SCCE Higher Education Compliance Conference 1 Federal Student Aid Program Participation Agreement A Work‐Plan for Compliance Officers 1 David Galloway, Director, Office of Audit, Compliance, and Ethics Kimberly Fearney, Director of Compliance/Ethics Liaison University of Connecticut Federal Student Financial Aid and Grants 2
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Federal Aid Program Participation Agreement€¦ · SCCE Higher Education Compliance Conference 1 Federal Student Aid Program Participation Agreement A Work‐Plan for Compliance
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SCCE Higher Education Compliance Conference
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Federal Student Aid Program Participation Agreement
A Work‐Plan for Compliance Officers
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David Galloway, Director, Office of Audit, Compliance, and EthicsKimberly Fearney, Director of Compliance/Ethics Liaison
University of Connecticut
Federal Student Financial Aid and Grants
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SCCE Higher Education Compliance Conference
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Agree to comply with…
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Title IX
Drug Free Schools/Workplace Acts
Clery Crime Statistics/Emergency
Procedures
Sa
nct
ion
s C
he
cks
Gain
ful
Em
plo
ymen
t R
ule
s
Voter Registration
FTC
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• Institutional eligibility• Code of conduct• Processing procedures such
as needs analysis, eligibility, etc.
• Financial responsibility and administrative capability
• Disclosures to students• Information reporting
requirements • State authorization• Accreditation• Definitions: academic year,
credit hour, etc.• Records retention
requirements• Financial aid counseling• No incentive payments
SCCE Higher Education Compliance Conference
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What else?
• Drug Free Schools Act
• Drug Free Workplace Act
• Clery Act
• Title IV of the Civil rights Act of 1964 (race, color or national origin)
• Title IX of the Education Amendments of 1972 (sex discrimination)
• FERPA
• §504 of the Rehabilitation Act of 1973 (accessibility)
• Age Discrimination Act of 1975
• Safeguarding Customer Information (GLBA)
• Financial Aid Regulations
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What else?
• Administrative Capability
• Financial Responsibility
• Provide Information (IPEDS+)
• Athletic Participation Disclosures
• Gainful Employment Provisions
• Copyright and DMCA Compliance Programs
• Voter Registration Program
• Lobbying
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SCCE Higher Education Compliance Conference
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Six‐year Cycle
Recertification
Compliance w/
Statute and
Regulations
Core Elements…
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Core Elements…• Ninety days to submit a new PPA for recertification.
• Signed by the President
• May be given “provisional” status.
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SCCE Higher Education Compliance Conference
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Core Elements
• Covers all locations
• May be sanctions(1) An emergency action.
(2) The imposition of a fine.
(3) The limitation, suspension, or termination of the participation of the institution in a Title IV, HEA program.
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What next?
• Use the PPA to identify key areas for compliance work plan
• Assess the key areas
• Develop action plan to address improvements
• Implement the action plan
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SCCE Higher Education Compliance Conference
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Broad Compliance Structure:Representative Schools
1. Academic Programs2. Asses Management3. Athletics4. Campus Security5. Civil Rights
6. Communications7. Contracts8. Development/Advancement9. Dining Services10. Disability Services11. Emergency Management12. Environmental Health and Safety13. Employee Welfare Benefit Plan14. Federal and State Disclosure15. Financial Aid16. Fiscal Management17. Governance18. Grants/Research Administration19. Human Resources20. International21. Intellectual Property22. IT/Computing23. Records Management24. Research25. Student Affairs26. Student Health27. Tax28. FTC Broadcast Rules
1. Environmental Health and Safety2. Research Administration3. Human Resources4. Accessibility5. Athletics6. Tax7. Donor Gift Restrictions8. Immigration9. Technology Transfer10. Investments11. Information Security and privacy12. Campus Security13. Student Life14. Financial Controls15. Controlled Substances16. Land Use/Planning17. Biohazards
Safety13. Ethics14. Export Controls15. Financial Aid16. Fund Raising and Development17. Governance18. Grants Management19. Health Care & Insurance
20. Housing21. Human Resources – Discrimination22. Human Resources – Benefits23. Human Resources – Recruitment, Hiring, Termination24. Human Resources – Retirement25. Human Resources – Unions26. Human Resources – Wages27. Immigration28. Information Technology29. Intellectual Property and Technology Transfer30. International Activities and Programs31. Lobbying and Political Activity32. Privacy and Information Security33. Program Integrity Rules34. Research35. Sexual Misconduct36. Tax