BeautyLink - Volume 8, Issue 2 - (Page 28)

AND THEN THERE'S COMPLIANCE Keeping the Little Things in Perspective IN TODAY'S WORLD it is easy to become complacent It is important that a school employs policies and procedures to ensure the anticipated disbursement dates are updated in the Common Origination and Disbursement System (COD) to reflect the actual disbursement dates for the loan. with the advantages of geo-positioning systems (GPS) to determine our route and distance to destination. It was not that long ago, that before one embarked for a destination, a map was purchased to identify and "map-out" the best route. Use of the maps served much the function as current GPS systems available in our vehicles and phones. But, there was a distinct advantage of the maps that is not as readily available in modern technology. The map provided a quick "visual" of where you were headed before embarking. Such a visual allowed you to keep the overall picture in mind when you began the nuanced maneuvering on the route. You were able to recall that point on the map that would be the final destination and have a "feel" for whether you were heading in the right direction, although there were many specific stops and turns that may be encountered. Likewise, in financial aid administration there are a number of specific policies that are required to ensure the school stays on course for the overall compliance destination required by the U.S. Department of Education's (ED) broad compliance map. We will touch on three items that are often overlooked in the portfolio of compliance requirements. Anticipated vs. Actual Disbursement Dates It is not uncommon that anticipated disbursement dates a school indicates when originating a Federal Direct Loan do not materialize to be the actual dates for the funds the borrower receives. Therefore, it is important that a school employs policies and procedures to ensure the anticipated disbursement dates are updated in the Common Origination and Disbursement System (COD) to reflect the actual disbursement dates for the loan. Direct Loan Quality Assurance Process (DLQAP) SHERWIN HIBBETS 28 ED requires schools that participate in the Federal Direct Loan Program, to have a quality assurance (QA) process in place.1 [See 34 CFR 685.300(b)(9).] An adequate DL QA process should include, as a minimum, procedures to cover these components: * Regulatory compliance in reporting loan records, disbursements, and adjustments to disbursements to the COD System, to include that such transactions are done within applicable timeframes, etc. * Accuracy in disbursements made for the correct amount to the correct student. * Monthly reconciliation and award year close-outs that are performed timely. | B EAU TYLINK | FO CUSING ON F INANC IAL S | 2016 * Compliance with general regulatory provisions pertaining to the DL program, e.g., separation of duties, etc. Additionally, once a school has developed and implemented a DL QAP, it must have as part of its process a regular review of the DL QAP, which must occur at least biennially. Drug and Alcohol Abuse Prevention Program Most schools are aware of the need to have drug-free campuses, etc. However, many forget the requirement to have a drug and alcohol abuse prevention program (DAAPP). Schools acknowledge this requirement - and that they have such a program in operation - when they sign their Title IV program participation agreement (PPA). Not only are schools required to have such a program, it is mandated that it be reviewed for effectiveness, and that sanctions are being carried out, at least once every two years. A record of the outcome of the review must be maintained on file for auditors and ED program reviewers. Reporting Results of Verification for V4 and V5 Selected Applicants This requirement is relatively new. 2015-2016 is only the second year it has been in place. Yet, left ignored, it will morph into a potentially large issue in an annual compliance audit or ED program review. It is important that schools understand that the Identity Verification Results reporting is in addition to the traditional reporting of verification statuses to COD. The 2014-2015 expansion 2 of verification requirements to include identity and high school completion status has as a basic goal to ensure that students receiving Federal Student Aid are legitimate, and otherwise eligible, students appropriately enrolled at the school. Schools are required to report the results of students in verification tracking groups V4 and V5 by the earlier of 120 days after the student's last date of enrollment for the award year, or September 26, 2016, for 2015-2016, or within 60 days of the school's first request to the student to submit the required V4 or V5 identity and high school completion documentation.3 We have noted three small, but key points on the journey to Title IV compliance. Keeping these items in view as you picture the overall ED compliance map, will assist in ensuring you have a safe journey with ED on the trek. 1 ED's Electronic Announcement of November 13, 2013 2 ED's Electronic Announcement of November 13, 2013 3 Federal Register/Vol. 80, No. 47/Wednesday, March 11, 2015/ Notices

Table of Contents for the Digital Edition of BeautyLink - Volume 8, Issue 2

Message From the AACS President and CEA Chair
Workings of Washington
CEA Gets Amped Up in Vegas
The Bottom Line: What You Should Discuss With Your CP
Revelations About the Department of Education
Do’s and Don’ts of Shopping for Suppliers — It Isn’t Retail Therapy!
And Then There’s Compliance
Students and Money Management
Voices From the Classroom
Superstar Graduate
Beauty Changes Lives
People & Places
New Products & Services
Associate Member Profiles: Financial Services
New School Members
Upcoming 2016 Events
Index to Advertisers

BeautyLink - Volume 8, Issue 2