NYSFAAA What to Expect, when you’re Expecting? An Audit What you should expect today! • • • • • • • Private, SUNY, and CUNY Perspective Federal Title IV and NYS TAP Reviews & Audits Top 10 findings Preparing Facilitating Negotiating the results Preventive Planning to Minimize Potential for Findings Q and A Federal Program Review • Usually conducted by Regional Office Program Review Specialists • Can be conducted by the US ED. Office of Inspector general • Review office procedures and student financial aid, bursar, and registrar records • Disallowances based directly on findings State Audits • Conducted by NYS Comptroller's Office • Review College academic, bursar and registrar records • Comprehensive review of college academic policies as they relate toward financial aid • Disallowances are based on the sample population findings and calculated over all recipients The potential liability from State Audits is usually much higher than the potential liability from Federal Program Reviews Federal Audits Top 10 Findings • 1. R2T4 calculation errors • 2. R2T4 late refunds –(SUNY) • 3. Commencement of Attendance proof • 4. SAP (SUNY) • 5. Pell grant Payments overpayment • 6. FWS time sheet errors • 7. NSLD reporting errors late or missing grad date • 8. Verifications errors • 9. Entrance or Exit interviews missions • 10. Conflicting Information SUNY Audit Findings 2010-2012 • R2T4 - Timely return of funds • FWS - No signed contract for off-campus employment • Loan Disbursement Notification - Timely “Notice of Disbursement” and right to cancel the loan for both Perkins and DL Notification must be done for all disbursements • Loan Reconciliation - Reconciliation not performed monthly • SAP - No SAP policy for professional school that does not use letter grades • Reporting to clearinghouse -Did not report student status changes within 60 day time allowance NYS TAP Audit – TOP 10 Findings • • • • • • • • • • 1. Ineligible program 2. Course not applicable toward the degree 3. Satisfactory Academic Progress 4. Ability to Benefit 5. Refunds not made in timely fashion 6. Missing folders or documents 7. Not a NYS resident 8. Not a HS graduate 9. Undeclared major 10. Funds not applied to account properly Preparing for an Audit • Ask the entity performing the audit for the scope and timeframe • Meet with academic, financial, and legal counsel staff to discuss audit • Review appropriate contact individual(s) from each office • Review how information will be shared • Identify space for auditors During Audit • Stay CALM!!!!!!! • Remember the auditors are only doing their job they are not out to “get you” • Provide records to auditors as quickly as possible • Take your time when answering questions • Never GUESS, if unsure – do research • Reach out to colleagues if you have questions • Do Not blindly trust!! – Verify • Ask for regulation citation for finding • Keep in mind the auditor may be mistaken • Dispute findings during audit Final Meeting • Do not admit to anything!! • If something is missing - search for it • If a timeline was missed – double check that it was • If a policy is not in writing – put it in writing • Ask for timeframe for submitting additional responses and for receiving preliminary and final repots • Seek legal advise before you agree to anything What Should I Do Now • Review and update Financial Aid Office procedures manual • Review college bulletin to assure accuracy of information and compliance with regulations • Review Middle States and other accreditation documents • Review NYS Education Department “Inventory of Registered Programs” to assure all college offerings are approved If a college practice or procedure does not look correct than you need to speak up Ultimately the College President and Administration are Responsible There is no substitute for a GOOD PLAN!