ADHERENCE TO POLICIES AND PROCEDURES
Introduction
The ethical practices component of the administrative review is designed to determine if policies
are developed in accordance with the legal obligations applicable to the institution and its
governing board, if the policies are effectively communicated to constituents, and if the policies
are administered in a manner that maintains the public's trust in the integrity of the institution.
This standard also examines the district's compliance with the consumer disclosure
requirements, the standards of fmancial responsibility, and the administrative capability
standards established for postsecondary vocational institutions participating in the federal
student financial assistance programs. These standards and requirements are noted in the Federal
Student Aid Handbook and The Blue Book, which are published by the United States
Department of Education (USDE) to be used as guidelines for compliance.
All aspects of the district's operations should be conducted in an ethical and fair manner, with
particular attention to those factors that affect students, employees, and patrons of the district.
An annual review of policies, directives, and practices should be conducted to incorporate
changes necessitated by new or revised laws and regulations and to identify any existing policy
or practice that may unfairly or negatively impact the district's students, employees, partners, or
the taxpayers who support the district.
Commendations or Strengths
After review of the financial aid files for the 2006-07 award year, it is clear the financial aid
officers were careful to extend the payment period when the student would drop from full time to
part time. The use of Professional Judgment was used prudently and it was noted that the current
financial aid officer at El Reno, who will be leaving in December, has been working with her
replacement for several weeks prior to her departure. This will assist the El Reno location with a
smoother transition once the current director leaves.
Specific Recommendations for Improvement
This administrative review standard was met.
General Suggestions for Improvement
In establishing whether the institution was following its policies and procedures, a cursory
review of student files from the 2006-07 award year was conducted on November 6, 2007, at the
Chickasha campus and November 7, 2007, at the EI Reno campus. The file review indicated
areas of noncompliance with Title IV regulations. These areas, although noncompliant, did not
adversely affect the administrative process. As a disclaimer, only one day was allotted to the file
review at each campus as part of the evaluation process; therefore, the areas of noncompliance
listed are not to be deemed as all-inclusive and the school is not limited to the areas noted for
correction. The financial aid director at each location was provided a list of student files thatwere to be reviewed and each director was made aware of the concerns raised as the review
progressed.
Monitoring of Satisfactory Academic Progress (SAP) on El Reno Campus
The El Reno campus does not monitor its SAP standards appropriately for all full-time students. It appears the school was monitoring full-time students in the morning and afternoon sections on a separate basis. That is, a student who was doing poorly in the morning section but alright in the afternoon section would be viewed as satisfactory for the afternoon and be disbursed a portion of the Pell rather than a full disbursement because of his attendance in the morning. The school cannot separate a student’s morning and afternoon attendance to determine which time would keep the student eligible of Pell if the student had excessive absences. The student either meets the SAP requirements as a whole based on their enrollment and grades or does not meet the requirement.
When the instructor determines the student’s SAP, the GAP (grade point average) should be indicated on the sheet that is returned to the financial aid office.
SAP Clarification
The SAP policy needs to be clarified to distinguish between scholastic probation, fmancial aid
probation, and fmancial aid suspension due to the student's failure to maintain SAP. Typically,
scholastic probation is indicative of the student's grades in association with the registrar's office
that may affect the student's eligibility to receive financial aid depending on the school's policy.
If the school does not wish to distribute aid to students while on scholastic or fmancial aid
probation, it is recommended the school consider indicating in its consumer information that
students on scholastic probation will be suspended from fmancial aid or placed on fmancial aid
suspension until eligibility has been reestablished. Note: The school does have the discretion to
disburse aid to students who are placed on a fmancial aid probation status if it so chooses. If the
institution chose to do this, information should be updated in the school's consumer information
and student handbook to reflect this policy.
Authorization to Credit Pell for Books and Supplies
Currently, the school has the student authorize the crediting of books and supplies out of Pell
monies on the same page as the award letter. The student's authorization permission should be
separate from the student's award letter.
Return to Title IV Not Performed
It was noted that students who withdrew and were fmancial aid recipients did not have a return
to Title N calculation performed. It is suggested the fmancial aid officer review all students
who withdrew during the 2006-07 award year and then do a return calculation for each. Any
otherwise eligible student who began attendance at an institution and was disbursed or could
have been disbursed Title IV grant or loan funds prior to a withdrawal has earned a portion of
those Title IV funds. The fmancial aid officer should familiarize herself with GEN-00-24 and its
revision issued as GEN-04-03 when doing the calculations.
Student Accounting Ledger Sheet – Chickasha
When the evaluation team asked for a student account ledger sheet for selected students at the
Chickasha campus, the aid director could not provide a clear listing of what had been charged and what had been credited to the student's account due to system parameters in that location's system. The evaluation team ultimately ended up with a Student Fee Roster Sheet and used that
in conjunction with the Pell Grant Request Sheet to determine the amounts disbursed. It is recommended the school consider using an accounting system that would meet its needs for the various offices, including financial aid, in providing a good audit trail for its students. The evaluators did not have the difficulty they had at Chickasha when the El Reno files were reviewed as that location was under a different accounting system.
Student Information Delays
One student was missing information to complete her financial aid folder but did submit the information after her ·first payment period had passed. She was not paid for the first payment period even though, technically, she could have been paid as the school had nothing in' its policies prohibiting a disbursement. It now appears the student was "under disbursed." If the school desires to refrain from making a Pell disbursement to an otherwise eligible student due to a missed deadline, it must state the deadlines and consequences for missing those deadlines in its consumer information.
New Financial Aid Officer Support
The new financial aid officer, who will take over at E1 Reno sometime in December, is strongly encouraged to attend the workshops and conferences offered within the state related to the federal and state student financial assistance programs. Participating in these events provides the opportunity to network with other financial aid officers as well as stay updated on changes in program guidelines and regulations. This participation also provides a broader understanding of the various financial aid programs available to eligible postsecondary students. It is recommended school administration officials be supportive of her requests to attend these training sessions whenever possible.
RESPONSE TO ADHERENCE TO POLICIES AND PROCEDURES
RECOMMENDATIONS:
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