International Education Council 2015 Student Loan Conference and Workshop Department of Education: Overview from the Foreign Schools Team Marcia Fediw, Jamal Steward, Eric Miles, Thomas Killiam, and Michael Stein
Agenda Welcome and Introductions U.S. Department of Education (ED) Structure and Roles and Foreign School Participation Data SAIG Enrollment Procedures Compliance Audits Audited Financial Statements Method of Payment Recent Developments and Reminders 2
3 U.S. Department of Education
Federal Student Aid An OFFICE of the U.S. DEPARTMENT of EDUCATION Chief Operating Officer (James Runcie) appointed by President of the United States Policy Liaison Technology Finance Performance Management Customer Experience Risk Management Administrative Services Acquisitions Business Operations Federal Loan School Support Team Training Officers Program Compliance Multi-regional and Foreign School Participation Division 4
Foreign School Participation Data 399 Institutions 38 Countries 23,296 Students $1 Billion annually Foreign CDRs (Sector rates) FY2011 (3-yr): 3.8% FY2010 (3-yr): 4.6% FY2009 (3-yr): 7.3%
Institutional and Program Eligibility Primary Application Types: Initial Certification Recertification Reinstatement Eligibility Only Voluntary Withdrawal Updates Mergers Change in Ownership 6
Institutional and Program Eligibility Documents Required and Reviewed Legal Authorization & Degree Granting Authority Public, Private Non-Profit or For-Profit Academic Catalog, Programs & Locations, Partnerships School Policies: Admissions, Refund Policy, SAP, R2T4 Special requirements and documents for Medical, Veterinary, and Nursing Programs 7
Student Aid Internet Gateway (SAIG) SAIG allows authorized entities to exchange data electronically with the Department Organizations enroll individuals as Destination Point Administrators (DPAs) in the SAIG DPAs are assigned Destination Points (TG numbers/mailboxes) that receive and transmit data for various Title IV student aid program systems Each entity must designate one individual as its Primary DPA 8
SAIG Enrollment Procedures Required Electronic Processes [34 CFR 668.16(o)] To be in compliance a school must: Enroll in SAIG Use FAA Access or its SAIG mailbox to exchange FAFSA or ISIR data with the Department s Central Processing System (CPS) Use the Common Origination and Disbursement (COD) website or its SAIG mailbox to exchange award and disbursement data for Direct Loans, and Submit to the National Student Loan Data System (NSLDS) student enrollment records, and NSLDS transfer student monitoring records 9
Batch and Web Services There are different batch and Web services available to EDapproved foreign institutions: Central Processing System (CPS) Free Application for Federal Student Aid (FAFSA) data, including corrections, can be entered and submitted over the SAIG National Student Loan Data System (NSLDS) NSLDS is a national database that collects and maintains individual student data for all Title IV, HEA student loan borrowers and grant recipients Common Origination and Disbursement (COD) System COD enables Direct Loan origination, disbursement, and other required reporting information to be exchanged electronically through the SAIG 10
FSA Software FSA provides three software products to facilitate electronic data exchange: EDconnect A Windows-based file transfer protocol program that enables users to send and receive FSA information electronically EDExpress A financial aid management software package schools use to manage Title IV student financial aid application data, package awards, and exchange origination and disbursement data with COD SAIG Web Portal Used by DPAs to manage mailboxes, view data transmissions history, restore files, and change SAIG passwords 11
SAIG Enrollment Form Foreign schools must complete a paper SAIG enrollment form, which is available on the Foreign Schools Information Page 12
SAIG Enrollment Form Enrollment actions available: Designating a Primary DPA With All Services (Required) Designating a Non-Primary DPA All Online Services (COD, FAA Access to CPS, NSLDS) COD Online and NSLDS Online COD Online Only NSLDS Online Only Adding/Modifying Services for an Existing DPA Updating/Changing an Existing DPA* Designating an Institutional Third-Party Servicer DPA Note: *Currently, to update/change an existing DPA, e-mail FSA.foreign.schools.team@ed.gov for further guidance. 13
SAIG Enrollment Form Enrollment forms are broken down into four Steps: Step One Collects information about your school and the DPA you want to enroll. Information Needed to Complete Step One: Item 1: TG Number/Mailbox of Primary DPA or DPA who s information is being changed Item 2: Name of Organization Item 3: Demographic details of designated DPA. 14
SAIG Enrollment Form Step Two Adds the appropriate services for the school and the DPA identified in Step One. Information Needed to Complete Step Two: Items 5 through 14: Eight-digit OPEID number Federal School Code number Direct Loan School Code number Name of Organization 15
SAIG Enrollment Form Step Three Collects the required agreements and signature pages from the Primary DPA (and if applicable, the Non-Primary identified in Step One). Information Needed to Complete Step Three: The signature of the Primary DPA (and if applicable, the Non- Primary DPA identified in Step One). 16
SAIG Enrollment Form Step Four Collects the required authorization from the school s President/CEO or Designee to process the enrollment information for the DPA identified in Step One. Information Needed to Complete Step Four: The signature of the school s President/CEO or Designee 17
Two Factor Authentication All authorized users are required to enter two forms of authentication to access FSA systems via the Internet: The first factor is something that an individual knows his or her User ID and password The second factor is something that an individual has a token that generates a One-Time Password (OTP) If an institution needs additional TFA tokens, the Primary DPA should send an e-mail to TFA_Communications@ed.gov, and include the school name and OPE ID on the correspondence 18
Active Confirmation Active confirmation is the process of confirming access needs of enrolled staff and deleting access that is no longer required If active confirmation is not completed within the prescribed timeframe, all services and access assigned to the organization and individuals could be permanently removed Every organization enrolled for a SAIG account must review and validate its assigned TG numbers annually 19
Common Mistakes and Useful Links Common Mistakes to Avoid Submitting photocopies of SAIG enrollment form signature pages. Not designating a Non-Primary DPA to serve as a backup to the Primary DPA. Password sharing and the sharing of system access. Useful Links for DPAs FAA Access to CPS Online https://faaaccess.ed.gov NSLDS Online https://www.nsldsfap.ed.gov COD https://cod.ed.gov/cod/loginpage FSA Software https://www.fsadownload.ed.gov/ 20
Financial Statement Reporting Title IV Funds Received During Fiscal Year $10,000,000 + $9,999,999 - $3,000,000 Home Country GAAP Required annually, in English Required annually, in English Public & Private Non-Profit U.S. GAAP & GAGAS Required annually, in English Required annually, in English, may omit for 2 consecutive years after U.S. GAAP & GAGAS audit For-Profit Home Country GAAP & U.S. GAAP & GAGAS Required annually, in English $2,999,999 Required annually, - $500,000 in English Not Required Less than $500,000 Not required, except during Not Required Initial Certification NOTE: If a foreign institution has a financial condition or financial reporting problem, the Secretary may require the foreign institution to submit audited financial statements in a manner specified by the Secretary. 21
Financial Analysis Assessment of institutional financial viability and health using financial ratios that are weighted & combined into a single composite score of financial responsibility Composite scores range from negative 1.0 through positive 3.0. Less than 1.5 is a failing score, but some schools may qualify for zone if score is at least 1.0 22
Other considerations Financial Analysis Past performance (including timely submission of acceptable compliance audits and audited financial statements) Going concern statements Qualified, Adverse, Disclaimed Auditor Opinions Failure to repay Title IV, HEA program liabilities owed to ED 23
Financial Analysis In general, No news is good news For Currently Participating Institutions, if a problem: Zone Alternative (Score 1.0 1.4, not exceed 3 consecutive years), Zone reporting requirements, Restricted Method of Payment HCM1 & audit attestation. Provisional Certification 10% LOC (minimum), Provisional certification, Zone reporting requirements, Restricted Method of Payment HCM1 or HCM2, audit attestation. Letter of Credit only 50% LOC (minimum), can be considered financially responsible. No Zone reporting, no Method of Payment restrictions, no audit attestation. New / Reinstatement Institutions Letter of Credit only as above. 24
Title IV Funds Received During Most Recent Fiscal Year $500,000 + Less than $500,000 Compliance Audits Public & Private Non-Profit Standard Compliance Audit Submit Annually Alternative Compliance Audit Submit Annually Alternative Compliance Audit may cover up to 3 fiscal years IF Receive < $500,000 in most recent FY period Fully Certified Has submitted timely acceptable compliance audits for two consecutive years and has no history of late submissions since then Notified by ED For-Profit Standard Compliance Audit Submit Annually NOTE: If a foreign institution has an administrative capability or compliance reporting problem, the Secretary may require the compliance audit to be performed at a higher level of engagement, and may require a compliance audit to be submitted annually. 25
Compliance Audit Reporting Conducted by Certified Independent Auditor Due no later than six months after the end of the institution s fiscal year Alternative Compliance Audit Institution received less than $500,000 in U.S. Dollars in Title IV, HEA Program Funds Standard Compliance Audit Institution received more than $500,000 in U.S. Dollars in Title IV, HEA Program Funds 26
Compliance Audit Reporting A Reminder Notice is e-mailed 60 days prior to the audit due date A Reminder Notice is e-mailed 30 days prior to the audit due date A Missing Compliance Audit letter is e-mailed if the audit has not been submitted and accepted by the due date A Citation Letter is mailed, via courier, and electronic copies are e-mailed to the institution Once cited, the institution will be placed on Heightened Cash Monitoring, required to submit a Letter of Credit on a U.S. Bank for 5 years, and be Provisionally certified 27
Compliance Audit Reporting Purpose of Compliance Audit Reporting Ensure an institution is taking corrective action to administer Title IV programs correctly, and Ensure recipients have received all Title IV, HEA programs funds they are entitled to receive, and Ensure ED is reimbursed for the cost of any errors in program administration caused by the institution 28
Compliance Audit Resolution Compliance Audit Resolution is a process that normally occurs after an institution submits an acceptable compliance audit report Compliance audits ensure that Title IV, HEA funds have been expended correctly, but auditors may identify weaknesses and errors in Title IV, HEA program administration Schools are expected to implement corrective action for each finding of non-compliance to prevent recurrence Compliance audit reports containing more serious findings are flagged for additional resolution by the Multi-Regional and Foreign School Participation Division 29
Compliance Audit Resolution Final Audit Determination Letter completes compliance audit resolution process Letter may assess a monetary liability to recover unauthorized costs incurred by ED or borrower due to incorrect administration of Title IV, HEA programs. Liabilities are not punitive and are not fines School may appeal liabilities, if any, if it has evidence to indicate that the auditor s finding was incorrect or if ED s determination was incorrect Letter provides payment instruction and appeal instruction, if liabilities asserted 30
Top Ten # of Foreign School Audit Findings FY 2014 Grouping Top Ten Deficiencies Top Ten Foreign School Audit Findings by School and Number of Findings for Federal Fiscal Year 2014 Number of Percent Finding Code Description Findings STUDENT CONFIRMATION REPORT FILED LATE/NOT FILED/NOT RETAINED FOR FIVE YEARS/INACCURATE 145 23.4% STUDENT STATUS - INACCURATE/UNTIMELY REPORTING 76 12.3% STUDENT CREDIT BALANCE DEFICIENCIES 68 11.0% ENTRANCE/EXIT COUNSELING DEFICIENCIES 44 7.1% RETURN OF TITLE IV FUNDS MADE LATE 43 6.9% ATTENDANCE RECORDS MISSING/POLICY INADEQUATE 32 5.2% INFORMATION IN STUDENT FILES MISSING/INCONSISTENT 30 4.8% REPEAT FINDING - FAILURE TO TAKE CORRECTIVE ACTION 19 3.1% INCORRECT CALCULATION OF EXPECTED FAMILY CONTRIBUTION AND/OR COST OF ATTENDANCE 18 2.9% ENROLLMENT STATUS NOT VERIFIED BEFORE DISBURSEMENT 15 2.4% Total Top Ten Deficiencies 490 79.0% Other Deficiencies 130 21.0% Total 2014 Deficiencies 620 100.0% 31
Method of Payment Refers to the way an institution receives Title IV, HEA program funds Types: Advanced Payment Heightened Cash Monitoring 1 (HCM1) Heightened Cash Monitoring 2 (HCM2) Reimbursement HCM1, HCM2 and Reimbursement used to mitigate risk and protect the federal interest in Title IV, HEA funds 32
Method of Payment Advanced Payment Institution draws down Title IV funds prior to disbursement Drawdown may not exceed actual or expected disbursement amount HCM1 Institution must make disbursements prior to drawing down funds Audit requirements Additional documentation may be required 33
Method of Payment HCM2 Institution must make disbursements prior to drawing down funds Institution submits a request for reimbursement (Form 270) Required documentation must show student(s) were eligible and received Title, IV funds Department initiates drawdown for school Reimbursement Differs from HCM2 according to internal review procedures 34
Recent Developments and Reminders New for Foreign Schools Foreign Schools Handbook Foreign School Update ID: FS-2015-01 National Student Clearinghouse DCL ID: GEN-17-07 New Direct Loan Fees for FY 2015 and FY 2016 New for Students FSA ID FSA Conference Las Vegas, Nevada Tuesday, December 1 Friday, December 4, 2015 35
Contacting Us E-mail: FSA.Foreign.Schools.Team@ed.gov Phone: 202-377-3168 Fax: 202-377-3486 Mail: U.S. Department of Education Multi-regional and Foreign School Participation Division Union Center Plaza, 7 th Floor 830 First Street, NE Washington DC, 20202 (20002 if overnight/courier) 36
37 QUESTIONS?