I Will Survive… A Program Review!
By: Dotti Davidson, FAS Consultant
I’ve had the pleasure of surviving and conquering a program review by the Department of Education. Ahead of their scheduled visit, there was a call from ED in August saying, “Congratulations, you are the lucky winner of a program review to be conducted in September.” Of course, it was the same week the annual audit was taking place. Going through that nerve-wracking encounter reinforced the importance of conducting consumer information audits at institutions to ensure they will pass with flying colors when the day comes that they get an early Christmas present of a program review.
Based on many past experiences, there are consistent issues that schools need to correct. Here are some questions to consider as you prepare your institution for a program review.
Disability Services
Do you have information about facilities and services available to students with disabilities on your school’s home page? If you don’t have a link for disability services on that page, get it updated. Although the regulations don’t state this, ED has indicated this is an expectation.
Intercollegiate Sports
Does your school participate in an intercollegiate athletic program? If so, is The Report on Athletic Program Participation Rates and Financial Support Data, commonly called the EADA Report (Equity in Athletics), posted on your website? Was a link to this report provided in the annual disclosure notice? Or was a separate notice sent to students about this report? Ensure you have proof that the notice was sent.
Academic Program Disclosures
Does your school offer a program that prepares students for initial state certification or licensure (ex., teacher licensure)? You must provide a general disclosure to prospective and enrolled students whether a program leading to professional licensure or certification meets educational requirements in each U.S. state and territory. The regulations apply to all types of instruction (e.g., in-person and online). Here is an example of a university’s disclosure page.
National Student Loan Data System (NSLDS) Notice
Do you have the appropriate NSLDS notice on your website? Many institutions don’t have this on their financial aid website. Schools that enter into an agreement with a potential student, student, or parent of a student regarding a Title IV, HEA loan are required to inform the student or parent that the loan will be submitted to the National Student Loan Data System (NSLDS), and will be accessible by guaranty agencies, lenders, and schools determined to be authorized users of the data system. It is best practice to add a statement to the financial aid webpage that discusses Federal Direct Loans.
Substance Abuse Prevention Program
Is the Drug and Alcohol Abuse Prevention Program (DAAPP) notification being provided to all employees and students? Yes, you say we send it annually. That’s great, but if it’s sent only once a year, that is insufficient. You must ensure EVERY student and employee receives this. Therefore, if you send it in August, what about the student who enrolls in October for one of your modules? One school updated its portal to require every new hire and student to acknowledge receipt of the DAAPP. Does it outline the applicable legal sanctions under state, local, and federal law? Multiple schools have neglected this portion.
Substance Abuse Program Review
Is the Drug and Alcohol Abuse Prevention Program biannual review published on the website? The document asks, “Is the school complying with the spirit and not just the letter of the law?” Furthermore, the guide states, “Many campuses that have conducted successful and productive biennial reviews have included program inventories, policy inventories, and enforcement analyses. Their reports have included supporting documentation for each of these categories, such as descriptions or copies of the programs and policies, procedures for annual notifications, and descriptions of and supporting documentation for the means of assessing program effectiveness and enforcement consistency.” Have you also informed current and prospective students about school policies regarding vaccinations?
Student Voter Registration Forms
What department is making a good faith effort to distribute a voter registration form to each student enrolled? You must ensure this is done 120 days prior to the deadline for registering to vote within the state, except for states that have same-day registration at the time of voting. I’ve recommended that schools create a basic webpage for voter registration and send out an email notification. Proof of this email notification should also be retained for your records.
Constitution Day Celebration
What department is ensuring that Constitution Day, September 17th, is being acknowledged and celebrated? Many schools hand out mini-Constitutions at a booth set up in the Student Center or they held a Lunch-and-Learn hosted by the Political Science Department. However, they did not document this was being done. They now take pictures of the event and save them in their Consumer Information Constitution Day file.
Copyright Infringement Warnings
Do you have a statement on the Information Technology webpage that explicitly informs students that unauthorized distribution of copyrighted material, including unauthorized peer-to-peer file sharing, may subject them to civil and criminal liabilities? The penalties for violating federal copyright laws and the school’s disciplinary action must be listed. Most statements I have encountered are not fully comprehensive and must be updated.
Here is a comprehensive example.
More common issues can be mentioned, but you’re undoubtedly overwhelmed and frantic about complying with the topics listed. It’s recommended that a consumer information calendar/log be created to track each notification that must be sent. Correspondingly, create a consumer information folder where you save each notification sent each year. This will give you peace of mind for the inevitable Program Review.
For added peace of mind, consider collaborating with a Financial Aid Services (FAS) consultant to assess your institution’s preparedness for a program review. Our consultants can deliver a comprehensive action plan to ensure your institution successfully navigates its next program review.
