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 Group
Financial Institution Oversight Group
Performance Improvement and Procedures Group
Integrated Partner Management Group

School Eligibility Group

The School Eligibility Group (SEG) is responsible for administering a program of eligibility, certification, and oversight of schools, and their servicers, participating in the Department of Education Federal Student Aid Programs. This compliance program, which also includes financial analysis and audit resolution, is administered in accordance with policies and procedures established by the Performance Improvement and Procedures Group and utilizing the automated systems and facilities developed and maintained by the Integrated Partner Management Group. To accomplish this mission, the School Eligibility Group is divided into the following divisions:

• Western School Participation Division
• Central School Participation Division
• Northeast School Participation Division

Each of these Divisions has responsibility for the oversight of specific schools assigned to them. Two of the three divisions have additional responsibilities. One division is responsible for providing all oversight for publicly traded schools, as well as other designated schools, and serving as the central resource for school financial analysis. The other division is responsible for providing oversight of foreign schools and serving as the central resource for audit resolution and oversight initiatives. Each division has the following common responsibilities, which are carried out by their respective School Participation Branches:

• Examines and analyzes to determine the approval or denial of the initial and renewal eligibility applications submitted by schools for participation in the Federal Student Aid program.
• Processes and maintains records of schools’ Program Participation Agreements and notices of eligibility to participate in the Federal Student Aid program.
• 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 and takes appropriate actions.
• Evaluates and acts upon the findings, conclusions, and recommendations produced by other support units, e.g. audit resolution, etc.
• Identifies closed, bankrupt, and troubled schools and notifies appropriate Department of Education offices.
• Works with state agencies and accrediting agencies on closed schools and other issues.
• Identifies requirements for tuition recovery programs and coordinates the fulfillment of these requirements.
• Determines liabilities and/or recommends administrative actions.
• Works closely with and/or refers matters to the Office of the Inspector General and Administrative Actions and Appeals Group and other offices.
• Works closely with Performance Improvement and Procedures Group on the development and/or revision of policies and procedures.
• Reviews and updates pertinent institutional databases.

Western School Participation Division

The Western School Participation Division is responsible for performing all of the above oversight and eligibility functions for institutions within the western region. This division is also responsible for performing these same functions for the large publicly traded, common ownership, and other designated schools. In addition, this division provides financial analysis support to all other branches having specific school oversight responsibility. To accomplish this mission, the Western School Participation Division is divided into the following four branches:

• San Francisco School Participation Branch
• DC School Participation Branch 1
• DC School Participation Branch 2
• Financial Analysis Branch

This Branch performs the oversight functions described above under the description for the SEG Divisions for its designated schools.

DC School Participation Branch 1 & 2

These Branches perform the oversight functions described above under the description for the SEG Divisions for large publicly traded, common ownership or other designated schools. In addition, these Branches also perform audit resolution and financial analysis for their respective schools.

Financial Analysis Branch

This branch is responsible for all activities related to the financial analysis of all schools participating in the Title IV student aid programs, with the exception of those schools assigned to the DC School Participation Branches. To accomplish this mission, the Financial Analysis Branch performs the following:

• Performs financial analyses and monitors financial status.
• Requests letters of credit and heightened cash monitoring actions.
• Manages and monitors missing / late financial submissions.
• Informs and collaborates with the School Participation Branches on financial analysis results.
• Reviews and evaluates programmatic publications for consistency with established policies and procedures (e.g., Federal Student Aid Handbook, Audit Guide, Federal Student Aid Coach, Blue Book, etc.).
• Works closely with or refers matters to the Office of the Inspector General and Administrative Actions and Appeals Group.
• Collaborates with Performance Improvement and Procedures Group on the development and/or revision of policies and procedures.
• Reviews and updates pertinent institutional databases.

Central School Participation Division

The Central School Participation Division is responsible for performing all of the above oversight and eligibility functions for institutions within the central and southern regions. To accomplish this mission, the Division is divided into the following two branches:

• Atlanta School Participation Branch
• Chicago School Participation Branch

Both of these Branches perform the oversight functions described above under the description for the SEG Divisions for schools within their designated areas.

Northeast School Participation Division

The Northeast School Participation Division is responsible for performing all of the above oversight and eligibility functions for institutions within the northeast region, as well as foreign schools. In addition, this division is also responsible for serving as the central resource for audit resolution and oversight initiatives. To accomplish this mission, the Northeast School Participation Division is divided into the following four branches:

• New York School Participation Branch
• Foreign School Participation Branch
• Audit Resolution Branch
• Oversight Initiatives Branch

New York School Participation Branch

This Branch performs the oversight functions described above under the description for the SEG Divisions for schools within their designated areas.

Foreign School Participation Branch

This Branch performs the oversight functions described above under the description for the SEG Divisions for foreign schools.

Audit Resolution Branch

This branch is responsible for coordinating the resolution of compliance related audits involving schools participating in the Title IV Federal Student Aid programs, with the exception of those schools assigned to the DC School Participation Branches. To accomplish this mission, the Audit Resolution Branch performs the following:

• Provides recommendations to PIP for refining audit exception criteria.
• Performs audit resolution.
• Informs and collaborates with the School Participation Branches on audit resolution results.
• Manages and monitors late / missing audits.
• Reviews and evaluates programmatic publications for consistency with established policies and procedures (e.g., Federal Student Aid Handbook, Audit Guide, Federal Student Aid Coach, Blue Book, etc.).
• Works closely with or refers matters to the Office of the Inspector General and Administrative Actions and Appeals Group.
• Collaborates with Performance Improvement and Procedures Group on the development and/or revision of policies and procedures.
• Reviews and updates pertinent institutional databases.

Oversight Initiatives Branch

This branch is responsible for performing a variety of crosscutting functions related to the oversight of schools participating in the Title IV Federal Student Aid Programs. In particular, the Oversight Initiatives Branch is responsible for the following:

• Schedules and conducts Clery Act reviews.
• Schedules and conducts other compliance review initiatives as required.
• Manages the memorandum of understanding with the Federal Bureau of Investigation.
• Manages and performs data analysis on annual Clery reports and FBI data.
• Works closely with or refers matters to the Office of the Inspector General and Administrative Actions and Appeals Group.
• Collaborates with Performance Improvement and Procedures Group on the development and/or revision of policies and procedures.
• Reviews and updates pertinent institutional databases.

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Financial Institution Oversight Group

Financial Institution Oversight Group (FIOG) is responsible for administering a program of oversight of guaranty agencies, lending institutions, and servicers participating in the Department of Education Federal Family Education Loan (FFEL) Program. The oversight activities are administered in accordance with policies and procedures established by the Performance Improvement and Procedures Group and utilizing the automated systems and facilities developed and maintained by the Integrated Partner Management Group. To accomplish this mission, FIOG is divided into the following divisions:

• DC Financial Institution Division
• Eastern Financial Institution Division
• Central Financial Institution Division
• Southern Financial Institution Division

Each of these Divisions has responsibility for the oversight of guaranty agencies, lenders, and servicers participating in the Title IV loan programs, including conducting nation wide program review initiatives. The DC Financial Institution Division is responsible for emerging issues involving guaranty agencies, lenders, and servicers, including conducting nationwide program review initiatives. A complete description of the oversight functional responsibilities is provided below.

• Conducts risk assessment of financial institutions participating in the FFEL program.
• Conducts comprehensive program reviews of guaranty agencies, lenders, and servicers.
• Conducts focused program reviews of guaranty agencies, lenders, and servicers.
• As required, monitors guaranty agencies, lenders, and servicers to obtain early warning and/or confirmation of issues related to program compliance and financial stability.
• Evaluates and acts upon the findings, conclusions, and recommendations produced by audit resolution.
• Determines liabilities and /or recommends fines.
• Monitors the Common Review Initiative process.
• Works closely with or refers matters to Office of the Inspector General and Administrative Actions and Appeals Group.
• Collaborates with Performance Improvement and Procedures Group on the development and/or revision of program review policies and procedures.
• Reviews and updates pertinent databases.

In addition to the above functions, the DC Financial Institution Division is responsible for performance of the audit resolution function for those financial institutions required to submit annual audits. In this regard, the DC Division is responsible for performing the following:

• Collaborates with Performance Improvement and procedures Group on the development and/or revision of audit resolution policies and procedures.
• Manages / monitors late / missing audits.
• Resolves external and internal audits (IPA and OIG) of FFEL program financial institutions.
• Reviews and evaluates the effectiveness of the institution’s correction / mitigation efforts of noted exceptions in audit reports.
• Reviews and evaluates programmatic publications for consistency with established policies and procedures (e.g., Audit Guide, Federal Student Aid Coach, Blue Book, etc.).
• Works closely with or refers matters to the Office of the Inspector General and Administrative Actions and Appeals Group.
• Reviews and updates pertinent institutional and student databases.

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The Administrative Actions and Appeals Group (AAAG) administers the Secretary’s authority to fine, limit, suspend, terminate and take emergency actions against postsecondary educational institutions that participate in the Federal Student Aid programs. In addition, AAAG administers the Secretary’s authority to resolve appeals of final audit and final program review determinations and the authority to initiate debarment and suspension proceedings against individuals. The Group also acts as the initial arbitrator of such actions against guaranty agencies, lenders, and servicers. In performing its responsibilities, the activities of the Administrative Actions and Appeals Group include:

• Develops, initiates, and imposes Emergency/Termination/Limitation/ Suspension/Fine actions and assists in settlement negotiations with the Department of Education’s Office of General Counsel.
• Participates in the development/drafting of school revocations and most school recertification denials and coordinating of reconsideration appeals.
• Coordinates and resolves appeals by program participants from final audit and final program review determinations.
• Initiates debarments and suspensions.
• Issues warning letters to participating institutions for non-reporting violations prior to initiating adverse administrative actions/imposing sanctions.
• Participates in on-site reviews with program review teams.
• Acts as advisor to the SEG and FIOG leadership on adverse administrative actions.

Performance Improvement and Procedures Group

The Performance Improvement and Procedures Group provides support to both SEG and FIOG through the development and review of policy, procedure development and refinement, training, and resolution of difficult matters. This organization also works closely with the Integrated Partner Management Group in planning, structuring and delivering guidelines and training. Specifically, this organization’s responsibilities include:

• Serves as a liaison to Federal Student Aid’s policy organization to provide recommendations for policy development and communicating policy decisions back to Program Compliance.
• In partnership with Federal Student Aid’s policy organization, represents Program Compliance in addressing regulatory and statutory changes with the Office of Postsecondary Education (OPE).
• Conducts quality assurance evaluations to determine the effectiveness of SEG and FIOG procedures.
• Assists SEG and FIOG in drafting, refining, and communicating changes in business process procedures.
• Coordinates with Integrated Partner Management Group in the development and training of SEG and FIOG staff in the use of program compliance automated systems.
• Reviews and evaluates programmatic publications for consistency with established policies and procedures (e.g., Federal Student Aid Handbook, Audit Guide, Federal Student Aid Coach, Blue Book, etc.).

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Integrated Partner Management Group

Integrated Partner Management Group (IPMG) is responsible for managing the design, development and maintenance of automated information systems provided in support of SEG and FIOG. To accomplish its mission, IPMG is divided into two Divisions: Operations Support Division and the Technical Management Division.

Operations Support Division

The Operations Support Division provides stable operations by establishing and managing policies, procedures, and guidelines for the IPM system. It gathers requirements, analyzes risk, and validates user requirements and system issues, recommending solutions that provide the best value. It is responsible for the management of earned value on significant development projects as needed. The Division performs quality control reviews to ensure business needs are consistently being met, and conducts data integrity and reconciliation activities to consistently provide and maintain reliable data and reporting. It provides support to the Risk Analysis Model and triggers, and provides reports and data to other Department and external parties as required.

Technical Management Division

The Technical Management Division is responsible for managing IPM application technology infrastructure, liaison with the Virtual Data Center (VDC), oversight of the Configuration Management Process (CMP), and support of the Routing Identifier (RID) and OPEID crosswalk used by other Federal Student Aid systems. This Division participates in meetings with other Enterprise Initiatives/ Projects and is responsible for performing impact analysis and advising management of any technical issues or risks pertaining to IPM systems. The Division manages, develops and implements procedures in compliance with system security policies and ensures development and periodic revisions of System Security Plans (SSP) and Disaster Recovery Plans (DRP). The Technical Management Division ensures that periodic Certification and Accreditation (C&A) of IPM systems are done in a timely manner and corrective actions are executed for all identified findings and vulnerabilities. It supports audits on IPM systems by other agencies like GAO, IG or any other independent agency authorized by Federal Student Aid. It is responsible for and adherence to Configuration Managements Plans (CMP), coordination of and participation in the Change Control Board (CCB) meetings and testing processes.

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