Surviving a Title IV Program Review

Rhonda Pickerel, Manager, and Julie Setzer, Senior Specialist, Education, Nonprofit, and Commercial Services

Federal Program Review—this term strikes fear into the hearts of financial aid administrators everywhere. The Federal Student Aid (FSA) division of the US Department of Education (ED) conducts periodic Federal Program Reviews to assure that colleges and universities who administer Title IV aid are abiding by the provisions that govern Title IV programs. After many years of deferring program reviews for schools whose A-133 annual audits did not indicate problems, FSA has stepped up their program review schedule over the past year and a half. This action has greatly increased the chances of schools undergoing program reviews, regardless of audit status. Your college or university could be next!

So, what exactly is a Federal Program Review, and how does your school prepare for it before you are selected for one? A Federal Program Review is conducted by two or more reviewers from ED to assure your school is in compliance with Title IV regulations. This involves either an in-person or virtual review, normally a week in length, to review student records as well as other institutional documents. There are always follow-up questions and requirements from the reviewers as well. The reviewers will ask your school to provide a list of students who received Title IV aid during certain academic years, as well as all of the school’s catalogs, academic calendars, academic and financial aid policies, and consumer information, among many other types of documentation. The reviewers will select students from the reports that your school provides and do an in-depth review of each student’s Title IV aid that was awarded and disbursed, and all other circumstances that may impact Title IV eligibility. Your school may be subject to a limited-focused review or a full scope review depending on the requirements the reviewers have. Schools that have Title IV findings or violations may be subject to liabilities (monetary amounts that schools have to repay to ED due to improper receipt or disbursement of Title IV funds) and/or fines (more serious misconduct or other violations).

Schools usually have up to four weeks to prepare for the review but may have a shorter time frame depending on when the announcement is made and when the review is scheduled to begin. Four weeks or less is a tight time frame for such a review and can throw an institution into a frenzy to secure all required documents as well as determine if there are any issues to be aware of prior to the review. One way to relieve much of the stress of preparation is to have an outside consulting firm (with professional staff experienced in Title IV regulations and Federal Program Reviews) conduct an Operational Review ahead of time, to determine if the school meets Title IV compliance standards and if there are problem areas that can be remedied prior to any Federal review. Operational Reviews, such as the ones conducted by Attain’s experts, are comprehensive and often more thorough than some Federal Program Reviews.

What happens during an Attain Operational Review, and how does it help your institution? Our comprehensive assessment evaluates the people, processes, and technology that comprise your financial aid operations. Following our review, we provide schools with a customized action plan to reduce compliance risks, improve efficiencies, and streamline the flow of paper and electronic data.

Similar to a federal program review, our assessment starts with an on-campus or virtual visit during which we interview staff, and review institutional eligibility documents, policies and procedures, and student files. We also analyze the staffing level and expertise in the financial aid office, examine how operations are coordinated at the institution, and evaluate the general use of technology to support financial aid processing.

By conducting an inventory of existing policies and procedures and reviewing how the policies and procedures are applied in a sampling of student files, we can help uncover any processing gaps or compliance shortfalls. We then provide detailed recommendations to help put you on the right track for meeting applicable regulatory requirements and best practices.

Attain’s comprehensive assessment will help ensure your school is prepared for a Federal Program Review; and we will specifically review areas that are identified by ED as part of their Top 10 Program Review Findings:

Top Ten Program Review Findings

1.          Student Status – Inaccurate/Untimely Reporting

2.          Return to Title IV (R2T4) Calculation Errors

3.          Entrance/Exit Counseling Deficiencies

4.          Verification Violations

5.          Consumer Information Requirements Not Met

6.          Satisfactory Academic Progress Policy Not Adequately Developed/Monitored

7.          Student Credit Balance Deficiencies

8.          Lack of Administrative Capability

9.          Account Records Inadequate/Not Reconciled

10.        Crime Awareness Requirements Not Met


Your institution has already been selected for a Federal Program Review. How can you obtain assistance with preparation? Attain can assist with preparation for a Federal Program Review as well as resolution of findings and responses to ED. Our consultants have decades of experience both working in college and university financial aid offices as well as consulting with schools in need of our services. Contact us directly at with any questions or to learn more about our services.


About the Authors

Rhonda Pickerel 

Rhonda Pickerel is a Manager in Attain's Education, Nonprofit, and Commercial Services practice and oversees the Financial Aid Management and Student Services (FAMSS) division. She has over 30 years of financial aid and higher education experience working with public universities and colleges, as well as private, for-profit, and nonprofit institutions. During her 14-year career as a consultant, she has managed several financial aid reviews for clients, including “mock” program reviews, Title IV compliance reviews, processing reviews, and general operational reviews.

Julie Setzer is a Senior Specialist in the Financial Aid Management and Student Services (FAMSS) division of Attain’s Education, Nonprofit, and Commercial Services practice. She has over 34 years of financial aid and higher education experience working with public colleges and universities as well as private nonprofit institutions. During her six years as a consultant, she has provided interim management services at a number of schools as well as taken part in several “mock” program reviews, Title IV compliance reviews, processing reviews, and general operational reviews.