‘P4’ Approach Can Yield Program Review Success
To handle federal financial aid program reviews most effectively, take the “P4” approach.
Greg Wallis, Harrison College vice president of finance, outlined his “P4” steps for the more than 130 participants in USA Funds®’ recent Higher Education Compliance webcast.
Wallis has coordinated six separate program reviews for a national private career school. Based on the lessons he’s learned through his own experiences, Wallis recommended focusing on these four Ps to navigate the U.S. Department of Education review process:
  • Preparation.
    • Immediately contact the Department representative identified as the lead reviewer.
    • Plan the logistics.
    • Assign responsibility and due dates for the materials requested in advance, especially the student data.
    • Be extremely mindful of the regulations for personally identifiable information.
    • Inform/engage outside regulatory assistance.
    • Identify where you might have gaps/issues.
  • Presentation.
    • Prepare two complete sets of binders of requested information.
      • Provide one to the Department’s review team in advance.
      • Keep one for your records so that you know exactly what you have provided to the Department.
    • Organized, tabbed exhibits with a table of contents.
    • Follow the PII requirements, using sealed envelopes and packages you can track.
    • Present only what is requested.
  • Personalities.
    • Appoint a single point person on your team who will work well with the Department to handle reviewers’ requests, and to share all school-presented materials.
  • Pursuit.
    • Exit meeting:
      • Ask questions, get details on issues cited, and follow up on issues as needed.
    • Touch base with the reviewer in the following weeks and months.
    • Program review letter:
      • Immediately review and provide to outside regulatory assistance as needed.
      • Know your deadlines.
    • Program review response:
      • Draft, review, redraft and finalize.
      • Be complete.
      • Cite statutes and regulations.
To learn more higher education compliance tips, and to find out how USA Funds Compliance AdviserSM can help you assess your level of compliance with the administration of Federal Direct Loan Program requirements, see the webcast recording. Select Listen on the USA Funds Compliance Adviser information page to access the recording.
Contact USA Funds for additional information about USA Funds Compliance Adviser.​