Create a Policies and Procedures Manual to Comply with Federal Regulations
January 24, 2011
Appeared in
Enrollment Management Report and The Successful Registrar
Making sure your institution complies with federal regulations such as those recently released on program integrity can be a daunting task. Directives that apply to you might come from statutes, regulations, the Federal Student Aid Handbook, and Dear Colleague letters.
Beyond understanding what the regulations mean and how they apply to your institution, you also need to create policies and procedures that ensure compliance.
The federal government requires certain things to be put into writing, said Eileen O'Leary, assistant vice president of student financial services at Stonehill College in Massachusetts. It doesn't require institutions to have a policies and procedures manual. But creating one is good business sense, she said. Both O'Leary and Bernie Pekala, director of student financial strategies at Boston College, have created manuals for their offices.
Besides making it easier to administer federal financial aid programs, the manuals are helpful to show to auditors. "It's time well spent because the auditors will look at it and say you are well organized," Pekala said. They are also great resources for staff development and training.
If creating a manual seems like a huge job, plan to do it over time. "We didn't go out and decide ‘This month we're going to make a policies and procedures manual,'" O'Leary said. Instead, her office added policies as they came up, and the manual has been a work in process for about eight years.
"Start it and don't look at it as a daunting task. Every step forward is a step toward completion," Pekala said.
Follow a process you can manage
O'Leary and Pekala took different approaches to creating policies and procedures manuals for their offices. O'Leary started the process about eight years ago. Her office created policies and procedures as they came up. Staff members who write the processes follow a template that includes tasks that should be completed in a situation, what documentation is acceptable, and what action the staff member would take. When the institution implemented a Banner student information system, staff members added the details of what to do on each screen in the system.
The manual is saved in a folder on a network drive. Policies and procedures are saved as Microsoft Word documents in folders by topic.
When Pekala came to Boston College 16 years ago, there were some written policies and procedures in various formats. He pulled them together for a manual and filled in the gaps. A graduate assistant was assigned to work on the project.
Pekala's office revises the manual each time the Higher Education Act is reauthorized or every five years. Staff members also add supplements when a new requirement goes into effect. And each year, the office creates a new document that functions like an executive summary.
He used to print the manual each year, but now he keeps it on the server.
Get help from colleagues
Finding out how your colleagues word policies and what procedures they follow can be very helpful,
O'Leary and Pekala said. Listservs and professional organizations are good places to find information
and examples. But keep in mind that there might be more than one way to handle certain programs
within the federal regulations. For example, O'Leary and Pekala take very different approaches to administering the TEACH Grant.
The National Association of Student Financial Aid Administrators is a valuable resource, O'Leary and
Pekala said. It has a template for a manual, they said. They agreed that it provides useful information for this project but that it can be intimidating. The association also offers the AskRegs service. Members can e-mail questions about the federal regulations, and a NASFAA staff member will answer them. Some of the questions and answers are posted on the association's website.
Staff members should be responsible for writing the policies and procedures for the areas they work in. "Sharing the joy is very important," O'Leary said. "The person important for work-study management should be writing up the policy for that, and the one managing the TEACH Grant should write that. They will be more likely to get it right," she added.
The staff members should bring drafts to staff meetings where everyone can read them and make
corrections, she said.
It's a good idea not to impose hard deadlines for this project, Pekala said. But you should request progress reports from staff members, he added.
Not all federal regulations apply to your office. For example, the campus police are responsible for regulations regarding campus crime. That's why it's important to trust your colleagues to comply, O'Leary said. But someone on campus needs to be responsible for overall compliance, she said.