wishes in your continued success with online education.
Sincerely, Chyrl
Keeping the SAF programs and funding in compliance, stay on top of any problems in the area of school administration.
Dear Chyrl,
Personally, I think that preparing everyone involved in the process where a program review could be triggered is of critical importance to avoid triggering a review. If everyone involved know what could trigger a review, they will avoid doing such tasks.
After everyone is fully knowledgeable about what not to do, creating a simulation process to internally execute a program review will be the next step. Using an internal or external auditor to run the review and prepare a report pointing the flaws or weak areas where the school should improve to avoid penalties by mistakes that could be purposely or not and take the necessary measures to eradicate such flaws.
Sincerely,
Angela
I think we have to start preventing triggering a program review with our Policy and Procedures Manual. This is the daily tool the Financial Aid Officer will use to do his work. Initial and continuos training is very important too to keep the staff up to date with changes in regulations, improve customer service, etc. Another tool is to do internal audits to detect mistakes and make any necessary changes in the process before the external auditors come.
Brenda,
Your overview of how to guarantee compliance is excellent. It is critical to the FA process for all to be propeely trained and cross-trained to ensure successful processing.
Thanks, Chyrl