Well Ollie, this is another fine mess you've gotten me into!

So let’s conclude our examination of the financial aid mess that CSU finds itself in. In the section of the report sent to the university by the US Department of Education, General Terms and Conditions, the department outlines what the university’s responsibilities are regarding being able to apply for full status in September 2015.

First, if we look at Paragraph 2a. we find that the university “...certifies that on the date it signs this Agreement, it has a drug abuse prevention program in operation that it has determined is accessible to any officer, employee, or student at the Institution.” That is very curious because when I searched for the aforementioned program on the CSU website, I couldn’t find it. For some reason the results of the search don’t scroll so I was only able to see what is presented below.

If the university asserted to the Department of Education that such a program exists, I, as an employee, would be hard pressed to know where to look for the program. If it can’t be found on the university web site through their search engine then how might an employee or student find this information? Additionally, if the administration manages this required program the way they comply with the provisions of the Illinois Freedom of Information Act, then I can assure you that the institution would not have been in compliance with this requirement.  If I can’t find the program on the university web site, then how might I find it? I am sure that those who struggle with the truth in this administration will have some justification for why your humble narrator could not find the policy that the university apparently agreed to implement last year.
Second, the university agrees to comply with the Standards for Safeguarding Customer Information, that is a provision of the Gramm-Leach-Biley Act. This federal requirement is designed to protect student records and as is stated in the agreement, “...The Secretary considers any breach to the security of student records and information as a demonstration of a potential lack of administrative capability...” Two questions arise for me. The first is how would the university or its students or faculty know if they were in compliance given there is no director of compliance and the compliance function is being managed by committee. I am sure an interim will be named to join the long list of interims throughout the university. The more pressing question is whether there has already been a breach that the university is aware of and not communicated or if this is simply boilerplate language for agreements like this.
Third, paragraph 18 states that the "university will not knowingly...." Some of these provisions are of concern. The requirements that certain persons not be employed or contracted with is appropriate and yet how, given the repeated employment of cronies, unqualified persons, and those who lied on their job applications, could the university guarantee that these provisions would be complied with? It stretches credulity as far as I can see.

Secondly, the agreement requires the university to “complete, in a timely manner, and to the satisfaction of the Secretary, surveys conducted as a part of the Integrated Postsecondary Education Data System(IPEDS) or any other Federal collection effort, as designated by the Secretary, regarding data on post-secondary institutions.” 

Any Title IV eligible institution is required to submit IPEDS surveys, generally about three times per year. There are about a dozen different surveys that are part of Department of Education collection effort. The surveys and their due dates are accessible on the IPEDS web site. The consequences of non-compliance are determined by the Federal Student Aid office. Punishment could include fines of up to $20,000 per instance, or suspension of the financial aid program. This university has on occasion not submitted its IPEDS data as required, submitted information late or revised information after submission. Who at the university has the expertise in collecting, scrubbing and submitting data to ensure that revisions aren’t necessary?  It surely wouldn’t be anyone who has no experience in higher education like the Associate Vice President of Enrollment Management or someone whose professional credibility has been brought into question by proven plagiarism. How could either of these administrators be trusted to submit to the Department of Education data that could be considered credible or accurate given their history at the university?

So to recap, 1) the university is operating until 2015 on a provisional status; 2) that status requires compliance with a number of things the university has been out of compliance with; 3) there is yet another interim financial aid director to oversee the cleanup of the financial aid mess; 4) financial aid is being supervised by an Associate Vice President who has demonstrated a lack of ability to manage vital university functions; 5) the university is at risk because continued failure could lead to sanctions that could essentially close the university; and 6) the Board is noticeably silent about all of this.
It would appear this financial aid situation is serious and yet nary a peep from the Board of Trustees. No discussion at board meetings??? Surely the Board must have considered how tenuous a situation this is. Or maybe not, given their continued statements of confidence in this failed administration.