Program Review Guide

Chapter IV: Program Review Focus Items

In consultation with regional office staff, IRB-HQ has identified 34 focus review items for
1994. Reviewers should focus the program review on these deficiencies. Any deviations
from the focus items list should be discussed with a supervisor.

The 34 focus items were selected because they represent areas where serious deficiencies
often result in significant liabilities to schools for improper use of federal funds or cause harm
to past or current students. By focusing program reviews on these critical items, reviewers
will be better able to 1) identify the most serious deficiencies and compliance issues; 2) use
limited staff time and resources more productively; and 3) avoid duplication of effort between
ED reviews, and in reviews and audits conducted by independent auditors, guaranty agencies,
state entities, and accrediting agencies.
A list of the focus items follows. The list is formatted to also serve as a checklist to guide the
reviewer on-site.
Note: Reviewers should test for inconsistent or conflicting information when examining the
focus items. An institution must maintain accurate or consistent data in order to support the
eligibility of each aid recipient; therefore, the reviewer should identify any discrepancies in
student and institutional records and ensure they are properly resolved. The following are
some examples of conflicting information:
a. Some schools ask the student to provide similar information on different forms.
For instance, the admissions application may ask students about their
employment history. Often, students report employment here, but show no
wages for the same period on their financial aid application.
b. A parent's tax return reports significant interest income for four consecutive
years, but the aid applications reflect minimal assets every year. (Since interest
income is reported for the prior year and assets are reported for the current
period, a correlation needs to be drawn over more than one year).
The following discussions summarize key issues associated with a review of the focus items.
These summaries are not meant to be all-inclusive. For instance, if there is a serious problem
with a school's satisfactory academic progress policy not specifically discussed here, continue
to review the issue based on regulatory or statutory requirements. These focus review item
summaries are meant to provide guidance to reviewers, but not replace reviewer discretion
and professional judgement.
Also, many of the typical problems are only briefly discussed, and do not include all possible
considerations the reviewer must address. For example, in examining financial aid transcripts,
the reviewer notes that financial aid was disbursed, even though a transcript showed the

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student was in default. However, the reviewer must determine whether the school
performed additional follow-up on what was reported on the transcript. There might be
documentation in the student's file showing the student had made satisfactory arrangements to
repay the defaulted loan, and was therefore an eligible student.
Finally, even if it is not listed as a focus item, the reviewer should not ignore a serious
problem that becomes obvious in the review process, especially if it may represent potentially
significant liabilities or may have affected many students adversely.
References are provided in a concise format at the end of each focus item to guide the
reviewer to the appropriate regulatory or statutory authority. Dates are provided only for
newly issued regulations. Full information on regulatory references for the focus items is
found in the generic paragraphs. Please note that many recently issued regulations were not
yet effective as of the time this Guide was prepared.
Although the Guide will be updated regularly, reviewers are reminded of the continuing
importance of remaining current on regulatory and statutory requirements.

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T Program Review Focus Items 1994

FISCAL: Page
‘ 1. Fiscal Records/Audit Trail Inadequate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4
‘ 2. Excess Cash Maintained . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-5
‘ 3. EDPMS 272 Expenditure Report Inaccurate . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-7
‘ 4. Advances Used for Non-Program Purposes . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-8
‘ 5. Matches Not Made in Campus-Based Programs . . . . . . . . . . . . . . . . . . . . . . . . 4-9
‘ 6. Late/Unpaid Refunds . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-10
‘ 7. Refund Calculation Incorrect . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-11
‘ 8. Credit Balances Not Paid to Students . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-12
‘ 9. FFEL Disbursements Not Attributed to Payment Periods . . . . . . . . . . . . . . . . 4-13
STUDENT ELIGIBILITY:
‘ 10. Ability to Benefit Violations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-13
‘ 11. Satisfactory Academic Progress Standards Not Monitored/Developed . . . . . . 4-15
‘ 12. Ineligible Non-Citizen . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-16
‘ 13. Attendance Records Missing/Inaccurate . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-16
‘ 14. Financial Aid Transcript Missing/Incomplete . . . . . . . . . . . . . . . . . . . . . . . . . 4-17
AWARDING/DISBURSEMENT:
‘ 15. Incomplete Verification . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-19
‘ 16. Independent Status (Not Documented; Incorrect; Unreasonable Professional Judgement) 4-20
‘ 17. Perkins Loan Promissory Notes Missing/Unsigned . . . . . . . . . . . . . . . . . . . . . 4-20
‘ 18. Timecards for FWS Students Missing/Invalid . . . . . . . . . . . . . . . . . . . . . . . . . 4-21
‘ 19. Improper Pell Calculations/Disbursements . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-21
‘ 20. Student Aid Report Invalid . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-23
‘ 21. Disbursements Made Prior to Midpoint . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-24
‘ 22. Enrollment Not Verified Before Disbursement . . . . . . . . . . . . . . . . . . . . . . . . 4-25
‘ 23. Need Analysis Improper/Undocumented . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-26
‘ 24. FFEL Loan not Prorated for Programs < One Year . . . . . . . . . . . . . . . . . . . . . 4-27
‘ 25. FFEL Loan Amounts Incorrect for Grade Level . . . . . . . . . . . . . . . . . . . . . . . 4-27
OTHER:
‘ 26. Ineligible Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-28
‘ 27. Ineligible Location . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-29
‘ 28. Unresolved Items From Past Reviews/Audits . . . . . . . . . . . . . . . . . . . . . . . . . 4-30
‘ 29. FISAP Income Grid not Documented . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-30
‘ 30. Perkins Loan Due Diligence Deficiencies . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-32
‘ 31. Improper Commissioned Sales Rep Practices . . . . . . . . . . . . . . . . . . . . . . . . . . 4-33
‘ 32. Clock/Credit Hour Conversion Improper . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-33
‘ 33. FFEL Student Confirmation Report Not Filed/Inaccurate . . . . . . . . . . . . . . . . 4-34
‘ 34. High Default School (Entrance/Exit Counseling, Withdrawal Rate, etc.) . . . . 4-35

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Review Focus Items

FISCAL:

1. FISCAL RECORDS/AUDIT TRAIL INADEQUATE

FIS 3000, 3010, 3050,3060

The institution's fiscal records should provide a clear audit trail of the status of federal funds
from the time they are received by the school through the time they are used to pay students'
eligible charges, delivered to the students for indirect educational expenses, or refunded to
the programs.
Confirm the institution's methodology for determining the need for the amount of funds
drawn through EDPMS. Then, verify how the school documents the use of the funds drawn.
There must be a detailed accounting of the use of all federal funds received by the institution.
If the school received $10,000 in funds on 6/1/94, there should be a listing (ledger/journal)
specifying the students to whom the funds were disbursed and the applicable program (e.g.,
FSEOG). The records for the bank account in which the federal funds are held must show
that federal funds received were not used by the institution until they were delivered to the
students (e.g., credited to their account). There should also be records of all FFEL check
negotiations.
If federal funds are received and deposited in an account and combined with non-federal
funds, there must be a separate record to show the status of federal funds in that account at
all times. The overall account balance dropping below the balance of federal funds on hand in
the account would be an indication that advances are being used for non-program purposes.
Federal funds should be maintained in a non-interest bearing account (except for the Federal
Perkins account funds). However, if the federal funds are in an interest-bearing account, the
interest earned on those funds must be returned to the Department.
There should also be a correlation between the different fiscal records at the institution. For
example, the ledgers show $10,000 was received on 6/1/94, and disbursed to 20 students
on 6/3/94. Fiscal records (e.g., vouchers or ledgers) should reflect either payments against
those students' charges, or checks issued to students, on or prior to 6/3/94. There is no
specific requirement for an individual student account statement, but a school must maintain
some system for evaluating students' accounts to determine when funds received have
exceeded eligible costs for the applicable periods.

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The fiscal system must also account for recoveries and refunds back to the Title IV programs.
The fiscal records must reconcile with specific program allocation limits set by the
Department (e.g., Pell Grant Program Statement of Account, Campus Based Allocation
Letters), and information provided to the Department in reports such as the Pell Grant
Program Student Payment Summary, FISAP, and the Federal Cash Transactions Report
(EDPMS 272). Therefore, the fiscal records should be able to identify not only the program,
but the award year to which the funds are being applied. For example, if the records show
Federal Pell Grant funds were disbursed to students on 7/5/94, were those funds for the
1993/94 or the 1994/95 award year? This determination is critical in ensuring they are
reported against the appropriate year's authorization on the EDPMS 272 report.
The same standards of accountability also apply to the Federal Perkins Loan Fund. Those
funds should only be used to make loans to students and pay certain program costs, as
defined in 34 CFR § 674.47. There should be records showing the deposit of repayments
received from students, and interest earned on the assets of the account.
The institution must also identify to banks those accounts containing federal funds, as specified
in 34 CFR §§ 674.19, 675.19, 676.19, and 690.81.
Reviewing this system will require examining bank statements, fiscal reports, detailed ledgers,
checkbooks, etc. Institutions' fiscal systems will vary, and there is no "usual" format. A Fiscal
Review Worksheet has been provided as Appendix E to this Guide to assist the reviewer.
34 CFR § 668.23 General Provisions
34 CFR §§ 674.19 and 674.47 Perkins Loan, 675.19 FWS, 676.19 FSEOG
34 CFR § 682.610 FFEL
34 CFR §§ 690.81 through 690.84
The Blue Book (Accounting, Recordkeeping, and Reporting by Postsecondary
Educational Institutions)
U.S. Department of Education's Guide to Payment Management System
Fiscal Records Review Training, Trainee Guide, Fall 1991

2. EXCESS CASH MAINTAINED

FIS 3110

Evaluate the amount of funds drawn through EDPMS by the institution to verify that the funds
are used for their intended purpose within the specified deadlines (FED WIRE 1 day,
ACH/EFT 3 days). This is not strictly an evaluation of money in the federal bank account since
the institution may have already earned the funds by crediting students' accounts, but has not

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yet transferred the funds to its operating account. In such cases, the funds are not federal
funds, and there is no excess cash.
Review reconciled bank statements and disbursement records/ledgers, comparing the
amount received with the actual usage of funds.
Some schools draw funds based on projections of need (e.g., prior year's disbursement
levels, % of allocations). If the projection is too high and the school will be unable to use all
the funds in the specified timeframe, the excess should be returned to the Treasury.
Some schools improperly draw the total amount of their fund authorization at the beginning
of year. The school then gradually disburses the funds over the course of the year, possibly
earning interest on the funds.
Verify that funds returned to the Title IV account due to refunds or recoveries are
immediately reallocated and used to pay students' awards. Some schools ignore
refunds/recoveries when determining the amount of funds they draw through EDPMS. As a
result, the refund/recoveries accumulate in the school's account.
Failure to make Title IV refunds to Pell Grant and Campus-Based accounts also constitutes
excess cash maintained by the institution.
Determining whether excess cash exists in the Federal Perkins Loan fund is more
complicated. The institution can properly hold such funds, and must earn interest on them.
However, the institution is required to evaluate the amount of funds in the account to
determine whether it has more funds than it can reasonably expect to lend out to its students.
Guidance for the determination of excess funds in the Federal Perkins Loan account is
provided in DCL 92-12. The institution is also required to expend the Federal Perkins Loan
account funds on hand to make loans to students before drawing its Federal Cash
Contribution (FCC) through EDPMS. Check that schools do not draw the FCC while there
are still adequate funds in the account.
34 CFR § 668.16 General Provisions (12/1/87), reissued as 668.14(b) on 4/29/94
34 CFR § 690.74 Federal Pell Grant
34 CFR § 205.4 (a) Money and Finance, Treasury Regulations, 12/14/77
U.S. Department of the Treasury Circular #1075 and #1084
U.S. Department of the Treasury, Treasury Financial Manual, Chapters 6-2000,6-8000
U.S. Department of Education's Guide to Payment ManagementSystem
The Blue Book (Accounting, Recordkeeping, and Reporting by Postsecondary
Educational Institutions)
Fiscal Records Review Training, Trainee Guide, Fall 1991
IRB Memos 91-22 and 93-7

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3. EDPMS 272 EXPENDITURE REPORT INACCURATE

FIS 3100

The institution's receipt and expenditure of funds are reported on the Federal Cash
Transaction Report (EDPMS 272). Compare the institution's records of Title IV expenditures
to confirm that both the interim and cumulative amounts agree with the amounts reported to
the Department for the specific periods required on the EDPMS 272, and that all
expenditures are equal to or less than the authorized levels.
The following are other suggested review strategies:
" If interest was earned on any federal funds in the institution's accounts
(other than the Federal Perkins Loan account), confirm that the interest
is reported on the EDPMS 272.
" Confirm the status of federal cash on hand against reconciled bank statements.
" Compare the closing balance of the prior EDPMS 272 with the opening
balance of the current EDPMS 272 for consistency.
" Review for proper reporting when transferring funds between
programs; compare to the appropriate FISAP report.
" Verify that the institution's records were revised based on adjustments
and disallowances noted on page 3 (272-B) of the EDPMS 272.
" Ensure that the expenditures listed on the EDPMS 272 reconcile with
other reports filed for the same period (a reconciled Pell Grant Final
Student Payment Summary, the FISAP, etc.).
" Compare receipt of federal funds listed on EDPMS 272 with deposits
into school's accounts.
Institutions may incorrectly report funds received at the end of a reporting period as disbursed
within that period to avoid the appearance of excess cash. For example, $40,000 was
received on 9/29/93, but not disbursed until 10/3/93. However, the school reported the
funds disbursed on the EDPMS 272 for the period ending 9/30/93, rather than report
$40,000 cash on hand as of 9/30/93.
For ease in tracing Title IV funds, obtain the "POO number" (document number) from the
EDPMS 272 by programs from the allocation letter(s).
34 CFR §§ 674.19 Perkins Loan, 675.19 FWS, and 676.19 FSEOG
34 CFR §§ 690.81 through 690.83 Federal Pell Grant
U.S. Department of Education's Guide to Payment Management System
The Blue Book (Accounting, Recordkeeping, and Reporting by Postsecondary
Educational Institutions)
Fiscal Records Review Training, Trainee Guide, Fall 1991

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 Program Review Guide

4. ADVANCES USED FOR NON-PROGRAM PURPOSES

FIS 3040

Funds received by the institution under the Title IV programs are held in trust for intended
Title IV aid recipients and the Department.
This finding is often accompanied by a finding for excess cash, where the institution draws
funds it is not yet entitled to and uses the funds for unauthorized purposes. As noted in the
discussion for Excess Cash Maintained, the reviewer must determine whether or not the
funds in the federal account have already been earned by the institution. Look for large,
undocumented, lump-sum transfers of funds from the federal accounts.
With co-mingled accounts, verify that the total account balance did not go below the balance
of federal funds present in the account.
Institutions may also fail to deposit their own funds to reimburse federal accounts for costs
such as bank service charges and returned check fees. Therefore, Title IV funds are
improperly used to used to pay the costs. Federal Perkins Loan funds can be used to pay
certain program costs, as specified in 674.47.
Schools have also used federal funds for such diverse purposes as meeting institutional
payrolls, paying personal expenses, as collateral for loans, and for investment purposes.
34 CFR § 668.14 General Provisions (12/1/87), reissued as 668.16 on 4/29/94
34 CFR § 674.8 Federal Perkins Loan
34 CFR §§ 675.18 FWS and 676.18 FSEOG
34 CFR § 690.81 Federal Pell Grant

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5. MATCHES NOT MADE IN CAMPUS-BASED PROGRAMS

FWS 1090, FPERK 8190, FSEOG 9010

Verify that the institution has made the proper institutional match for campus-based funds (the
required percentages of matching funds have changed several times in recent years). Also,
confirm that the match was made at the time the funds were drawn through EDPMS by the
institution.
Details of the institutional share requirements are provided in the Federal Student Financial
Aid Handbook, Chapters 6, 7 & 8.
The institution should also be able to document how the match was made. In some cases, a
school may deposit actual funds into the appropriate bank accounts, and the bank statements
and ledgers will reflect the amount and date of the match. In other cases, the school will
credit students' accounts for the full amount of the award, and then draw down a percentage
of the full amount based on the federal share. In this scenario, the match would not be
documented on the bank statement, since there would be no actual deposit of institutional
funds into an account.
Given the previous scenario, where the school made its FWS match by drawing down $750
out of a $1000 payroll for a payment period, verify that each student was eligible for the 25%
institutional match (students working off campus at a private, for-profit organization require a
50% institutional match).

Other recommended review procedures are as follows:

" Verify the accuracy of the institutional match calculations (many schools
incorrectly calculate the match as 25% of the federal allocation, instead
of 25% of the combined federal/institutional contributions).
" Note that some institutions may receive waivers for institutional match
requirements in the FWS and FSEOG programs. The school should
have documentation of the waiver.

34 CFR § 674.8(a)(2) Perkins Loan

34 CFR § 675.26 FWS
34 CFR § 676.21 FSEOG
HEA, §§ 413(c)-FSEOG, 443(b)(5)-FWS, and 463(a)-Perkins
DCL, GEN 92-21, October 1992
The Blue Book, 5/6/91
Federal Student Financial Aid Handbook

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6. LATE/UNPAID REFUNDS
GEN 2380 ,2340 FFEL 5170

Confirm that refunds due to the Federal Pell Grant, Federal SEOG, or Federal Perkins Loan
were paid to the federal account within 30 days of the school's determination that the
students withdrew or dropped out (determination date). Refunds to the Federal Stafford,
FSLS, and FPLUS Loan calculated on or after July 20, 1989, must be returned to lenders
within 60 days of the determination date.

Review the school's procedures for identifying the determination date for drop-outs and "no-
show's". Clock-hour schools usually have a dismissal policy if students miss a number of
consecutive days, or miss a certain percentage of hours offered. Make sure the school
adhered to the policy. Accrediting and licensing bodies may also specify some criteria for
determining the withdrawal date.
Many credit-hour schools improperly assume students dropped out at the end of the term
they last enrolled in, even if they received all incomplete grades. If the school's records show
students informally withdrew, the school must determine the date the students last attended,
and use the date for calculating refunds.
To verify timeliness, compare the date the refund was paid to the date the school determined
the student withdrew.
Other recommended review procedures are as follows:
" Look at cancelled refund checks and account transactions to verify the
date funds were actually transferred (e.g., a check may have been dated
6/15/94, but the bank stamped the check received and negotiated on
7/30/94. If this is common, school may be holding refund checks.)
" Ask if there is a system for refunds to be "approved" before refund
checks can be sent to lender; this may result in checks being held for
long periods after being drawn.
" Try to call and verify last dates of attendance with students whose
attendance records show long period of absences, then one final day of
attendance.
" Check whether the school automatically gives LOAs to students who
say they want to withdraw. This allows the school to hold the money
another 60 days or so.

34 CFR §§ 668.21 and 22, General Provisions

34 CFR §§ 682.605 through 682.607 FFEL

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7. REFUND CALCULATION INCORRECT

GEN 2360,2371

Confirm that the institution's refund consumer information and refund calculations are in
compliance with the school's refund policy and regulations, and are mathematically correct.
Make sure the refund policy is "fair and equitable", using the calculation that is most beneficial
to the student if more than one refund formula applies (i.e., pro rata, licensing body,
accrediting body). Check that pro rata calculations are performed for all first-time students
who withdraw from the school within 60% of the period for which they were charged,
beginning 7/22/92. Also, ensure that the correct last date of attendance is used in the
calculation.
Other recommended review procedures are as follows:
" Review students' account records and verify all costs in the calculation
are for the enrollment period in question (e.g., unpaid charges from
prior semester not added in), and are specified in enrollment contracts
and consumer information.
" Ensure that correct tuition adjustments are made to tuition charges.
Pro-rata requires adjustment based on hours completed; some state
policies may specify using hours offered. The school must use the
policy that results in the largest refund to the student.
" Check that the unpaid amount of scheduled cash payments is subtracted
from the amount of funds to be retained by the school (new provision,
see DCL 94-13).
" Confirm that repayment calculations have been performed, when non-
FFEL funds were disbursed to students for indirect expenses.
" Verify that the costs for books, supplies, and equipment have been
properly adjusted based on the requirements of the formula (e.g., the
cost of beauty kits was prorated). See Q & A section of DCL 94-13.
" Ensure any excused absences counted as completed hours are based
on a documented policy.

34 CFR §§ 668.21 and 668.22, General Provisions

34 CFR § 682.606 FFEL
The Higher Education Amendments of 1992 (P.L. 102-325)
Federal Student Financial Aid Handbook, Chapter Three, issued as DCL 94-13, 3/94

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8. CREDIT BALANCES NOT PAID TO STUDENTS

FIS 3171, GEN 2381

Review the institution's policy and procedures for applying payments to students' accounts,
monitoring whether students' disbursements exceed costs, and providing budgetary assistance
to students.
Some schools don't keep individual student account records. ED does not require them to
do so, but the school must have a system for determining when disbursements exceed costs,
and promptly delivering the excess funds to the students.
Review records for sampled students to determine if credit balances were held without
students' permission. If credit balances are currently being held, check if school has enough
funds in operating accounts to make disbursements to students. IRB 93-8 provides further
guidance regarding credit balances. According to ED's Policy Development Division, the
current standard regarding prompt delivery of excess funds to students is 45 days. An NPRM
clarifying this issue was in preparation as of the date this Guide was prepared.
A student's authorization for the school to hold funds in excess of direct charges must be in
writing. Check that statements designed by schools clearly explain to students that they are
giving permission voluntarily. Statements should not be embedded in the middle of other
certifications, under one signature. A school must also obtain students' permission to apply
Federal Pell Grant funds to charges other than tuition, fees, or institutionally charged room
and board.
Other recommended review procedures are as follows:
" Verify what budgeting measures are taken (e.g., are funds paid out to
students on a schedule?) if statement says funds held for budgeting.
" Note that, even with the student's permission, funds cannot be held
indefinitely (payment period for Pell & Campus-Based funds, loan
period for FFEL).
" Confirm that the institution deposited all FFEL funds held with the
student's permission in a designated trust account, and are not co-
mingled with other funds or used for other purposes. This provision of
682.604 (d)(ii) became effective 2/19/93.
" Verify the school's "stale" check procedures when students do not
negotiate checks sent to them for indirect expenses. Are the checks
ever canceled, and what happens to the funds?
34 CFR § 668.14 General Provisions (reissued as 668.16 on 4/29/94)
34 CFR § 682.604 FFEL
34 CFR § 690.78 Federal Pell Grant
IRB 93-8

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9. FFEL DISBURSEMENTS NOT ATTRIBUTED TO PAYMENT PERIODS

FFEL 5271

Check that the institution adheres to the payment period concept as defined in 668.22(c) for
FFEL funds when students withdraw from school. Payment periods correspond to
semesters, trimesters, quarters, etc., for programs with academic terms. At a minimum, a
payment period is the time between the beginning and the midpoint, or between the
midpoint and the end of the academic year for programs without academic terms. Confirm
how the school defines its payment periods.
For example, if a student attended only two trimesters, and the full loan amount covering a
three trimester loan period was disbursed, one third of the loan amount must be attributed
back to the lender. This process must take place before determining the amount of loan
funds to be included in a refund calculation.
34 CFR § 668.22 General Provisions
DCL GEN-88-32

STUDENT ELIGIBILITY:

10. ABILITY-TO-BENEFIT VIOLATIONS

GEN 2000, 2001

Confirm the school's determination that students who do not possess a high school diploma
or its equivalent (GED) have demonstrated the ability to benefit (ATB). All students enrolled
on or after 7/1/91 were required to pass a test approved by the Secretary in order to receive
Title IV funds, and that test must be independently administered. Prior to 7/1/91, students
could not be admitted to the school unless they first demonstrated ATB.
Review all information about the test used by the school, including the test itself, an answer
key, scoring guide, and instructions explaining the procedures for administering the test.
Recommended review procedures are as follows:
" Ensure that any test used for all Title IV recipients enrolling as of 7/1/91
is one of the approved tests listed in the Federal Register.
" Verify the complete approved test was administered, the school cannot
use only selected parts of the test.
" Recheck the scoring of the test; make sure the student actually passed.

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" Verify that the test was administered as specified by the developer (the
test was timed, if required; re-test procedures followed, etc.), by
interviewing the test administrator (tester) and students.
" Ascertain whether the tester meets the independence criteria in the
Federal Register notice (review the tester's contract with the school).
" Confirm whether tests meet licensing and accrediting requirements
(some agencies approved only certain ATB tests, even before the
Department did so).
" If students fail the ATB test and then submit documentation of high
school graduation or GEDs, the reviewer may want to verify the
authenticity of that information.
When discussing the process with officials and the tester, determine how the documentation
that the student passed the test is maintained. Is there a certification for each student who
passed, signed by the tester? Does the test administrator keep a roster of all students tested
to be checked against the results noted in students' files? There are no specific measures
required by the Department, but there have been some cases where administrator records
showed students failed their ATB tests, but the file documentation showed they passed!
Refer to Appendix C of this guide for recommended questions to ask regarding the ATB
process.
Finally, since students who cannot demonstrate ATB can still be admitted to the institution,
verify that the school has a method to identify such students to ensure they do not receive
Title IV assistance.

HEA Sec. 484(d)

Higher Education Technical Amendments of 1991 (P.L. 102-26)
34 CFR § 600.11 Institutional Eligibility
34 CFR § 668.7 General Provisions
Federal Register Notice of 12/30/92
Federal Register Notice of 12/19/90
DCL, GEN 91-20
Federal Student Financial Aid Handbook, Chapter 2
IRB Memo 92-2, 2/20/92

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11. SATISFACTORY ACADEMIC PROGRESS STANDARDS

NOT MONITORED OR DEVELOPED
GEN 2390, 2400

See Appendix G--Satisfactory Academic Progress (SAP) Policy Checklist

Institutions are required to 1) establish satisfactory academic progress (SAP) standards and, 2)
confirm that students are maintaining those standards prior to releasing any federal student
financial aid. An institution may award Title IV funds only to eligible students. Maintaining SAP
is one eligibility criterion all students must meet.
The institution must have a written satisfactory academic progress policy which is the same as,
or stricter than, standards for non-Title IV aid recipients.
Verify with institutional officials if they have checked with their accrediting body for specific
SAP criteria; if yes, is the school in compliance? Does the policy contain all elements required
in the regulations? Was the policy correctly applied for all students in the sample?
Establish when the school evaluates SAP. Determine which office is responsible for
determining whether a student is maintaining SAP. Review the procedures in place to ensure
that students who failed to meet the satisfactory academic progress policy are denied aid.
Other recommended review procedures are as follows:
" Verify that the institution's quantitative measure of progress correlates to
its stated maximum timeframes.
" Check that the standards were consistently applied.
" Ensure students are informed of appeal rights and procedures.
" Confirm documentation maintained for all exceptions to SAP standards
granted, based on appeals.
" Recheck calculation of elements used in standards (e.g., GPA,
cumulative hours/credits earned), especially if school's system is not
computerized.
" Verify that the standards define the effect of course incompletes,
withdrawals, course repetitions, noncredit remedial courses, credit by
exam, and other special considerations.

34 CFR § 668.7 General Provisions

34 CFR § 668.14 General Provisions, reissued as 34 CFR § 668.16 on 4/29/94

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 Program Review Guide

12. INELIGIBLE NON-CITIZEN

GEN 2190

Examine documentation collected for all students who have reported they are eligible non-
citizen permanent residents on their institutional applications. This also applies to parents of
students who are applying for PLUS Loans.
A student's SAR should contain some comment regarding confirmation of permanent
residency status. The Higher Education Amendments of 1992 required schools to collect
"secondary" confirmation from INS (Form G-845) for all students whose status was not
confirmed on the SAR. Prior to that, secondary confirmation was not mandatory, and
students were required to document their eligible non-citizen status based on the criteria
described in Chapter Two of the Federal Student Financial Aid Handbook.
34 CFR § 668.7 General Provisions
HEA, Section 484(h) & (i)
DCL, GEN 92-21, October 1992

13. ATTENDANCE RECORDS MISSING/INACCURATE

GEN 2040, 2050

Complete and accurate attendance records are essential for evaluating students' Title IV
eligibility. Although there is no regulation specifically requiring attendance records, institutions
must have a system in place to verify student enrollment status, course length, eligibility for
subsequent payments, and refund calculations.
Discuss with institutional officials the process for recording the classes or number of hours
students attend each day. Is attendance taken periodically during the day, or are there sign-
in/sign-out sheets? How is partial attendance recorded, rounded to the nearest hour, half
hour, etc.? How are records kept at any externship sites?
Compare attendance records to any other records or reports kept for other agencies, such as
JTPA and VA. Test the cumulative attendance list against source records. Check that hours
have been properly compiled, including the actual addition for manual systems or the data
entry for computerized systems.
Other recommended review procedures are as follows:
" Look closely at attendance records with excessive white out, especially
if the student withdrew. Try to contact students to verify information.

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 Program Review Guide

" Ask students about absences (especially extended periods) and verify
that the attendance records correspond.
" Determine how make-up hours are documented. Some schools do
not differentiate between make-up hours spent working on specific
coursework, and extra time students may spend at school practicing on
their own.
" Look for cases where all students sign in and out at exactly the same
time every day. Also, check holiday schedules, doctor's notes and other
notations in students' files to confirm deviations in attendance are
accurately recorded. Many discrepancies of this kind may signal the
attendance records were hastily created after the fact.
Missing or inaccurate attendance records may mean the undocumented classes or hours
cannot be counted for purposes of determining students' eligibility.
34 CFR § 668.23 General Provisions
34 CFR §§ 674.19 Federal Perkins Loan, 675.19 FWS and 676.19 FSEOG
34 CFR § 682.610 FFEL
34 CFR § 690.82 Federal Pell Grant

14. FINANCIAL AID TRANSCRIPT MISSING/INCOMPLETE

GEN 2150

Check to determine whether complete financial aid transcripts (FATs) are collected from all
prior postsecondary schools reported by students. The school must have some record that
shows students were asked about prior schooling, and their responses to the question.
Many times students report prior schooling on admission applications, but do not report the
same information on their financial aid applications. Schools must have a way to coordinate
this information and collect FATs from all prior schools indicated on any institutional records.
During the review, check Admissions, Registrar, and Financial Aid records for indications of
prior postsecondary attendance.
Other recommended review procedures are as follows:
" Check that the school has not disbursed Title IV funds when FAT
reports student is in default/owes repayment.
" Verify FAT is completely filled out and form provides all required
documentation (see 668.19).

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 Program Review Guide

" Review for conflicting information on FAT (e.g., reporting school says
the student attended beyond the five-year record retention period, but
application information shows the student attended there four years
ago).
" Verify that the school has obtained a financial aid transcript from the
Federal Student Aid Information number (1-800-4-FED-AID) for closed
schools.
" Check the collected FATs for information on other schools previously
attended and ensure that FATs were collected for all prior schools not
previously reported to the institution.

Note: It is a school's responsibility to ensure it collects complete FATs; the school must follow
up if it receives incomplete or conflicting information on FATs.
34 CFR § 668.7 General Provisions
34 CFR § 668.19 General Provisions

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 Program Review Guide

AWARDING/DISBURSEMENT:

15. INCOMPLETE VERIFICATION:

GEN 2491

Check that required verification was completed for all selected students. If a student's data
was not processed through a need analysis with the required verification edits, the school
must proceed as if the student was selected. The information to be verified and the specific
types of required documentation are listed in The Verification Guide.
Other recommended review procedures are as follows:
" Carefully check untaxed income items identified on tax returns (these
are often misreported).
" Ensure the verification documentation collected is complete (e.g., all
required signatures are present on documents).
" Check that the school identified any revised information on documents
collected, and performed any required need analysis.

Although many schools verify all selected applicants, schools were not required to verify more
than 30 % of their total applicants prior to 7/23/92. A school choosing to verify only 30%
must document how it identified the 30% who were verified. The 30% limitation was
removed from statute by the Higher Education Amendments of 1992. The Department has
yet to issue guidance to institutions regarding any change to the verification limitation
requirements.
Please note: Schools participating in the Institutional Quality Assurance Program (IQAP) are
exempt from selected sections of the General Provisions regulations. IQAP schools should
not be cited for failure to complete verification of a student selected by the processor. A
basic premise of the IQA Program is to allow schools to design their own verification
programs, based on problem areas identified as critical at their schools.
34 CFR § 668.54 through 668.59 General Provisions, reissued 4/28/94
Minor changes to §§ 668.57 & 668.59 on 8/27/92
The Verification Guide
IRB Memo 91-27, 2/5/92

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16. INDEPENDENT STATUS (NOT DOCUMENTED; INCORRECT;

UNREASONABLE PROFESSIONAL JUDGEMENT)
GEN 2161

Check that documentation was collected to support the status of students who were classified
as independent for financial aid eligibility purposes because they reported they were not
claimed by their parents in two prior years, and they had resources in excess of $4000 in
each of the years specified on their applications. These criteria were in effect for the years
1987/88 through 1992/93. The "conditional" criteria requiring documentation were removed
from the definition of an independent student in the Higher Education Amendments of 1992.
If the student applied for financial aid in past years, check that documentation of income for
the dependency status issue matches information provided on prior applications, if applicable.
There is no specific definition of what is acceptable documentation for this issue. Therefore, a
parent's statement that the student was not claimed would suffice instead of copies of his or
her tax returns.
With regard to professional judgement, check that all adjustments are documented, and that
adjustments were made on a case-by-case basis. Note: An institution cannot retroactively
justify undocumented adjustments.

HEA, § 480(d)
Higher Education Amendments of 1986 (P.L. 99-498)
Higher Education Amendments of 1992 (P.L. 102-325)
DCL, GEN 86-35, November 1986
DCL, GEN 92-21, October 1992
Note: There are no regulations providing guidance on professional judgement.

17. MISSING/UNSIGNED FEDERAL PERKINS LOAN PROMISSORY NOTES

PERK 8200, 8210

Confirm that signed, complete, and valid promissory notes are on file for all sampled Federal
Perkins Loan recipients.
Discuss with appropriate school officials the system for having students sign promissory notes.
There should be a control to ensure funds are not disbursed until a note is signed (both the
note and schedule of advances). Some schools improperly make the disbursement first, and

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then have the student sign the note. Then, the school may fail to reverse the disbursement if
the student withdraws without signing the note, creating ineligible disbursements.
Certified true copies are acceptable in lieu of an original note, but regular photocopies are not
acceptable.
34 CFR §§ 674.16, 674.31, and 674 - Appendix A through D (Perkins Loan)

18. TIMECARDS FOR FWS STUDENTS MISSING/INVALID

FWS 1040, 1100

Verify that for each student paid under FWS there is a record showing the number of hours
he or she worked each day. The institution is liable for all federal funds disbursed for the
period if a timesheet is not maintained.
Check that timesheets are supported by a certification from the student's supervisor that the
student worked and earned the amount paid.
Collect the timesheets for a sample of the payroll periods in the year under review, and
cross-reference those with payroll records. If student class schedules are available, compare
them to students' work hours to ensure students did not work when they were supposed to
be in class.
34 CFR § 675.19 FWS

19. IMPROPER FEDERAL PELL GRANT CALCULATIONS/DISBURSEMENTS

PELL 4030, 4040, 4050, 4060 ,4080,4090,4130,4131,4140

An institution must determine a student's Federal Pell Grant eligibility, taking into account the
student's expected family contribution (Pell Grant Index prior to 1993/94), enrollment status,
budget, and award year/payment period duration.
Chapter Four of the 1992/93 Federal Student Financial Aid Handbook specifies the regulatory
requirements for calculating Federal Pell Grant eligibility prior to the Higher Education
Amendments of 1992 (Reauthorization).
Reauthorization changed most aspects of calculating a student's Federal Pell Grant eligibility.
Reauthorization eliminated the separate Pell Grant family contribution (PGI), and the specific

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Pell Grant cost of attendance (COA) requirements. Family contribution and COA
methodologies are now consistent for all Title IV programs.
Reauthorization also added a minimum duration requirement (30 weeks) to the academic
year definition. The new definition of an academic year is the most significant change in
calculating a student's Federal Pell Grant eligibility. The specific procedures for the eligibility
calculation are provided in DCL 93-33, which also represents Sections 2 and 3 of Chapter
Four of the 1993/94 Federal Student Financial Aid Handbook. Please pay special attention to
the "hold harmless" provision delineated in the second paragraph of DCL 93-33.
The reviewer must verify that the scheduled award and payment amount were properly
calculated. Schools often miscalculate these figures for award periods of less than a full
academic year.
Generally, a student must submit a valid Student Aid Report (SAR) or Electronic Student Aid
Report (ESAR) to establish eligibility for a Federal Pell Grant. The (E)SAR requirements are
discussed in the Student Aid Report Invalid focus item. If a student submits a valid (E)SAR later
in the award year, the institution may not make a retroactive disbursement for a prior term if
the student did not complete that term.
Other recommended review procedures are as follows:
" Carefully check award calculations for non-standard payment periods.
" Verify that the proper calculation was performed when an FAT from a
prior school shows the student received Federal Pell Grant funds at
another institution in the same award year.
" Check special consideration issues, especially for incarcerated students
and students receiving JTPA funding, as discussed in Section Three,
Chapter Four of the Federal Student Financial Aid Handbook.
" Review the elements used in constructing the COAs, especially the
maximum standard allowance, and child care allowance.

34 CFR §§ 690.3, 690.61, 690.62, 690.63, 690.75, and 690.83 Federal Pell Grant
Federal Student Financial Aid Handbook

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20. INVALID STUDENT AID REPORT

PELL 4090, 4180

Check that SARs and ESARs are valid, and compare with academic records to verify they
were received while the student was eligible and still enrolled.
ESARs must be signed to be valid (see 34 CFR 690.2 for definition of a valid SAR). Signature
requirements for ESARs were more restrictive prior to 12/28/91. The ESAR format may vary
slightly based on the software used. In some cases, the ESAR certification is a separate, pre-
printed document. When reviewing these separate certifications, the date the students
indicate they signed the certification might predate the ESAR processing date. It cannot be a
valid ESAR if the student signed the ESAR certification, and certified the correctness of the
ESAR data before the ESAR was produced!
Schools have been known to have students sign the ESAR certification when they fill out their
financial aid application, in order to save time later when the ESAR comes in. Ask students
and staff what documents are completed when students first apply (especially if many of the
ESAR statements are undated).
Please note that as of 7/23/92 a full-data paper roster from the Central Processing System
(CPS), or a formatted output document from a CPS-produced tape or cartridge could be
used in place of an (E)SAR to justify Federal Pell Grant payments to a student.
Also, check the comments on (E)SARs to ensure that student eligibility problems, such as
loan defaults, Selective Service registration problems, or problems identified through the new
Social Security number match have been resolved. Such problems, identified through
electronic matches with other databases, should now cause a "C" code to appear next to the
EFC on the (E)SAR. Some schools do not print the actual comments on the ESAR, but print
a list of codes in the body of the document. See Chapter Two, Appendix B of the Federal
Student Financial Aid Handbook for a translation of the codes.
34 CFR § 668.7 General Provisions (Social Security match requirements added to this
regulation in 3/16/94 Federal Register)
34 CFR §§ 690.13, 690.14, and 690.61 Federal Pell Grant
34 CFR § 690.2 Federal Pell Grant
HEA, Section 401(f)
The Higher Education Amendments of 1992 (P.L. 102-325)
The 1993/94 Federal Student Financial Aid Handbook
DCL, GEN 92-21, October 1992

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21. DISBURSEMENTS MADE PRIOR TO MIDPOINT

PELL 4040

Students must complete the payment period for which they have already been paid before
they can receive additional Federal Pell Grant disbursements. Some schools schedule
payments for the date students are expected to reach the midpoint, based on the original
class schedule. The school then might make the payment without verifying whether the
students actually completed the required hours. The student may then drop out without ever
completing the required number of clock or credit hours, having therefore received an
overpayment.
Compare the account records with attendance/academic records for all students in the
program review sample. Verify whether subsequent disbursements were made only after the
students completed the required number of clock or credit hours. For example, a school's
academic year is divided into two 450-hour payment periods. The school cannot make the
second disbursement until the student has completed the 450th, and started the 451st clock
hour.
An institution may consider excused absences when determining the number of clock hours
completed. Excused absences refer to missed classes that are not required to be made up,
and must be based on the school's documented policy. Excused absences may not be
considered if students must eventually complete all clock hours in their program of study (e.g.,
cosmetology programs with state requirements for actual hours completed).
A similar determination must be made when students are enrolled in a non-term program
measured in credit hours. Where an academic year is defined as 30 credit hours, the second
disbursement cannot be made until the completion of at least 15 credit hours. If a student has
completed 14 credit hours, and then begins the next segment of the program encompassing
6 credit hours, the payment cannot be made until the student has completed that segment.
Please note, this does not apply to FFEL disbursements. Strict adherence to payment periods
for FFEL is not required unless the student withdraws, at which time loan attribution applies.
For FSEOG and FWS, funds can be credited to students' accounts up to three weeks prior to
the beginning of classes for a payment period, as long as the student has registered for that
payment period. If the student never enrolls for the payment period, the funds must be
returned to the program.
FSEOG regulations allow the student's entire annual award to be disbursed at one time if the
award amount is less than $501.
34 CFR § 690.3 Federal Pell Grant
34 CFR § 690.75 Federal Pell Grant

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22. ENROLLMENT NOT VERIFIED BEFORE DISBURSEMENT

GEN 2130, FFEL 5100

An institution may award Title IV funds only to eligible students. Verify that student
enrollment status was confirmed before Title IV funds were disbursed.
Compare disbursement records with attendance records and academic transcripts to confirm
students' enrollment status at the time of disbursement. Check that disbursements have not
been made in the following circumstances:
" The student is not registered for classes.
" FWS payments made to a student for work performed after the student
withdrew from school.
" Federal Pell Grant payments are made after a student's last date of
attendance (LDA) without a valid (E)SAR or other official notification of
the student's EFC.
" FSEOG and Federal Perkins Loan disbursements are made after
students LDA (see DCL 94-13 for limited late disbursement criteria).
" FFEL disbursed after LDA without late disbursement approval (late
disbursement rules specified at 682.604(e) effective 2/19/93, based on
guaranty agency criteria prior to that).

The reviewer should also verify that the correct enrollment status was used in determining a
student's eligibility for Federal Pell Grant disbursements before a disbursement is made.
Schools are required to ensure that disbursements are based on a correct enrollment status,
and therefore must have a system to monitor changes prior to payment (different rules apply
if the enrollment status changes after payment has been made).
34 CFR § 668.7 General Provisions
34 CFR §§ 674.9 Federal Perkins Loan, 675.9 FWS and 676.9 FSEOG
34 CFR §§ 682.604 and 682.605 FFEL
34 CFR § 690.75 Federal Pell Grant
Higher Education Amendments of 1992, (P.L. 102-325), § 411

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23. NEED ANALYSIS IMPROPER/UNDOCUMENTED

GEN 2222, 2270, 2290

Verify that the need analysis performed to determine student eligibility was complete.
An institution must receive an official Expected Family Contribution (EFC) under the Federal
Methodology to document a student's Title IV eligibility, beginning with the 1993/94 award
year. The institution may recalculate an EFC without resubmitting the information for an
official recalculation, but the school is liable for any incorrect calculation.
Prior to 1993/94, under the Congressional Methodology, schools could award and disburse
funds having performed and documented the calculations themselves (PGI recalculations
could be performed by the school to demonstrate that award amounts would not change).
The Department approved various need analysis software packages that schools used to
determine EFCs and PGIs. The reviewer should be careful to recheck all manual calculations
performed by the school, and verify that software packages were approved by the
Department.
Other recommended review procedures are as follows:
" Verify the institution has received official EFCs beginning in 1993/94.
" Confirm EFCs and PGIs were properly calculated when need analysis
data was changed.
" Ensure the correct procedure was used to determine EFCs for other
than standard nine-month duration.

HEA, Sections 471 through 480, Part F

The EFC Formula, 1993/94
The Pell Grant Formula through 1992/93
The Congressional Methodology through 1992/93

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24. FFEL LOANS NOT PRO RATED FOR PROGRAMS < ONE YEAR
FFEL 5141

Ensure the loan amounts have been pro rated for programs of less than a full year. This
provision was effective on or after October 1, 1992. Regulations providing more specific
guidance will be issued at a later date.
For purposes of proration, the academic year is divided into thirds. The specific proration
amounts are described in DCL,GEN 92-21.
Until regulations are published, institutions are required to make a good faith effort to meet
the statutory requirements.
The Higher Education Amendments of 1992 (P.L. 102-325) § 428
DCL, GEN 92-21, 10/92
34 CFR § 682.604 FFEL

25. FFEL LOAN AMOUNTS INCORRECT FOR GRADE LEVEL

FFEL 5220

Verify that the academic level on the FFEL application corresponds to the school's
documented grade-level progression criteria. Some schools incorrectly certify grade levels on
the loan application based on the number of years the student has been present at the
institution, without consideration of the grade level progression criteria, or incorrectly report a
higher grade level based on past educational experience unrelated to the student's current
program.
Compare the academic record/transcript showing the number of credits or hours the student
had completed as of beginning of loan period with the loan period reported on the loan
application.
34 CFR § 682.603 FFEL

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 Program Review Guide

OTHER:

26. INELIGIBLE PROGRAM

GEN 2180, 2181

Verify that students are awarded Title IV funds only for courses that are part of an approved
program of study at the institution. (See Section 484(b) of HEA for exceptions). Determine
whether the school's state licensing or accrediting bodies require approval of all individual
programs of study, and that the required approval was received.
Many licensing bodies are very exacting in approving clock-hour programs. If the school
deviates from the specific conditions of the course approval, the program may not be eligible.
For example, if a course is approved and licensed as a 900 clock-hour program, but the
school only offered 850 hours of instruction as of the date the students graduated, that
program is not the same program approved by the licensing body. The licensing body should
be consulted to determine the effect of the deviation from program approval requirements.
The Higher Education Amendments of 1992 changed the eligibility definition for programs of
less than 600 clock hours at proprietary institutions of higher education and postsecondary
vocational institutions. Refer to 34 CFR 668.8(d) for details of revised program length
requirements.
Other recommended review procedures are as follows:
" Confirm with school officials that all programs of study are listed in the
catalog, and that they are all approved programs (schools sometimes
add new or pilot programs prior to getting approval).
" Ensure the program meets the minimum program length requirements
as specified in statute and regulation.
" Verify that ESL-only courses admit students who already possess pre-
existing work skills.
" Check that off-site laboratory work at a clock-hour school is faculty-
supervised.

34 CFR § 600.2 Institutional Eligibility 4/29/94 and 4/5/88

34 CFR § 668.8 General Provisions 4/29/94 and 12/1/87
HEA, Section 481(e)
Higher Education Amendments of 1992 (P.L. 102-325) § 495
DCL, GEN 92-21, October 1992
IRB Memo 93-6, 4/28/93
Federal Student Financial Aid Handbook, Chapter 3

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27. INELIGIBLE SCHOOL/BRANCH/LOCATION

GEN 2170, 2300, 2311

Examine all appropriate documents to verify the eligibility of the school and all its branches
and classroom locations. The type of documents will vary, but the school should have
documentation from accrediting and licensing bodies which describe the school and its
programs of study. Compare the licensing/accrediting documents with the institution's latest
eligibility letter from the Department.
The school should be able to demonstrate that its licensing and accrediting bodies have
approved all locations where instruction is being offered, if approval is required. Specific
criteria as to whether approval is required for all locations may vary based on the licensing
agency and accrediting body. In some cases, approval of a location is not required if
complete programs of study are not offered and only individual classes are taught. The
reviewer should learn accrediting and licensing body requirements. Title IV funds awarded
based on enrollment at ineligible locations are school liabilities.
Verify that the school has notified the Department when changes occur, such as a change of
ownership that results in a change in control, and a change in address.
The Higher Education Amendments of 1992 stipulated further conditions of a school's
eligibility to participate in the Title IV programs, such as limitations on the percentage of
incarcerated students or students without high school diplomas or the equivalent. Regulations
specifying these requirements were published on 4/29/94. Refer to 600.5(a)(8), 600.5(d),
and 600.7(a) of the 4/29/94 Federal Register for the most important changes.
34 CFR §§ 600.2, 600.4-7, 600.30-32 Institutional Eligibility
HEA, Section 481(a)
Higher Education Amendments of 1992 (P.L. 102-325)
DCL GEN 92-21, October 1992

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28. UNRESOLVED ITEMS FROM PAST REVIEWS/AUDITS

GEN 2240, 2330

Verify that all issues identified in past program reviews and audits have been completely
resolved by the institution. Previous reviews may include those conducted by guaranty
agencies or SPREs. In cases where prior audits or reviews are still open, confirm that the
school is pursuing resolution of the outstanding issues. This involves more than the school
taking the necessary action to resolve the specific problems from the reviews/audits. The
school should have also taken measures to prevent a reoccurrence of the identified problems.
Repeat findings of a systemic nature usually means that the school either ignored findings and
requirements of prior reviews and audits, or did not have the capability to make the required
corrections. These types of problems may demonstrate a lack of overall capability to
adequately administer the Title IV programs.
If an institution is part of a chain of schools with centralized administration, systemic problems
previously identified at other locations may be considered repeat violations if uncovered at
the school currently under review.
34 CFR § 668.14, reissued as 668.16 on 4/29/94

29. FISAP INCOME GRID NOT DOCUMENTED

CBA 0030

Review the FISAP applications to verify the figures reported by the institution for the number
of eligible aid applicants enrolled at least half-time during the applicable award year at Part III,
Section E. The FISAP uses eligible aid applicant information from the recently completed year
to determine whether the institution will receive any "fair share" funding in FSEOG, FWS, and
Perkins for the following year. For example, schools filed the FISAP application for the
1994/95 award year in October 1993, using eligible applicant data from the 1992/93 award
year.
Careful consideration should be given to the definitions and instructions that accompanied
each application concerning "eligible aid applicants" and "application." Please note that
students cannot be counted in the income grid figures if they do not have all information
needed to perform an approved needs analysis on file with the institution.
Request documentation supporting the dependency status and total family income for all
students included on the income grid for eligible aid applicants. Test the supporting

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documentation to confirm that students from the review sample are correctly reported.
Make sure all income used in the need analysis is included. Many schools have omitted
parents' untaxed income or all dependent students' income.
Next, test the documentation against what was reported on the income grid itself. Confirm
the number of students reported in some of the lower income categories. For example,
count the number of dependent students with family incomes between $6000 and $8999,
and verify that the number matches with what was reported at line 27 on the grid. If students
are incorrectly reported (especially when included in lower income categories than they
should be), the student body appears to look needier, and the school might get more fair
share funding than appropriate.
Additional points to note:
" Ensure the institution included all changes to students' income and
dependency status, including professional judgement.
" Students with prior bachelor degrees are considered graduate students
on the grid, even if they are in an undergraduate program.
" Check the figures reported in Section D (tuition and fees, and Pell Grant
disbursements) against fiscal records.
" Verify that no-show students have been excluded from the grid (schools
that use reports generated by a processor sometimes fail to screen out the
no-shows).
" Look over the documentation for cases where students are included
twice under different social security numbers.

34 CFR § 674.19 Federal Perkins Loan

34 CFR § 675.19 FWS
34 CFR § 676.19 FSEOG
IRB-S-88-3, IRB-91-4, and IRB-93-12.

Please note that errors in the income grid might change an institution's campus-based
allocation only if the institution received fair-share funding for the applicable award year.

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 Program Review Guide

30. PERKINS LOAN DUE DILIGENCE DEFICIENCIES

PERK 8090, 8140, 8180, 8230

(See Appendix I -- Perkins/NDSL Due Diligence Checklist)

The reviewer must verify whether an institution is correctly performing due diligence
procedures for its Perkins Loan borrowers.
Many institutions contract with outside agencies to service their Perkins Loan collection
efforts. In these cases, the reviewer should review a copy of the contract or other
documents that specify the services these agencies perform to verify they cover the regulatory
requirements. At a minimum, the institution itself should be providing the required exit
counseling for students who withdraw or graduate.
If school staff perform due diligence procedures themselves, the reviewer must discuss the
process with school officials to ensure all regulatory requirements are met. Trace some of
the students in the review sample who have entered repayment to see actual records and to
verify that the process works as designed. The school must be able to document its
compliance with all due diligence requirements.
Following are some of the deficiencies which may be discovered:
" inadequate exit counseling;
" inadequate contact with borrower during grace period;
" inadequate billing procedures, including late charges;
" inadequate address searches, skip-tracing;
" inadequate collection procedures/student not reported to credit
agencies, and loan not accelerated; and
" improper deferments granted.

34 CFR § 674.41 through 674.50 Perkins Loan

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 Program Review Guide

31. IMPROPER COMMISSIONED SALES REPRESENTATIVE PRACTICES

FFEL 5000

Under 34 CFR § 600.7, a commissioned sales representative at a school approved for

participation in the Title IV programs cannot provide prospective or enrolled students with
FFEL applications, names of lenders, or other information to encourage students to apply for
loans. Further, the Higher Education Amendments of 1992 prohibited any institution from
providing a commission, bonus or other incentive based on an employee's success in securing
enrollments, admissions, or financial aid.
The reviewer should interview a sales representative to verify compensation policies, and ask
what part they play in providing students with information about loan availability. This should
also be discussed with school administrators. Additionally, the reviewer should ask students
and other school personnel, especially financial aid staff, how loan information is provided.
The applicable regulations and statutes deal with an institution's eligibility to participate in the
programs. Violations reflect on the administrative capability of the institution, and could
possibly affect Title IV eligibility.

HEA, Section 487(a)(20)

The Higher Education Amendments of 1992 (P.L. 102-325)
DCL, GEN 92-21, October 1992
34 CFR § 600.7 Institutional Eligibility

32. CREDIT/CLOCK HOUR CONVERSION IMPROPER

(CODE TO BE ASSIGNED)

Verify the school has correctly determined the credit hour measurement of its programs for
purposes of determining students' Title IV eligibility. This applies to undergraduate vocational
educational programs* of less than two years in length, unless each course within the
program is fully acceptable for credit toward the school's degree programs.
The credit/clock hour conversion criteria are defined in the Federal Register published on
7/23/93; effective date: 7/1/94.
* See § 668.8(2)(iii),(iv), and (v) for definitions of vocational educational program.
34 CFR §§668.8 and 668.9 General Provisions 7/23/93

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 Program Review Guide

33. FFEL STUDENT STATUS CONFIRMATION REPORT NOT FILED/INACCURATE

FFEL 5210 AND 5260

Find out which office completes the student status confirmation reports--SSCRs (it is usually
Financial Aid or the Registrar), and ask to see at least a sample of the reports for the period
under review. IDS will show which guaranty agencies the school has utilized in the past.
Guaranty agencies are required to solicit confirmation of student enrollment status at least
twice a year (usually in the Fall and Spring), so there should be a minimum of two completed
confirmation rosters for each year at the school. Schools must keep copies of the reports
they submit. Usually, a guaranty agency can confirm whether a report was submitted.
Failure to submit reports or reporting inaccurate status information can signal that the school is
trying to conceal refund problems.
Other recommended review procedures are as follows:
" Check the status of each FFEL recipient in the program, review sample
against the confirmation rosters to verify whether the enrollment status
or status change date has been correctly reported.
" If the Financial Aid Office completes the confirmation reports, verify that
there is a system by which that office is provided up-to-date information
from the registrar about student status.

34 CFR §§ 682.605 and 682.610 FFEL

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 Program Review Guide

34. HIGH DEFAULT SCHOOL

FFEL 5030, 5040, 5130, 5131

(See Appendix H-- Default Review Checklist)

Check that schools with default rates in excess of 20% have implemented an approved
default management plan. The plan for schools with rates of 30% or higher must include all
elements of Appendix D of the General Provisions regulations from 6/5/89.
Other recommended review procedures are as follows:
" Check that delivery of loan funds for first-time borrowers is delayed.
" Confirm that loan entrance and exit counseling is expanded.^
" Verify that student retention, counseling, and placement procedures are
enhanced.^
" Ensure no FSLS loans are certified (30% and above).
" Check that the pro rata formula is included in refund procedures.^
" Verify that loan references are updated and additional references are
identified.^
" Determine whether schools with commissioned sales representatives
have compensation structure based on student retention.

^
These issues are optional parts of the default management plan for schools with rates
under than 30%.
Refer to IRB Memo 91-15 (5/14/91) for further guidance and requirements.
34 CFR §§ 668.15, and 668-Appendix D, General Provisions
34 CFR §§ 682.603, 682.604, and 682.606 FFEL
HEA §§ 485(b), 428(a)(b)

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