Contingency Planning: How to Keep Operating During Any Type of Disaster

Session Overview

A Personal Experience
Contingency Planning
Reference Information
General Guidance
Dear Colleague Letter GEN-04-04

A Personal Experience

Cathy Brown
University of West Florida

What’s The Worst That Could Happen?

Earth
Wind
Fire
Water
Humans

"If you fail to plan, then you plan to fail"

Evacuation

"If you fail to plan, then you plan to fail“ (continued)

Security/Safety
Public
Data

“Not Just Back, Better”

Taking care of faculty and staff
Immediate relief for

What We Learned

Know the likely hazards you face and plan accordingly
Back

Contingency Planning

Mary Haldane
Federal Student Aid

What Are the Different Types of Emergency Plans

Occupant Emergency Plan
Ensures Safety

What Are the Different Types of Emergency Plans (continued)

Disaster Recovery Plan
Ensures

Why Develop a Contingency Plan?

Ensure the Safety of Students, Faculty,

Why Develop a Contingency Plan? (continued)

Minimize Damage and Losses Resulting From

How to Develop a Contingency Plan – A Five Point Plan

How to Develop a Contingency Plan – A Five Point Plan

Important Components of a Contingency Plan

Response Team
Roles:
Senior Management Team
Damage Assessment

Important Components of a Contingency Plan (continued)

Training
Testing
Alternate Facilities
Location
Equipment

Important Components of a Contingency Plan (continued)

Notification/Activation Procedures
Notification of Senior Management

Important Components of a Contingency Plan (continued)

Continuity Activities
Activities to Perform to

Important Components of a Contingency Plan (continued)

Communication Plan
Internal Procedures and Templates
External

Important Components of a Contingency Plan (continued)

Vital Records
Location
Media
Access

Important Components of a Contingency Plan

Data Backup and Off Site Storage
Awareness

Lessons Learned – Contingency Planning

People Are the First Priority
Practice – Practice

Lessons Learned – Contingency Planning (continued)

KISS Principle
A Contingency Plan Is a

Lessons Learned - Occupancy Emergency Planning
Establish Building Captains
Establish Floor Captains

Reference Information / General Guidance

Anthony Jones
Office of Postsecondary Education

Reference Information

Dear Colleague Letters, Federal Registers, and Electronic Announcements
General guidance for

Reference Information (continued)

Hurricanes Katrina & Rita:
Electronic Announcements (posted on IFAP beginning

Reference Information (continued)

Federal Student Aid Handbook
Regulations
Professional Judgment
FFEL and Direct Loans

Regulatory Guidance

Regulatory guidance is in 34 CFR 682.211(f)(11) -- allows loan

Regulatory Guidance (continued)

Similar treatment for Federal Direct Loans
DCL GEN-04-04 (FP-04-03) clarifies

General Guidance for Disasters

Unless otherwise noted, guidance applies to Federally-declared disaster

General Guidance for Disasters (continued)

Guidance applies to all Title IV borrowers,

General Guidance for Disasters (continued)

Guidance also applies to institutions, lenders, and

General Guidance for Disasters (continued)

When Federally-declared disaster has impacted a school’s

General Guidance for Disasters (continued)

Always document when deviating from otherwise required

GEN-04-04: General Provisions

If school is unable to continue providing student’s eligible

GEN-04-04: General Provisions (continued)

If, as a direct result of a disaster,

GEN-04-04: General Provisions (continued)

Disaster-related assistance received by from the Federal or

GEN-04-04: General Provisions (continued)

FAAs are encouraged to use their professional judgment

GEN-04-04: General Provisions (continued)

If student fails to meet satisfactory academic progress

GEN-04-04: General Provisions (continued)

For those applicants selected for verification whose records

GEN-04-04: General Provisions (continued)

Schools are strongly encouraged to provide full refund

GEN-04-04: General Provisions (continued)

If student withdraws because of a disaster, the

GEN-04-04: General Provisions (continued)

Student directly affected by disaster need not request

GEN-04-04: General Provisions (continued)

If Title IV credit balance exists for any

GEN-04-04: General Provisions (continued)

Concerns related to deadlines and timeframes in the

GEN-04-04: General Provisions (continued)

Concerns related to deadlines and timeframes in the

GEN-04-04: Federal Pell Grants

If, due to a disaster, a school is

GEN-04-04: Campus-Based Programs

If an institution is unable to use at least

GEN-04-04: Campus-Based Programs (continued)

If an institution is having trouble filing its

GEN-04-04: Federal Work-Study

If a school is unable, due to a disaster,

GEN-04-04: Federal Work-Study (continued)

Affected institutions must make waiver request by contacting

GEN-04-04: Federal Work-Study (continued)

The Secretary encourages institution to employ their FWS

GEN-04-04: Federal Perkins Loans

Any borrower in “in-school” status at time of

GEN-04-04: Federal Perkins Loans (continued)

For a borrower who is in repayment

GEN-04-04: Federal Perkins Loans (continued)

Institutions that have concerns regarding the following

GEN-04-04: FFEL and Direct Loans

Any borrower in “in-school” status at time

GEN-04-04: FFEL and Direct Loans (continued)

If institution is unable to complete

GEN-04-04: FFEL Loans

Lenders are authorized not to disburse loan proceeds to

GEN-04-04: Federal Direct Loans

If institution is unable to meet promissory note,