Summary: This resource summarizes the audits I am aware of, resources associated with them, and compliance elements that are supported external to the SFA office.
Types of Audits:
- Department of Education
- Selections are not recurring (as are other audits) but factors that can commonly contribute to a selection are increases in federal aid usage (which comes with increases in enrollment) and duration of time since a school was previously audited by the Department of Education.
- Annual A-133
- Under our FAFSA eligibility agreement as a school (Program Participation Agreement) we are obligated to comply with the Single Audit Act. This act requires schools to have an audit conducted in accordance with >several regs we don't need to dive into< and to publish the results of that audit within the applicable annual deadlines (there are a couple of nuances here, but generally its the end of March or within 30 days of the school receiving the final audit report).
- Audit Agency: We use KPMG. They are a well known and highly respected auditing firm and they complete both the Annual A-133 (SFA audit) as well as the annual Fiscal audit (finance side). We select the auditing firm to work with and they are paid by the university, however they must be a qualified audit firm under several legal standards. Once the final audit letter is provided both the CFO and the Financial Aid Director must sign both sets of audit results. This ensures transparency between Finance and Financial Aid.
- I handle the annual upload to the several federal systems that is required at the end of this audit. Steve and Debbie in Finance contribute, as do the KPMG audit managers.
- VA Audit
- This is normally done annually, and its much more new to me since my team took it over from Bob and Jessica. The normal audit is significantly smaller than the Annual A-133. It was also less documented than ours, so we have work to do to cut down the administrative time this takes.
- VA Risk Assessment
- This is the new type of audit we were selected to participate in with the VA this year. We expect it to become a standard practice, but frequency and the final process they will use are still in development. Regent was part of 6 schools selected for the initial pilot of this experience. Due to lack of experience on the Virginia Department of Veteran's Affairs side, this audit was much more administratively intensive than I hope it will be in the future.
- Accreditation
- Each audit requires inclusion of our accreditation letters from all agencies. Ryan Murnane is my point of contact for these and I keep copies locally for these letters as well. So far every accrediting audit/review requires inclusion of financial aid information. This sometimes involves an interview with me during the site visit, my written credentials, and an overview of the financial support and counseling resources available to students.
- VA Annual Updates
- Each year (outside of audits) our VA Certifying Officials have to provide the full University Catalog to the VA, complete annual required VA training (this takes about 6-8 hours), review all programs we offer and expire phased out ones and add new ones.
Things Audits Include (Outside of FA Specific Items):
- Academic Calendars
- Tuition Rates & Fees
- Student Transcripts
- Documentation that we are compliant with the prohibiation against incentive compensation for securing enrollment
- Faculty Credentials (included in some reviews)
- Documentation of continued external training for FA Employees
- Documentation that the FA office is administratively capable (under staffing in FA would violate the federal Program Participation Agreement)
- Consumer Disclosures
- Enrollment Reporting Compliance
- Accurately reporting effective dates, correct status, within the 60 day compliance window
- Accurately reporting CIP codes and program length
- Compliance with data security under the Gramm-Leach-Bliley Act (I work with Ben and Steve in IT for this, its part of the wonderful security training we all get to do each year)
- Proof of compliance with Cash Management regulations for Title IV Funds (I work with the Business Office/Finance team for this)
- Process and student samples demonstrating compliance to confirm a student has established initial participation in courses
- Student refund policy
- Enrollment classification policy (full time, 3/4 time, ect)
- Overview of any written agreements we have between schools or other qualifying entities
- Separation of duties between approving a student for an award and providing the funds to that student
There are multiple other areas of compliance that are not always recurring parts of an audit, but can (and are) periodically requested.
FA Specific Audit Items:
- Student Verification Files
- Verification Policy
- Student SAP Assessment Files
- SAP Policy
- Student Cost of Attendance Files (this includes the reported cost of attendance out from banner to COD, one of the federal systems)
- Accurately reported disbursement dates to COD (federal system)
- Accurately reporting verification completion per student to COD (federal system)
- Proof of compliance with reconciliation of federal aid program funds requirements
- Copy of the annual Cohort Default Rate information (there are penalties if our rate exceeds 10%, and this scale upward from here)
- Net Price Calculator tool
- Process documentation for determining student eligibility for federal student aid
- Overview of direct loan processing and controls over the process
- Compliance with the Truth in Lending Act and private loan disclosures
- Process documentation that we check student eligibility at the time of disbursement
- Documentation that a risk assessment and communication process is in place
I have specific articles and P&P documents for these things but have not linked them here yet. We are migrating all of our stuff from Fresh Desk to Fresh Service, so the links are about to change. I've attached some of the related documentation non-student documentation here so you can get an idea of whats covered (this is just some of the bigger picture items).