Midwest Association of Student Financial Aid Administrators

MINNEAPOLIS, MN OCTOBER 18-21

MASFAA: TIME TO REFOCUS

Midwest Association of Midwest Association of Student Student Financial Aid AdministratorsFinancial Aid AdministratorsThe following is a presentation prepared

for MASFAA’s 2009 Conference in Minneapolis, MN October 18-21, 2009

TOPIC:

After HEOA – Cockpit Checklist Approach: Ideas for Campus Awareness, Review, and Implementation

PRESENTER: Joyce Hall, Executive Director

Division of Financial Aid

Purdue University



HEOAHEOAFirst Things First:• President, Provost, or CFO agree on who is responsible

for review of HEOA.• Do you have a Government Relations Office? A

Compliance Office?• We had a vacuum – Government Relations is focused on

proposed legislation. We had no designated compliance officer on date of signing of HEOA.

• Financial Aid volunteered to coordinate review and implementation of HEOA.

2



HEOAHEOABackground Preparation:

• Meeting to discuss plans for review of HEOA (Sept 11, 2008).

Invited:VP for Finance, Treasurer Institutional Research

RepAsst VP Enrollment Management RegistrarDirector of Audits VP for Student Services

• Came prepared with: Recommendations for review of specific sections of HEOA Communication Plan

• Ex., News article in Purdue News announcing HEOA Task Force charge

• Memo to invite to Kick-Off meeting those assigned to implementation

• Creation of SharePoint website to track HEOA progress (more later)

Public Hearing Schedule Neg-Reg Schedule 3



HEOAHEOABackground Preparation:

• Proposed Membership HEOA Task Force (Approved)Executive Director, Division of Financial Aid, ChairRegional Campus Student Aid Directors (3)Enrollment Management Reporting (1)Internal Auditor – DirectorOffice of Institutional Research (1)BursarRegistrarAssistant ComptrollerFinancial Aid Office

Policy Analyst Senior Associate Directors (2) Loan Assistant Director

4



HEOAHEOABackground Preparation• Chair – Recommended to VP, Asst Treas/VP Student

Services – Purdue Implementation Assignments

• List Suggested Assignments by Title, Part, then Section

Example: Title IV Student Aid

Part A Grants Section 401 Pell Grants – Pell Grant Administrator

Assistant Director Senior Associate Director Section 402 Academic Competitiveness Grants –

(same as above) Section 402 Federal TRIO Programs – Director

Campus Federal TRIO

Program (See Appendix for Full Details on

Assignments) 5



HEOAHEOANext Step:

• Memo to Task Force Members – Sept 17, 2008

• Issued Request to serve on Task Force

• Provided Summary of Staff Assignments for Review/Implementation

• Provided copy of NASFAA HEOA Summary Memorandum copies to:

• VP Business Services, Assistant Treasurer• Asst VP Enrollment Management• VP Engagement• Executive VP, Treasurer• VP Student Services• Provost

• HEOA Task Force met bi-monthly by telephone conference call until Aug, 2009.

6



HEOAHEOAAnother Important Step: Getting People Involved

• Invited all people with implementation assignments to overview presentation on HEOA

Copies to: (Important for invitees to know senior management is aware)• VP Business Services, Assistant Treasurer• CFO• VP Engagement• VP Student Services• Provost• Asst VP Enrollment Management

• Oct 20, 2008 – Presentation occurred – 27 attendees• Provided Summary HEOA• Introduced Task Force Members• Agenda

Overview HEOA Review Task Force Membership Explain public hearings and Neg-Regs Review resources available Provide ‘template’ for each to use to document implementation Due Date – Nov 14, 2008

7



HEOAHEOAGetting Perspective HEA

• Covered HEA History – 1965

• Other examples of important legislation 1964-65

• Quote from President Lyndon Johnson – 1965

• Perspective on HEOA timeframe

(Next, a few example slides)

8



9

Reauthorization Legislationis Huge – Totals 1,100 Pages

Title I: General Provisions

Title II: Teacher Prep

Title III: Institutional Aid

Title IV: Student Assistance

Title V: Developing Institutions

Title VII: Graduate and Postsecondary Improvement Programs

Title VIII: Additional Programs

Title X: Private Student Loan Improvement

Title XI: Studies and Reports



Reauthorization

In the Beginning

1965 HEA 1968 1972 1976 1980 1986 1992 1998

Reauthorization wasscheduled for:2004 (not happening) 2005 (NADA) 2006 (No Way) 2007 (No How)

5 Years and 16 Extensions of the HEA Law Later (continuing resolutions)

July 31, 2008 – House/Senate pass H.R. 4137

President Bush signs H.R. 4137 – August 14, 2008

Getting Perspective HEA

10



HEA signed into Law 1965HEA signed into Law 196511



HEOA signed into Law 2008HEOA signed into Law 200812



13



14



15



What Is ExpectedBefore Regs Come Out

Good faith effort to comply

Conference Bill – Absence of a date means Regulation goes into effect on August, 14, 2008!

16



HEOAHEOAREVIEWED WITH IMPLEMENTATION TEAM:

• College Cost

• Accreditation

• Student Financial Aid

• Title II: Teacher Professional Development

• Title VI: International Education

• New Key Disclosures

• Student Sunshine Loan Provisions

Resources Used: NASFAA, ACE, NACUA (National Association of College & University

Attorneys)

17



SharePoint is a platform used to:SharePoint is a platform used to:

Share information

Work together in teams

Manage projects

How Did We Track Our How Did We Track Our HEOA Task Force Work? . . . HEOA Task Force Work? . . . Used SharePoint Used SharePoint WebsiteWebsite

18



HEOAHEOA

WE COULD NOT HAVE DONE IT

WITHOUT SHAREPOINT WEBSITE.

19



Manage Projects EfficientlyManage Projects Efficiently

Shared document workspaces

Project task lists

Shared calendars connected to Outlook

Alerts and notifications

20



You will log in using your Purdue Career Account user-id and password. Remember to begin with ONEPURDUE as show below:

21



22



23



24



25



26



27



Title/Section: Effective Date: Action Needed:

Identify Person(s) Responsible for Implementation:

Timeline for Implementation:

TaskCompleted

List the Specific Regulatory Change You are Reviewing

Date Regulatory Change is to Take Effect

Be as Specific as Possible

By Name and Department

Use Date(s) or ASAP if Applicable

Section 488Institutional and Financial Assistance Information for Students

•Institution must develop plans to detect and prevent unauthorized distribution of copyrighted material on IT systems, and offer alternatives to illegal-downloading or peer-to-peer distribution of intellectual property 488(P)(i)(ii)(iii)

14-Aug-09 Review current documents and revise as needed. Nowin place:1. Purdue IT Resource Acceptable Use Policy2. Acceptable use policy for network usage in University housing (ResNet)3. Copyright notice posted on University's SecurePurdue web site4. SecurePurdue video on illegal downloading5. University Copyright Office web site6. University Copyright Office publication "A Guide to Copyright"7. University Regulations document with copyright section posted on the Dean of Student's web site

Donna Ferullo, University

Copyright Officeand

Joanna Grama, ITAP Networksand Security

1-Jul-09 •COMPLETE and currently in place:1. Purdue IT Resource Acceptable Use Policy2. Acceptable use policy for network usage in University housing (ResNet)3. Copyright notice posted on University's SecurePurdue web site4. SecurePurdue video on illegal downloading5. University Copyright Office web site6. University Copyright Office publication "A Guide to Copyright"7. University Regulations document with copyright section posted on the Dean of Student's web site

Example: Documentation of ImplementationExample: Documentation of Implementation

28



Example: Documentation of ImplementationExample: Documentation of Implementation

HEOA Requirements for Copyright and Peer-to-Peer File Sharing

Summary Statement

The following steps have been taken to be in compliance with the HEOA copyright and peer-to-peer file sharing requirements:

1. Updated both IT@P and University Copyright Office web sites to incorporate more detailed information on copyright infringement penalties.

2. Provided more links between the IT@P and University Copyright Office web sites.

3. Reviewed copyright information available at IT@P, University Copyright Office and Dean of Students Office to ensure that it is sufficient.

4. University Copyright Office expanded distribution to students of its publications.

5. Reviewed current security procedures.

6. Added copyright link to Purdue’s home page.

7. Provided information on alternative resources for sharing music, video and images.

Respectfully submitted,

Donna L. Ferullo Director, University Copyright Office March 4, 2009

29



HEOAHEOAMonitoring HEOA at Purdue – Going Forward

• Get advice from Compliance VP/University Attorney on new policies or issues as regulations are final.

Example: Student Loan Code of Conduct Zachary’s List – and sex offenders – Pell Grants

• Provided VP for Compliance with final SharePoint summary and documentation

• Recommended others in University monitor non-student aid going forward.

Examples: Title I Title II

• Financial Aid to monitor Financial Aid-related: Title ITitle IV

30



HEOAHEOASuggestions for Schools of Smaller Size with Limited

Staffing

• Divide and conquer.

• Identify 5 or 6 financial aid directors you trust in their knowledge and willingness to work.

• Meet monthly by conference call; rotate the chair duties.

• Make assignments by sections of new regulations.

• Use NASFAA webinars to help understand requirements!

• Get a SharePoint website to post section reviews using an agreed template.

31



HEOAHEOASuggestions for Schools of Smaller Size with Limited

Staffing

• Allow each school to link to the summary to document how they will comply and attach copies of proof of compliance.

• If concerned about confidentiality, have those sections only viewable by the specific school.

• Get support from higher administration to tell others within the institution they will be tapped as needed to review sections of the law applicable to their office when needed.

(Ex., campus crime (Police), Registrar, Admissions, Distance Education, Dean of Students, Student Hospital, etc, etc.)

32



APPENDIX

33



34



35

Purdue Implementation Assignments:

NASFAA Summary of the Higher Education Opportunity Act (HEOA)September, 2008

Rev. 10/10/08

* First Person Listed is the Lead

Section: Person(s) Responsible:

TITLE I – GENERAL PROVISIONS

Section 101. General Definition of Institution of Higher Education Joyce Hall, Executive Director, Division of Financial Aid, et al

Section 102. Definition of Institution of Higher Education for Purposes of Title IV Programs Joyce Hall, Executive Director, Division of Financial Aid

Section 103. Additional Definitions Joyce Hall, Executive Director, Division of Financial Aid

Section 104. Protection of Student Speech and Association Rights / Sense of the Senate (Information) - Tony Hawkins, Dean of Students

Section 105. Protection of Student speech and Association Rights / Sense of the Senate (Information) - Tony Hawkins, Dean of Students

Section 106. Treatment of Territories and Territorial Student Assistance (Information) - Joyce Hall, Executive Director, Div of Fin Aid

Section 107. Drug and Alcohol Abuse PreventionJim Westman, Director, Purdue University Student Hospital, (John Cox, Chief, Purdue Police), Sandy Monroe, Assistant Vice President for Student Services, Lori Tang

Section 108. Prior Rights and Obligations Technical Change (Information)

Section 109. Diploma Mills Secretary of Education

Section 110. Improved Information Concerning the Federal Student Financial Aid Web site Secretary of Education

Section 111. Transparency in College Tuition for Consumers

Jacquelyn Frost, Director, Office of Institutional Research, Maria Drake, Assistant Director, Division of Financial Aid, Carol Cooper, Senior Associate Director, Division of Financial Aid, Brent Drake, Associate Director, Enrollment Management

Section 112. Textbook Information Bob Kubat, University Registrar

Section 113. Database of Student Information Prohibited Secretary of Education

Section 114. In-State Tuition Rates for Armed Forces Members, Spouses, and Dependent Children John Higgins, Bursar, Bob Kubat, University Registrar

Section 115. State Higher Education Information System Pilot Program State Higher Education



36



Rev. 10/10/08


Section 116. State Commitment to Affordable College Education State Higher Education

Section 117. Performance-Based Organization for the Delivery of Federal Student Financial Assistance Secretary of Education

Section 118. Procurement Flexibility Secretary of Education

Section 119. Certification Regarding the Use of Certain Federal Funds - Lobbying by Schools Information to Vic Lechtenberg, Vice Provost for Engagement

Section 120-154. Institution and Lender Reporting and Disclosure RequirementsMarvin Smith, Senior Associate Director for Operations, Division of Financial Aid

TITLE III – INSTITUTIONAL AID

Section 303. American Indian Tribally Controlled Colleges and Universities N/A

Section 304. Alaska Native and Native Hawaiian-Serving Institutions N/A

Section 305. Predominantly Black Institutions N/A

Section 306. Native American-Serving, Nontribal Institutions N/A

Section 307. Assistance to Asian American and Native American Pacific Islander-Serving Institutions N/A

Section 313. Endowment Challenge Grants Mike Ludwig, Director, Sponsored Programs Services

Section 315. Programs in STEM Fields - New "YES" Partnership Grant - Minority Youth Chris Ladisch, Vice Provost

Section 316. Investing in Historically Black Colleges & Universities & Other Minority Serving Institutions N/A

Section 319. Authorization of Appropriations - For Tribal Colleges (Information)

TITLE IV – STUDENT ASSISTANCE Overall: Joyce Hall, Executive Director, Division of Financial Aid

PART A – GRANTS TO STUDENTS



37



Rev. 10/10/08


Section 401. Federal Pell Grants

Donna Rush, Financial Aid Administrator, Division of Financial Aid, Kirsten Reynolds, Assistant Director, Division of Financial Aid, Marvin Smith, Senior Associate Director,Division of Financial Aid

Section 402. Academic Competitiveness Grants

Donna Rush, Financial Aid Administrator, Division of Financial Aid, Kirsten Reynolds, Assistant Director, Division of Financial Aid, Marvin Smith, Senior Associate Director, Division of Financial Aid

Section 403. Federal Trio ProgramsDean Ballotti, Assistant Dean of Students/Director of Horizons Program – Horizons Program

Section 404. Gaining Early Awareness and Readiness for Undergraduate ProgramsDrew Koch, Director, Student Access, Transition & Success, Chris Ladisch, Associate Provost or Randy Woodson, Provost

Section 405. Academic Achievement Incentive Scholarships (Information) - Program Eliminated

Section 406. Federal Supplemental Education Opportunity GrantsShelley Havrilesko, Assistant Director, Division of Financial Aid, Brad Bessenbacher, Financial Aid Administrator, Carol Cooper, Senior Associate Director, Division of Financial Aid

Section 407. Leveraging Educational Assistance Partnership Program State Agencies

Section 408. Special Programs for Students Whose Families are Engaged in Migrant & Seasonal Farm Work - High School Equivalency Programs (HEP) and College Assistance Migrant Program (CAMP)

(Information) ?

Section 409. Robert C. Byrd Honors Scholarship Program State Higher Education Agencies

Section 410. Child Care Access Means Parents in School - (Child Care Program: grants require application?) Joyce Hall, Executire Director, Division of Financial Aid

Section 411. Learning Anytime Anywhere Partnerships (Eliminated)

Section 412. TEACH GrantsKirsten Reynolds, Assistant Director, Division of Financial Aid, Marvin Smith, Senior Associate Director, Division of Financial Aid

PART B – FEDERAL FAMILY EDUCATION LOAN PROGRAM

Section 421. Limitations on Amounts of Loans Covered by Federal Insurance Lenders



38



Rev. 10/10/08


Section 422. Federal Payments to Reduce Student Interest Costs Guarantors

Section 423. Voluntary Flexible Agreements Guarantors

Section 424. Federal PLUS Loans

Kirsten Reynolds, Assistant Director, Division of Financial Aid, Cheryl Dixon, Financial Aid Administrator, Division of Financial Aid, Marvin Smith, Senior Associate Director, Division of Financial Aid

Section 425. Federal Consolidation Loans


Section 426. Default Reduction Program Lender / Guarantor

Section 427. Requirements for Disbursement of Student LoansKirsten Reynolds (Assistant Director, Division of Financial Aid), Marvin Smith, Senior Associate Director, Division of Financial Aid

Section 428. Unsubsidized Stafford Loan Limits


Section 429. Loan Forgiveness for Teachers employed by Educational Service Agencies


Section 430. Loan Forgiveness for Service in Areas of National Need


Section 431. Loan Repayment for Civil Legal Assistance Attorneys


Section 432. Reports to Consumer Reporting Agencies & Institutions of Higher Education - (Loans to be reported as "education loan")

Lenders / Consumer Reporting Agencies



39



Rev. 10/10/08


Section 433. Legal Powers and Responsibilities Secretary of Education

Section 434. Student Loan Information by Eligible Lenders Lenders / Guarantors

Section 435. Consumer Education Information - (Must work with schools to develop debt management/financial literacy training for students)

Guarantors / Work with schools - David Reseigh, JLD Administrator, Division of Financial Aid

Section 436. Definition of Eligible Institution & Eligible Lender - (Cohort default) Secretary of Education / Joyce Hall Information

Section 437. Discharge and Cancellation Rights in Case of Disability

Kirsten Reynolds, Assistant Director, Division of Financial Aid, Brad Bessenbacher, Financial Aid Administrator, Division of Financial Aid, Marvin Smith, Senior Associate Director, Division of Financial Aid, Carol Cooper, Senior Associate Director, Division of Financial Aid

Section 438. Conforming Amendments for Repeal of Section 439 (Information)

PART C – FEDERAL WORK-STUDY PROGRAMS - Section 441-447

David Reseigh, JLD Administrator, Divisision of Financial Aid, Lauren Franks, Financial Aid Administrator, Division of Financial Aid, Marvin Smith, Senior Associate Director, Division of Financial Aid

PART D – FEDERAL DIRECT STUDENT LOAN

Section 451. Terms and Conditions of Loans


Section 452. Funds for Administrative Expenses Secretary of Education

Section 453. Guaranty Agency Responsibilities and Payments; Reports and Cost Estimates Guarantee Agency

Section 454. Loan Cancellation for TeachersLenders / Guarantors / Kirsten Reynolds, Assistant Director, Division of Financial Aid)

PART E – FEDERAL PERKINS LOANS - Section 461-466Brad Bessenbacher, Financial Aid Administrator, Division of Financial Aid, Carol Cooper, Senior Associate Director, Division of Financial Aid



40



Rev. 10/10/08

* First Person Listed is the LeadPART E – FEDERAL PERKINS LOANS - Section 461-466

Brad Bessenbacher, Financial Aid Administrator, Division of Financial Aid, Carol Cooper, Senior Associate Director, Division of Financial Aid

PART F – NEED ANALYSIS - Section 471-473

Deb Watkins, Senior Assistant Director, Division of Financial Aid, Brenda White, Financial Aid Administrator, Division of Financial Aid, Marvin Smith, Senior Associate Director, Division of Financial Aid

PART G – GENERAL PROVISIONS RELATING TO STUDENT ASSISTANCE - Section 481-493Joyce Hall, Executive Director, Division of Financial Aid, Carol Cooper, Senior Associate Director, Division of Financial Aid

Section 494. Regulatory Relief and Improvement Secretary of Education

Section 494A. Transfer of AllotmentsCarol Cooper, Senior Associate Director, Division of Financial Aid

Section 494B. Purpose of Administrative PaymentsCarol Cooper, Senior Associate Director, Division of Financial Aid

Section 494C. Advisory Committee on Student Financial Assistance (Information)

Section 494D. Regional Meetings and Negotiated Rule-Making Secretary of Education

Section 494E. Year 2000 and Requirements at the Department (Repealed)

Section 494F. Technical Amendment of Income-Based Re-PaymentsLenders / DOE / Kirsten Reynolds, Assistant Director, Division of Financial Aid, Information

PART H – PROGRAM INTEGRITY

Section 495. Recognition of Accrediting Agency or Association Chris Ladisch, Vice Provost

Section 496. Eligibility and Certification ProceduresJoyce Hall, Executive Director, Division of Financial Aid, Carol Cooper, Senior Associate Director, Division of Financial Aid

Section 497. Program Review and Data Secretary of Education

Section 498. Review of Regulations Secretary of Education

PART I – COMPETITIVE LOAN AUCTION PILOT PROGRAM

Section 499. Competitive Loan Auction Pilot Program Evaluation Secretary of Education



41



Rev. 10/10/08


Section 499. Competitive Loan Auction Pilot Program Evaluation Secretary of Education

TITLE V – DEVELOPING INSTITUTIONS - Section 501, 502, 505 N/A

PART B – PROMOTING POSTBACCALAUREATE OPPORTUNITIES FOR HISPANIC AMERICANS N/A

TITLE VII - GRADUATE AND POSTSECONDARY IMPROVEMENT PROGRAMS - Section 701-710Cyndi Lynch, Director of Fellowships, Professional Development, Grad School

TITLE VIII - ADDITIONAL PROGRAMS - Section 801-903 (Refere to details) Sponsored Research ?

TITLE X - PRIVATE STUDENT LOAN IMPROVEMENT

A - Preventing Unfair & Deceptive Private Educational Lending Practices & Eliminating Conflicts of InterestLenders / Kirsten Reynolds, Assistant Director, Division of Financial Aid - FYI

B - Improved Disclosures for Private Education LoansLenders / Kirsten Reynolds, Assistant Director, Division of Financial Aid - FYI

C - College AffordabilityLenders / Kirsten Reynolds, Assistant Director, Division of Financial Aid - FYI

D - Financial Literacy: Studies and Report Secretary of Education

TITLE XI - STUDIES AND REPORTS - Section 1101-1124 - (Mandated Studies)

Documents

Midwest Association of Student Financial Aid Administrators