Beauty Link - Volume 4, Issue 1 - (Page 26)
HOW TO PREPARE AND WHAT TO EXPECT
BY DENNIS CARIELLO AND PATRICIA EDELSON
One topic that frequently comes up among school owners is the prospect of a program
review team from the Department descending on their school. Often the feeling is that there is no way to prepare. This article will give you some insight into the process so you will know what to expect and can be prepared if you’re subject to a program review.
efore You Are Ever Contacted
As a school owner, you should be prepared for a program review long before you get notiﬁed of a pending review. Create a culture of compliance at your school and show that it is important to you. Make sure someone on your staff is dedicated to compliance efforts and working to identify and remedy compliance problems. Have written policies and keep them up-to-date. Shop your school—ﬁ nd out what a prospective student hears from their ﬁ rst call to your school through the enrollment process. Take advantage of the many training sessions the Department offers both online and at various locations to ensure your staff is fully trained and up-to-date on the latest in Title IV regulations. Keep your records organized. Aside from promoting a culture of compliance and having access to information that conﬁ rms whether the school is compliant, having all the material in a place where it is accessible for your review will make the process much easier on you. There is nothing more problematic (or embarrassing) than a school with records that are out of order in a box somewhere. If a school’s records are a mess, there’s a good chance that compliance will be lacking—and the Department is likely to have that mindset if they ever come onsite.
How Did I Get So Lucky?
No one wants a program review and it is easy to understand why. Even if your school is run perfectly, an onsite review represents time away from managing your school and educating students. While you never know if it is “your time” for a program review— the Department may select a school for a review because it has never had one. There are some things you can look at to help you (1) guess whether you are due for one and (2) prepare for one by focusing on key topics. The key is looking at your school the way the Department would. The Department uses various risk factors that help in determining which schools are selected for review. While risk factors can change from year to year, and are usually driven by current
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“hot topics,” there are a number of them that remain consistent. For example, when a school has a high number of cases of professional judgment, including dependency overrides, it may indicate something is amiss. Of course, that shouldn’t prevent you from making professional judgments that are valid—just make sure you document what you’ve done and can back up your judgments. Other indicators include: • School populations with high percentages of students without a high school diploma; • Large numbers of students with “unchanged ages” from one year to the next; • A signiﬁcant increase in Title IV funds received; • Student complaints; and • Referrals from various sources, including an ofﬁce within the Department, current or former employees, state or accrediting agencies, the media or your annual independent audit. These “red ﬂags” could drive what the reviewer looks for and determine the course of the review. Thus, if you have a sense of what brought the reviewer to your door in the ﬁ rst place, you can better prepare yourself with the answers you need. This year, in light of the new misrepresentation rule and the new consumer disclosures required as part of the gainful employment rule, the Department is likely to focus on your website and other promotional materials. In addition to consumer disclosures, we expect the Department will also focus on issues surrounding incentive compensation, your method of evaluating high school diplomas and how you identify students who unofﬁcially stop attending. If your programs are eligible for clock to credit hour conversion, make sure the conversion has been calculated correctly. Of course it shouldn’t come as a surprise that gainful employment issues will be a focus item as well.
The Program Review: Before the Onsite
Once a program review is scheduled, working with the reviewer is in your best interest. You share a common goal; you both want any unscrupulous school owners uncovered and their access to
Table of Contents for the Digital Edition of Beauty Link - Volume 4, Issue 1
Message from the AACS President and CEA Chair
Workings of Washington
A Trade Show Workout
Building a Bulletproof School
The Art of Edutainment
Beyond the Fluff
And Then There's Compliance
Beauty Changes Lives
Spring Operations Conference Info
AACS Is Connecting Members
Associate Member Profiles: Collections
People & Places
New Products & Services
New School Members
Upcoming 2012 Events
Index to Advertisers
Beauty Link - Volume 4, Issue 1
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