Home Sponsored Content Glenn Bogart, J.D. – A nationwide Title IV compliance consultant, since 1992
Glenn Bogart, J.D.  – A nationwide Title IV compliance consultant, since 1992

Glenn Bogart, J.D. – A nationwide Title IV compliance consultant, since 1992

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Title IV compliance reviews

How would your college fare in a program review? If you want to find out, call me. I use judgmental sampling to find the students who are most likely to have compliance failures and potential liabilities. Generally, this can be done in three days, regardless of the size of the school, at a modest cost. On top of that, it is not unusual for me to find money on the table that more than pays for the cost of the visit.

Program review responses

If they were always right, they wouldn’t give you an opportunity to respond – not to mention, a right to appeal! Program reviewers are just people, and they can be wrong, just like anybody else. Sometimes they are wrong in pretty spectacular fashion – but that may not be obvious even to an experienced financial aid director. In this, as in other important business matters, having an expert on hand can make all the difference.

I will come to your college, if necessary, to oversee any necessary file reviews and to write a professional response. If I can do this from home, I’ll do that, and save you the travel expenses. At this point, we want to try to keep it collegial, if possible – ED doesn’t need to know a hired gun is involved. I’ll write it, and you sign it. Of course, ED may be a little surprised at “your” expertise – especially if I cite case law in your response, which I sometimes find a useful tactic.

The initial response to a program review report is your first chance to try to talk them out of some of those findings – don’t blow it! If you treat this as a do-it-yourself project, there’s about a 95% chance you are not going to be happy with the results – the same as if you were to build your own house without expert help.

Program review and audit final determination appeals; fees

A Final Program Review Determination or Final Audit Determination isn’t really final. The law and regulations give you an opportunity to appeal – but this definitely isn’t a job for an amateur. The case will be decided by an administrative law judge in the Department’s Office of Hearings and Appeals. He or she will be a real judge, and is going to want to hear real argument and real case law that supports your position. If you go in there and just tell him what a good school you have, ED’s lawyer will squash you like a bug.

I can write your appeal, write your brief(s), and present your oral argument if that becomes necessary. No guaranteed win, of course – but you could do a whole lot worse in picking a representative for your school. Since I operate as a consultant, and not as an attorney, I can afford to charge my clients a lot less. My fees are $125 an hour, plus expenses.

And in conclusion

Glenn BogartGlenn Bogart is the man to call if you have a higher education compliance problem – or if you don’t, and you want to keep it that way. Law degree, ex-Fed, ex-corporate financial aid executive, and independent consultant for 27 years.

Call Glenn Bogart at 205-249-5453. Do it now!

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