TASFAA Community Blog
Doug Savage, TG Senior Regional Account Executive
In many organizations, when the topic of hiring an external service provider comes up, there are usually two schools of thought. From one perspective, getting help from the outside is perceived as less than ideal; decision makers may cite cost, expertise limitations, and a lack of understanding of organizational culture as factors that discourage outsourcing. On the other hand, outsourcing may provide many advantages, including relief for overtaxed staff, reduced training and maintenance needs, and a resource to augment internal expertise.
The following steps help to determine where to head when making this decision.
The most important factor in making the decision to outsource is the business objective. What specific need is trying to be met? Surprisingly, many organizations make outsourcing decisions without clearly defining their objective. This results in frustration, as those in the office will have differing perspectives on the challenge that needs to be addressed leading to different solutions. Once the objective has been clearly defined, it becomes easier to address.
Next, determine the risk that will be faced if the objective is not met. This is a consideration that is often disregarded. Is the objective attempting to address an issue that is critical in nature? Will financial loss, revocation of licenses or privileges, or experience a loss of business opportunities be incurred if the business objective is not met? What is the impact? Determine this in advance; this will provide an understanding of the importance of an effective solution. It may open other opportunities that are less costly or labor-intensive options.
After determining the business objective and identifying the risks involved in not meeting the objective, the next step is to outline all of the functions, features, and expectations for the solution. Once these have been identified, categorize them as “essential” versus “nice to have,” and rank them within these specific categories. The completed list should prioritize all elements.
Once the business need has been defined, the business risk evaluated, and the needs versus the wants identified, examine existing resources to determine feasibility in addressing the business challenge internally. Some issues to consider include:
After taking each of the steps above, it should be asked whether enough information is available to make a decision. Determine what will be needed to address challenges using existing resources or when considering outsourcing. Even if the “wrong” decision is made, going through these steps will provide a way to identify where failures might have occurred. Ultimately, if the decision is made to hire a service provider, the answers to many of the above questions can help evaluate options in the marketplace helping to meet business objectives.
Doug Savage is a senior regional account executive with TG serving schools in TASFAA. You can reach Doug at (800) 252-9743, ext. 6711, or by email at email@example.com. Additional information about TG can be found online at www.TG.org.
There are two upcoming leadership events sponsored by the NASFAA Leadership Development and Professional Advancement Committee. Mark your calendars now or visit the NASFAA website for additional details as they become available.
NASFAA Leadership Conference
The Leadership & Legislative Conference is an annual three-day event, held in the Washington, D.C. area, providing intensive preparation for NASFAA members in association leadership positions, about to assume such positions, or who aspire to association leadership roles. This year, the event will be held March 10-12, 2013 at the LEnfant Plaza Hotel, Washington, DC. Learn more about this unique event online now at www.nasfaa.org/leadership/.
NASFAA Pre-Conference Leadership Seminar
A full day event entitled A Seminar in Successful Financial Aid Leadership will be held on Saturday, July 13th, prior to the NASFAA Conference in Las Vegas NV. This seminar is intended for directors or those who aspire to director roles to provide skills, knowledge and a resource base to enable you to be better in your roles as leaders on your campus as well as managers and administrators in your offices. The cost of the seminar is $115 and registration will be available on the NASFAA Conference website.
DEPARTMENT OF EDUCATION
34 CFR Part 685
[Docket ID ED-2012-OPE-0010]
William D. Ford Federal Direct Loan Program
AGENCY: Office of Postsecondary Education, Department of Education.
ACTION: Announcement of early implementation date.
SUMMARY: The U.S. Department of Education (Department) issues this document to establish the date for the early implementation of William D. Ford Federal Direct Loan (Direct Loan) program regulations that establish a new income-contingent repayment plan based on the President's "Pay As You Earn" repayment initiative (the Pay As You Earn repayment plan).
DATES: The early implementation date for Sec. Sec. 685.208(k)(1) and 685.209(a), published November 1, 2012 (77 FR 66087), is December 21, 2012.
FOR FURTHER INFORMATION CONTACT: For information about the Pay As You Earn repayment plan or how to apply for Pay As You Earn repayment, the
Federal Student Aid Information Center (FSAIC) at 1-800-4FEDAID (1-800- 433-3243). For information on the establishment of the early implementation date, Jeff Baker at 1-202-377-3000.
If you use a telecommunications device for the deaf (TDD) or a text telephone (TTY), call the Federal Relay Service (FRS), toll free, at 1-800-877-8339.
Section 482(c) of the Higher Education Act of 1965, as amended (HEA), requires that regulations affecting programs under title IV of the HEA be published in final form by November 1 prior to the start of the award year (July 1) to which they apply. However, that section also permits the Secretary to designate any regulation as one that an entity subject to the regulations may choose to implement earlier and the conditions for early implementation.
On November 1, 2012, the Department issued final regulations in 34 CFR part 685 for the Pay As You Earn repayment plan (77 FR 66087). In the preamble to the final regulations, the Secretary announced the Department's intent to implement the new Direct Loan program regulations establishing the Pay As You Earn repayment plan as soon as possible.
Implementation Date of These Regulations
The Secretary is exercising the authority under section 482(c) of the HEA to designate the following amended regulations in 34 CFR part 685 for early implementation beginning on December 21, 2012, at the discretion of individual borrowers:
(1) Sec. 685.208(k)(1).
(2) Sec. 685.209(a).
If a borrower elects to implement the Pay As You Earn repayment plan early in accordance with this notice, the borrower will have the rights and be subject to the obligations under both Sec. Sec. 685.208(k)(1) and 685.209(a). To implement the Pay As You Earn Plan early, a Direct Loan borrower must request to repay his or her eligible loans under that plan.
Accessible Format: Individuals with disabilities can obtain this document in an accessible format (e.g., braille, large print, audiotape, or compact disc) on request to one of the contact persons listed under FOR FURTHER INFORMATION CONTACT.
Electronic Access to This Document: The official version of this document is the document published in the Federal Register. Free Internet access to the official edition of the Federal Register and the Code of Federal Regulations is available via the Federal Digital System at: www.gpo.gov/fdsys. At this site you can view this document, as well as all other documents of this Department published in the Federal Register, in text or Adobe Portable Document Format (PDF). To use PDF
you must have Adobe Acrobat Reader, which is available free at the site.
You may also access documents of the Department published in the Federal Register by using the article search feature at: www.federalregister.gov. Specifically, through the advanced search feature at this site, you can limit your search to documents published by the Department.
(Catalog of Federal Domestic Assistance Number: 84.268.)
Dated: December 3, 2012.
Secretary of Education.
[FR Doc. 2012-29525 Filed 12-6-12; 8:45 am]
BILLING CODE 4000-01-P
Credit-based Programs and R2T4
Return of Title IV (R2T4) doesn't have to be daunting. This session walks through a credit-based example to help you understand what it is and when it applies so you can effectively counsel students and help them make informed decisions about withdrawing from school.
Specific topics include:
December 6 @ 11 AM Central time https://glhec.webex.com/glhec/k2/j.php?ED=156736417&UID=1115743912&HMAC=b9fa1cbb9c75111a931d7a897295d839132deab0&RT=MiM3&FM=1
December 12 @ 2 PM Central time https://glhec.webex.com/glhec/k2/j.php?ED=156736472&UID=1115744542&HMAC=6d49443e892e1a0b3cca59c174888968b2ea0c80&RT=MiM3&FM=1
December 20 @ 11 AM Central time https://glhec.webex.com/glhec/k2/j.php?ED=158080427&UID=1119444837&HMAC=7d5fe825d07ad7b3402db58bac1770af4edadd3c&RT=MiM3&FM=1
Clock-hour Programs and R2T4
Return of Title IV (R2T4) doesn't have to be daunting. This session walks through a clock-hour example to help you understand what it is and when it applies so you can effectively counsel students and help them make informed decisions about withdrawing from school.
Specific topics covered include:
December 5 @ 2 PM Central time https://glhec.webex.com/glhec/k2/j.php?ED=156736612&UID=1115745182&HMAC=f6d98ea7460b7a26462f84c0494513b9b72b0750&RT=MiM3&FM=1
December 11 @ 11 AM Central time https://glhec.webex.com/glhec/k2/j.php?ED=156736672&UID=1115745407&HMAC=65bf7d29e868b1532ade3e0f3caf8169d73d6e3b&RT=MiM3&FM=1
December 19 @ 2 PM Central time https://glhec.webex.com/glhec/k2/j.php?ED=158080127&UID=1119443152&HMAC=442f853fa10263dd8ed3cae2f3c283b4e70f30a4&RT=MiM3&FM=1
Satisfactory Academic Progress: Moving Students in the Right Direction
To be eligible for FSA funds, a student must make satisfactory academic progress (SAP), and schools must have a reasonable policy for monitoring that progress. Learn the basics of the SAP policy and how it affects you. This session will review the requirements so you can respond to your students’ needs and move them toward successfully completing the program for which they are receiving aid.
• Understanding institutional requirements
• Identifying student eligibility requirements
• Appreciating the differences between qualitative and quantitative components
• Exploring consumer information requirements
December 4 @ 11 AM Central time https://glhec.webex.com/glhec/k2/j.php?ED=158080852&UID=1119446077&HMAC=1d9a91608fe8d1eb243e528ddb1cb98d0e7d9171&RT=MiM3&FM=1
December 18 @ 2 PM Central time https://glhec.webex.com/glhec/k2/j.php?ED=158080902&UID=1119446757&HMAC=d9e0eaa111b0788796dee3a485b501434ef2c13e&RT=MiM3&FM=1
A Guide to Great Lakes Default Prevention Tools
December 7 @ 2 PM Central time https://glhec.webex.com/glhec/k2/j.php?ED=156699522&UID=1115641302&HMAC=d1e206b14538a7f4679258cf1b5a4777fba9854b&RT=MiM3&FM=1
Planning for the Shopping Sheet -- Make a List and Check it Twice Linda Peckham
Senior Training Strategist, Great Lakes Higher Education Guaranty Corporation
The Financial Aid Shopping Sheet, developed by the Department of Education in conjunction with the Consumer Financial Protection Bureau, was designed to provide students with an improved comparison tool when making a college enrollment decision. The form is intended to help students better understand how much grant aid, versus loan and work aid, they are being offered. The form also provides information about the college, including graduation rates, default rates, and average student indebtedness, to help students make a more informed choice.
Although not mandatory for the 2013-14 aid cycle (except for institutions that must comply under E.O. 13607), over 350 institutions will adopt the Shopping Sheet and are actively planning for implementation, most without the support of their enterprise software providers. The Great Lakes Training team spoke with several of these institutions to learn more about why they chose to participate in this first year and to ask what advice they would offer their peer institutions who will implement the template next year.
Ryan C. Williams, Associate Vice President of Enrollment Management at Syracuse University, says the university embraced the new Shopping Sheet because "it really supports our core mission to provide financial literacy for students throughout their lifecycle with us - from pre-enrollment to graduation." Reflecting on the usefulness of the Shopping Sheet for students, he noted, "The Sheet will really highlight those institutions that do not meet full need, and it will make it much more apparent to students what their future debt burden will be." Williams also feels that by providing the Shopping Sheet to returning students, the institution can help offer better information about increasing loan debt for students who take longer than four years to graduate. "They will be able to see the immediate impact of these decisions on their future loan debt."
Gaining a full understanding of future debt burdens and understanding the risk-benefit analysis of the enrollment decision is very much the Department of Education's intended goal of the template. But as Tabatha Turner, Senior Associate Director of Scholarships and Student Aid at UNC-Chapel Hill, notes, "Students will still use 'emotional college when making a collecge choice even when the long-term costs are made clear, but at least the Sheet will provide a way for families to compare those choices consistently from college to college and in ways that differ from the traditional award letter."
The Shopping Sheet, for example, will illustrate for a family that "Net Cost" is the difference between total cost and gift aid. Student loans, work-study, and Parent PLUS loans are listed as "options to pay net costs." In this way, the Shopping Sheet will clarify that loans, if needed, may in fact increase the long-term cost of the educational purchase decision.
Rick Shipman, Director of Financial Aid at Michigan State University, agrees that the Shopping Sheet, with its increased clarity about loans, will
help students understand the bottom line about their college purchase decision and highlight the long-term impact of their college choice on their financial lives." He cautions that for some students, the Shopping Sheet cannot replace the benefits of one-on-one counseling with financial aid staff about the award letter, and advises his staff to work closely with at-risk families before they make enrollment decisions.
At the University of Notre Dame, Director of Financial Aid Mary Nucciarone and her team are strong supporters of the Shopping Sheet and are working to make it available to both entering and returning students by early March. She emphasizes that the Shopping Sheet, with its comprehensive data about average debt, default rates and graduation rates, is a great tool for schools to display "their good news to students."
Nucciarone anticipates, however, that the Shopping Sheet will generate questions. For example for students who do not receive any loans as part of their award, Nucciarone notes, "The Shopping Sheet delineates loan information and students may wonder why their aid award letter does not include them or why the average loan debt is being reported on the Sheet." She is working with her counseling staff to find ways to help families understand the differences between the Shopping Sheet and the institutional award letter.
The Department of Education is currently building partnerships with enterprise software providers so that they can support the use of the Shopping Sheet in future award cycles and make it easier for more schools to use the tool. In the meantime, most of the 350 early adopters are using institutional resources to make the template work in this first year. Tips for colleagues considering adopting the Shopping Sheet this year or next include:
I know everyone wants to know all the details and have all the information to implement the 2013-2014 verification items right now. I promise you that ED is working hard to get information out to all of our schools outlining procedures, verification language that can be used when requesting data, possible documents, processing steps, etc. Please stay tuned to IFAP for more updates and guidance.
Speaking of verification, however, if you were not aware policy recently updated the program integrity website(http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/verification.html) with six new verification Q & As to help the current verification process – disbursing unsubsidized aid when verification is not complete (VER-Q11); what to do when SNAP or child support paid is not reported on the FAFSA but appears on the VWS (VI-Q2 and VI-Q6); acceptable transcript documentation (DOC-Q2 and DOC-Q10); and changing FAFSA data to include a rollover as a correction (CHD-Q2).
One important piece of information to point out under VI-Q2 and VI-Q6 is that a record of account transcript can now also be used as one of the possible items for acceptable documentation when verifying an amended return. Please see the program integrity Q & A website for more detailed information.
A lot of schools are still asking if a student has reached their Pell 600% limit can they receive FSEOG funds. The answer – possible but unlikely. Remember in the FSEOG program a school must set up two selection groups. The first selection group contains students with the lowest EFCs who will also receive a Pell Grant. However, remember that this provision does not require a student to receive a Pell Grant in the same payment period as FSEOG just that they receive Pell in the same award year they are receiving FSEOG.
The second selection group consists of those students with the lowest EFCs who are NOT receiving Pell Grants. The second selection group will be utilized only if there are remaining FSEOG funds after making awards to all Pell grant recipients in the first selection group. Please note that students not receiving any Pell Grant during the award year as a result of exceeding their Pell LEU limits would fall in the second selection group. And though it is possible to award FSEOG to students in the second selection group, many schools are unable to award FSEOG to students in the second group because they never get beyond awarding FSEOG to Pell recipients with low EFCs in their first selection group.
Another question I have been getting a lot is around how to award Pell to a student with less than 100% eligibility remaining in the award year due to reaching the Pell 600% limit. In those cases you would award the student Pell similar to how you handle a transfer student. You would award up to the normal full amount allowed in the first payment period and provide any remaining amount in the second or subsequent payment periods. For example, if a student is enrolled in a standard term semester program (fall and spring) with an annual Pell award of $4800 (100%) with a current LEU of 523.867% then their remaining eligibility is 76.133% of the annual award ($3654.384). Remember you do not round the percentages. Assuming the student is full-time, the school would disburse 50% of the annual award ($4800) in the 1st term ($2400) and would disburse the remainder of the annual award in the second term, up to the remainder of their LEU = $1254.384 (26.133%). Remember you may round the dollar amount down to $1254 (26.125%), or award the cents $1254.38 (26.133%). What the school would NOT do is take the remaining amount of Pell for the year ($3654) and spread it out evenly among the terms the student would be attending.
SAP and Clock Hour Programs
For schools with clock hour programs please note that policy did post examples of how to measure the quantitative component of SAP on the program integrity Q & A website (http://www2.ed.gov/policy/highered/reg/hearulemaking/2009/sap.html) back in late August under the R-Q9 question. Three examples were provided to showcase how to measure the quantitative requirement at the end of the 3 possible payment period scenarios allowed under clock hour programs. Please review the program integrity website for specific details.
Federal Student Aid (FSA) recently announced the availability of an Electronic Income-Based Repayment (IBR) Application on the StudentLoans.gov Website. Through interfaces with the National Student Loan Data System (NSLDS) and the Internal Revenue Service (IRS), the Electronic IBR Application streamlines the application process for the majority of borrowers who choose to repay their eligible William D. Ford Federal Direct Loan (Direct Loan) Program and/or Federal Family Education Loan (FFEL) Program loans under the IBR Plan. Borrowers will use the application to initially apply to repay under the IBR Plan and to subsequently meet the plan’s annual income documentation requirement.
FSA has provided a high level summary of the Electronic IBR Application and details the following information:
The complete article can be found here: Electronic Income-Based Repayment Application in PDF Format, 94KB, 5 Pages
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