GSFC 411 e-newsletter [Jan. 2009]

Welcome to the Online GSFC411 Newsletter Archive
JANUARY 2009 Newsletter
GAcollege411 Partner Update The latest news about the GAcollege411 website. View Update
College...Yes, You Can Day to Visit the State Capitol GSFC is set to host "College, Yes You Can" Day at the Georgia State Capitol on Monday, January 26, 2009. Read Full Article
2008 Georgia Oglethorpe Progress Award Recipient GSFC recently received the 2008 Georgia Oglethorpe Progress Award for meeting criteria that world class organizations use to create and sustain high performance. Read Full Article
GAcollege411 Working Group to meet on Wednesday, January 7, 2009 The GAcollege411 Working Group will be meeting on Wednesday, January 7th at the Technical College System of Georgia from 9:00 a.m. to 12:00 p.m. Read Full Article
February is Financial Aid Awareness Month If it's February it is Financial Aid Awareness Month in Georgia. We hope you are planning activities on your campus to promote financial aid possibilities to students. Read Full Article
Compliance Corner Compliance Corner features policies and procedures and frequently asked questions regarding Compliance reviews of GSFC's scholarship and grant programs. Read Full Article
Georgia Student Finance Commission 2082 East Exchange Place Tucker, Georgia 30084 (770) 724-9000 or 1-800-505-GSFC (4732) FAX (770) 724-9089

College...Yes, You Can To Visit the State Capitol
The Georgia Student Finance Commission (GSFC) will host a "College, Yes You Can" Day at the State Capitol on Monday, January 26, 2009 in the South Wing from 9:00 a.m. to 1:00 p.m. The purpose of "College, Yes You Can" Day is to help familiarize students with the services and products offered by GSFC and other state agencies. Several computer workstations will be set up to help students plan, apply and pay for college. In addition, members of the Georgia Association of Student Financial Aid Administrators (GASFAA) and Path2College 529 Plan will be on hand to share information about the financial aid process and saving for college. For additional information, feel free to contact Monica Cherry at monicac@gsfc.org. If you are in the neighborhood, stop by the State Capitol for the "College, Yes You Can" Day. Hope to see you there.
Georgia Student Finance Commission 2082 East Exchange Place Tucker, Georgia 30084 (770) 724-9000 or 1-800-505-GSFC (4732) FAX (770) 724-9089

2008 Georgia Oglethorpe Progress Award Recipient
We are pleased to announce that GSFC received the 2008 Georgia Oglethorpe Progress Award. To GSFC, the Georgia Oglethorpe Award Process is like the "Good Housekeeping Seal of Approval," because through the process, people outside our organization and outside our industry can see us for what we are becoming an organization that meets the criteria that world class organizations use to create and sustain high performance. One strength that was noted by our evaluators is our commitment to and focus on our partners and customers (you!) as we work to enhance our services, products and customer satisfaction. Receiving this award is yet another indicator that, collectively, our efforts are paying off. Not only have our bottom line results improved this year, we now have external confirmation that the strong organizational foundation we are creating to enhance our performance is working. As a public service organization, it is encouraging to receive validation of our efforts from an organization whose focus is process and organizational excellence. We look forward to continuing our efforts with, and for you, as we strive toward our vision of being the premier provider of student financial aid and educational services for Georgians. Georgia Oglethorpe Award Process, Inc. is a nonprofit public-private partnership that provides low-cost, high-value education, assessment, feedback, and recognition to Georgia's business, industry, government, education, healthcare, and nonprofit organizations. It promotes both strategic and tactical organizational performance improvement and excellence through use of the Criteria for Performance Excellence - the same Criteria used to determine recipients of the Malcolm Baldrige National Award.
Tim Connell accepts the Georgia Oglethorpe Progress Award from Lonice Barrett, representing Governor Sonny Perdue and Victoria Taylor,
Executive Director of the Georgia Oglethorpe Award Process, Inc.
Georgia Student Finance Commission 2082 East Exchange Place Tucker, Georgia 30084 (770) 724-9000 or 1-800-505-GSFC (4732) FAX (770) 724-9089

GAcollege411 Working Group to meet on January 7, 2009
The GAcollege411 working Group will be meeting on Wednesday, January 7th at the Technical College System of Georgia. The meeting will be at 9:00 a.m. and concludes by 12:00 p.m. This group meets to review changes to the website, activities taking place around the website and other initiatives involved around encouraging students to pursue post-secondary education. If you would like to attend the meeting, please contact Sarah Baumhoff at sarahb@gsfc.org or by calling 770724 -9021.
Georgia Student Finance Commission 2082 East Exchange Place Tucker, Georgia 30084 (770) 724-9000 or 1-800-505-GSFC (4732) FAX (770) 724-9089

Financial Aid Awareness Month
If it's February it is Financial Aid Awareness Month in Georgia. We hope you are planning activities on your campus to promote financial aid possibilities to students. One great statewide event that we encourage you to promote at your institution is College Goal Sunday. The event, which will be held on February 15th, helps students and families complete the application for college financial aid the Free Application for Federal Student Aid, or FAFSA. This year, over 20 colleges, universities and high schools throughout the state will participate in College Goal Sunday. For more detailed information about College Goal Sunday, visit www.collegegoalsundayga.com.
Georgia Student Finance Commission 2082 East Exchange Place Tucker, Georgia 30084 (770) 724-9000 or 1-800-505-GSFC (4732) FAX (770) 724-9089

Compliance Corner
The Post On-Site Compliance Review Reporting Process of the State Scholarship and Grant Programs Third in a Series of Three Articles to Help You Better Understand the State Scholarship and Grant Program Compliance Review
process
After the Compliance Team has concluded an institution's on-site Compliance Review of the State Scholarship and Grant Programs (S&G), correspondence and reports between the Compliance Team and the institution will begin. At the Exit Interview, the institutional officers will receive a schedule of preliminary findings noted during the on-site review and documents to assist the institution in resolving the findings. After the lead Compliance Officer explains each finding type, additional information is given concerning the time line for the submission of reports between the Compliance Team and the institution. Following the applicable time line, a Compliance Review of the institution's S&G program can take several months to complete. In further detail the reporting process time line is as follows:
Grace Period for Submitting Missing Documentation 10 days (Business) Preliminary Report 30 days (Calendar) Institutional Response 30 days (Calendar) Final Report 30 days (Calendar) Institutional Response 30 days (Calendar) Closure 30 days (Calendar)
Upon the completion of the on-site Compliance Review process, the institution's GSFC Compliance Review committee or task group should begin the process of preparing a response to the schedule of preliminary findings (given at the Exit Interview) to be submitted during the 10-day missing documentation grace period. Using the Missing Documentation Guidance for Clearing Findings During 10-Day Grace Period form (see Attachment A) the institution must submit documentation to the lead Compliance Officer no later than ten (10) business days after the Exit Interview. The documents should be securely submitted either by mail, scanned and emailed, fax, overnight mail service or hand delivery. The Compliance Team will review the documentation and will note the result of the additional information on the Preliminary Report unless the documentation clears the finding or the finding is removed by the Compliance Team due to misinterpretation or error. Documentation that does not fit within the guidelines of missing documentation should not be submitted during the 10-day missing documentation grace period. Data Correction Request forms are not considered missing documentation. The institution's GSFC Compliance Review committee or task group can be useful in the reporting process beginning with the first in a series of reports the institution will receive, the Preliminary Report.
Thirty (30) calendar days after the Exit Interview, the Compliance Team will issue to the Institutional Officers via secured email a formal Preliminary Report Letter (see Attachment B) and a formal Preliminary Report (see Attachment C). The Preliminary Report Letter contains instructions on how to respond to the Preliminary Report and the date the institution's response should be submitted to the lead Compliance Officer which is thirty (30) calendar days from the date the institution receives the report. The Letter also contains a list of each finding type that remained after the 10-day missing documentation was reviewed. In addition, the institution is asked to refrain from remitting any monetary liabilities associated with each finding until after the Final Report and all supporting documentation has been submitted and reviewed. A cover sheet follows the Preliminary Report letter, which contains cursory information about the on-site Compliance Review with the institution's name, date of review, Compliance Officers conducting the review, list of the institutional officers, and the fiscal year (see Attachment D). The Preliminary Report also contains information about the institution and the Compliance Review detailing the exceptions noted during the on-site Compliance Review process. The report contains detailed information about each finding and may have as many as five (5) different sections that must be addressed by the institution. These sections are:
I. FINDINGS II. REQUIRED CORRECTIVE ACTION III. STUDENT LIABILITY IV. AREA OF CONCERN V. MANAGEMENT NOTE
The FINDINGS section consists of all the findings listed on the schedule of preliminary findings given to the Institutional Officers at the Exit Interview, minus any findings that were cleared during the 10-day missing documentation grace period. In some cases, findings may be added or removed from the Preliminary Report based on a post-review performed by the Compliance Officers after the initial onsite review. For the purpose of describing the different sections of the Preliminary Report, the components that make up the five sections of the report will be identified as "sub-sections". After each finding title, there is a sub-section where the institution may concur or not concur with the finding along with a place for the respondent's signature, title and date. The next sub-section contains the student's name, last four digits of their social security number, fiscal year(s), award term(s), award amount(s) and the program(s) associated with the finding. There can be several terms and programs associated with a finding. The award amount(s) are the potential monetary liabilities that the institution may or may not be required to refund back to GSFC depending on the finding's final resolution. The explanation sub-section details what was viewed in the student's file during the on-site review. Example; a Grade Point Average (GPA) finding explains why the student did not meet the GPA requirement for the HOPE Scholarship. The explanation will identify the Attempted-Hour checkpoint and the reviewers GPA calculation. Next, the regulation sub-section identifies the regulation relevant to the finding. This sub-section can contain references to several regulations for different S&G programs. The regulation sub-section can assist the institution to further address the finding for eventual resolution. The requirement sub-section pertains to the action the institution must perform in order to resolve the finding. This can include the submission of additional documentation, the remittance of funds (after the Final Report is submitted) back to GSFC or both. Following is an example of this section for further clarification.

The REQUIRED CORRECTIVE ACTION section requires the institution to submit corrective action plan for each finding type detailing the actions the institution will take to ensure students receiving State funds meet program requirements. Required Corrective Actions plans can assist the institution by focusing the institution's attention to their current policy and procedures to determine if there is a need to review and revise the policies or to implement additional measures to their processing procedures.
The STUDENT LIABILITY section is not an institutional finding. However, the institution's assistance is required in the resolution of a Student Liability but the responsibility of returning any potential monetary liability belongs to the student identified in the Compliance Review. Students are responsible for submitting all information requested by an institution. A student's failure to submit all the requested information is classified in a Compliance Review as a False Certification Student Liability. Example; a student submits an admissions application to an institution and fails to disclose all the previous schools the student attended and the corresponding academic transcripts. The student submits an application for the HOPE Scholarship. Unaware of the missing transcripts, the institution determines the student's cumulative HOPE Grade Point Average. The student is awarded and receives the HOPE Scholarship. Later, a Compliance Review reveals the missing transcript. Thus, the student's HOPE eligibility is in question. During the reporting process, if the missing transcript is not submitted or once received, the submitted transcript determines the student ineligible, the student is held liable for the return of any HOPE funds. In addition, if the transcript is not received, the institution notifies GSFC to place a refund due status on the student's file preventing the student from receiving any future State aid until the matter is resolved.
The AREA OF CONCERN section deals with matters noted by the Compliances Officers while reviewing student files during the on-site review process. The Area of Concern section does not contain findings but issues that the Compliance Review process brings to the attention of the institution. For example; during a Compliance Review, it appears that a student may be eligible for the HOPE Scholarship. The student has an application and appears to meet all other HOPE requirements. However, the Compliance Officer will not make the determination of the student's HOPE eligibility. Determining the student's eligibility is the institution's responsibility. The Compliance Officer merely brings to the institution's attention that the student appears eligible and requests the institution to re-evaluate the student's eligibility and if eligible, explain the circumstances that prevented the student from being awarded.
The MANAGEMENT NOTE section also does not contain findings. The Management Note section is intended to bring to the institution's attention matters that could affect the institution's awarding of State aid. For example; the Compliance Review process identifies that there are discrepancies between the course hours listed on the institution's academic transcript and the course hours listed in the institution's course catalog. This could affect the student's Attempted-Hours Checkpoints, End-of-Spring Checkpoints, Total Paid-Hours and the Total Attempted-Hours calculations. The institution should review the matter and make a determination of any necessary changes.
The institution's response to the Preliminary Report should be submitted to the lead Compliance Officer no later than thirty (30) days after the institution receives the Preliminary Report. However, if the institution is unable to meet that deadline, the institution can request a fifteen (15) day extension. The extension must be requested before the Preliminary Report response deadline. For each finding response, the sub-section (concur with this finding/do not concur with this finding) should be completed along with the respondent's signature and date. If the institution concurs with a finding, it should be noted on the response. If the institution does not concur with a finding, it should be noted along with a written explanation accompanying the response and any relevant documentation that provides proof of eligibility as it pertains to that finding. The institution is expected to logically organize the documentation submitted to the lead Compliance Officer. All supporting documentation received should numerically correspond to the finding number it relates to. Example; with finding #23: Missing Academic Transcript, the institution submits the missing transcript labeling it #23. It is important to note that the institution will have several opportunities to submit documentation to resolved findings.
If the Compliance Review identifies discrepancies in data (hours-IRD and tiers-INV) between the institution's records and GSFC's records, the institution will also receive a Data Correction Request form (see Attachment E) to use in submitting a request to GSFC for correcting the data. The Preliminary Report will specifically identify the data that needs to be corrected. The Data Correction Request form should indicate the corrections are in response to a Compliance Review. The form should be submitted to the GSFC Financial Aid Operations Department. The lead Compliance Officer must also receive copies of the Data Correction Request form with the institution's Preliminary Report response.

Corrective action plans should also be submitted with the institution's response to the Preliminary Report. As described earlier, the REQUIRED CORRECTIVE ACTION requires the institution to submit a corrective action plan for each finding type detailing the actions the institution will take to ensure students receiving State funds meet eligibility requirements. The institution's response should also be logically organized. If the Preliminary Report contains a STUDENT LIABILITY and/or an AREA OF CONCERN section, the institution must indicate if it concurs or does not concur with each section. The institution should submit a response following the instructions listed in the requirements sub-section for each STUDENT LIABILITY and each AREA OF CONCERN. Following the earlier example for a STUDENT LIABILITY, if the missing transcript is not received, the State funds must be returned to GSFC as follows:
A notification letter is sent to the student from your institution indicating the student's ineligibility for the HOPE funds awarded in the terms listed above. Your institution should forward a copy of this letter to GSFC for our record-keeping purposes. GSFC will post a refund due status in the student's account to prevent future awards. Once the funds are collected from the student, they should be forwarded to GSFC. The remittance should include the student's name and SSN and awards information. The student's refund due status will be removed upon the completion of the adjustment of funds. The student's eligibility for future awards can be reinstated when the refund is paid in full, if all other eligibility criteria are met.
The same applies for the AREA OF CONCERN section. The institution must indicate if it concurs or does not concur with the Area of Concern. In following the earlier example of a student identified as a potential HOPE Scholar, but not awarded, the institution must explain the circumstances that prevented the student from being awarded State funds. If the institution concurs after performing a reevaluation, the institution should contact GSFC Financial Aid Operations to request a retroactive award as follows:
A notification letter is sent to the attention of GSFC Financial Aid Operations on institutional letter head requesting a retroactive award. The letter must have the student's name, social security number, terms(s) of award, tier, term hours, award amounts by tuition, fees and books. A copy of the request referencing the program review should be forwarded to the Compliance Team.
If the institution does not concur, the institution must provide GSFC with an explanation as to the circumstances that prevented the student from being awarded the HOPE Scholarship for the terms indicated on the Preliminary Report.
The MANAGEMENT NOTE section generally does not require a response. However, it is expected that the institution will examine the disclosed information and address the situation accordingly, if needed. The Preliminary Report will give an explanation of what was observed during the Compliance Review. If the institution needs additional information, a request for further explanation should be added to the institution's response to the Preliminary Report.
After the institution submits its response to the Preliminary Report, the responses and all the supporting documentation will be reviewed by the Compliance Officers. Thirty (30) calendar days later, the institution's President, will receive a formal Final Report Letter (see Attachment F) and a formal Final Report (see Attachment G) via secured email. The Institutional Officers will receive a copy of the Final Report Letter and Final Report. The Final Report Letter contains the date the institution is expected to submit a response to the Final Report and instructions in the remittance of any monetary liabilities. Like the Preliminary Report Letter, the Final Report Letter will contain a list of each finding type. A cover sheet follows the Final Report Letter, which contains cursory information about the on-site Compliance Review with the institution's name, date of review, Compliance Officers conducting the review, list of the institutional officers, and the fiscal year (see Attachment H). The Final Report is constructed very similar to the Preliminary Report. However, a noticeable difference from the Preliminary Report to the Final Report, the Final Report will not contain the sub-section where the institution may concur or not concur with the finding nor the respondent's signature, title and date. The Final Report will address all the sections on the institution's response to the Preliminary Report. For the findings the institution concurs with, the findings may be Closed with no further action required by the institution. For example; a finding of IRD (Incorrect Reporting of Data) and INV (Incorrect Invoicing), requires a Data Correction Request form from the institution. After the Compliance Officers reviews the forms, the finding should result in a Closed status and noted on the Final Report. A finding can also remain Open due to additional requirements or documentation needed from the institution or the remittance of funds back to GSFC. With both a Closed and an Open status, there is an explanation located in the requirements sub-section of each finding. An Open finding may be associated with a monetary liability where the documentation received did not resolve the finding in order to receive a Closed status. For example; the institution concurs with a GPA finding. The finding will remain Open until the institution returns the monetary liabilities for the term(s) associated with the GPA finding. The Required Corrective Action plans, Student liability and Area Of Concerns will either be Closed or will remain Open depending on whether or not the institution submits a response to each section following the instructions listed on the Preliminary Report.
After the Final Report is submitted, the institution will have thirty (30) calendar days to submit their response. The institution should address those findings that remained Open on the Final Report. If additional documentation (example; academic transcripts, S&G applications, etc.) was not submitted with the institution's response to the Preliminary Report, the institution should submit the documents in their response to the Final Report. It is important to note that the institution has thirty (30) days to submit relevant documentation to Close a finding and relieve any associated monetary liability after the institution submits its response to the Final Report. However, there is an established Compliance Review Appeals Policy (see Attachment I) that allows an institution to appeal a finding that the institution feels it correctly awarded. If there are no appeals or additional documentation submitted for review, the institution should remit any monetary liabilities to GSFC using the remittance device (see Attachment J). The remittance device is pre-populated with the student's name, last four digits of their social security number, fiscal year, award year, term, program, term hours and a section for tuition, fees and books. In remitting funds back to GSFC, the institution should place a check mark in the last column to indicate if funds for this term are included in the refund. After all findings, corrective action plans, student liabilities and area of concerns have been resolved and all monetary liabilities refunded to GSFC, the institution's President will be issued a Closure Letter (see Attachment K) with a copy sent to the Institutional Officers. The Closure Letter will acknowledge the receipt of funds remitted back to GSFC as a result of the monetary liabilities associated with the review. The institution's contact person will later receive a survey from the Compliance Team requesting their input on the Compliance Review process. The administration of the State's Scholarship and Grant programs is challenging given changes in the program regulations, new staff hires, etc. Sometimes, the Compliance Review process identifies an institution's need for training. In this situation, the institution will receive a Compliance Review Training Letter (see Attachment L) referring the institution to the GSFC Learning Resources Team (LearningResources@gsfc.org) for training. An excellent resource, the Learning Resource Team can assist the institution with any training needs necessary to the institution for the proper administration of the State's Scholarship and Grant programs. The Learning Resource Team will contact the institution to schedule a time and location for training. In addition, the Georgia Student Finance Commission Program Administration Team (ProgramAdministration@gsfc.org) can assist institutions in answering any regulatory questions about financial aid. However, any specific questions concerning the Compliance Program Review of your institution should be addressed to the Compliance Team. The GSFC Compliance Team is dedicated to our mission to work with the Georgia institutions in the proper administration of the State Scholarship and Grant Programs so that we can all be good stewards of State funds. The GSFC Compliance Team encourages all institutions to contact us at ComplianceTeam@gsfc.org any time prior to, during, or after the review for assistance in answering Compliance related questions or providing clarification about the Compliance Review process. You may also contact Richard Hawkshead, Vice President of Internal Audit & Compliance, at 770-724-9012 or Richard@gsfc.org, should you have any questions or comments.
Read Part I of this series here.
Georgia Student Finance Commission 2082 East Exchange Place Tucker, Georgia 30084 (770) 724-9000 or 1-800-505-GSFC (4732) FAX (770) 724-9089