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External Compliance Program Review

Overview
Program Review Process
     Purpose
     Announcement of Program Review
     Required Documentation
     Entrance Conference
     Review of Materials
     Program Review Communication
     Exit Conference
     Preliminary Program Review Report
     Final Program Review Report
Institution Documentation & Security
Compliance Department Systems of Internal Control
Most Common Findings
Contact Information

Overview

The Illinois Student Assistance Commission (ISAC) is responsible for the oversight of colleges that administer ISAC gift assistance programs. This includes ensuring program integrity through eligibility, fund disbursement, and payment reconciliation. The review of an institution’s financial aid records gives ISAC a measure and process to safeguard the assets it has entrusted to colleges, to check the accuracy and reliability of the data submitted, and to ensure and protect the overall integrity of ISAC’s programs.

Program reviews will be conducted on a schedule that is determined based on a risk assessment and the availability of ISAC resources. ISAC conducts all program reviews in accordance with IL Admin Rules, General Provisions Section 2700.60.

The majority of program reviews are conducted at ISAC. The program review is typically announced; however, ISAC reserves the right to make unannounced reviews. ISAC shall have access to all records related to ISAC programs, and institutions are required to provide requested documents in a timely manner.

If a program review is conducted at ISAC, an institution must send the appropriate documentation to ISAC. An institution will have the opportunity to respond to the preliminary findings before a final report is issued. Program Review findings may be appealed in accordance with IL Admin Rules, General Provisions Section 2700.70.

Program Review Process

Purpose

The purpose of a program review is to evaluate compliance with state and federal rules and regulations, analyze an institution’s administrative capability and suggest improvements that can be made in procedures and recordkeeping, ensure that ISAC gift assistance programs and the Federal Family Education Loan Program are administered correctly, ensure that award determination was calculated accurately and to identify liabilities that may be owed to ISAC.

The following are steps of a program review.

  • Announcement of Program Review
  • Entrance Conference
  • Review of documentation
  • Exit Conference
  • Preliminary Program Review report
  • Final Program Review Report

Announcement of Program Review

The first step of the program review process includes notifying the college of the review by sending an announcement letter, via e-mail, no later than 30 days before the date scheduled for the program review. The announcement letter, Program Review Questionnaires and the Program Review Material Listing are sent to the Financial Aid Director with copies to the President. The letter formally announces the review date, the academic years that will be covered, programs to be reviewed, documentation that must be submitted to ISAC in advance and date the materials are due back to ISAC.

Required Documentation

The following items are required for the program review:

  • ISAC Program Review Questionnaires (included with the announcement letter) 
  • Program Review Material Listing (i.e., school materials such as hard copy of the school catalogue to review consumer information & compliance, policies and procedures for awarding state funds, withdrawal and satisfactory academic progress policies)
  • Program review samples (student records for the selected samples, such as admission records, financial aid transcripts, registration, attendance & enrollment reports and verification documents)

Entrance Conference

The examiner will conduct an entrance conference with institution’s officials (i.e., staff members from the financial aid, registrar and business departments) at the beginning of the review. The purpose of the entrance conference is to provide information about the review and the program review process. It also provides the opportunity for the examiner to gather specific financial aid processing information, for example, details pertaining to satisfactory academic progress (SAP) monitoring.

Since the majority of the ISAC’ reviews are conducted at ISAC’s Deerfield office, the entrance conferences are conducted via telephone conference call. The on-site review entrance conferences are conducted at the institution. The entrance conference date is the review date listed on the Program Review Schedule. An Entrance Conference Agenda is provided to the institution.

Review of Materials

The reviewer conducts a thorough examination of the materials provided by the school for each student in the program review sample (randomly selected from all recipients in award years being reviewed) for confirmation of compliance with policies and procedures, to provide recommendations for improvements in administrative capability and identify corrective action needed. Findings that could result in liabilities being assessed are ineligible grant awards, required refunds not made or calculated incorrectly, and award and payment ineligibility issues.

The following are covered in the review testing:

  • institutional eligibility: program eligibility, administrative capabilities and system security;
  • applicant eligibility: student eligibility (specific to each program administrative rules);
  • payment processing: enrollment status, certification/authorization, verification of disbursement and refunds;
  • payment and data reconciliation: institutional fiscal records, timely cancellations/adjustments of awards;
  • file maintenance/record retention: record keeping and policies and procedures; and
  • fiscal responsibility for program funds and accounting practices for the disbursements of funds.

Program Review Communication

Due to the off-site nature of conducting the reviews, e-mails and telephone conferences are the primary means of facilitating the activities of the review between the examiner and the institution. The Program Review Department maintains a shared e-mail box for all program review communication.

During the review of the documents, an e-mail is sent with a list of questions, and a request for additional documentation. The examiner will schedule a specific date and time to review this request, and answer any questions when necessary.

Exit Conference

The examiner will hold an exit or status conference (via telephone conference or on-site) at the end of the program review. The purpose of the exit conference is to address the next steps in the program review process, and to summarize the initial findings. These findings are tentative/preliminary, and the analysis of any additional documentation submitted within 21 business days may result in changes (reductions or additions) to the findings reported. An on-site visit may be necessary based on the institution’s response and supporting documents.

Preliminary Program Review Report

The Preliminary Program Review Report identifies the preliminary findings. The report is provided when the exit conference is scheduled. The institution is given the opportunity to respond to each finding.

Final Program Review Report

The Final Program Review Report concludes all reviews of the institution’s response and supporting documentation. This report is the final conclusion of the review. It identifies each final finding, the institution's response, the final program review determination, and any observations and recommendations. Upon the conclusion of the review of the institution’s response an e-mail is sent indicating the final summary of financial liability. The institution is required to send a refund check upon the receipt of the final summary of financial liability. The Final report is issued to the institution’s President and a copy to the Director of Financial Aid.

Audit findings may be appealed in accordance with IL Admin Rules, General Provisions Section 2700.70.

Institution Documentation & Security

The program review will involve the exchange of confidential information, and ISAC administrative rules require all educational institutions to be responsible for implementing appropriate security procedures to protect the integrity of the data accessed, stored, transmitted or received. The program review materials can be provided via the following:

  • ISAC secure FTP website (available to all institutions participating in the ISAC FTP process for program processing)
  • Scanned documents via e-mail (limited number of documents due to ISAC e-mail file size limitation)
  • Federal Express & UPS Mail Services (personal information must be protected)

All materials and student records must be clearly identified to correspond to the items requested in the Program Review Material Listing and the samples. Links to electronic documents are not acceptable.

Program Review Department Systems of Internal Control

The Program Review Department ensures that all electronic communication of data is encrypted & password protected. Full Social Security numbers do not appear in the reports; only the last four digits of the Social Security number (i.e. XXX-XX-1234) are listed.

All work papers and institutional materials provided for the review are kept in a central work area with restricted access that is locked daily. The Program Reviewers are required to return all work papers to the central work area and close all open documents on work computers at the end of the workday. In addition, all of the closed program review files are maintained in a locked file room. This protocol is also maintained for on-site reviews.

Most Common Findings

The most common program review findings include:

  • Approved MAP Award Letter language not used
  • Illinois residency not verified
  • Reconciliation issues
  • Overbilling
  • Satisfactory Academic Progress policy either not in compliance or not monitored

All of the common findings listed above are addressed within pages for each gift assistance program in the FAA area on this website and are summarized in a Program Review Frequently Asked Questions document.

Contact Info

Program Review Department - F & A Division
Illinois Student Assistance Commission
1755 Lake Cook Road
Deerfield, IL 60015-5209
866.247.2172 ext. 18563
isac.programreviews@isac.illinois.gov