POLICIES

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POLICIES PROCEDURES MANUAL

• Presented to CASFAA Proprietary Certification
  Workshop
• December 2, 2006
• Ontario, CA
• By
• ADDALOU DAVIS
• Interim Associate Director of Financial Aid,
  Sacramento State

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POLICIES PROCEDURES MANUAL

• DISCUSSION OUTLINE
• Why should institutions have a policies and
  Procedures Manual?
• How to develop the manual
• Questions

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POLICIES PROCEDURES MANUAL

• Why should institutions have a policies and
  procedures manual?
• 1. Compliance with Department of Education
  Regulations
• 2. Good Business practice
• 3. Consistent framework for administration of aid
• 4. institutional collaboration for administration
  of aid

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POLICIES PROCEDURES MANUAL

• REASON 1 Compliance with Department of
  Education Regulations
• 20 United States Code, section 1094(a)(3)
• An institution will establish and maintain such
  administrative and fiscal procedures and records
  as may be necessary to ensure proper and
  efficient administration of funds received from
  the Secretary

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POLICIES PROCEDURES MANUAL

• Reason 2 Good Business Practice

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POLICIES PROCEDURES MANUAL

• 34 Code of Federal Regulaions, Section 668.14
• By entering into a program participation
  agreement, an institution agrees that..
• (4)it will establish and maintain such
  administrative and fiscal procedures and records
  as may be necessary to ensure proper and
  efficient administration of funds received from
  the Secretary.

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POLICIES PROCEDURES MANUAL

• 34 Code of Federal Regulations 668.14 (continued)
• The secretary considers an institution to have
  that administrative capability of the
  institution
• (4) has written procedures for or written
  information indicating the responsibilities of
  the various offices with respect to the approval
  of disbursements and delivery of Title IV, HEA
  program, assistance and preparation and
  submission of reports to the Secretary.

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POLICIES PROCEDURES MANUAL

• 34 Code of Federal Regulations 668.53
• (a) An institution shall establish and use
  written policies and procedures for verifying
  information contained in a student aid
  application in accordance with the provisions of
  this subpart.

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POLICIES PROCEDURES MANUAL

• Code of Federal Regulations 668.53 (continued)
• These policies and procedures must include
• The time period within which an applicant shall
  provide the documentation
• The consequences of an applicants failure to
  provide requirement documentation within the
  specified time period

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POLICIES PROCEDURES MANUAL

• 34 Code of Federal Regulations 668.53 (continued)
• The method by which the institution notifies an
  applicant of the results of verification if, as a
  result of verification, applicants EFC changes
  and results in a change in the applicants award
  or loan

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POLICIES PROCEDURES MANUAL

• 34 Code of Federal Regulations 668.53 (continued)
• (4) The procedures the institution requires an
  applicant to follow to correct application
  information determined to be in error
• (5) The procedures for making referrals under
  668.16

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POLICIES PROCEDURES MANUAL

• Code of Federal Regulations 668.16 (g) (1) (2)
• Refers to the Office of Inspector General of the
  Department of Education for investigation any
  credible information indicating
• Fraud
• Misrepresentation
• Conversion
• Breadth of fiduciary responsibility

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POLICIES PROCEDURES MANUAL

• 34 Code of Federal Regulations 668.53 (continued)
• (b) The institutions procedures must provide
  that it shall furnish, in a timely manner, to
  each applicant selected for verification a clear
  explanation of
• 1. The documentation needed to satisfy the
  verification requirements.
• 2. The applicants responsibilities with
  respect to the verification of application
  information, including the deadlines for
  completing any actions required under this
  subpart and consequences of failing to complete
  any required action.

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POLICIES PROCEDURES MANUAL

• US Department of Education The Blue Book
• Control activities usually involve 2 elements
• Establishing what should be done, and
• Serving as a basis for the procedures to effect
  the policy.

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POLICIES PROCEDURES MANUAL

• US Department of Education The Blue Book
  (continued)
• The Education Department (ED) strongly recommends
  that participating schools create policies and
  procedures manuals that cover the entirety of the
  schools participation in the Title IV programs.

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POLICIES PROCEDURES MANUAL

• Reason 2 Good Business Practice
• US Dept. of Education The Blue Book
• To document how and when the school establishes
  specific policies and procedures
• Provide a single location for the schools
  policies and procedures

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POLICIES PROCEDURES MANUAL

• Reason 2 Good Business Practice (continued)
• US Dept. of Education The Blue Book
• To serve as a valuable reference during a program
  review or audit
• Provide the basis for orientation and training of
  new employees
• Refreshing the skills of current employees

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POLICIES PROCEDURES MANUAL

• Reason 3 Consistent framework for
  administration of aid
• Provide guidance for exercise of professional
  judgment
• Provide procedure for reviewing an application
  verification packaging changing awards
  required documentation

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POLICIES PROCEDURES MANUAL

• Reason 3 Consistent framework for
  administration of aid (continued)
• Establish what needs to be done
• Establish how it should be done
• Establish by whom it should be done
• Establish when it should be done

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POLICIES PROCEDURES MANUAL

• Reason 3 Consistent framework for
  administration of aid (continued)
• NASFAA resources (MUST BE A MEMBER OF NASFAA)
• Policies and Procedures Tools
• Provides sample template for a PPM
• Provides a regulatory resources guide

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POLICIES PROCEDURES MANUAL

• Reason 4 institutional collaboration for
  administration of aid
• Financial Aid People are
• Sharing
• Helpful
• Borrow from each other
• Recognize it isnt necessary to reinvent the
  wheel
• Borrowed from Karen Price-Scott, Pratt
  InstituteThank you!!

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POLICIES PROCEDURES MANUAL

• Reason 4 institutional collaboration for
  administration of aid (continued)
• Reasons
• Motivation
• Training (new staff, new regs, new president)
• Compliance
• Defines office structure/organization
• Clarifies roles and responsibilities
• Ensures consistency
• Improves communication
• Provides documentation for Audits and Program
  Reviews

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POLICIES PROCEDURES MANUAL

• Reason 4 institutional collaboration for
  administration of aid (continued)
• Objectives
• Makes the workload more manageable
• Divide, Distribute, Delegate
• Helps develop a system to evaluate the
  effectiveness of the office
• Improves processes

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POLICIES PROCEDURES MANUAL

• Development of a PPM
• Getting started
• Get over it!!! Just do it!!!
• Intimidation and fear of the task
• Shear size of it
• Finding time
• Knowledge viewed as power by some who dont want
  to share!
• All parties MUST share!!!!!

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POLICIES PROCEDURES MANUAL

• Development of a PPM (continued)
• What are we really doing?
• Are tasks being completed as assigned?
• Are we being efficient?
• Are we using time well?
• Can be a wonderful source of finding more
  productivity with less effort!

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POLICIES PROCEDURES MANUAL

• Development of a PPM (continued)
• What is a policy vs. a procedure?
• Policies answer what and why
• May arise from a specific issue or a general
  issue
• Helps determine a specific, consistent response
• Procedures answer how and who
• Implementation of specific tasks
• Assignment of the task

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POLICIES PROCEDURES MANUAL

• Development of a PPM (continued)
• Influences
• Internal
• Admissions Records
• Academic Affairs
• Student Affairs
• Financial Services
• President, Provost

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POLICIES PROCEDURES MANUAL

• Development of a PPM (continued)
• External influences
• State and Federal Laws and regulations
• Personnel laws and regulations
• Civil Rights
• Affirmative Action
• Americans With Disabilities

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POLICIES PROCEDURES MANUAL

• Development of a PPM (continued)
• Begin with written policies
• Focus on policies because they form the
  foundation for the procedures.
• Dont try to get by with just going straight to
  procedures
• Stay on task! This is not the time to multi-task

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POLICIES PROCEDURES MANUAL

• Development of a PPM (continued)
• Who should be included in development?
• Director, all staff (dont forget the MVPs (the
  front-counter staff)
• Admissions, Records, Academic Affairs, Student
  Financial Services, Housing, Student Affairs,
  Presidents Office, Development Office, Athletic
  Office

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POLICIES PROCEDURES MANUAL

• Development of a PPM (continued)
• Include timing issues
• Include staffing issues
• Include regulatory issues
• Include political issues
• Include known institutional policies

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POLICIES PROCEDURES MANUAL

• Development of a PPM (continued)
• Evaluation and Assessment
• Is it an effective and efficient tool for the
  office?
• Is it concise and clearly written?
• Is it valid and appropriate?
• Does it achieve its goal?

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POLICIES PROCEDURES MANUAL

• Development of a PPM (continued)
• Making good choices
• What is best for your institution?
• Size, type, organization
• Assign tasks
• Have each manager describe what their division
  does (how and why!!)
• Have procedures reviewed by staff who actually do
  the work
• Involve as many people as possible
• Involve ALL staff

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POLICIES PROCEDURES MANUAL

• Development of a PPM (continued)
• Electronic or paper format?
• Must consider end-user
• Electronic easier to update
• Paper easier for auditors
• Ensure everyone uses most updated version
• KEEP IT SIMPLE!!!!!

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POLICIES PROCEDURES MANUAL

• Development of a PPM (continued)
• What should your PPM look like?
• Outline/Table of Contents
• Paragraphs
• Sections
• If electronic, can you control/click to get to
  your answer?

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POLICIES PROCEDURES MANUAL

• Development of a PPM (continued)
• Start creating
• Have everyone write one procedure that they do on
  a daily basis
• Ask everyone to think of one policy they use on a
  daily basis
• Your skeleton should be very informal
• You will re-write later, so dont worry about
  final form at the beginning!

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POLICIES PROCEDURES MANUAL

• Resources to Use
• Old manuals (if available)
• Notes from staff meetings
• Bulletins or emails
• Office and institutional memos
• Ask a colleague!
• Conference handouts
• NASFAA template

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POLICIES PROCEDURES MANUAL

• Living Document!
• Remember a PPM is a living document
• May be changed on a daily, weekly, monthly
  (sometimes hourly) basis
• Be sure to update at least once a year
• Develop a calendar for when to do the annual
  update
• Determine the staff person who will be
  responsible for updating

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POLICIES PROCEDURES MANUAL

• Have fun!
• Be creative
• Have a PPM party day
• Give everyone a piece of the action
• Have someone who doesnt know anything about
  financial aid read it
• Style and format at the end
• JUST DO IT!!!!!

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POLICIES PROCEDURES MANUAL

• QUESTIONS
• and
• COMMENTS