Glenn Bogart Compliance

Title IV compliance assistance and administrative litigation since 1992

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On-site compliance review service:

 Can you afford not to do this?

One compliance error, multiplied by hundreds of student files, can put a school into the dumpster overnight. 

There is not a financial aid director on earth who knows everything (not that I know everything, either).  What I do know, though, as a result of working with many schools for many years, all across the nation, is how ED's program review function works.  I know what they're looking for, and I know what they're finding -- so I can look for the same things. 

Dealing with program reviews all the time gives me a perspective that no financial aid director can possibly have.  And in writing appeals of final determination letters, I have to stay abreast of the administrative case law -- so I know how the administrative judges deal with ED's findings, too. 

In the process of checking out a school's compliance, I often find money on the table that's theirs for the taking.  How? 

As often as not, the return of Title IV funds turns out to be a problem -- and if a school isn't doing returns of Title IV funds correctly, half the time they're sending back too much. 

Another one:  failure to do professional judgment adjustments when appropriate.  At least 90% of the schools I visit are guilty of this.  When I fix that, my on-site review pays for itself, many times over!

And how about this:  ED policy has changed, such that now you can keep a lot more Pell money when a student drops out before 30 days, in many cases.  Many schools are not taking advantage of this, and it costs them hundreds of dollars every time a Pell recipient drops out in the first 30 days -- which is precisely when most of the ones who drop out within the first term end up doing it!  If you haven't seen your net Title IV revenue on early drops go up dramatically in recent years, you're probably doing it wrong.

If you don't use my on-site compliance review service, there's a very good chance that you will continue to give away money unnecessarily, and that you will continue not to get money that ought to be yours. 

Can I guarantee that my visit will save your school more than it costs?  Nope.  But that's what usually happens, so it's a pretty good bet. 

Put my experience to work for your school.  Call 205 249-5453 today! 

Program review response and appeals services:

If there's real money at stake, hire a professional! 

God bless financial aid directors.  They have a very hard job, and most of them do it well -- even the ones who get into difficulties in a program review.

And some of them are fighters, too.  They can't wait to respond to that program review report, to straighten out those reviewers who got it all wrong.  Big mistake!

Some, on the other hand, just can't wait to agree with every finding and perform every crazy file review that has been demanded.  Another big mistake!

The point is, responding to a program review or OIG audit or inspection is an art, and very few people are masters at it.  I will tell you without fear of contradiction that I am.  You should view your program review or audit as a serious adversarial matter, because that is what it is! 

Unless you have somebody at your school who has responded to over a hundred ED program reviews and OIG audits and inspections, and who has lots of experience dealing with ED's Office of the General Counsel and Office of  Hearings and Appeals, you need to get an outside professional to do this for you, or at least to assist your counsel in doing it.  Put my years of experience to work for you.



-- Juris Doctor, 1986, Western New England University, Springfield, Massachusetts.  Darned right, it's accredited!

-- Bachelor of Arts, 1974, Southern Illinois University, Carbondale, Illinois.  It is accredited, too.  Moreover, the school was listed in "Playboy" as a top 10 party school when I decided to go there.  A better recommendation could not be had, in those days.


Independent consultant, 1992 to present.  I do program review responses and appeals, and I also do on-site compliance reviews.  But you already know that, having read this far.

Director of Internal Audit and Compliance, 1992, Phillips Colleges, Inc., Gulfport, MS.  Responded to literally dozens of program reviews and OIG audits/inspections.  Designed and implemented internal audits, supervising a staff of four.  Hey, it wasn't my fault they went down the drain.  I did my best to help get 'em off, but sometimes you run out of money before you run out of appeals.

Vice-President, Student Financial Aid, HCTIA, Inc., Birmingham, Alabama, 1987-92.  Directed financial aid operations and policy for a group of more than 20 schools.  Dusted it up a bit with ED, too.  Why can't we all just get along?

Program Review Officer, U.S. Department of Education, Atlanta and San Francisco regional officer, 1979-82.  Performed program reviews at all types of schools, from big universities to beauty colleges.  Placed in charge of audit review project when Washington got behind.  Several cash awards for sustained superior performance.  I know, maybe that's not saying much . . .