Common Review Initiative The Primary Choice

1
Common Review Initiative The Primary Choice

• Diana Oglesby,
• NSLP
• Wanda Hall,
• Edfinancial Services

2
CRI Leadership

• Current biennium
• Chair Char Feist, SLND
• Chair-elect Diana Oglesby, NSLP
• Secretary Kelvin Deloch, LOSFA
• Treasurer Bernie Girata, AES/PHEAA

3
CRI Concept

• All guarantors have combined resources to conduct
  a single review of large lenders and servicers
• These CRI reviews meet the requirements of 34 CFR
  682.410(c)(1) for each CRI-participating guarantor

4
Commitment to Quality

• Attribute testing
• Statistically valid sampling
• Continual updating of work papers
• Six reviewers instead of one or two
• Consistent documentation
• Reviewer training
• Quality review process
• Experienced lead reviewers

5
Reducing RedundancyCalendar Years 2006-2007

• CRI program reviews have benefited lenders with
  fewer guarantor reviews
• 14 CRI reviews completed
• Individually would have resulted in 175 reviews
• Net reduction of 161 reviews

6
Reducing RedundancyCalendar Years 2008-2009

• CRI program reviews continue to benefit lenders
• 19 reviews
• Individually would have resulted in 241 reviews
• Net reduction of 222 reviews

7
Integrity with Efficiency

• Thoroughness that ensures integrity
• Brings together reviewers from various guarantors
• Enhanced by knowledge of the review teams
• Reduces the number of reviews while remaining
  robust

8
Reminder

• CRI public site
• Current review schedule
• Participating guarantors
• CRI Council members
• Review guides
• Prior presentations
• Located on NCHELP website
• http//www.nchelp.org/pages/page.cfm?id24.

9
Review preparation

• First contact approximately 75 days prior to
  review
• Engagement letter and questionnaire sent 60 days
  prior to review
• Data file for sample
• Sample chosen will be sent to lender/servicer
• Lender/servicer may see workbooks prior to review

10
Review Completion

• After review end, lender/servicer given three
  weeks to respond to initial findings
• Review report to be sent to lender/servicer
  within 60 days of end of response period
• Lender/servicer given 30 days to respond to
  report
• Extensions to time frames may be granted
  depending on circumstances

11
Significant Events

• Effective January 1, 2008 the Common Review
  Initiative (CRI) was granted permanency by the
  Department of Education.
• As of October, 2008, CRI has conducted 35
  lender/servicer reviews since its inception.

12
Significant Events

• Annual reviewer training session
• October 2008 meeting in Austin,Texas
• Approximately 50 attendees
• Training scheduled for each October

13
Significant Events

• Review Testing Expanded
• LaRS
• Consolidation Rebate Fees
• Inducements (to be implemented soon)
• E-signature process maintenance (to be
  implemented soon)

14
Significant Events

• ED does not attend CRI on-site reviews
• Workbooks, reports and work papers made available
  to ED after review
• ED liaison participates in monthly Council
  conference calls

15
Significant Events

• Secure website
• Facilitate review team preparation
• Secure file-sharing among reviewers
• Secure storage of CRI review work papers
• Uploading review information to ED
• New feature
• Eliminates sending review data via postal mail or
  email

16
Significant Events

• CRI IT Committee
• Working toward secure solutions
• Encrypted laptops, flash drives and email
• Procedures if password compromised or
  laptop/flash drive stolen
• Procedures for terminating access upon personnel
  change
• Standardized file format and transmission process
  to collect lender/servicer population data

17
Questions?
18
Lender/Servicer Perspective
19
A TOP Priority

• Communication
• Cooperation
• Clarity

20
Preparation

• In advance
• Review CRI Program Review Guide (both entities)
• New guide available?
• Receipt of Engagement Letter
• Read thoroughly and make sure you clearly
  understand before pulling any reports
• Ask questions if not!

21
Preparation

• Data selection
• How presented?
• Staff
• Primary contact(s)
• System
• Provide access?

22
Preparation

• Documents
• Paper vs electronic
• To what extent?
• Reviewer working environment
• Ample space and proximity to staff

23
Data Selection

• Discuss system options/limitations
• How much access needed
• How pass and share data? Secured FTP?
• Understand the requested criteria
• Common terms not always common
• Understand the reasoning behind the requested
  criteria
• Avoids misunderstanding and looking for a needle
  in haystack
• Provide requested data for sample selection well
  in advance
• Provides opportunity to fine-tune if needed

24
Staff Preparation

• Questionnaire
• Experience
• Frustrating for all parties if staff unable to
  answer questions
• Delays process
• Availability
• Frustrating for CRI team if have to constantly
  wait
• Entrance Conference
• Sets the tone
• Exit Conference
• Opportunity to make sure all on the same page

25
Technical

• Discuss system needs
• To what extent will want to use
• Assist reviewer in understanding proprietary
  system utilization
• Proprietary systems are not bad
• Assist reviewer in extracting information from
  the system
• Back to having experienced staff available

26
Documents

• Discuss document needs
• Paper vs electronic
• Discuss document layout / design
• Special reports
• Easy to understand
• Good to agree upon layout and content in advance
• Have all documents ready for reviewer upon
  arrival
• All placed in one location by CRI Chapter

27
Exit Conference

• Appropriate attendees
• General discussion of process
• Discussion of collected information
• Discussion of additional needs and expectations

28
Post Review

• Continue communication with CRI lead
• Be expeditious, clear and concise in
  communication
• Need a call to better communicate Do it!
• Do not hesitate to plead a case
• You know your system
• Know the rules and how they apply
• Retain copies of all pertinent documents

29
Questions?