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The following is a presentation prepared for
NASFAAs 2007 Conference in Washington, DCJuly
8-11, 2007
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Developing Policies and Procedures

• NASFAA Conference
• July 2007
• Washington, DC

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Presenters

• Mona Lucas
• Dow Lohnes, PLLC
• Washington, DC
• Georgette DeVeres
• Claremont McKenna College
• Claremont, CA

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For Discussion

• Why have documented policies and procedures?
• Getting started
• Helpful hints for the development of policies and
  procedures
• Questions, comments

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• Why should institutions have documented polices
  and procedures?

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Why have documented policies and procedures?

• 1. Compliance with Department of Education
  laws and regulations
• 2. Good business reasons

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Why have documented polices and procedures?

• 3. To ensure consistent, organization wide,
  mutually agreed upon framework for Title IV
  administration.
• 4. To ensure institutional collaboration with
  regard to Title IV administration.

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• Reason 1
• Compliance with Department of
• Education Laws and Regulations

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20 United State Code1094(a)(3)

• The institution will establish andmaintain
  such administrative andfiscal procedures and
  records asmay be necessary to ensureproper and
  efficient administrationof funds received from
  theSecretary . . .

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34 Code of Federal Regulations 668.14

• By entering into a programparticipation
  agreement, aninstitution agrees that
• (4) It will establish and maintainsuch
  administrative and fiscalprocedures and records
  as may benecessary to ensure proper
  andefficient administration of fundsreceived
  from the Secretary.

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34 Code of Federal Regulations 668.16

• The secretary considers an institution to have
  that administrative capability if 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 the preparation and
  submission of reports to the secretary.

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334 Code of Federal Regulations668.53

• 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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34 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 required documentation within the
  specified time period.
• 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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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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Referrals under section 668.16 (g)(1)(2)

• Refers to the Office of Inspector Generalof the
  Department of Education forinvestigation any
  credible informationindicating
• Fraud
• Misrepresentation
• Conversion
• Breach of fiduciary responsibility

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34 Code of Federal Regulations 668.53

• (b) The institutions procedures must provide
  that it shall furnish, in a timely manner, to
  each applicant selected for verification a clear
  explanation of
• The documentation needed to satisfy the
  verification requirements
• 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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USDE The Blue Book

• Control activities usually involvetwo elements
• Establishing what should be done and
• Serving as a basis for the procedures to effect
  the policy

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USDE The Blue Book

• ED strongly recommends thatparticipating
  schools create policiesand procedures manuals
  thatcover the entirety of the schoolsparticipat
  ion in the Title IVprograms

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• Reason 2
• Good business reasons

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USDE The Blue Book

• To document how and when theschool establishes
  specific policesand procedures provide a
  singlelocation for the schools policiesand
  procedures

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USDE The Blue Book

• To serve as a valuable referenceduring a
  program review or auditand provide the basis
  fororientation and training of newemployees and
  refreshing the skillsof current employees

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• Reason 3
• To ensure consistent,organization wide,
  mutuallyagreed upon framework for TitleIV
  administration

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• Reason 4
• To ensure institutionalcollaboration with
  regard toTitle IV administration

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Getting started

• Establish what should bedone as well as how,
  when,and by whom

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NASFAA Resources

• Policies and Procedures TOOLS
• NASFAA Policies and Procedures ManualSample
  Template
• Policies and Procedures TOOLS RegulatoryResource
  s Guide
• Self Evaluation Guide for InstitutionalParticipa
  tion in Title IV and otherprograms

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Helpful hints for the development of policies and
procedures
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Financial Aid People

• Sharing
• Helpful
• Borrow
• Recognize it is not necessary to
• reinvent the wheel

Thank you Karen Price-Scott
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Reasons

• Motivation?
• Training
• New Staff / New Regs/ New Pres
• Compliance
• Define office structure/organization
• Clarify roles and responsibilities
• Consistency
• Improve Communications
• Documentation for Auditors and Program Reviewers

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Objectives

• Make work load manageable
• Divide and Distribute
• Develop a system to evaluate your office
• Improve your processes

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Development

• Getting Started
• Get Over it!!!
• Intimidation Fear of the task
• Size of the task
• Knowledge viewed as power
• Are all parties cooperating?
• What are we REALLY doing?
• Are tasks being completed as assigned?
• Discovery

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What is this thing?

• Policy Vs. Procedure
• Policy answers the questions
• What? and Why? - General
• What are the general issues or concerns?
• What should be the general response?
• Procedure answers the questions
• How do I implement and carryout the policy?
• What are the specific tasks?

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Policy Influences

• Internal
• Enrollment policies
• Academic Affairs
• Student Affairs
• Financial Services
• Board of Trustees
• External
• State Federal Laws

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Policies and Procedures

• Policy Development is the most important aspect
  of this process. This must be your first step as
  well.
• Dont try to decrease time spent in this area.
• We aid administrators have a tendency to
  multi-task, dividing our attention.
• Focus on the policies because they form the
  foundation for your procedures.

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How do I develop?

• Development Cycle
• Begin to create by asking
• Why is the Policy Procedure Manual necessary?
  Who needs it?
• Disregard no one!
• Be concerned about all affected
• Staff
• Students
• Other administrators

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Who Is Involved

• Financial Aid Director
• Financial Aid Staff
• Academic Affairs
• Bursar/Finance
• Housing
• Student Affairs
• Presidents Office
• Other

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How do I develop?

• Development Cycle
• Implementation/Execution
• Communication of policies
• Think about timing issues
• Think about political issues
• Evaluation and Assessment
• Is this PP effective and efficient?
• Is the PP valid and appropriate?
• Is it achieving its goal?

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Making Solid Choices

• Decide what works best for your institution.
• Size
• Type
• Organization
• Assign tasks
• Who does What, where when and How?
• Who works on the manual

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Making Solid Choices

• Involve as many people as possible.
• Large task
• Attachment gives a sense of ownership
• Creates cooperation
• All staff members have something to contribute.
• Assess their expertise

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Making Solid Choices

• Consider your institutions system
• Do you want paper or electronic format?
• Electronic is easier to update
• Paper is easier for Auditors
• Must ensure all are using the most update version
• Consider the users
• Keep it simple!!
• What do you want your manual to look like?

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Start Creating

• Document what your office staff is currently
  doing
• Suggestions
• Have office specialist document what they
  actually do on a daily basis.
• Skeleton of your manual should be informal.
• You can rewrite later dont worry about the final
  form now.

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Start Creating

• Review current Policy
• How can you improve?
• Let others outside of your office review.
• Decide if changes are needed
• Review current Procedures
• Assess what changes should be made.
• Both policy and procedure must go hand in hand.
• Say what you do and do what you say
• All exceptions to the rules must be included

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Resources to Use

• Old manuals
• Bulletins
• Office Memos
• E-Mails
• Colleagues
• State Agencies
• NASFAA Template

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Start Creating

• Take the old PP and incorporate it into your new
  manual.
• Your design should flow easily
• Choose wording carefully
• Remember your users
• Include all exceptions
• Format changes should be uniform

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Making Changes

• Update
• Updating never ends of course!!!
• Changes in regulations
• Staffing or office organization
• Institutional changes
• System upgrades
• Develop a calendar for regular updates

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Tips on Getting Started

• Make style and format decisions first!
• Dont recreate the wheel!
• Start small, keep it simple and easy!
• PLAN and PLAN some more!

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In summary . . .

• What are the optional pieces of our manuals?
• What are the required parts?

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Questions?

• CONTACT
• Mona Lucas
• Dow Lohnes, PLLC
• [phone]
• mlucas_at_dowlohnes.com
• Georgette DeVeres
• Clarmont McKenna College
• [phone]
• Georgette.deveres_at_clarmontmckenna.edu

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Special Thanks

• Karen Price-Scott, Pratt Institute
• Jane Pennington, Middle Tennessee School of
  Anesthesia
• David Haygood, Academic Management Services, Inc.

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