Consulting Services • Published 11/28/2016 Overcoming Regulatory Challenges: Helping One University Hit the Books

Challenge

As anyone in higher education knows, sometimes outside factors can make it difficult for institutions to focus on doing what they do best: providing an opportunity for a quality education and positive student experience. A recent client of ours discovered these challenges firsthand when a Federal Title IV Program Review by the U.S. Department of Education overwhelmed administrators and left them seeking outside help. Our client, a higher education school system, underwent a Program Review of their Title IV participation and the initial Program Review Report identified nearly 20 findings to be addressed. In order to resolve these issues, the client would have to conduct a complete file review and reconstruction of the past two award years for every student attending four of their campuses who were awarded Title IV aid. Furthermore, the client was expected to complete this review within three short months. The school reached out to the P&N team with the following project goals:

• Complete file review and reconstruction for all students awarded Title IV aid at select campuses over the past two award years
• Meet the file review deadline of three months
• Relieve the regulatory review workload in order for their staff to continue to focus on their daily obligations
• Become better prepared for future regulatory reviews

P&N’s approach is to work with institutions to determine the best course of action that meets their needs, rather than relying solely on cookie cutter out-of-the box solutions.

Drew Blanchard 
Associate Director, P&N Consulting

Approach

With years of experience in higher education, our team is aware that issues like limited resources, tight timelines, and lack of adequate processes often challenge schools when it comes to meeting regulatory requirements. In this scenario, our client had no existing processes to thoroughly handle the file review process and its staff and resource levels could not reasonably accommodate a three-month deadline. Therefore, the first step we took was to create a customized workflow and schedule for the client. P&N’s team worked with the Department to adjust deadlines, created work management tools to streamline the file review process, and developed a detailed plan of action to keep the project on track. We also helped manage the project and assisted the client onsite and remotely.

When it comes to regulatory reviews, accuracy and consistency are two key challenges facing institutions. P&N coordinated their response with both the Department and the school’s legal counsel in order to ensure that the response was in line with regulations and expectations to avoid any future surprises. This included having specific findings thrown out and others reduced, in addition to taking advantage of any formulas for reducing liability that were applicable. In this scenario, the Department had identified flaws in the client’s Title IV processes and needed assurance that the client had fully resolved all issues in the file review with accuracy and consistency. By carefully coordinating with staff members, implementing a detailed workflow that covered all requirements, and creating a custom calculation component used to review and process student files, P&N allowed the client to present its resolution to the Department with confidence.  The resolution was reviewed and accepted by the Department without rebuttal.

Not only did our team help our client solve their immediate problem by efficiently and accurately reviewing all student financial aid files in a short amount of time, but over time we also helped them streamline and refine their financial aid processes for the long term. For example, we helped limit the school’s regulatory risk in the future by reviewing their Cost of Attendance Budgets and their Title IV Policies and Procedures Manuals. Working with the P&N team, our client implemented an ongoing voluntary Title IV compliance review process conducted before the school’s annual Title IV audits.

Results

By working with our team to respond to a challenging regulatory review, our client was able to fully overcome their immediate obstacles, better prepare them for the future, and ultimately dedicate more resources to doing what they do best: providing an opportunity for a quality education to their students. Some of the results we helped achieve include:

• Complete review and reconstruction of thousands of financial aid transactions within the Program Review deadline
• Successful resolution of the Department‘s requirements in review of many Title IV processes (e.g. Verification, Pell Grants, Direct Loans, SAP / Appeals, R2T4, etc.)
• Assistance with return of the reduced Program Review liabilities to the Department, to the students, and to the lenders, where applicable
• Implementation of a voluntary annual compliance review process to limit risk going forward
• Establishment of a mutually beneficial long-term relationship that continues to this day