One of the functions of the U.S. Department of Education is to oversee the Federal Student Aid programs to ensure they are administered correctly and that institutions are meeting the FSA requirements for institutional eligibility, financial responsibility, and administrative capability.

School Participation Divisions review information about each title iv approved school from a variety of sources including accrediting agencies, state licensing boards and agencies, student complaints, and of course, financial and compliance audits.

This information is evaluated by ED and FSA to assess the potential risk to the FSA programs and if necessary, act to investigate a school. One of the ways ED does this is by conducting program reviews at schools that exhibit certain indications of problems or pose a potentially significant risk of failing to comply with the rules and regulations governing title iv participation.

Knowing what to watch out for can help you avoid compliance problems.

These findings represent data ED reported based on findings from Program Review audits and compliance examinations reports conducted by FSA and published in the last twelve months for fiscal year 2019.

  1. NSLDS Roster Reporting: Student Status – Inaccurate/Untimely Reporting
  2. Verification Violations
  3. Entrance/Exit Counseling Deficiencies
  4. Return of Title IV (R2T4) Calculation Errors
  5. Student Credit Balance Deficiencies
  6. Crime Awareness Requirements Not Met
  7. Consumer Information Requirements Not Met
  8. Drug Abuse Prevention Requirements Not Met
  9. Inaccurate Recordkeeping
  10. Lack of Administrative Capability


Findings like these are preventable.

Higher Ed Executives provides colleges and universities with objective and confidential assessments that can help you uncover unknown compliance problems and improve title iv administrative and operational procedures and processes.

Our comprehensive assessments cover the full spectrum of FSA requirements for institutional eligibility, financial responsibility, and administrative capability.

Call us today for a free no-obligation consultation and to find out how our assessments can work for you.

Institutions with questions about Title IV and compliance with Federal Regulations related to Federal Student AId Programs are welcome to contact our office for assistance.


Responding to an audit or program review can be overwhelming, particularly for schools with limited financial aid office personnel. Whether your school is required to implement corrective actions, perform file reconstruction and aid recalculation, or simply prepare a response or appeal, having a partner you can rely on will minimize the burden on your financial aid office while giving you the expertise and support your school needs to resolve even the toughest issues.

Our subject matter expertise covers a wide range of regulatory and compliance issues facing colleges and universities. With our hands-on experience, we can help you resolve findings and reduce potential liabilities from an audit or program review quickly and without disrupting your day-to-day operations.

We take the stress out of audits and program reviews: 

  • Review findings cited in audit reports or program review determinations
  • Research regulatory issues and questions
  • Perform required file reconstruction and award recalculation
  • Develop and implement corrective action plans
  • Assist with Heightened Cash Monitoring and Reimbursement
  • Prepare responses and appeals to the U.S. Department of Education

Don’t let the pressure of an audit or program review disrupt your financial aid office operations. Our audit and program review resolution services help your financial aid staff stay focused on administering financial aid for your students.

We’re here when you need us.

Call today for more information


Institutions with questions about Title IV and compliance with Federal Regulations related to Federal Student AId Programs are welcome to contact our office for assistance</strong>.



West Virginia’s Public Colleges recently made the news when the Department placed more than a dozen schools in the state on Heightened Cash Monitoring after the schools failed to provide their audit on time. It’s extremely rare to see a public school placed on Heightened Cash Monitoring since public schools are backed by the “full credit and faith of the state” but the Department cited the State’s colleges for their demonstrated lack of administrative capability over the late and missing audits. So let’s look at the ten reasons a school gets placed on HCM.


Accreditation Problems – Includes accreditation actions such as the school’s accreditation has been revoked and is under appeal, or the school has been placed on probation.

Administrative Capability – Concerns about the institution’s ability to manage the Title IV programs including student file maintenance, record retention, and verification. 

Audit Late/Missing – School did not submit their audit by the due date and is considered not financially responsible.

Audit (Severe Problems) – School has severe audit findings which could include financial statements, internal controls, and compliance with laws, regulations, and provisions of contract or grant agreements.

Default Rate – A school’s cohort default rate for Perkins loans made to students for attendance at the school exceeds 15% or the cohort default rate for Federal Stafford loans or for Direct Subsidized/Unsubsidized Loans made to students for attendance at the school equals or exceeds 30% for the three most recent fiscal years or if the most recent cohort default rate is greater than 40%.

Denied Recertification (PPA Not Expired) – School’s recertification was denied but its Program Participation Agreement has not yet expired.

Financial Responsibility – School has a failing or a zone composite score or other concerns such as unreconciled accounts.

Change In Ownership Problems (Eligibility) – Issues identified with information needed on a Change in Ownership application such as missing/incorrect same-day balance sheet or other needed documentation; or an unreported CIO is discovered.

Program Review – School is being reviewed by the Department as part of its normal oversight and monitoring responsibilities or as a result of concerns regarding the school’s administrative capability and financial responsibility.

Program Review (Severe Findings) – School has potential of severe program review findings such as failure to make refunds or return of Title IV funds.



Many schools believe that using a third party financial aid servicer protects them from compliance problems. The surprising truth is that often the likelihood of compliance problems actually increases when schools engage a third party processor. At the most recent FSA conference in Atlanta, ED was very clear that they do not endorse or approve third party servicers, and only recently began auditing them in program reviews.

The U.S. Department of Education has found as part of their third party servicers program reviews that many servicers share the same kinds of findings and violations and institutions that contract with third parties to perform some aspect of administering aid to students, are severally liable for any issues resulting from their servicers improper practices and shortfalls.

ED put together a top 16 list of findings common among third party servicers citing too many problems that put schools at risk.

If you use a third party servicer now or are considering using one, be sure to ask them for a copy of their most recent program review report before you get locked into a contract that may be difficult to break.

  1. Inadequate Contract / Written Policies and Procedures
  2. Inadequate Record Keeping
  3. Failure to Maintain Adequate Audit Trail
  4. Failure to Perform Proper Reconciliation
  5. Satisfactory Academic Progress Deficiencies
  6. Failure to Resolve Conflicting Information
  7. Verification Violations
  8. Student Credit Balance Deficiencies
  9. Return of Title IV Deficiencies
  10. Leave of Absence Deficiencies
  11. COD – Inaccurate/Untimely Reporting
  12. NSLDS – Inaccurate/Untimely Reporting
  13. Entrance/Exit Counseling Deficiencies
  14. Inadequate Notices and Authorizations (Required Disclosures)
  15. Failure to Report Third-Party Servicer
  16. Standards of Administrative Capability

Want to learn more about managing your institution’s risk? Click here


The Higher Education Act of 1965, as amended,  requires annual financial and compliance audits of Title IV HEA programs for all institutions that participate in in FSA programs. Schools are required to arrange for regular independent audits that include the operation of the Federal Student Aid programs.
According to the U.S. Department of Education, these are the top ten audit findings from institutions annual FSA Audits conducted by IPAs and CPAs.
  • Repeat Finding – Failure to Take Corrective Action
  • NSLDS Roster Reporting – Inaccurate/Untimely Reporting
  • Return to Title IV (R2T4) Calculation Errors
  • Return to Title IV (R2T4) Funds Made Late
  • Verification Violations
  • Pell Grants – Overpayment/Underpayment
  • Qualified Auditor’s Opinion Cited in Audit
  • Entrance/Exit Counseling Deficiencies
  • Student Credit Balance Deficiencies
  • Improper Origination of Direct Loans

Want to learn more about managing your institution’s risk? Click here