Functional Statements > Federal Student Aid

C. Program Compliance

The Program Compliance office is responsible for providing integrated oversight and management improvement services to institutions, managing the systems and operations used for determining eligibility and implementing program and financial reviews of guarantee agencies and FFELP lenders and related agencies or organizations. To accomplish this mission, the Program Compliance office is divided into the following areas:

School Eligibility Channel
Financial Partner Eligibility & Oversight
Integrated Partner Management

School Eligibility Channel

The School Eligibility Channel (SEC) is responsible for providing integrated oversight and management improvement services to institutions receiving student financial assistance program funds, in accordance with policies and procedures established by the Performance Improvement and Procedures Branch. To accomplish this mission, the School Eligibility Channel is divided into the following divisions:

• Administrative Actions and Appeals Division
• School Participation Management Division (Northeast, South-Central, Northwest)
• Performance Improvement and Procedures Branch (PIPB)

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Administrative Actions and Appeals Division

The Administrative Actions and Appeals Division administers the Secretary's authority to fine, limit, suspend, terminate and take emergency actions against postsecondary educational institutions, which participate in the Federal Student Aid programs. In performing its responsibilities the Administrative Actions and Appeals Division:

• Resolves and coordinates appeals by institutions from final audit and final program review determinations.
• Develops and initiates Emergency/Termination/Limitation/Suspension/Fine actions and assists in settlement negotiations with the Department of Education Office of the General Counsel.
• Participates in the development /drafting of revocations and most recertification denials and coordinates reconsideration appeals.
• Initiates debarments and suspensions.
• Issues "Warning Letters" to schools for non-reporting violations prior to imposing sanctions.
• Participates in Model Case Enforcement (i.e. conducts on-site reviews with case management teams).
• Acts as advisory to the school participation management teams on administrative actions.

School Participation Management Division

The School Participation Management Division is responsible for providing integrated oversight and management improvement services to institutions receiving student financial assistance program funds. In performing its responsibilities, the School Participation Management Division is organized into four branches. The following three Branches all perform the same functions:

• School Participation Team - Northeast
• School Participation Team - South-Central
• School Participation Team - Northwest

Each School Participation Team is responsible for the following:

• Develops, plans, and implements a nationwide program for monitoring and improving institutional compliance with legislation and regulations.
• Consistently monitors schools and their agents through on-site and off-site reviews and analysis of various reports to provide early warning of program compliance problems.
• Conducts analyses and approves institutional applications for Federal Student Aid program funding of all schools seeking initial or renewal certification.
• Processes and maintains schools' Program Participation Agreements, and notices of eligibility for institutions to participate in various Federal Student Aid programs.
• Recommends appropriate actions e.g., methods of funding (reimbursement, heightened cash monitoring, etc.), emergency actions, and limitation, suspension, termination, or fine actions.
• Reviews, maintains, and updates pertinent institutional and student data in various databases.
• Directs all functions related to certification determinations for foreign institutions of higher education including financial analysis, compliance audit analysis/resolution, program reviews, and training.
• Identifies closed, bankrupt, and troubled schools and notifies appropriate Department of Education offices.
• Resolves student loan discharge problems.
• Works with state agencies and accrediting agencies on closed schools and other issues.
• Identifies institutional performance bonds and tuition recovery programs and coordinates these activities.
• Works with State agencies to identify discharged loans for students who are also eligible to receive tuition reimbursements from State bonds or tuition recovery programs.

Performance Improvement and Procedures Branch

• Develops, disseminates, reviews, and evaluates operational policies, procedures and guidelines for the school participation management process.
• Serves as a liaison to Federal Student Aid's policy organization to provide recommendations for policy development and communicates policy decisions back to the SEC organization.
• In partnership with Federal Student Aid's policy organization, represents SES when addressing regulatory and statutory changes with Office of Postsecondary Education (OPE).
• Performs quality control evaluation to determine the effectiveness of the School Eligibility Channel's (SEC) operations.
• Provides on-going training to SEC staff on system enhancements to ensure consistent application of policies and procedures for all institutions participating in the FSA programs.
• Reviews and coordinates the SEC review of Title IV programmatic publications for consistency with established procedures (e.g. Federal Student Aid Handbook, Audit Guide, Federal Student Aid Coach, Blue Book).
• Provides on going training to SEC staff on system enhancements to ensure consistent application of policies and procedures for all institutions participating in the Federal Student Aid programs. The training and communication effort must be coordinated with Integrated Partner Management (IPM) and other SEC organizations.
• Provides direct support to SEC in the resolution of difficult school cases.

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Financial Partner Eligibility & Oversight - Regions (I, II, IV, V, VI, IX)

Financial Partner Eligibility & Oversight is responsible for the implementation of program and financial reviews of guaranty agencies and FFELP lenders and related agencies or organizations. Provides technical assistance to these groups on the proper administration and management of the FFEL program. Identifies and analyzes major issues affecting lender and guarantor compliance with program requirements, and develops national priorities, goals, and guidelines for monitoring the programmatic stability of the Federal student loan guarantors. In performing its responsibilities, the Financial Partner Eligibility & Oversight is organized into four regional components. The following four regional components all perform the same functions:

• Northern Region (Chicago)
• Atlanta Partner Services Duty Station
• Southern Region (Dallas) Partner Services
• Eastern Region (New York) Partner Services
• Boston Partner Services Duty Station
• Western Region (San Francisco) Partner Services

Each regional component is responsible for the following:

• Conducts program and financial reviews and audits of guaranty agencies and FFELP lenders related agencies or organizations.
• Monitors on a consistent basis guaranty agencies through on-site reviews and analysis of various reports from the agencies, to provide early warning of program compliance and due diligence problems and signs of financial instability, and to recommend and undertake necessary corrective actions.
• Works closely with and/or refers cases to OIG.
• Reviews reports of program violations and evaluates regional findings and recommendations for consistency and conformance to policy.
• Recommends actions to resolve or avoid financial and program compliance problems faced by guarantors and compliance of lenders.
• Provides technical assistance and service to lenders, guaranty agencies, the general public, and congressional offices, through site visits, follow-up reports, correspondence and telephone communications.
• Conducts Exceptional Performance Reviews, Determinations and Annual Re-designations.
• Conducts Voluntary Flexible Agreement (VFA) Reviews
• Conducts Focused Completion Reviews

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Integrated Partner Management

Integrated Partner Management (IPM) is primarily responsible for managing the systems and operations used for determining eligibility and monitoring the performance of schools that participate in the Title IV programs. To perform its responsibilities, the IPM is responsible for:

• Providing system support for application and oversight tools (e.g. the Electronic Application for Approval to Participate in Federal Student Financial Aid (app.), fez-Audit for submission of financial statements and compliance audits through the web, Postsecondary Education Participants System (PEPS), Case Management Oversight (CMO) Net).
• Serves as liaison to business owners to understand all business requirements.
• Manages requests for workflow management.
• Providing system change management support to ensure accurate and timely system updates.
• Performs data management and data quality assurance.
• Manages and supports the risk model which evaluates school data to determine the probability that Title IV funds are at risk.
• Providing reports and data to internal and external customers as required.
• Oversees lifecycle of the Routing Identifier (RID).
• Manages security processes to protect system assets and resources.
• Serve as Virtual Data Center (VDC) liaison for app. and fez-Audit applications and PEPS system.
• Performs data reconciliation activities.
• Providing training to system users from other Federal Student Aid service areas and financial partners.
• Develops, maintains and supports ancillary services infrastructure (e.g. imaging, workflow).
• Performs database administration.

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