Combating Fraud While Protecting Aid for True Students May 21, 2014 - PowerPoint PPT Presentation

Combating Fraud While Protecting Aid for True Students May 21, 2014 • The webcast will begin at the top of the hour. • There is no audio being broadcast at this time. • If you need assistance, contact Blackboard Collaborate: 866-388-8674. • An archive of this webcast will be available on the WCET website next week. wcet.wiche.edu 1

Combating Fraud While Protecting Aid for True Students May 21

Combating Fraud While Protecting Aid for True Students Welcome. • Megan Raymond, WCET Thank you Blackboard • Collaborate! If you have technical issues: • • Call 866-388-8674 Use the chat box for • questions. Archive, PowerPoint, and • Resources available next week. wcet.wiche.edu 3

Questions from the Audience  If you have a question during the presentation, please add your questions to the chat box. We will monitor the chat box and have time for Q&A at the end of each section. wcet.wiche.edu 4

Moderator Luke Dowden Director, Office of Distance Learning University of Louisiana at Lafayette wcet.wiche.edu 5

Presenters Joseph Agins Kishia Brock Ruby Miller Director, Ethics and Compliance Vice President of Student Associate Dean of Affairs and Advancement, Enrollment Services, Investigations, Rio Salado College Rio Salado College Apollo Education Group, Inc. wcet.wiche.edu 6

Preventing Federal Student Aid Fraud Rings Joseph Agins Director, Ethics and Compliance Investigations, Apollo Education Group, Inc. wcet.wiche.edu 7

Preventing Federal Student Aid Fraud Organized Schemes Joe Agins Director Ethics and Compliance Investigations Apollo Education Group/University of Phoenix

SFA Fraud in the News SFA Fraud in the News (Video) wcet.wiche.edu

SFA Fraud in the News

SFA Fraud in the News

SFA Fraud in the News Watch News Clip

Regulatory References In Summary  US Department of Education > Standards of Administrative Capability > Resolving Conflicting Data  C.F.R § 668.16(f) – An institution must develop and apply an adequate system to identify and resolve discrepancies in the information that the institution receives from different sources with respect to a student's application for financial aid under Title IV, HEA programs…  C.F.R § 668.16(g) – An institution has an obligation to refer to the Office of the Inspector General of the Department of Education for investigation any credible information indicating that an applicant for Title IV may have engaged in fraud or other criminal conduct… wcet.wiche.edu

Regulatory References In Summary  Fighting Fraud With the Red Flags Rule  Issued by the Federal Trade Commission (FTC)  Requires many businesses and organizations to implement a written Identity Theft Prevention Program designed to detect the warning signs — or "red flags" — of identity theft in their day-to-day operations. By identifying red flags in advance, businesses will be better equipped to spot suspicious patterns that may arise -- and take steps to prevent a red flag from escalating into a costly episode of identity theft. wcet.wiche.edu

Audit Report from Office of Inspector General, U.S. Dept of Education Additional Safeguards are Needed to Help Mitigate the Risks that Are Unique to the Distance Education Environment . U.S. Dept of Ed. OIG. Feb. 2014 http://www2.ed.gov/about/offices/list/oig/auditreports/fy2014/a07l0001.pdf Audited 8 institutions , all sectors, enrollments from 7/2010 to 6/2011 Key risk areas identified :  Verification of student identity  Determination of student’s academic attendance  Calculation of cost of attendance for distance ed students Some recommendations included :  Smaller, more frequent disbursements  Develop a general regulatory definition of “attendance” and distinguish between distance education and traditional campus-based.  Cost of attendance should reflect actual educational needs wcet.wiche.edu 15

Fraud Ring Characteristics   Schemes typically target online and the less- Participants provide personal info to Ring expensive and/or two-year “entry level” Leader, who will register for school, apply for programs federal student aid, and “do all of the homework” to maintain attendance until the funds are disbursed  Fraud “Ring Leader” recruits participants enticing them with an opportunity for free  money Once funds are disbursed, Ring Leader and participant split the funds, stop attending, and the student is not heard from again  Scheme participants typically target vulnerable populations (e.g. younger persons  and/or in economically depressed areas) Scheme ring leaders often attend school themselves as well as helping recruits to attend fraudulently  Most participants never graduated high school or completed a GED program but  falsify admissions Ring leaders will also set up student accounts with stolen identities to avoid having to split the proceeds  Ring Leader often sets student accounts up with one or a few common addresses/phone numbers/emails wcet.wiche.edu

Questions from the Audience wcet.wiche.edu 17

Kishia Brock Ruby Miller Vice President of Student Associate Dean of Affairs and Advancement, Enrollment Services, Rio Salado College Rio Salado College wcet.wiche.edu 18

Institutional Profile  Rio Salado College  1 of 10 Maricopa Community Colleges  Open Access  Tuition  $215 out-of-state online  $81 in-state  Rapid enrollment growth  65,000 credit/non-credit students annually  44,393 online students annually  PeopleSoft School wcet.wiche.edu

Our Experience wcet.wiche.edu

Rio Salado Timeline July 2013 2007-2011 12/2011 – Authentication Aggressive 8/2012 Soft process – all reporting Launch new students July 2011 8/2012 For Fall 2014 - Strategic Working with Identity Decisions Maricopa to Authentication based on data launch approach Districtwide wcet.wiche.edu

Consequences of Fraud  Financial  Reputation/public image  Debt student and institutional  Staff time and resources  Rising cohort default  Staff Morale rates  Reporting  Inaccurate headcount  OIG reporting and FTSE projections  Testifying  Identity theft claims wcet.wiche.edu

Formulating an institutional Approach  Define and Communicate Staff Expectations  What activity constitutes suspicion?  How do we apply a fair and equitable standard?  Risk = Legal, e.g. Office of Civil Rights (OCR)Complaints  Collaborate with Institutions  Lansing Community College  Apollo Group/University of Phoenix  Implement Strategically  Student Success Driven  Student Conduct Driven  Admissions Driven  NOT Financial Aid Driven wcet.wiche.edu

Balancing Act Fraud Access Prevention wcet.wiche.edu

Resources Straw Students Pell Runners Legitimate inquiries Students wcet.wiche.edu

Formulating an Institutional Approach  College-wide effort instead of a “financial aid problem”  Institutional Research  Academic Integrity  Admissions  Student Code of Conduct  Legal  Embedded into Student Success initiatives  Realign student flow  All incoming students seeking a degree or certificate  Authenticate identity  Authenticate prior education  Referrals  Report analytics  Establish new organizational responsibilities  Judicial Affairs Office  Academic Integrity Team wcet.wiche.edu

Redesign the Student Flow Clear Intent Authentication Program Seeker Student Success Supplemental Identity Placement Testing Prior Education Academic Advisement New Student Orientation wcet.wiche.edu

Open Access  Collaborated with Legal  Students quick admit and enroll  They can self-pay and/or go on a payment plan and skip prior learning authentication  Financial Aid process does not begin until prior education and ID are authenticated wcet.wiche.edu

Authentication – College process  Identity – new to college program seekers are required to submit government issued IDs  Process – students quick admit, TO DO items go on their student record. They must submit:  Scanned color copy  Document is reviewed and verified  TO DO items are removed (TO DO items are removed after both required documents are received)  Unacceptable documents are submitted to Judicial Affairs Associate Dean for sanction (Student Conduct Code)  Administrative Hold may be placed on student record  Communication  Auto email notifying student documents have been received  Message in message Center in SIS with detailed instructions  Notes are entered into SIS in the comments section to communicate with other staff around the college  Timeline  3-5 business days to process and remove after both documents have been received wcet.wiche.edu