Ten simple steps the business manager can take to evaluate the financial aid office.

1. E-Book
THE BUSINESS MANAGER’S
TEN-STEP GUIDE TO
TITLE IV ADMINISTRATION
TEN SIMPLE STEPS THE BUSINESS
MANAGER CAN TAKE TO EVALUATE THE
FINANCIAL AID OFFICE
- WEBER & ASSOCIATES, INC. -
A publication of Weber & Associates, Inc.
© Weber & Associates

2. TABLE OF
CONTENTS
f
t
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Step
1
Review
Federal
Funds
Bank
Statements
Step
2
Review
Title
IV
Accoun=ng
Records
Step
3
Review
student
account
records
Step
4
Compliance
with
Return
of
Title
IV
Funds
Requirements
(R2T4)
Step
5
Policies
and
Procedures
Step
6
Entrance
and
Exit
Interviews
Step
7
Default
Management
Step
8
Records
Balance
with
ED
Step
9
Verifica=on
and
Comment
Codes
Step
10
Dependency
Overrides
and
Professional
Judgments

3. STEP
1
Review Federal Funds Bank Statements

4. • Are
the
words
“FEDERAL
FUNDS”
in
the
official
name
of
the
bank
account
in
which
federal
funds
are
deposited?
• Do
the
federal
funds
leave
the
account
within
3
days
of
electronic
deposit?
• If
there
is
a
credit
balance
at
the
end
of
the
month,
look
at
the
next
month’s
statement
to
determine
if
the
funds
le`
the
account
within
3
days.
• If
a
check
was
sent
to
the
U.S.
Department
of
Educa=on
to
return
Title
IV
Funds,
was
the
check
deposited
in
a
=mely
manner?
Incidentally,
comple=ng
returns
by
check
are
not
recommended.
• Was
there
any
record
or
report
to
indicate
that
the
end-­‐of-­‐month
bank
statement
had
been
reconciled?
Review Federal Funds Bank Statements
f
t
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5. STEP
2
Review Title IV Accounting Records

6. • Are
the
General
Ledger
entries
for
all
Title
IV
programs
up-­‐to-­‐date?
• Do
the
cash
balances
for
the
prior
month
match
the
balance
on
the
current
month’s
bank
statement?
• Do
the
fund
disbursement
totals
at
COD
agree
with
the
ins=tu=on’s
fund
disbursement
records?
Review Title IV Accounting Records
f
t
in

7. STEP
3
Review account records of charges and
payments for five students

8. Review Student Account Records
f
t
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9. • Each
student’s
account
record
must
provide
a
clear
audit
trail
of
charges
and
payments.
• Does
the
student’s
account
show
a
credit
balance?
– A
school
is
permieed
to
hold
credit
balances
if
it
obtains
a
voluntary
authoriza=on
from
the
student
(or
parent,
in
the
case
of
PLUS)
– Funds
received
that
cause
a
credit
balance
must
be
applied
to
charges
or
returned
to
the
student.
• If
you
discover
any
errors
in
the
areas
listed
above,
you
should
review
more
files.
If
the
trend
con=nues,
you
may
have
problems.
Review Student Account Records
f
t
in

10. STEP
4
Compliance with Return of Title IV Funds
Requirements (R2T4)

11. • R2T4
is
the
Return
of
Title
IV
Funds
Policy
-­‐
The
R2T4
policy
must
be
applied
when
a
student
has
dropped
from
aeendance.
• Do
you
know
how
to
perform
the
calcula=on?
If
you
do
not,
your
financial
aid
staff
should
be
able
to
explain
it.
• The
files
and
account
ledgers
of
several
students
who
recently
withdrew
need
to
be
reviewed.
• More
informa=on
on
R2T4
is
available
in
Volume
5
of
the
Federal
Student
Aid
(FSA)
Handbook.
Compliance with Return of Title IV
Funds Requirements (R2T4)
f
t
in

12. • It
is
important…
– To
review
and
determine
that
the
calcula=ons
have
been
performed
properly
and
in
a
=mely
manner.
– To
ensure
that
the
repayment
has
been
made
in
a
=mely
manner
and
to
the
appropriate
aid
source
by
the
appropriate
party.
– There
is
a
record
of
the
calcula=on
in
the
student’s
financial
aid
file.
Compliance with Return of Title IV
Funds Requirements (R2T4)
f
t
in

13. STEP
5
Policies and Procedures

14. • Does
your
ins=tu=on
have
wrieen
policies
and
procedures
regarding
its
financial
aid
processes?
• Are
they
up-­‐to-­‐date?
• How
frequently
are
they
reviewed
and
updated?
• Who
in
your
organiza=on
owns
and/or
manages
the
policies
and
procedures
documents?
Policies and Procedures
f
t
in

15. Policies and Procedures
• Do
you
have
adequate
staff
to
administer
the
procedures?
• Are
the
procedures
followed
or
just
wrieen,
then
forgoeen?
• Does
your
financial
aid
staff
understand
the
procedures?

16. • How
does
your
financial
aid
staff
learn
when
a
student
has
withdrawn
from
school?
Timely
response
is
essen=al.
• How
are
the
standards
of
academic
progress
(SAP)
applied?
• Who
is
responsible
for
monitoring
the
standards
of
academic
progress
(SAP)
policy?
• When
and
how
is
the
financial
aid
office
no=fied
with
respect
to
changes
in
a
students
academic
progress?
Some Audit & Program Review Questions
that Your Procedures Should Address
f
t
in

17. • How
is
federal
money
received
and
who
applies
it
to
the
student’s
account?
The
person
performing
this
task
may
NOT
be
the
financial
aid
officer.
• How
are
students
no=fied
when
their
federal
money
is
received?
• If
Federal
Work
Study
earnings
are
applied
to
the
student’s
account,
how
do
students
provide
wrieen
permission
for
your
ins=tu=on
to
do
so?
Some Audit & Program Review Questions
that Your Procedures Should Address
f
t
in

18. Some Audit & Program Review Questions
that Your Procedures Should Address
• How
does
your
ins=tu=on
gather
and
record
ac=vi=es
involved
with
the
Campus
Crime
Act?
Who
is
responsible
for
collec=ng
the
data
and
filing
this
report?
• Who
is
responsible
for
the
IPEDS
reports?
How
is
the
data
gathered?
• Who
gathers
informa=on
for
the
FISAP?

19. STEP
6
Entrance and Exit Interviews

20. • Review
five
current
financial
aid
student’s
files.
– If
they
received
a
student
loan,
is
there
an
Entrance
Interview
in
the
file?
• Review
the
files
of
five
withdrawn
or
graduated
students.
– If
they
received
a
student
loan,
there
should
either
be:
• An
Exit
Interviews
on
file
OR
• An
Exit
Interview
completed
on
the
www.studentloans.gov
website.
• Ask
your
financial
aid
officer
how
she
reviews
Electronic
Cohort
Delinquency
Reports
(ECDR).
Default Management
f
t
in

21. • What
are
your
ins=tu=on’s
procedures
for
obtaining
Entrance
and
Exit
Interviews?
• Are
the
procedures
wrieen?
• Are
the
procedures
followed?
• If
you
have
found
missing
Entrance
and
Exit
Interviews,
it
would
be
best
to
have
someone
review
ALL
financial
aid
student’s
files
and
collect
any
missing
documents.
Entrance & Exit Interviews
f
t
in

22. STEP
7
Default Management

23. • Review
your
ins=tu=on’s
default
management
plan.
Is
it
wrieen
in
a
procedure?
• Are
the
procedures
followed?
• Is
default
management
an
ongoing
ac=vity
or
something
that
is
done
once
a
year
when
the
annual
default
reports
are
issued?
• Is
someone
on
your
staff
assigned
responsibility
for
default
management?
Default Management
f
t
in

24. STEP
8
Records Balance With ED

25. • Ask
your
financial
aid
officer
to
show
you
the
most
recent
reconcilia=on
showing
that
the
ins=tu=on’s
disbursement
records
agree
and
balance
with
COD.
– The
net
amount
disbursed
for
Pell
should
agree
with
the
net
amount
shown
at
COD.
Records Balance With ED
f
t
in

26. • At
year’s
end,
the
net
amount
of
Pell
Grants
disbursed
less
refunds
shown
at
COD
and
your
ins=tu=on
should
be
equal.
• This
is
also
necessary
if
your
ins=tu=on
par=cipates
in
Federal
Direct
Loans.
The
net
amount
of
subsidized,
unsubsidized
and
PLUS
loans
in
the
school’s
records
should
equal
the
amount
on
record
at
ED
Direct
Loan
office.
Records in Balance
f
t
in

27. STEP
9
Verification and Comment Codes

28. • Does
your
financial
aid
staff
fully
understand
the
importance
of
verifica=on
and
comment
codes?
• Does
your
financial
aid
staff
fully
understand
the
importance
of
resolving
conflic=ng
informa=on?
• Check
a
few
files
and
look
for
the
ISIR.
The
Expected
Family
Contribu=on
(EFC)
value
can
be
found
at
top-­‐right
of
the
first
page
of
the
ISIR.
Does
it
have
an
asterisk
next
to
it?
Is
there
a
“C”
next
to
the
EFC?
Verification and Comment Codes
f
t
in

29. • If
there
is
an
asterisk,
have
the
appropriate
forms
been
collected,
reviewed
and
stored
in
the
student’s
financial
aid
file?
• Have
the
financial
aid
officer
explain
how
she
reviews,
addresses
and
resolves
verifica=on
and
comment
codes.
Verification and Comment Codes
f
t
in

30. STEP
10
Dependency Overrides
and
Professional Judgments

31. • Ask
your
financial
aid
officer
to
explain
her
policies
for
making
a
dependent
student
independent
(performing
a
dependency
override).
• Ask
your
financial
aid
officer
to
explain
how
and
when
she
uses
professional
judgment.
• Ask
to
see
samples
of
how
these
professional
judgments
are
documented.
• A
large
number
of
professional
judgments
could
lead
to
a
Program
Review
by
the
U.S.
Dept.
of
Educa=on.
Dependency Overrides and
Professional Judgments
f
t
in

32. • It
is
very
important
to
the
long-­‐term
health
and
strength
of
your
ins=tu=on
that
you
complete
these
ten
steps.
• It
is
far
beeer
that
you
be
the
first
to
ask
these
ques=ons
than
to
have
them
asked
of
you
first
by
an
auditor,
federal
program
review
officer
or
the
U.S.
Department
of
Educa=on
Inspector
General’s
Office.
You Are Not Being Mean!
You Are Being Smart!
f
t
in

33. Weber & Associates, Inc.
Contact Us
Toll-Free: (888) 857-8690
Weber
&
Associates,
Inc.
is
a
full-­‐service
federal
student
aid
management,
processing
and
consul=ng
company
serving
colleges
&
universi=es
of
all
sizes.
info@weberassociatesinc.com
A publication of Weber & Associates, Inc.