Program Review Guide

Appendix N. Sample Program Review Report

June 6, 1994
Mr. I.V. League, President
No Particular College
1 Main Street
Anytown, USA 00000 PRCN
Dear Mr. League:
On May 15-19, 1994, Ms. I. M. Perceptive, Program Officer,
conducted a program review of the Title IV federal student
financial assistance programs administered at your
institution. The findings of that review are presented in the
enclosed report.
This report contains findings regarding the school's
administration of the Title IV student financial assistance
programs. Following are some of the report's findings of
noncompliance: 1) Independent Student Status Not Documented,
and 2) Satisfactory Academic Progress Standards Not Monitored.
Note to Reviewer: Additional comments in this section may be
appropriate if very serious problems are found in the program
review. Refer to IRB Procedures Memorandum 91-28 for
guidance.
Findings of non-compliance are referenced to the applicable
statutes and regulations and specify the action required to
comply with these statutes and regulations. Please review and
provide a full response to the findings indicated in this
report, detailing the corrective actions taken by the
institution. Your response should be sent directly to this
office, to the attention of Ms. Perceptive, within 30 days
unless otherwise noted.
Note to Reviewer: New language will be incorporated into this
letter explaining the consequences to the institution for
failure to respond, or failure to provide a complete response.
I would like to express my appreciation for the courtesy and
cooperation extended during the review. If you have any
questions concerning this report, please call Ms. Perceptive
at (555) 867-5309.
Sincerely,

Chief, Section I
Institutional Review Branch
Field Operations Service/IPOS
Student Financial Assistance Programs
Enclosure

cc: Ms. E. Sar, Financial Aid Administrator

July 1, 1994 Page N-1

 Program Review Guide

Sample Program Review Report (continued)

PROGRAM REVIEW REPORT

Please note, a table of contents is not required as part

of the report format, however it may be helpful in
particularly lengthy reports.
No Particular College
1 Main Street
Washington, D.C. 20202
(555) 222-2222
TABLE OF CONTENTS
Page
A. BACKGROUND . . . . . . . . . . . . . . . . . . . . . 3
B. SCOPE OF REVIEW . . . . . . . . . . . . . . . . . . 3
C. FINDINGS REQUIRING INSTITUTIONAL ACTION . . . . . . 4
1. INDEPENDENT STUDENT STATUS NOT PROPERLY
DOCUMENTED . . . . . . . . . . . . . . . . . . 4
2. SATISFACTORY ACADEMIC PROGRESS STANDARDS NOT
MONITORED . . . . . . . . . . . . . . . . . . . 6
3. INCONSISTENT INFORMATION FOUND . . . . . . . . 7
4. FSEOG MATCHING REQUIREMENT NOT MET 8
D. TECHNICAL ASSISTANCE . . . . . . . . . . . . . . . . 8
RECOMMENDATION . . . . . . . . . . . . . . . . . . . 8

July 1, 1994 Page N-2

 Program Review Guide

Sample Program Review Report (continued)

INSTITUTIONAL REVIEW DATA SHEET

No Particular College
1 Main Street
Washington, D.C. 20202
(555) 222-2222

DATES OF REVIEW: May 15-19, 1994

AWARD YEARS REVIEWED: 1991-92 1992-93 1993-94

STUDENT SAMPLE SIZE: 10 10 10

OPE ID #: 1000000X

EIN #: 0000000000005A

TYPE AND CONTROL: Proprietary/ 1 Year-Less Than

2 Years

ACCREDITATION: Accrediting Commission for

Schools Used in Examples

REVIEWING ED OFFICIAL(S): Ms. I.M. Perceptive

SFA PROGRAM PARTICIPATION (as of [insert appropriate date] ):

1991-92 1992-93 1993-94

$500,000 $600,000 $400,000

Federal Pell Grant Program
Federal Family Education Loan
(FFEL) Programs:
600,000 575,000 500,000 Federal Stafford Loan
4,000 -0- -0- Federal SLS (FSLS)
-0- 30,000 35,000 Federal PLUS (FPLUS)
4,000 50,000 45,000 Federal Perkins Loan Program
9,000 -0- -0- Federal Supplemental
Educational Opportunity
Grant (FSEOG) Program
Source: Institutional Records (or other source as appropriate)

DEFAULT RATE: (1989) 22.0%

(1990) 40.1%
(1991) 30.1%

Source: U.S. Dept. of Education's Institutional Data System

July 1, 1994 Page N-3

 Program Review Guide

Sample Program Review Report (continued)

No Particular College - Program Review Report - page 2

METHOD OF FUNDING: Advance Payment

INSTITUTIONAL OFFICIALS CONTACTED:

Mr. I.V. League, President

Ms. E. Sar, Financial Aid Administrator
Mr. C.P. Accountant, Business Office Manager
Ms. A.T. Bee, Director of Admissions

July 1, 1994 Page N-4

 Program Review Guide

Sample Program Review Report (continued)

No Particular College - Program Review Report - page 3

INTRODUCTION
A. BACKGROUND
No Particular College opened in January 1969, at its current
location. Branch campuses were opened in Baltimore MD in
1974, and Richmond VA in 1979. The institution is co-owned by
Mr. I.V. League, and Mr. Strictly Anonymous.
No Particular College offers training leading to a degree or
certificate in the following fields:
Computer Science
Accounting
Medical Technician
Paralegal Specialist
No Particular College is accredited by the Accrediting
Commission for Schools Used in Examples. School records
indicate a current enrollment of approximately 265 students,
with approximately 80% of the student body currently receiving
financial aid. The institution participates in the Federal
Pell Grant, FFEL, FSEOG, and Federal Perkins Loan programs.
B. SCOPE OF REVIEW
A program review was conducted during the week of May 15-19,
1994, to examine the administration of the Title IV SFA
programs. The focus of the review was to determine No
Particular College's compliance with the statutes and federal
regulations as they pertain to the institution's
administration of Title IV programs. The review consisted of,
but was not limited to, an examination of No Particular
College's policies and procedures regarding institutional and
student eligibility, individual student financial aid and
academic files, attendance records, student account ledgers,
and fiscal records. In addition, interviews were conducted
with students and appropriate institutional personnel.
A statistically valid sample was identified for review from
the 1991/92, 1992-93, and 1993-94 award years. From this
sample, the reviewer selected a random sample of student
files. The student files were reviewed in detail, including
academic, admissions, financial aid and fiscal records. The
attached Appendix A lists the names and social security
numbers of the students whose files were examined during the
program review. Students are referenced throughout this
report by the numbers noted in Appendix A.

July 1, 1994 Page N-5

 Program Review Guide

Sample Program Review Report (continued)

No Particular College - Program Review Report - page 4

During the visit, some areas of noncompliance were noted.
Findings of noncompliance are referenced to the applicable
statutes and regulations and specify the actions to be taken
by the institution to bring operations of the financial aid
programs into compliance with the statutes and regulations.
Although the review was thorough, it cannot be assumed to be
all-inclusive. The absence of statements in the report
concerning the institution's specific practices and procedures
must not be construed as acceptance, approval, or endorsement
of those specific practices and procedures. Furthermore, it
does not relieve No Particular College of its obligation to
comply with all of the statutory or regulatory provisions
governing the Title IV programs.

C. FINDINGS AND REQUIREMENTS

1. INDEPENDENT STUDENT STATUS NOT DOCUMENTED
FINDING: The institution failed to properly document three
students' independent status for the 1991/92 award year.
Student #6 was processed as an independent student based on
his assertions that he was not claimed as a tax exemption by
his parents in 1989 and 1990, and that he had resources in
excess of $4000 in both 1988 and 1989. However, No Particular
College did not collect documentation to support these
assertions, as required in statute. The same deficiency was
found in the files of students #7 and 9.
By failing to properly establish students' eligibility for
Title IV, HEA funds, No Particular College may have deprived
other needy students of funds, caused Title IV funds to be
misdirected to ineligible students, and received Title IV
funds for which it was not eligible.
REFERENCES: Higher Education Amendments of 1986 (P.L. 99-498)
Section 480(d), enacted 10/17/86, effective 7/01/87
"Dear Colleague" Letter GEN 86-35, 11/86
REQUIREMENT: The Financial Aid Administrator (FAA)
acknowledged that new staff members were hired during the
1991/92 award year, and that they had not been adequately
trained about documentation requirements for independent
students. The FAA stated that proper training was provided
before 1992/93 awards were processed, and the reviewers
observed that documentation was collected for all students in
1992/93.

July 1, 1994 Page N-6

 Program Review Guide

Sample Program Review Report (continued)

No Particular College - Program Review Report - page 5

Therefore, due to the systemic nature of this finding for the
1991/92 award year, No Particular College must determine the
extent of improper Title IV awards made to students in that
year within 60 days of receipt of this letter.
To confirm the dependency status for all 1991/92 aid
recipients, No Particular College has two options. It may
either review the files of all Title IV recipients claiming
independent status for the award year, or it may review all
the students in the statistically valid sample claiming
independence (see Appendix B for listing). In either case,
the institution may collect documentation to ascertain
students' correct status. If No Particular College detemrines
that an incorrect status was used in determining the student's
award, it must recalculate the award and will be liable for
all Title IV funds disbursed in excess of the students'
revised need. If the school is unable to collect appropriate
data to support a claim of independence, and cannot perform
dependent student calculations, it will be held liable for all
Title IV funds disbursed to those students for the 1991/92
award year.
The institution must provide a report of all liabilities in a
spreadsheet format with the following column headings:
Student's Name
Student's Social Security Number
Liability Amount (by Title IV Program)
Please note, all FFEL liabilities must reflect the total
amount of funds approved for and disbursed to the student,
including origination and guarantee fees. This amount will be
greater than the amount received at the school.
If the school chose to review the statistically valid sample,
this office will extrapolate the liabilities over the universe
of aid recipients for the 1991/92 award year. The school will
be notified of the total liability amount in the Final Program
Review Determination Letter. This letter will also contain
instructions for payment of these liabilities.

July 1, 1994 Page N-7

 Program Review Guide

Sample Program Review Report (continued)

No Particular College - Program Review Report - page 6

2. SATISFACTORY ACADEMIC PROGRESS STANDARDS NOT MONITORED
FINDING: The institution did not consistently apply its
satisfactory academic progress (SAP) policy standards to all
of its students.
The reviewers found that Title IV funds were disbursed to
students #1 and 19 for the Fall 1993 semester even though
their cumulative grade point averages were below the required
standard (3.0) at the end of the Spring 1993 semester. There
was no documentation that the institution made any exceptions
to the SAP policy based on special circumstances.
By failing to adequately or consistently monitor SAP
standards, the institution may be disbursing ineligible Title
IV aid to students who have ceased to be making SAP; by
failing to properly establish students' eligibility for Title
IV, HEA funds, No Particular College may have deprived other
needy students of funds, caused Title IV funds to be
misdirected to ineligible students, and received Title IV for
which it was not eligible.
REFERENCES: 34 CFR 668.7(c), General Provisions, 12/1/87
34 CFR 668.14(e), General Provisions, 12/1/87
reissued as
34 CFR 668.16(e), General Provisions, 4/29/94
REQUIREMENT: Federal regulations require an institution to
consistently apply its SAP standards for measuring whether a
student is maintaining satisfactory academic progress before
disbursing Title IV funds. Unless the institution can provide
documentation that the students were meeting SAP requirements
for the Fall 1993 semester, all Title IV funds disbursed to
students #1 and 19 for that semester are institutional
liabilities.
In response to this finding, No Particular College must either
provide documentation substantiating the students'
eligibility, or confirm the liability amounts. The
institution must also provide written assurances that SAP
standards will be consistently applied and monitored for all
students in the future. Instructions for the payment of any
liability will be provided in the Final Program Review
Determination letter.

July 1, 1994 Page N-8

 Program Review Guide

Sample Program Review Report (continued)

No Particular College - Program Review Report - page 7

3. INCONSISTENT INFORMATION IN STUDENT FILE
FINDING: The review of Student #8's file revealed
inconsistent information. The 1992/93 student aid report
(SAR) indicates that the student had $0 income in 1991, but
the student noted on her 1991/92 financial aid application
that she had worked from June though December 1991.
The financial aid office maintains separate files of students'
application information separately for each award year. The
Financial Aid Administrator confirmed that staff usually
reviews only a student's current year's file, and would
therefore not identify a discrepancy from a previous year's
file, as noted for student #8.
No Particular College's failure to resolve inconsistent
information could result in the improper use of Title IV, HEA
funds and deprive eligible, needy students of assistance.
REFERENCES: 34 CFR 668.14(f), General Provisions, 12/1/87
reissued as
34 CFR 668.16(f), General Provisions, 4/29/94
34 CFR 690.77(b), Federal Pell Grant, 10/14/87
REQUIREMENT: An institution must identify and resolve all
discrepant information before disbursing Title IV funds.
In response to this finding, No Particular College must
contact student #8 and resolve the discrepancy. If the
student's income for 1991 changes as a result, a revised need
analysis must be performed. The institution is liable for any
Title IV funds disbursed in excess of the student's revised
need. The institution is liable for all Title IV funds
disbursed in 1992/93 (except FPLUS or FSLS funds) if it is
unable to contact the student and resolve the discrepant
information.
No Particular College must also apprise this office of
procedures it has developed and implemented to ensure that
inconsistent information is identified and resolved prior to
the disbursement of Title IV funds.
Instructions for the payment of any liability will be provided
in the Final Program Review Determination letter.

July 1, 1994 Page N-9

 Program Review Guide

Sample Program Review Report (continued)

No Particular College - Program Review Report - page 8

4. FSEOG MATCHING FUNDS REQUIREMENT NOT MET
FINDING: The institution did not provide matching funds in a
timely manner for the FSEOG disbursed for the 1991-92 award
year. The institution matched the funds drawn and disbursed
throughout 1991-92 after the end of the award year, on July 9,
1992. By not making the institutional match in a timely
manner, the institution reduced the funds available, therefore
depriving eligible students of need-based aid.
REFERENCE: 34 CFR 676.21 Federal SEOG Program, 12/1/87
REQUIREMENT: Beginning with the 1989/90 award year,
institutions were required to match the federal share of FSEOG
funds with the institutional contribution at the time the
federal funds are disbursed.
The institution must provide written assurances that it has
implemented procedures to ensure it provides the institutional
match of FSEOG federal funds in a timely manner. A recurring
finding in the future could result in an informal fine being
proposed.
D. TECHNICAL ASSISTANCE
RECOMMENDATION
Discussions with the Admissions Director regarding
identifying "no-show" students revealed that the
institution allows students to begin classes up to 30
days after instruction commenced. This practice appears
to put such students at a severe disadvantage, especially
in the shorter 600 clock hour programs. There appear to
be no procedures for evaluating whether such students
have any preexisting knowledge that would facilitate
their ability to quickly make up the coursework they
missed. The Department is concerned that this practice
may place these students at a severe disadvantage, and
may hinder their ability to successfully complete their
programs of study.
We recommend that the institution reevaluate the process
of allowing students to begin classes so late after
instruction has commenced. We also recommend that No
Particular College evaluate the past performance of
students admitted under this criteria, and consult with
its accrediting body for further recommendations. We
request that the institution apprise this office of any
decisions or actions taken with regard to this
recommendation.

July 1, 1994 Page N-10

 Program Review Guide

Sample Program Review Report (continued)

NAME OF INSTITUTION: No Particular College

Appendix A
1991-92 Award Year
Student's Name Social Security Number
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
1992-93 Award Year
11.
12.
13.
14.
15.
16.
17.
18.
19.
20.
1993-94 Award Year
21.
22.
23.
24.
25.
26.
27.
28.
29.
30.

July 1, 1994 Page N-11