Title IV Compliance: Policies & Procedures

In the ever-changing would of Title IV compliance, it’s hard to live with the, “set it and forget it” mentality. However, many fall victim to the downfalls of their own preparation. You may have spent all that time writing your policies and procedures years ago, so there is really no need to look at those on a yearly basis…right? Unfortunately, these do need to be reviewed annually and updated accordingly. There is no time like the present to start this process and to make sure all your bases are covered.

The Department of Education knows this is an arduous task and has created A Guide to Creating a Policies & Procedures Manual.

This is an excellent tool for policies and procedures and should be utilized if you are unsure if your current checks and balances is ticking all the right boxes. Another good tool to use is the most current Title IV Audit Guide (2016), which has the procedures used to test these requirements.

Here are some of the required procedures being tested during the audit process:

• Review, evaluate, and document the school’s procedures for updating student status for Pell and loan recipients.
• Confirm if the school has written policies and procedures for verifying student applications and that they meet the requirements of 34 C.F.R. § 668.53.
• Ascertain if the school’s LOA policy complied with 34 C.F.R. § 668.22(d)(3)(iii).
• Review and evaluate the school’s procedures for making disbursements.
• Review the school’s policy and procedures for identifying credit balances in student accounts (schools on reimbursement or cash monitoring payment methods cannot maintain credit balances).
• Review and evaluate the school’s procedures for:
  • Identifying students who either were or should have been withdrawn, dropped, terminated, or who are on a leave of absence.
  • Assuring returns of Title IV funds are paid in the proper sequence.
  • Paying the returns of Title IV funds within due dates.
• Obtain and review the school’s written procedures or written information regarding the approval, disbursement, and delivery of Title IV funds, and the preparation and submission of reports to ED. Compare those written procedures or written information to how activities are actually performed based on the conduct of audit work pursuant to this Guide. Report any differences between the written procedures and information and actual performance.
• Determine if the school has implemented a Direct Loan quality assurance system.
• Obtain and review the school’s satisfactory academic progress policy in effect during the audit. Ascertain if the policy conforms to the requirements of 34 C.F.R. § 668.16(e) and 668.34.
• For each campus, obtain and inspect the annual security report. Ascertain if each report contains all required crime statistics and policy statements in 34 C.F.R § 668.46(b).

There is never a better time than now to review your policies and procedures to make sure they are sufficient in nature. For example, if your campus crime document is one to two pages long, chances are it is not sufficient. There are a lot of requirements to fulfill, which typically fill up at least 15-20 pages. Be aware that The Clery Act is an area the Department of Education is closely reviewing right now. They are issuing fines, which can be hefty at times. 

The best way to avoid problems tomorrow is to address them today. Take the time to review your policies and procedures and make sure they are inclusive and up-to-date. A little bit of footwork now can pay dividends down the road!