Build the working table for a Title IV administrative-capability response

Key facts

Human involvement: YellowClose supervision
How AI is used: Set each audit finding beside the sentence of 34 C.F.R. § 668.16 the lawyer identifies, and list the policy or record in the file that bears on it. Do not write the response that will be sent to the Department.
What the lawyer must review: 34 C.F.R. § 668.16 requires an institution that participates in a Title IV, HEA program to demonstrate that it is capable of adequately administering that program. The Secretary considers the institution to have that capability if it meets the standards in the section, including administering the programs in accordance with the statutory and regulatory provisions, designating a capable individual to administer them, and having written procedures or written information on the responsibilities of offices for approval, disbursement, and delivery of Title IV assistance and for reports to the Secretary. The lawyer writes the response. Student information in the response remains an education record under 20 U.S.C. § 1232g. Formal Opinion 512: the lawyer checks every line of the table before using it.
Written for / version: United States versionUS

Who does what

Who does what
Role	What they do
Assistance	Potential support includes identifying points for review. Confirm the tool’s capability and permitted scope.
Lawyer	Set the scope, supervise the work closely, verify every part relied on, resolve omissions and exceptions, and approve the exact output.

Verify the applicable jurisdiction and the version of each relevant law, rule or instrument in force at the material time.
Confirm the output against the client’s instructions and the complete relevant source material, including omissions or contradictions.
Resolve exceptions and record the responsible lawyer’s approval of the exact output and intended use.