The School Voice in Common Policy NASFAA 2006 NASFAA 2006

Presenters Moderator: Jacki Fairbairn of Great Lakes Moderator: Jacki Fairbairn of Great Lakes Marilyn Ponti of Whitman College Marilyn Ponti of Whitman College Brenda Grady of USA Funds Brenda Grady of USA Funds

School Voice in Common Policy The PLAN: The PLAN: –A little history & structure lesson. –What is ‘common policy’? –Where does common policy come from? –What does common policy mean to schools? –What can schools do to help with the development of common policy?

Common Manual History Common Manual published Dec 1995 Common Manual published Dec guarantors subscribed initially 23 guarantors subscribed initially First policies effective April 1, 1996 First policies effective April 1, 1996 More than 900 policies developed & implemented More than 900 policies developed & implemented Almost 300 considered & not developed Almost 300 considered & not developed

Common Manual Structure Governing Board with representatives of each guarantor Governing Board with representatives of each guarantor –Meet monthly –Manage CM budget –Review, consider, approve all policies

Common Manual Structure Policy Committee with 12 members Policy Committee with 12 members –Meet weekly---sometimes more often –Meet via conference calls –Research, develop, review, refine, revise –Manage community comment periods –Provide final ‘commented’ proposal to Board for consideration

What Is Common Policy? Sources of common policy: Sources of common policy: –Federal guidance: statute, regulations, Dear Colleague Letters –Business needs of schools, lenders, guarantors –Community ‘best practices’

Common Policy & the School What does common policy mean to schools? What does common policy mean to schools? –One policy for key transactions –One source to document the one policy –One method for helping direct policy

Common Policy & the School Common policy also means: Common policy also means: A meaningful way to participate in the policy-development process

Common Policy & the School Where did those 900+ policies come from? Where did those 900+ policies come from? –Federal statute, regulations and correspondence [Federal proposals] –Guarantor, lender and school assessments of best practices [Guarantor proposals] –Reorganization and Corrections

Common Policy & the School “Federal Policy”: “Federal Policy”: –Statutory changes (ex.: HERA) –Regulatory changes (ex.: Nov. 1, 2002) –Dear Colleague Letters and FSAH changes (ex.:GEN-06-05)

Common Policy & the School “Guarantor Policy”: “Guarantor Policy”: –Case law precedents –Best practices –Absence of federal guidance

Common Policy & the School Reorganization and Corrections: Reorganization and Corrections: –Reorganized borrower eligibility, loan certification and loan delivery per school recommendations

School Voice in Common Policy How is common policy developed? How is common policy developed? –Policy proposal drafted Who drafts it? [Could be a school] Who drafts it? [Could be a school] Why do they draft it? Why do they draft it? Where does it go after it’s drafted? Where does it go after it’s drafted?

School Voice in Common Policy Policy Committee consideration Policy Committee consideration –Research all applicable resources –Consult with community experts regarding current practices, systems, etc. Refine text based on resources [Could be consulting with a school!] –Decide whether to go forward with the policy

School Voice in Common Policy Comment process: Comment process: –Distributed to community for comment (Public listserv, NASFAA, YOU?, etc.) Subscribe to the Public Listserv: Subscribe to the Public Listserv: –Send your request to: –In the BODY of the E ‑ mail message type : "Subscribe Public“ –Do not type the quotation marks!

School Voice in Common Policy Comment process continued: Comment process continued: –Comment period usually 3 weeks –Comments returned to the PC –More research, discussions with community experts [Could be a school!] –Comment responses & revised policy finalized

School Voice in Common Policy Final policy goes to Governing Board Final policy goes to Governing Board –Board reviews and assesses impact –Board meets monthly to consider and discuss proposed policies –Board votes on proposals---Requires a quorum in each meeting and a 2/3 approval for passage.

School Voice in Common Policy Approved policies are published: Approved policies are published: –In about 10 days to public listserve –In each guarantor’s newsletter –In the monthly ICM update –In the annual CM paper and ECM versions

School Voice in Common Policy How can a school participate? How can a school participate? –Subscribe to the Common Manual public listserv –Check batch summary publication for key issues –Review proposed policies –If you identify an issue: –COMMENT

School Voice in Common Policy Identify Omissions Identify Omissions –If you can’t find it: Is it missing? Is it missing? In the wrong place? In the wrong place? TELL US!

School Voice in Common Policy If you find it and it doesn’t tell you all you need to know: If you find it and it doesn’t tell you all you need to know: –Is it because there is no federal guidance? Should there be? –Has common policy omitted a key element? TELL US!

School Voice in Common Policy And then what? Do I have to write the policy? Do I have to write the policy?No. Do I have to consult or find time to research? Do I have to consult or find time to research?No.

School Voice in Common Policy CAN I write the policy? CAN I write the policy?YES CAN I consult or research? CAN I consult or research?YES

School Voice in Common Policy What else can I do? What else can I do? –Participate in Workgroups –Share with Colleagues –Use the Common Manual

School Voice in Common Policy If you use it to find information on loan delivery time frames, you may identify: If you use it to find information on loan delivery time frames, you may identify: –A great reference document that needs to be tied to the common policy statement

School Voice in Common Policy Reg Cite Link to toGlossary

School Voice in Common Policy If you use it to find information on loan delivery time frames, you may identify: If you use it to find information on loan delivery time frames, you may identify: –A part of the delivery process that is not covered by regs and that has created diverse policies in guarantor shops

School Voice in Common Policy If you use it to find information on loan delivery time frames, you may identify: If you use it to find information on loan delivery time frames, you may identify: –Another document or historical change that needs to be added to the history appendix

School Voice in Common Policy HistoryAppendixCite

Presenter Contact Information: Presenter Contact Information: –Marylin Ponti –Jacki Fairbairn Governing Board Chair –Brenda Grady, Policy Committee Member

School Voice in Common Policy Policy Committee Contact Information: Policy Committee Contact Information: –Dan Tryon, Policy Committee Co-Chair –Carolyn Small, Policy Committee Co-Chair