The Elusive Answer Researching the answer to a policy question. WASFAA Federal Issues Committee Fall 2013
Agenda Getting Started Policy & Regulations When to Ask Phrasing Your Question Do some research Who To Ask Everyone!
Getting Started Where Do Policy Regulations Come From Types of Legislation Laws, Regulations, Guidance, Policy Negotiated Rulemaking Code of Federal Regulations Spending Bills and Other Legislation
Types of Legislation Legislation Authorizing A law passed by Congress that establishes or continues a program. Appropriating A law passed by Congress that provides authority for federal agencies to obligate funds for specified purposes.
Laws, Regulations, Guidance, Policy Institutional Policy Each institution utilizes sector specific guidance to implement regulations Guidance Provided by ED (Dear Colleague Letters, Electronic Announcements, FSA Handbook) Department of Education writes regulations that implement laws written by Congress Congress writes laws that authorize and fund federal student aid.
Rulemaking Traditional Rulemaking: Department of Ed publishes NPRM (Notice of Proposed Rulemaking). The public is allowed to comment during a specified timeframe. Final regulations are issued after the comment period.
Rulemaking Negotiated Rulemaking: The NPRM is developed in conjunction with significantly affected parties through a series of meetings with representatives from various constituencies. The public is allowed a period to comment. Final regulations are issued after the comment period.
Code of Federal Regulations Title 34 CFR is Education Part Office of Postsecondary Education, Department of Education (668 Student Assistance General Provisions) Subparts Satisfactory Progress 34 CFR OR § § (a)(3) The policy provides that a student's academic progress is evaluated— (i) At the end of each payment period if the educational program is either one academic year in length or shorter than an academic year; or (ii) For all other educational programs, at the end of each payment period or at least annually to correspond with the end of a payment period;
Appropriations Congress Senate Appropriations Committee Labor, Health and Human Services, and Education House Appropriations Committee Labor-HHS- Education 1.Subcommittees make FY budget proposal 2.Appropriations committee vote 3.Full Senate/House vote 4.Each has different draft. New committee created with members of house and senate to reconcile bill. 5.Full Congress votes on bill.
Know when you need help Not 100% sure of answer Course of action being committed to by advisor, office, or school Will a student’s eligibility be impacted by the decision? It is always ok to ask questions! When to Ask
Phrase Your Question What’s the broad category for the question? 1. School eligibility 2. Student eligibility 3. Awarding 4. Disbursement 5. Individual aid programs Write out your question to avoid “research creep” (distractions)
Institutional Type Know your sector Public/Technical/Private/Proprietary 2year/4year Know your term type (2014 FSA 3-44) Standard Semesters/trimesters/quarters Nonstandard Credit hour/clock hour Non-term Know your Pell formula (2014 FSA 3-47) UW-Whitewater is a 4year, public, standard term, formula 1 institution.
Key Words Census date – search “disbursement” or “recalculation” Undocumented students – search “citizenship” Independent students – search “dependency status” or “independence criteria”
Do Some Research IFAP ifap.ed.gov NASFAA nasfaa.org IRS irs.gov Dept of Ed ed.gov Finaid.org HEAB heab.state.wi.us
Information for Financial Aid Professionals (IFAP) FSA Handbook iLibrary Reference guides Code of Federal Regulations Web based training FSA Assessments And more!!
FSA Handbook Click on “Current Handbook” on the right side of the screen. Application and Verification Guide, plus 6 volumes. Which volume do you select? Use the FSA Handbook Cheat Sheet to help you! If the volume you need is not available, check last year’s handbook... But BE CAREFUL, information may not be current.
Searching the Handbook Be careful how you phrase your search! Searching the AVG: “Simplified” 38 hits vs. “Simplified needs” 6 hits Searching Volume 3: “aggregate” 77 hits vs. “aggregate limit” 13 hits Even with this knowledge, you might still have searches with too many hits...
Searching the Handbook cont’d USE the Table of Contents Each volume has a separate PDF table of contents Volume 5 “post-withdrawal” – 218 hits “post-withdrawal disbursement” – 210 hits Searching table of contents, “post-withdrawal disbursement” 7 hits, all in the same section – best to go to that section!
iLibrary Current and archived publications related to Federal Student Aid Sorted by: Program Type (i.e., Pell, Perkins) Functional Type (i.e., Verification, PJ) Document Type (i.e., DCL, ISIR Guide)
NASFAA Members of NASFAA can access resources on their website: AskRegs Knowledgebase Student Financial Aid Research Compiled Title IV Legislation Policy & Procedure Guide Self-Evaluation Guide
IRS.gov Not just for ordering a transcript Forms and Pubs 1040 forms Tax tables Wage statements Wondering what that code on the 1099-R means?
Other Search Tips Check out IFAP “Hot Topics” and Information Pages for issues such as Gainful Employment Check out NASFAA “Publications” for Monographs on specific financial aid topics such as SAP State issues? Go to HEAB site “Information for Financial Aid Administrators” for the Monthly Memo and Policies and Procedures Manual
Start Asking Questions Your institutional colleagues WASFAA members NASFAA AskRegs Finaid-L listserv Department of Ed Trainers NSLDS COD Loan servicers
Federal Resources COD problems (loan origination, promissory notes not matching up) NSLDS problems (transfer monitoring files, help reporting an overpayment) Loan Servicing problems (student ret’d funds to both school & loan servicer) FAA Access issues (log in problems, support for ISIR Analysis Tool & R2T4 on the web) All numbers found here:
Federal Resources Federal Trainers Jamie Malone (312) Angela Smith (312) Byron Scott (312) Region V Office location: Chicago, IL States: Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin (312) Dept of Ed phonebook : cfm
Organize your findings Keep s in folders to refer back to later Start a file for each type of policy question Add notes to your Policy & Procedure Manual
Converse with Colleagues Network with WASFAA members! WASFAA meals – sit with someone new Interest sessions – ask your neighbor Receptions and activities – strike up a conversation or call WASFAA colleagues
Converse with Colleagues Network with Financial Aid Administrators and other higher ed professionals! And join the #FAchat First Tuesday every month, 12-1 CST Other hashtags to follow… #WASFAA #finaid #SAchat #EMchat #MASFAA
Federal Issues Committee Susan Johnson, UW-Whitewater Kate Sopha, Madison College Julie Waldvogel-Leitner, MPTC