This post was written by Dave Gelinas
October 12, 2008
Higher Education Act, Negotiated Rulemaking, Regulations
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Guest blogger Dave Gelinas is director of financial aid at Davidson College and the 2005-06 national chair
On October 6, I had the opportunity to attend the public hearing on regulating the Higher Education Opportunity Act which was held at Johnson C. Smith University in Charlotte. A total of 19 individuals offered public testimony over the course of the day.
As an aid administrator, when I think of “Higher Ed Act,” (with or without the “Opportunity” attached), I think of the many financial aid programs authorized by that law. I think of the many requirements my office will be responsible and accountable for. What I don’t tend to think of, and what makes the Higher Ed Act so voluminous, is that “my” programs are mainly under just one of the titles in the act. You know, good old Title IV, as in “return to.” The entire HEOA, though, encompasses 11 titles, ranging from General Provisions (Title I) to International Education Programs (Title VI) to Studies and Reports (Title XI). AND, under each title are numerous sections and parts. What opened my eyes at the hearing was the realization that the Title IV aid programs I know and love are but a small sliver of the entire Act, and other interested parties in higher education (not from the aid office) have strong feelings about those other titles and their parts and sections.
Only eight of the testimonies were given by aid professionals. The other 11 ranged from accreditation issues to campus safety and security to TRIO programs to copyright infringement (the enforcement of peer-to-peer file sharing prohibitions generated significant interest) to revenue provisions for career colleges. It was fascinating to hear those concerns expressed; suggestions given as to how the regulatory process should now proceed; and the advocacy for which groups should be represented at negotiated rulemaking. I found myself wondering how all these competing interests could possibly be resolved. I also realized that as an aid administrator, I am but one part of how an institution complies with this law, and it truly “takes a village” to carry out this massively complex piece of legislation.
If you have the opportunity to attend any of the remaining public hearings, I urge you to do so. Read the summary of the HEOA provided by NASFAA. (Or, be a glutton for punishment and wade through the entire Act.) Think of what you might want to testify about. You can also review testimony submitted by NASFAA to give you some ideas about issues to raise. In Charlotte, you could sign up for a testimony slot when you came to the meeting site, so “pre-registration” wasn’t necessary. Plan to leave a copy of your remarks with the Department of Education officials so they may be correctly entered into the public record. (And remember: Your testimony will be part of the public record.) Let your voice be heard.
It’s been a long time since my civics lessons back in school. Being able to be a part of what those civics lessons taught was both illuminating and instructive. It also gave me a greater appreciation for the work that has to be done to produce federal regulations. It was a well-spent day out of the office.
Dave Gelinas
2005-06 National Chair
This post was written by Dave Gruen
August 13, 2008
Higher Education Act, Regulations
2 Comments
I was sad to learn about the passing of the man that brought ‘Hot Buttered Soul’ to us back in the late sixties and early seventies – Isaac Hayes. Those of you near my age may remember his remarkable Academy Awards performance of the “Theme from Shaft” (and in my opinion, one of the all time great moments at the Academy Awards).
Recently I read an editorial in The Plain Dealer that highlights the unfunded mandates that will be placed on schools as a result of the Higher Education Opportunity Act (HEOA), which has not yet signed by the President. It seems to me that what gets lost in all of these new legislative directives are ‘the students.’ Mandating that states raise their budgets for higher education each year by at least as much as had been increased over the previous five years or risk losing funding in the College Access Challenge Grant program, will likely hurt poor students the most. The Act also requires significant reporting requirements for all our schools, which will certainly take away from the essential counseling we do that is so necessary to our students. Ouch!
Will our offices be able to meet these requirements without staffing and administrative cost increases? Who will pay? Please respond and let NASFAA know your perspective on those parts of the Act that are particularly onerous for your schools and states to implement. By the same token, there are parts of the legislation for which we need to congratulate Congress for passing (Year-round Pell Grants come to mind). Tell NASFAA about those too. Your NASFAA leadership needs your input to represent your views to Congress and with the other DC education associations.
Now I’m going to go dig through my old LP’s (remember those?) and enjoy some ‘Hot Buttered Soul’.
This post was written by Michael Bennett
June 23, 2008
Conferences, Regulations
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Two weeks ago NASFAA published an excellent seven page article titled “Federal Student Loan Checklist: Are You Up to Date?” to help members stay up-to-date on all their loan practices. I don’t know about you, but whenever I see the question “are you up to date?”, I take a deep breath and think: “Uh oh! I hope I don’t read something we should have been doing the past several months!”
This article serves as an illustration of the many, many changes made in the loan programs just in the last year. It is also important to note that the article is an outline of these changes, not a full explanation of each change. At the beginning of an article is a “table of contents” that links to 19 different topics that are also filled with hyperlinks to even more information and links. (Yes, you better go back and read this!)
Let’s face it, as a financial aid administrator you learn to understand and explain sentences like
“Beginning July 1, 2008, final rules make changes to 674.16, 682.208, 682.401, and 682.414, that require guarantors to report certain student enrollment dates to the current loan holder within 35 days of any changes in a student’s enrollment status that triggers the beginning of a grace period or the beginning or resumption of repayment.”
(If I were on a game show I would say “That answer is true, Bob.”)
“How is someone to keep track of all of these changes?” I think to myself. “And when can we get back to working with students and families?”
A frightening trend in federal student aid is the additional complexity being added to all federal loan programs. At its best, this complexity comes from sincere attempts to distribute aid equitably. But at its worst, this complexity adds to the administrative burden of both financial aid administrators and students. A fair balance can be difficult to find.
But that point is not what’s important in the immediate future. Part of serving students and families the best way we can is to ensure that we are up-to-date on the ever changing world of financial aid. Our work serves as the lifeblood of higher education and without our knowledgeable expertise, families suffer.
Besides reviewing the checklist, I also encourage everyone, if you haven’t already done so, to review the handouts of the upcoming NASFAA National Conference sessions. This will give you additional time to formulate your questions or to identify colleagues at similar institutions who you may want to compare loan policies and procedures. (Anyone need a drink?!)
Are you up to date?!