Common Program Review Issues

USA Funds® performs program reviews at schools to ensure that schools are meeting all regulatory requirements and guarantor policies in the Federal Family Education Loan Program. Correcting the most common issues found during these reviews will result in improved compliance and better service to students.

Here are some of the most common issues:

  • Inconsistent admissions requirements. Schools must obtain a copy of a student’s high school diploma and properly admit “ability to benefit” students, if required by the school’s policy.
  • Missing SAR or ISIR documentation. Student Aid Report or Institutional Student Information Record documentation missing from the borrower’s file at the time a student’s loan was certified, or discrepancies in SAR/ISIR data can contribute to problems in a program review.
  • Improper verification. Issues include not properly verifying SAR/ISIR information, including required documentation to account for an override of dependency status and missing or unsigned tax return documents.
  • Improper loan certification. The loan period, cost of attendance, Expected Family Contribution and estimated financial aid all must be calculated for the same length of time.
  • Student budget exceptions. Using incorrect student budget figures as a component of the cost of attendance and failing to include FFELP loan fees in calculating the borrower’s cost of attendance are common errors.
  • Improper loan proration. Schools must use the proper calculation for loan proration.
  • Failure to notify of the right to cancel EFT disbursements. Schools must notify student-borrowers of their right to cancel all or part of their Electronic Funds Transfer loan disbursement.
  • Inconsistent application of satisfactory academic progress. Program review issues arise when a school does not follow its internal procedures for satisfactory academic progress.
  • Inaccurate means to determine unofficial withdrawals. Schools are responsible for developing a method to determine whether a Title IV aid recipient has ceased attendance without notifying the school.
  • Incorrect Return of Title IV Funds calculation. Schools must properly calculate the return of Title IV funds when a student completely withdraws from all classes. The Return of Title IV Funds calculation is required for all refunds made on or after Oct. 7, 2000.
  • Out-of-date entrance- and exit interview forms. Schools must inform borrowers about the Master Promissory Note process, the extended repayment plan option, and availability of the Office of the Ombudsman.
  • Enrollment reporting discrepancies. Discrepancies between the financial aid and registrar offices must be reconciled in order to have a clean program review. In addition, schools must return enrollment reports in a timely manner.
  • Inaccurate or incomplete crime statistics. Schools must provide accurate and complete crime statistics to all students on an annual basis.

For more information about common findings during program reviews, refer to the Common Manual. If you have specific questions about program reviews or other Title IV aid issues, contact USA Funds AskPolicySM.