AACRAO talks with Department of Education

by Brad Myers, AACRAO President

Jeff Baker, Director of Federal Student Aid Policy for the Department of Education (DOE), recently reached out to AACRAO and NASFAA (National Association of Student Financial Aid Administrators) about getting some folks together to discuss the financial aid and enrollment regulatory changes that go into effect July 1 of this year.  They are commonly referred to as the new “150% reporting requirements,” or SULA (Subsidized Usage Limits Applied) within the aid industry.  The DOE has received many questions and concerns about the changes and the implementation timeline.

My thanks to the following AACRAO members who were able to join me in Washington, DC, on short notice for the discussion: 

• Adrian Cornelius, University of Maryland
• Scott Dittman, Washington and Lee University
• Catherine Mund, Howard Community College
• Steven Smith, University of Maryland, Baltimore County
• Katherine Thomas, University of Maryland

With the short notice, and striving to keep travel expenses minimized, we focused on contacting some “local” representatives, incorporating some different types of institutions, and including some folks very directly involved with implementing the new requirements.

In addition, Janie Barnett, associate executive director, and Quintina Barnett Gallion, assistant director of legislative affairs, were able to join us from the AACRAO Office.

We were also joined by a representative from the National Student Clearinghouse (since most of us report NSLDS enrollment information to the DOE through the NSC), financial aid professionals from three higher education institutions, many staff from the Department of Education, and several financial aid contractors working with the DOE.  It was a wonderful discussion that lasted for several hours, and, to me, represented how effectively we can (and need to) work together with our DOE and Student Financial Aid (SFA) colleagues.  My biggest disappointment was that the discussion would have been much timelier had it occurred several months ago. 

Jeff Baker and Valerie Sherrer, the Director of NSLDS (National Student Loan Data System) within the DOE, led the discussion.  They began the meeting by reviewing their goals:

• Review the new reporting requirements (“enhancements” as they referred to them) related to aid and enrollment,
• Identify issues and questions with the reporting requirements, and
• Discuss the development of training and communication materials for institutions.

Mr. Baker provided an overview of the legislation:

• The timetable is set:
  • An effective date of July 1, 2014.  That means that any aid disbursed for FY15 is covered and must be reported.  For some of us, that includes disbursements for Summer Term 2014.  Financial aid information is reported to COD (Common Origination and Disbursement) within DOE, and enrollment information is reported (directly or indirectly) to NSLDS.
  • Enrollment reporting can be submitted as late as October, but must align back to July 1 for financial aid data reported as of July 1.
• Legislative goals: 
• To evaluate aid-related programs based on the 150% timeframe for program completion.
• To evaluate completion rate information, particularly for Pell recipients as compared with other students in the same program.
• For accountability reasons, we will still have these reporting requirements even if subsidized loans go away for undergraduate students.  Note that subsidized loans for graduate students were eliminated last year.

Ms. Sherrer provided an overview of NSLDS and how it fits into the process:

• SFA data comes to NSLDS from COD, only at the time of disbursement.
• Enrollment data comes to NSLDS from NSC (National Student Clearinghouse) and other sources on a regular basis.
• All of our institutions are already reporting “Campus Level” information, and program information as it relates to the primary program utilized by SFA to set the aid budget for the student.
• "Program Level” reporting is the key to the new requirements and requires most of us to significantly change the detail we are reporting.  During the conversation, the group identified some particular issues and questions:
  • Examples of particular issues/questions related to definitions:
    • “Length of program,” particularly for grad students, joint degree/dual degree students, and associate to baccalaureate degree students.
    • Could we report just overarching “academic progress” for a given term?
    • How to “split” enrollment among programs within a term?
    • “Program begin/effective dates.” There are sometimes variations even among program groups.
    • Do we have a clear definition for “special programs” (like teacher education) since they have an impact on reporting requirements?
    • “Load rules,” particularly for certain graduate students.
  • Examples of particular issues/questions related to processes:
  • How to address mid-term program changes?  When does the program begin?
  • What about students who won’t graduate until a future term but are not enrolled in every term leading up to degree conferral? 
  • What does alignment between July 2014 data and October 2014 data really mean if an institution isn’t submitting enrollment reports until October?
  • Must all institutions report at least every 60 days, even if they have no enrollment during that part of the academic year (e.g., no summer school)?
  • What accountability is there for data mismatches between SFA data from COD and enrollment data from the institution?
  • Ms. Sherrer noted that they know the data won’t often match, but didn’t address any specific accountability issues.
  • She also noted that COD will be the only data system used to determine usage of aid.
    • NSLDS will review eligibility for aid based on COD data.
    • NSLDS will process any loss of interest evaluation for the students.
  • Some third-party vendor studend-information software applications are not fully up-to-date because of questions/issues they still have.
  • Many institutions will need to evaluate potential changes in data structure within systems to meet reporting requirements – then make them.  That likely can’t happen quickly, not even by October. Nevertheless, registrars, finanical aid officers, and information technology staff should begin conversations with each other immediately in order to prepare for proper enrollment reporting and coordination.
  • Institutions with home-grown student systems are struggling to accommodate the new requirements since they are “on their own” for interpretation and systems changes.
  • Examples of preparation issues:

The group then talked about some “next steps.”

• DOE acknowledged that they need to quickly review issues/questions that they need to address. 
• DOE agreed to draft additional training materials that can be reviewed by aid and enrollment folks for accuracy and input.
• DOE agreed to develop training/informational webinars that AACRAO and NASFAA can assist with to help our members address our implementation needs.

Everyone agreed that it was an excellent conversation and that we all learned a great deal.  We hope that we can fairly quickly pull together answers to issues and questions raised, and develop some helpful training materials for our members.

It is also a meaningful example of how much we increasingly need to work collaboratively to be successful in today’s higher education compliance environment – both within our institutions and with the Federal government.

Thanks again to our members and national office staff who were able to join me in DC for this important discussion. 

Be on the lookout for additional information and materials to be published in Connect in the near future.