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Session Overview
A Personal Experience
Contingency Planning
Reference Information
General Guidance
Dear Colleague
Letter GEN-04-04
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A Personal Experience
Cathy Brown
University of West Florida
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What’s The Worst That Could Happen?
Earth
Wind
Fire
Water
Humans
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"If you fail to plan, then you plan
to fail"
Evacuation Plan
When to close, when to evacuate?
Who’s
in charge?
Who stays, who goes?
Where to go and how?
When to return?
What can you take in 15 minutes and how?
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"If you fail to plan, then you plan
to fail“ (continued)
Security/Safety
Public
Data
Communications
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“Not Just Back, Better”
Taking care of faculty and
staff
Immediate relief for students
Putting the pieces back together; recovering
information
It will be better
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What We Learned
Know the likely hazards you face
and plan accordingly
Back up your data off-site
Identify building and
floor wardens
Have personal emergency kits at the ready
Training, training, training
People care. Let them help.
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Contingency Planning
Mary Haldane
Federal Student Aid
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What Are the Different Types of Emergency Plans
Occupant
Emergency Plan
Ensures Safety of Occupants of a Building
Evacuation
Shelter in
Place (SIP)
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What Are the Different Types of Emergency Plans
(continued)
Disaster Recovery Plan
Ensures the Recovery of IT Systems Contingency
Plan
Ensures the Continuation of Essential Functions Across a Wide Range of Potential Emergencies to Provide For:
Business Process Continuity
Organizational Continuity
IT Continuity
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Why Develop a Contingency Plan?
Ensure the Safety
of Students, Faculty, Staff, and Visitors
Prepare Staff and Students
for Any Emergency
Ensure the Continuation of Essential Functions During an Emergency
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Why Develop a Contingency Plan? (continued)
Minimize Damage and
Losses Resulting From an Inability to Perform Essential Functions
Facilitate
Decision Making During an Emergency
Achieve a Timely and Orderly Recovery From a Disruption of Services Caused by an Emergency
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How to Develop a Contingency Plan – A
Five Point Plan
Contingency Plan Development Team
Resources
Roles and Responsibilities
Business
Impact Analysis
Requirements, Processes, and Interdependencies for Contingency Planning
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How to Develop a Contingency Plan – A
Five Point Plan (continued)
Continuity Strategies
Cost, System Sensitivity, and
Recovery Time Objectives
Plan testing, training, and exercise
Plan maintenance
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Important Components of a Contingency Plan
Response Team
Roles:
Senior
Management Team
Damage Assessment Team
Continuity Activities - Lead and Team
Members
Resumption Activities - Lead and Team Members
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Important Components of a Contingency Plan (continued)
Training
Testing
Alternate
Facilities
Location
Equipment
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Important Components of a Contingency Plan (continued)
Notification/Activation Procedures
Notification
of Senior Management Team
Performing Damage Assessment Procedures
Essential Functions, Their
Priority Order for Recovery, and When They Need to Be Functioning
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Important Components of a Contingency Plan (continued)
Continuity Activities
Activities
to Perform to Keep Essential Functions Working
Resumption of Normal
Activities Procedures
Activities to Return the Institution to Normal Operating Procedures and Processing Capabilities
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Important Components of a Contingency Plan (continued)
Communication Plan
Internal
Procedures and Templates
External Procedures and Templates
Accounting for Faculty, Staff,
and Students Procedures
Contact information for faculty, staff, students/parents, and internal and external dependencies
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Important Components of a Contingency Plan (continued)
Vital Records
Location
Media
Access
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Important Components of a Contingency Plan
Data Backup and
Off Site Storage
Awareness and Education Activities
Flyaway Kits
Cell Phones and
Chargers
BlackBerries and Chargers
Identification
Contingency Plan
Occupant Emergency Plan
Disaster Recovery Plan
Vital Records
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Lessons Learned – Contingency Planning
People Are the First
Priority
Practice – Practice – Practice
Practice Real Scenarios
Assume No Essential
Services
Make Common Sense Decisions
Be Prepared to Make Decisions Outside of “Rules”
Involve Local Authorities
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Lessons Learned – Contingency Planning (continued)
KISS Principle
A Contingency
Plan Is a Living Document
Keep Plan Current
Confirm Communications Are
Received
Backup
Essential Data
Response Team
Phone Tree Callers
Pre-Position Vital Records at Alternate Site
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Lessons Learned - Occupancy Emergency Planning
Establish Building
Captains
Establish Floor Captains and Teams
Emergency Supplies
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Reference Information /
General Guidance
Anthony Jones
Office of Postsecondary
Education
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Reference Information
Dear Colleague Letters, Federal Registers, and Electronic
Announcements
General guidance for Title IV participants affected by a
disaster: GEN-04-04 (FP-04-03)
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Reference Information (continued)
Hurricanes Katrina & Rita:
Electronic Announcements (posted
on IFAP beginning 09/02/05) on topics including transfer students,
deadline extensions, adding federal school codes, CPS and COD technical support, etc.
Federal Register (09/09/05) announcing deadline extensions
IFAP links to additional information
09/11 Terrorist Attacks: GEN-01-11, GEN-01-12, GEN-01-13, all posted on IFAP 09/2001
Disaster Letter 99-28, posted on IFAP on August 5, 1999
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Reference Information (continued)
Federal Student Aid Handbook
Regulations
Professional Judgment
FFEL and
Direct Loans
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Regulatory Guidance
Regulatory guidance is in 34 CFR 682.211(f)(11)
-- allows loan holder to grant administrative forbearance for
up to 3 months if lender determines borrower’s ability to make payments has been adversely affected by:
Natural disaster;
Local or national emergency (as declared by appropriate government agency); or
Military mobilization
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Regulatory Guidance (continued)
Similar treatment for Federal Direct Loans
DCL
GEN-04-04 (FP-04-03) clarifies that this applies to Federally-declared disasters
as well
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General Guidance for Disasters
Unless otherwise noted, guidance applies
to Federally-declared disaster areas (individual or household assistance)
FEMA website
is official source (www.fema.gov)
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General Guidance for Disasters (continued)
Guidance applies to all
Title IV borrowers, students, and families who, at the
time of the disaster, were:
Residing;
Employed; or
Attending eligible postsecondary institution, in Federally-declared disaster area.
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General Guidance for Disasters (continued)
Guidance also applies to
institutions, lenders, and guaranty agencies impacted by a disaster
Additional
guidance may be issued that supplements or supercedes GEN-04-04 (usually through posts to IFAP)
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General Guidance for Disasters (continued)
When Federally-declared disaster has
impacted a school’s ability to administer Title IV programs,
DCL GEN-04-04 provides relief or specific guidance on how a school should proceed.
In many cases in which ED could not provide standard or across-the-board relief, we direct the school to contact their Case Management team for a case-by-case analysis of the school’s situation.
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General Guidance for Disasters (continued)
Always document when deviating
from otherwise required actions
Must document when invoking GEN-04-04 guidance
Note
that specific future statutory authority may change or enhance the guidance in GEN-04-04
For example, Hurricanes Katrina and Rita special exceptions and allocations, and R2T4 student grant overpayments
ED will most likely issue some form of guidance or statement when this authority is granted
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GEN-04-04: General Provisions
If school is unable to continue
providing student’s eligible program, we encourage establishing written agreement
with another institution
See 34 CFR 668.5 for applicable regulations
Attempt to reconstruct any records lost, destroyed, or rendered illegible due to a disaster, but if unable to do so, document in the student’s file that records were lost/destroyed/damaged due to disaster
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GEN-04-04: General Provisions (continued)
If, as a direct result
of a disaster, an institution is temporarily closed for
a period of time that impacts the length of the academic year, the institution should contact the appropriate Case Management team
Case Management will determine, on a case-by-case basis, continued program eligibility and students’ continued eligibility for Title IV assistance
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GEN-04-04: General Provisions (continued)
Disaster-related assistance received by from
the Federal or State government by disaster victims for
the purpose of financial relief, shall not be counted as income for the purpose of calculating a family’s EFC. Also, this assistance shall not be counted as a resource or estimated financial assistance.
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GEN-04-04: General Provisions (continued)
FAAs are encouraged to use
their professional judgment authority (granted under HEA §479A) to
reflect more accurately the financial need of students and families affected by a disaster
Must still make adjustments on a case-by-case basis and clearly document the student’s file with the reasons
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GEN-04-04: General Provisions (continued)
If student fails to meet
satisfactory academic progress standards due to a disaster, the
institution may apply the exception provision of “other special circumstances” contained in 34 CFR 668.34(c)(3)
must document student’s file that student’s failure to maintain SAP was due to disaster
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GEN-04-04: General Provisions (continued)
For those applicants selected for
verification whose records were lost or destroyed because of
a disaster, the verification requirements during the award year will not be enforced
Must document when verification is not performed for this reason
When reporting Federal Pell Grant disbursement, use verification status code “S”
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GEN-04-04: General Provisions (continued)
Schools are strongly encouraged to
provide full refund of tuition, fees, and other institutional
charges (or to provide comparable amount against future charges) if student withdraws as a direct result of a disaster
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GEN-04-04: General Provisions (continued)
If student withdraws because of
a disaster, the institution must perform the return of
Title IV funds calculations in accordance with 34 CFR 668.22, as it must for any student who withdraws
If institution makes refund of institutional charges, R2T4 calculations must must be based upon originally-assessed charges
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GEN-04-04: General Provisions (continued)
Student directly affected by disaster
need not request in writing a leave of absence
Documentation
of LOA must include reason for LOA and reason for waiving written request requirement
LOA definition generally applies only to clock hour or non-term programs
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GEN-04-04: General Provisions (continued)
If Title IV credit balance
exists for any reason when a student withdraws, it
must first be applied to any Title IV grant overpayment that exists as a result of the student’s withdrawal
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GEN-04-04: General Provisions (continued)
Concerns related to deadlines and
timeframes in the following areas should be addressed through
the appropriate Case Management team:
Cash management requirements (includes credit balances; notices and authorizations; borrower request for loan cancellation; excess cash; FFELP funds; and institutional eligibility, financial responsibility, and administrative capability)
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GEN-04-04: General Provisions (continued)
Concerns related to deadlines and
timeframes in the following areas should be addressed through
the appropriate Case Management team: (continued)
Return of Title IV funds (includes post-withdrawal disbursements)
Campus Security Reporting and Equity in Athletics Disclosures
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GEN-04-04: Federal Pell Grants
If, due to a disaster,
a school is unable to meet the deadlines for:
reporting
disbursement records, contact Case Management for a case-by-case analysis
final Pell Grant reporting, request extension by calling Pell Grant Customer Service (800-474-7268), or submit request via COD website (on “Request Post Deadline Processing” screen located on left hand side of menu under the School tab)
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GEN-04-04: Campus-Based Programs
If an institution is unable to
use at least 90% of each of its Campus-Based
allocations because of a disaster, the Secretary will consider the failure of an institution to expend funds solely due to a disaster as an appropriate criterion for a waiver of the underutilization penalty
Affected institutions must make waiver request by contacting Campus-Based Call Center (877-801-7168) for waiver submission guidelines
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GEN-04-04: Campus-Based Programs (continued)
If an institution is having
trouble filing its complete FISAP by the published deadline
because of a disaster, the institution should request assistance from the Campus-Based Call Center (877-801-7168)
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GEN-04-04: Federal Work-Study
If a school is unable, due
to a disaster, to expend at least 7% of
its FWS allocation to compensate students employed in community services, the Secretary will consider the failure of an institution to expend these funds solely due to a disaster as an appropriate criterion for a waiver of this expenditure requirement
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GEN-04-04: Federal Work-Study (continued)
Affected institutions must make waiver
request by contacting Campus-Based Call Center (877-801-7168) or following
annually-published waiver submission guidelines
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GEN-04-04: Federal Work-Study (continued)
The Secretary encourages institution to
employ their FWS students in the cleanup and relief
efforts for the communities affected by a disaster. These efforts would be considered part of the institution’s community services activities under the FWS Program.
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GEN-04-04: Federal Perkins Loans
Any borrower in “in-school” status
at time of disaster should continue to be in
“in-school” status during period of disaster-related nonattendance until such time as borrower withdraws or re-enrolls in next regular enrollment period (whichever is earlier)
Period of disaster-related nonattendance should not impact grace period
Document student’s file
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GEN-04-04: Federal Perkins Loans (continued)
For a borrower who
is in repayment at the time of a disaster,
but is unable to continue to repay the loan due to the disaster, the Secretary authorizes the institution to grant a forbearance for a period not to exceed three months
Borrower may request forbearance orally or in writing without submitting documentation (beyond 3 months requires written request and documentation)
Institution must document student’s file
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GEN-04-04: Federal Perkins Loans (continued)
Institutions that have concerns
regarding the following issues should contact the appropriate Case
Management team for a case-by-case analysis:
Billing and collection activities required by Part 674, Subpart C – Due Diligence
Borrowers in initial or post-deferment grace periods
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GEN-04-04: FFEL and Direct Loans
Any borrower in “in-school”
status at time of disaster should continue to be
in “in-school” status during period of disaster-related nonattendance until such time as borrower withdraws or re-enrolls in next regular enrollment period (whichever is earlier)
Period of disaster-related nonattendance should not impact grace period
Doesn’t affect how institution reports borrower’s enrollment status on SSCR
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GEN-04-04: FFEL and Direct Loans (continued)
If institution is
unable to complete and return SSCR to NSLDS according
to established schedule due to disaster, contact NSLDS Customer Service (800-999-8219) to modify reporting schedule
If using Nat’l Student Clearinghouse, contact Clearinghouse
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GEN-04-04: FFEL Loans
Lenders are authorized not to disburse
loan proceeds to institutions affected by a disaster if
institution’s operations have ceased or opening delayed.
Revised disbursement schedules, loan periods, completion dates, etc. may be necessary.
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GEN-04-04: Federal Direct Loans
If institution is unable to
meet promissory note, loan origination record, and initial and
subsequent disbursement record submission requirements due to a disaster, contact appropriate Case Management team for case-by-case analysis