The Elusive Answer: Researching the Answer to a Policy Question

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Wisconsin Association of Student Financial Aid Administrators (WASFAA) Federal Issues Committee Fall 2011 Conference Presentation

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  • [MH] Before we begin searching for an answer to a policy question it is important to understand where financial aid policy comes from.
  • [MH] There is a difference between authorization and appropriation. One creates a program, the other funds it. There may be programs created that are not funded, or not fully funded. The HEOA reauthorization created several programs which were never funded by Congress.
  • [MH] Laws go through several filters before they become institutional policy.
  • [MH]
  • [MH] Recently the department discussed (negotiated) Program Integrity Rules. The Federal Issues Committee took a survey of WASFAA members concerns about the proposed regulations. The comments on the Program Integrity NPRM were submitted to the Department. ED is required to consider all comments received and address them in the final regulations. http://www2.ed.gov/policy/highered/reg/hearulemaking/hea08/neg-reg-faq.html Negotiators are nominated by the public, and selected by the Department. In the same Federal Register Notice that announces the Department’s intent to conduct negotiated rulemaking or a subsequent Notice, the Department solicits nominations for negotiators to represent the constituencies who will be significantly affected by the regulations. Each committee includes at least one Department of ED representative. On each negotiating team’s ED webpage you can see a list of members. http://www2.ed.gov/policy/highered/leg/hea08/index.html#neg-reg Justin Draeger, president of NASFAA, was on the School-Based Loan Issues team during 2009 HEOA negotiations. If consensus is achieved, the Department uses that regulatory language in its NPRM. If consensus is not achieved, the Department determines whether to proceed with regulations. If the Department decides to proceed with regulations, it may use regulatory language developed during the negotiations as the basis for its NPRM, or develop new regulatory language for all or a portion of its NPRM.
  • [MH] CFR is broken into sections called “titles” Title 34 of the CFR contains regulations about Education. (R2T4 comes from return to Title 4 – which is accounts) List of all titles http://en.wikipedia.org/wiki/Code_of_Federal_Regulations#List_of_regulation_titles 34 CFR Parts http://www.access.gpo.gov/cgi-bin/cfrassemble.cgi?title=201034 The section symbol often replaces “CFR”. Often you will not see the Title referenced; in Higher Ed topics it is usually safe to assume the “34 CFR” is implied. It is further divided by outline division. a, b, c – 1, 2, 3 – i, ii, iii – A, B, C, - 1, 2, 3 – a, b, c Often divided down to identify a particular sentence.
  • [MH] Many financial aid laws are being made outside of the “normal” authorization process. Financial aid regulations are often involved in the federal budget process. The recent House and Senate proposed changes to financial aid are part of the appropriations (budget) process. We are currently at step four in the process as of 10/25/2011. A Continuing Resolution (CR) was passed which funds federal programs through November 18, 2011. If a final FY 2012 Spending Bill has not been approved by that time a new CR will need to be passed or the government could be furloughed. At the same time all this is going on there is a “super committee” working on additional budget cuts. The committee was created as part of the Budget Control Act (debt ceiling legislation). The committee is required to propose $1.5 trillion in budget cuts by Thanksgiving.
  • FSA Handbook Volume 3 Chapter 3 FORMULA 1: CREDIT-HOUR TERM-BASED PROGRAMS FORMULA 2: STANDARD-TERM PROGRAMS WITH LESS THAN 30 WEEKS IN THE FALL THROUGH SPRING FORMULA 3: GENERAL FORMULA FOR ANY TERM-BASED PROGRAM FORMULA 4: CLOCK-HOUR AND NONTERM CREDIT-HOUR PROGRAMS
  • Where to search [SJ] Talking points: A list of websites is a good start, but it can also be overwhelming if you don’t know which one is the best place to look. It’s important to think about your question and where the pertinent information is housed. This may be more than one site so in that case, it’s good to start with the site which most likely has the most information.
  • [SJ] Talking points: I want to focus on IFAP because of the amount of data housed here, and this is the site I go to most often to search for an answer. This doesn’t mean the other sites are not helpful. I often go to the IRS website for tax topics, but if I think the same information can be found on IFAP, I will go here first. Looking at the list I have here, FSA Coach is great for training & FSA Assessments is a good quality assurance tool, but in this case we are searching for that elusive answer so the two essential tools are the FSA Handbook and the iLibrary.
  • [SJ] Talking points: I find it is so much easier to go straight to the handbook; however, with six volumes plus the Application and Verification Guide, sometimes searching for the answer can seem like looking for a needle in a haystack. I’ve provided what I call the FSA Handbook cheat sheet to help know which volumes contain which data, but I also have some search tips for you.
  • [SJ]
  • [SJ]
  • [SJ] Talking points: The iLibrary is especially significant during times when the current handbook is not published. You need to know the most current guidance available, and I find it’s easiest to search under program type or functional type because I tend to struggle with knowing a DCL from an Electronic Announcement. . . Plus you can find everything you need for that topic in one place sorted by most recent publication.
  • [SJ] Talking Points: Chances are, if it’s a hot topic, you will be able to find information in one place. The Net Price Calculator is still a big topic so IFAP and NASFAA have a lot of resources in one place to make sure you are in compliance. I know this is the Fed Issues committee, but I wanted to point out that the HEAB site has a lot of information available if you are struggling with a state grant program. (Chapter 10, return of funds – I’ve been there often)
  • Who to ask Consider the nature of your question to determine where to look first.
  • [DS] You search for DCL GEN-06-09 in the upper left hand side of http://ifap.ed.gov/ifap/  At the bottom you can email Dan, which I’ve done for Visas not listed, but similar to acceptable recent Citizenship Verification changes in the FSA Handbook.
  • [SJ & MH] What if you forget the person’s name? Do you remember their institution? Try the WASFAA membership directory on the website. Send email or give them a call.
  • [SJ & MH] http://twitter.com/ http://www.linkedin.com/ http://google.com/+
  • The Elusive Answer: Researching the Answer to a Policy Question

    1. 1. The Elusive Answer Researching the answer to a policy question.WASFAA Federal Issues Committee Fall 2011
    2. 2. Federal Issues Committee Michelle Curtis, UW-Madison Melissa Haberman, UW Colleges Susan Johnson, UW-Whitewater David Sandra, UW-Madison Your name could be here, contact a committee member!
    3. 3. Agenda Getting Started  Policy & Regulations When to Ask  Phrasing Your Question  Do some research Who To Ask  Everyone!
    4. 4. Getting StartedWhere Do Policy Regulations Come FromTypes of LegislationLaws, Regulations, Guidance, PolicyNegotiated RulemakingCode of Federal RegulationsSpending Bills and Other Legislation
    5. 5. Types of Legislation
    6. 6. Laws, Regulations, Guidance, Policy
    7. 7. Negotiated Rulemaking Congressional laws are often passed without detailed instructions for implementation. Department of Ed issues guidance on how to implement. Draft regulations are issued in a Notice of Proposed Rulemaking (NPRM).
    8. 8. Negotiated Rulemaking The public is allowed a period to comment on the proposed rules. Committee of negotiators discusses draft regulations and ALL comments submitted.  Sometimes called “reg neg” Final guidance is issued in a Federal Register. (Looks a lot like the NPRM.)
    9. 9. Code of Federal Regulations Title 34 CFR is Education  Part 600-699 Office of Postsecondary Education, Department of Education (668 Student Assistance General Provisions)  Subparts 668.34 Satisfactory Progress 34 CFR 668.34 OR § 668.34 § 668.34(c)(3)(iii)(B)(4)(d) “Institutions that evaluate satisfactory academic progress annually or less frequently than at the end of each payment period.”
    10. 10. FY 2012 Appropriations 1. Labor-H 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.
    11. 11. When to Ask  Phrase your question  Do some research  Start asking questions It is always ok to ask questions!
    12. 12. Phrase Your Question Know your institutional type Use key words and topics Use “Ctrl + F” to search
    13. 13. Institutional Type  Know your sector  Public/Technical/Private/Proprietary  2year/4year  Know your term type (2011 FSA 3-44)  Standard  Semesters/trimesters/quarters  Nonstandard  Credit hour/clock hour  Non-term  Know your Pell formula (2011 FSA 3-47)UW Colleges is a 2year, public, standard term, formula 1 institution.Marquette is a 4year, private, standard term, formula 1 institution.
    14. 14. Key Words Census date – search “disbursement” Undocumented students – search “citizenship” Changes to marital status – search “household size”
    15. 15. 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
    16. 16. IFAPInformation for Financial Aid Professionals FSA Handbook iLibrary Reference guides Code of Federal Regulations Web based training (FSA Coach) FSA Assessments And more!!
    17. 17. 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.
    18. 18. Searching the HandbookBe careful how you phrase your search!Searching the AVG: “Simplified” 39 hits vs. “Simplified needs” 5hitsSearching Volume 3: “aggregate” 68 hits vs. “aggregate limit” 10hitsEven with this knowledge, you might stillhave searches with too many hits. . .
    19. 19. Searching the Handbook cont’d USE the Table of Contents!!! Each volume has a separate PDF table of contents Volume 5, chapter 2 “post-withdrawal” – 134 hits “post-withdrawal disbursement” – 129 hits Searching table of contents, “post-withdrawal disbursement” 6 hits, all in the same section – best to go to that section!
    20. 20. 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)
    21. 21. Other Search Tips Check out IFAP “Hot Topics” and Information Pages for issues such as NPC and Gainful Employment Check out NASFAA “Featured Topics” for Program Integrity Resources and the latest Congressional Acts State issues? Go to HEAB site “Information for Financial Aid Administrators” for the Monthly Memo and Policies and Procedures Manual
    22. 22. Start Asking Questions Your institutional colleagues WASFAA members NASFAA AskRegs Finaid-L Department of Ed Trainers NSLDS COD Loan servicers
    23. 23. Federal Services 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: http://ifap.ed.gov/docs/CallQRef.pdf
    24. 24. More Resources Dept of Ed phone book http://wdcrobcolp01.ed.gov/CFAPPS/employee_locato
    25. 25. Regulatory Questions Ask Regs on NASFAA http://www.nasfaa.org/products/ask-regs/Ask_Regs.aspx Finaid-L listserv finaid-l@lists.psu.edu http://lists.psu.edu/cgi-bin/wa?A0=finaid-l Federal Trainers Region V Office location: Chicago, IL States: Illinois, Indiana, Michigan, Minnesota, Ohio, Wisconsin (312) 730-1700
    26. 26. Need More Information FSA Handbook margin notes Dear Colleague Letter IFAP DCL Archive Author email listed at bottom of letter
    27. 27. Policy Development WASFAA colleagues Finaid-L NASFAA Professional Practice Tools Policies & Procedure Manual templates
    28. 28. Organize your findings Keep emails in folders to refer back to later Start a file for each type of policy question Add notes to your Policy & Procedure Manual
    29. 29. Converse with ColleaguesNetwork with WASFAA members!WASFAA meals – sit with someone newInterest sessions – ask your neighborReceptions and activities – strike up aconversationEmail or call WASFAA colleagues
    30. 30. Converse with ColleaguesNetwork with WASFAA members and otherfinancial aid administratorsTry Twitter #WASFAA #finaid #SachatConnect on LinkedInGoogle Plus
    31. 31. Federal Issues Committee Michelle Curtis, UW-Madison Melissa Haberman, UW Colleges Susan Johnson, UW-Whitewater David Sandra, UW-Madison Your name could be here, contact a committee member!

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