Tuesday, September 30, 2014

Developing a Social Media Program That Delivers

by Carissa Uhlman, Vice President of Student Success, Inceptia

As any Financial Aid professional will tell you, an ongoing challenge in communicating with students is simply getting them to engage in that communication. In a time when the words “you’ve got mail” just don’t have the same allure as they used to, and financial aid offices are being asked to do more with less, it is critical that every option is explored to find a timely and efficient way to reach students.

You’re invited to a free upcoming webinar, Developing a Social Media Program That Delivers: Practitioner Insights on Social Media Use within the Financial Aid Office, hosted by Inceptia. An overview of Millennial insights and social media trends will be provided by brand idea company, Agent; then, practitioners in the field will delve into assessing, developing, and maintaining an effective and innovative communication strategy. Join Melissa Niksic, Loyola University, Lenna Sliney, (formerly at) Rutgers University, and Justin Chase Brown, University of Missouri, as they discuss how incorporating social media, web, mobile, e-mail, video, digital, and even print elements into your communication flow can effectively engage students with a well-planned social media approach. 

This webinar will provide fantastic insight into the special considerations necessary to build a successful social media plan, including real examples of how this medium has contributed to thoughtful and, surprisingly, personal interactions with students.

During this informative and lively one-hour session, you will:
  • Get a meaningful picture of Millennials in order to uncover actionable insights for student engagement.
  • Hear how three financial aid offices have developed and executed effective, multi-tiered communication strategies at their institutions.
  • Get tips on creating quality content that is meaningful to students.
  • Find out how to measure the results of your efforts.
  • And more!

The webinar, “Developing a Social Media Program That Delivers: Practitioner Insights on Social Media Use within the Financial Aid Office,” will take place on Tuesday, October 21 @ 3:00 p.m. (ET) / 2:00 p.m. (CT). To secure your spot, register today at http://tinyurl.com/k7uowur. Plus, you can join the conversation by live-tweeting and sending questions in advance or during the webinar to #FAchat. You won’t want to miss it!

Wednesday, September 3, 2014

September Chat Topic: FAFSA Public Comment

On August 28th, Federal Student Aid announced the availability of the 2015-16 draft version of the Free Application for Federal Student Aid (FAFSA) and the Student Aid Report (SAR) for public comment. Comments are due by October 27th. This will be the basis for our September #FAchat.

You can review and/or submit comments by searching Docket ID number ED-2014-ICCD-0126 at http://www.regulations.gov or by linking directly to the page at http://www.regulations.gov/#!docketDetail;D=ED-2014-ICCD-0126.

The U.S. Department of Education (ED) attached several draft documents for which it is accepting comments that you can download: the 15-16 paper FAFSA, the 15-16 SAR, and the 15-16 SAR Acknowledgement. You can also download the supporting statement and related material.  There have already been comments that you can also review and comment on the comments page.

We encourage you to review the draft documents and supporting materials prior to the chat. As a ground rule for this particular chat, our discussion will be limited to a practical application of what ED is able to do for the 2015-16 aid year given the current legal framework. For example, it would be out of the scope of this discussion to suggest that the FAFSA be simplified to only a fraction of the questions currently on the form that are currently required by federal law. We hope things will change in the future to make the form simpler, but we're looking to spur a discussion this month on meaningful and practical changes for the 15-16 application materials that ED can implement.

We hope you will join us in discussing some practical changes for the 2015-16 FAFSA and submit your own comments to ED. All parties with an interest in how students finance higher education are welcome to join!

Tuesday, August 12, 2014

Tuesday, 8/12/14: August in the Aid Office

Okay, so August in the aid office is silly craziness, right? Join us today at noon central to talk about how we all handle it, from crowd control to stress relief. Have innovative ideas to share? We'd love to hear them! #FAChat is held the second Tuesday of each month at noon central time. You can join in the discussion at any time by adding #FAChat to your tweets.

Wednesday, July 9, 2014

7/8/14 #FAchat, the #NASFAA2014 Debrief

Here is our transcript of yesterday's chat, debriefing the NASFAA Conference that was held in Nashville, Tennessee last week. Thanks to all for joining in on the chat! Our next chat is scheduled for August 12th from 12-1 CST, but you can share your thoughts on financial aid using the #fachat hashtag at any time!

Monday, July 7, 2014

Thoughts on Financial Literacy from #NASFAA2014

#FAChat / #NASFAA2014 Tweet-up!

Tuesday July 1, 2014 at 5:30pm #FAchat participants from all over the country finally met in person during the National Association of Student Financial Aid Administrator's(#NASFAA2014) conference.

Thursday, June 26, 2014

Make the Most of #NASFAA2014 (Even If Not Attending)

The National Association of Student Financial Aid Administrators (NASFAA) Annual Conference begins in just a few days in Nashville, Tennessee! The NASFAA National Conference is the premier event serving the student financial aid community. Nearly 3,000 student aid professionals from across the nation attend the conference each year to teach, learn, network, and share best practices.

Attending conferences is a great way to develop professionally and obtain the necessary training to do your job well. However, we don’t always get the chance to attend the conferences we would like. The upcoming NASFAA conference might be that for you, but there are ways you can stay connected and still obtain some vital information from the meetings!

The NASFAA program this year boasts many different types of sessions, such as those about financial literacy, compliance, birds of a feather, policy, town hall, and more. If you’re unable to attend, you might find some live-tweeting helpful. Follow the official NASFAA 2014 hashtag (#NASFAA2014).

Last year, we chatted about making professional connections during NASFAA through Twitter. Those who will be in attendance can find a variety of ways to network with colleagues and many sessions. The speaker lineup is impressive this year, so even if you’re not attending, search the schedule and follow along at the hashtag so you can still benefit from a distance (or learn from more than just the sessions you’re attending). You can also follow the NASFAA twitter account @NASFAA for updates.

And, if you are attending the conference, please RSVP for the #NASFAA 2014 Tweetup!

Tuesday, June 24, 2014

A @FAFSA Twitter Fail

Twitter can be a powerful tool to build relationships and directly interact with stakeholders.  Unfortunately, one wrong move can be devastating. Misguided humor is sometimes the culprit as with a recent tweet from the Federal Student Aid branch of the U.S. Department of Education.

Usually, humor tends to be politically insensitive, but rarely mocking and offending their own customers and stakeholders. Unfortunately, someone @FAFSA made a bad judgment. They attempted to make a joke out of being poor. Not cool. This tweet reached thousands of people and had many replies, most of which called them out for their bad mistake.

The tweet was eventually deleted -- after being up for over an hour. Hopefully, the folks behind the account can make a public apology for the egregious error. This simply was not funny nor productive. And it offends not only the millions of students who need financial aid to attend college, but the financial aid administrators who help those students.


The FAFSA twitter account has since apologized for the above tweet (see below). Liz Gross, a social media strategist, makes a good point on her blog, regarding the backlash. While it was a mistake and should be getting attention, it's important to note that they publicly apologized and the good they've been doing with social media far outweighs this error.

Friday, June 20, 2014

#NASFAA2014 Tweetup!

In just over a week, thousands of financial aid professionals will be gathering in Nashville, Tennessee for the National Association of Student Financial Aid Administrators (NASFAA) 2014 conference. This year, we are partnering with NASFAA for our annual tweetup! There might even be some local treats available!
What is a tweetup, you ask?
A tweetup is an event where people who use Twitter come together to meet in person. Normally we connect with people online after we have met them. At a tweetup, you meet the people you might only otherwise know virtually (maybe through @nasfaa or @thefachat). Like finally putting a name to a face, a tweetup is a great opportunity to better connect with the people in your network and share just a little more than 140 characters at a time. If you have shared tweets with your colleagues the past few days (or maybe even longer), come by to visit with each other in person and enjoy some Nashville snacks courtesy of NASFAA!

Tweetup Date and Location
We're sure you want to soak in the conference and Nashville as much as possible and also network with your colleages. So, please join us as we network on July 1st at 5:25 p.m. (after the last session of the day) at the information desk in the Music City Center.

Please RSVP
It helps to know who is planning on joining us! Please RSVP for the #NASFAA2014 tweetup and feel free to comment on this post or tweet using the official #NASFAA2014 hashtag to spread the word and let everyone else know you're planning to be there so we know who we might expect to meet! We're excited to be able to host this together with NASFAA, so please join us!

Monday, June 9, 2014

Tuesday June 10, 2014 #FAchat: Financial Aid Innovations

What innovations have you implemented in your office? Tells us your great big ideas! Join us Tuesday June 10, 2014 from 12-1pm CST to talk about Financial Aid Innovations for this month’s #FAchat! Let’s talk about everything from Applications to Zero EFC. We’ll talk about innovations in financial literacy, default prevention, imaging documents, productivity and more!

Wednesday, May 14, 2014

Tuesday, May 13th #fachat with #acadv

We chatted about Satisfactory Academic Progress (SAP) on our May chat. And, unfortunately, it looks like Storify lost some of the tweets somehow, but a transcript of what could be collected is below. You can also see our SAP chat from last year on the #FAchat blog.

A special thanks to @AcAdvChat for joining us! Satisfactory Academic Progress is definitely an area we should collaborate with academic advisors so we can promote academic success with our students. And, like @sarah_pingel says, as we move forward, let's work to think of ways we can change to reduce instances of SAP and reframe the conversations away from student deficiences.

Tuesday, April 15, 2014

@LuminaFound Ideas Summit: #AffordCollege

Yesterday, April 14, 2014, in Washington D.C., the Lumina Foundation hosted the "Lumina Ideas Summit: New Models of Student Financial Support," which was a discussion about paying for college in the 21st century. The Lumina Foundation was able to commission several papers by a variety of authors who focused on new models of student financial support. The event was webcast live and the webpage currently states that a rebroadcast will be available soon. The authors presented and discussed their innovative ideas and the conversation also occurred on Twitter, using the #AffordCollege hashtag. Below you will see the #AffordCollege tweets before, during, and after the event.

Tuesday, April 1, 2014

Tips for Writing a Blog Interview

This is part two of two in a series about association blogs.

Once you have your association blog up and running what do you write about? A great place to start is profiles of association members. This gives members a chance to get to know each other and know more about the association. I really started to feel at home in the Wisconsin association after I presented an interest session at a conference. People who were in the session came up to me during the rest of the conference and started conversations with me. Sometimes all we need is an icebreaker to make going up to someone and starting a conversation a little less intimidating. The Wisconsin blog features profiles of members from all areas of the association to highlight their stories; we call this our We Are WASFAA posts.

Conducting an in person interview will give you the best material for writing a blog post. Phone interviews are the next best option. Some posts have been written by emailing the questions to an interviewee, but it can be harder to write the post that way. If the interviewee is willing to write the post themselves that may work better if it is not possible to conduct an interview.

Try to keep each article to approximately 1-2 pages of a word document in length. It is long enough to include detail, but not too long that people will stop reading before they finish.

When possible include a small picture related to the topic of the blog. In a We Are WASFAA blog post we try to share a photo of the interviewee in a professional setting and one in personal setting (with family, doing a recreational activity).

It is also helpful to include a small two line bio of the interviewer/author and a small photo. Include how author knows interviewee if appropriate. If you conduct an in-person interview a photo of the two of you together would be fun also.

Making time for two aid professionals to get together isn't always easy. Set a deadline to do the interview at least two weeks before your blog is due to the Blog Coordinator. This will give you enough time in case you have to reschedule or if you want to do any follow up questions.

I recommend that a second pair of eyes take a look at the article before you share it publicly. Sometimes it is easy to miss the little things when you have read your draft multiple times.

Most importantly, have fun! This is a great way to connect with another association member. You might find you have a common interest and end up presenting at a conference together in the future due to what you learn during the interview.

Example Interview Questions
  1. How did you get started in financial aid?
  2. What about your job has surprised you the most?
  3. What advice do you have for someone new to financial aid?
Association Leadership/Involvement
  1. How did you first become involved in the state/regional association?
  2. Why were you interested in an association leadership role?
  3. What advice do you have for someone new to the association?
  4. What advice do you have for someone who was just elected to an association leadership role?
  5. What recommendations do you have for someone who is interested in an elected position? Where should they get started?
Office Leadership
  1. Why were you interested in becoming a Financial Aid Director?
  2. What about your job has surprised you the most? What do you love most/least about your job?
  3. What advice do you have for someone in their first year of being a Financial Aid Director?
  4. What tips do you have for being an effective director?
Any Leadership
  1. What have you learned from your leadership role that you were not expecting?
  2. What tips do you have for being an effective leader?
  3. What is one thing you learned from your role as ---? (Role examples: Co-chair of a committee, elected representative, Financial Aid Director)
  1. You have presented at several conferences, how do you recommend someone get started with presenting?
  1. What do you like to do when you are not in the office?

Thursday, March 27, 2014

Strengthening the Federal Student Loan Program

On Thursday, March 27th, the U.S. Senate Committee on Health, Education, Labor and Pensions (HELP) had a hearing on "Strengthening the Federal Student Loan Program for Borrowers. There were several panelists testifying, including Jim Runcie, Chief Operating Officer of Federal Student Aid with the U.S. Department of Education; Dr. Michelle Cooper, President of the Institute for Higher Education Policy; Deanne Loonin from the National Consumer Law Center; Roberta Johnson, Director of Student Financial Aid at Iowa State University; and Marian Dill, Director of Student Financial Aid at Lee University.

You can see a summary of folks who were live-tweeting the hearing below, using the #LoanHELP hashtag. A video of the hearing, as well as written testimony from each panelist, is available on the Senate HELP website.

If you are a member of the National Association of Student Financial Aid Administrators (NASFAA), you should see an article summaring the hearing in NASFAA Today's News tomorrow morning!

In other news, Program Integrity Negotiated Rulemaking is also occurring right now. You can see a good summary of yesterday's negotiations from Rachel Fishman with the New America Foundation. You can follow those tweets by using the #NegReg hashtag. There were more negotiations today and a final session is planned for May to discuss PLUS Loans.

Tuesday, March 25, 2014

Starting a Financial Aid Association Blog

This is part one of two in a series about association blogs.

Blogs are not a fancy new thing. Financial Aid Associations have had newsletters since their beginnings. The Wisconsin Association’s first 1966 meeting notes discuss the creation of a newsletter. At that time it was delivered on paper; now it can be delivered electronically. A blog is a new tool for delivering a newsletter and so much more.

There are advantages to using a blog over a paper or pdf newsletter. Each article adds its own value as a separate blog post. Articles can be spread out as shorter weekly posts rather than a long newsletter monthly or quarterly. It may be easier for association members to find time to read one short post a week rather than a long newsletter monthly.

A blog is timely - it allows a more immediate response to be possible when new information needs to be shared. It also allows flexibility for experimenting with what to share with members. In addition blogs have the capability of real-time metrics to determine the popularity of certain content.

A blog allows interaction - members can comment on the blog and keep the conversation going.
A blog reaches new members –members are increasingly using social media to connect with others. It isn’t just the tech savvy or millenials using social media anymore. Today’s professionals have come to expect immediate and real time communication.

Wisconsin’s blog debuted in 2012 with an updated website. The blog is used to create connections among members, share information about association activities, and provide professional development resources. In order to keep track of what is being shared we use categories of blog posts. Keeping track by category allows us to present a variety of content. Categories are always evolving, but some examples include:
  • Updates from the President
  • Committee Updates
  •  We Are WASFAA – Interviews with WASFAA members (See next week’s blog post for more on this topic.)
  •  Meet ED – Interviews with Department of Education Trainers
  •  Tech Tips – Tips for using technology both in and outside of the workplace.
  •   Pro Dev Tips – Professional Development Tips such as getting the most out of conferences, how to present an interest session for the first time, and how to create enticing slide decks.

Coordinating a blog can be an intimidating undertaking, but it doesn’t have to be. We use a spreadsheet on Google Drive that several administrators can access.  It lists the date to post, the category, topic, author, team member coordinating the post, and the status. We also have a column that lists major events such as holidays and conferences to assist with planning. In my term as president this year I oversaw the creation of a new position in the association, Web Content Manager. This is in addition to the Web Editor position. The Content Management person is the primary contact person for coordinating the blog posts while the Editor has become the person managing the technical aspects of the website.  Dividing up the content and the technical aspects of the website and blog has made it possible to best utilize the strengths of the people filling those roles.

The association blog has fostered new sense of communication and community in the Wisconsin association and a blog can enhance communication in your association too. Listed below are several blogs to take a look at as examples of what can be done with a financial aid association blog.

Regional Student Financial Aid Association Blogs
Eastern (EASFAA) http://easfaa.org/b/
Rocky Mountain (RMASFAA) http://rmasfaa.wordpress.com/
Southern (SASFAA) http://sasfaa.blogspot.com/
Southwest (SWASFAA) http://swasfaa.org/b/
Western (WASFAA) http://wasfaa.org/b/

State Student Financial Aid Association Blogs
Wisconsin (WASFAA)  http://www.wasfaa.net/

Did we miss one? Please add it to the comments below!
Part two of this series coming next week – Tips for Writing a Blog Post

Tuesday, March 4, 2014

OIG Suggests Additional Safeguards Against Financial Aid Fraud

On February 25, 2014, the U.S. Department of Education’s Office of the Inspector General (OIG) released a Final Audit Report, titled “Title IV of the Higher Education Act Programs: Additional Safeguards Are Needed to Help Mitigate the Risks That Are Unique to the Distance Education Environment.” The report is a culmination of in depth review of eight institutions of higher education in their handling of Title IV funds for distance education students. The objective of the review focused on the “susceptibility to fraud and abuse to Title IV programs delivered to students enrolled in programs of study offered through distance education.”

In general, the results of the investigation demonstrated that institutions have problems verifying students’ identities, determining attendance at an academic-related activity, and determining cost of attendance. The OIG summarizes that “the regulations and guidance as they relate to verifying the identity of distance education students and the definition of attendance do not sufficiently mitigate the risks of fraud, abuse, and noncompliance.” Through this investigation, the OIG determined that the eight schools investigated “disbursed nearly $222 million to more than 42,000 distance education students who did not earn any credits during a payment period.”

Reports indicate there has been a vast increase in higher education enrollment in distance education courses as well as reports of fraud rings taking advantage of such programs to defraud the financial aid system (enrolling only to receive financial aid without an educational purpose). But, as the report indicates, Title IV programs are large and complex and require numerous entities to administer. The changing student population, technological advancement, and educational delivery methods offer increased challenges to awarding and disbursing Title IV funds. Although the U.S. Department of Education released final Program Integrity regulations on October 29, 2010, the OIG believes “further actions are needed to protect the integrity of the Title IV programs.”

It should be noted that, according to the cover letter, the Department is compelled to develop a final corrective action plan as a result of this audit within 30 days of the issuance of the report. This timeframe is not unusual, but gives very little time for financial aid administrators or the distance education community to have input or response in these important matters that affect us greatly.

Below is a summary of OIG’s recommendations:

Finding No. 1 - Regulations Related to Verifying Student Identity and Disbursing Title IV Funds Should Be Strengthened

Under this section, the OIG cites the Department’s current regulation (34 CFR §602.17(g)), which allows secure logins and passwords, but states “this requirement is not sufficient to protect Title IV funds.” The OIG asserts that a login and password do not confirm the student’s identity nor ensures the person is using it under a valid name or intending to obtain an education. The OIG also cites the fact that a school may hold a credit balance from financial aid that exceeds allowable charges, but only with the student’s explicit written permission (34 CFR §668.164(d) and (e) and 668.165(b)). A school may delay the disbursement of funds to determine whether a student is eligible for Title IV aid. Delaying disbursement or implementing smaller, more frequent disbursements “decreases the risk of unscrupulous people targeting the school.” Disbursing aid incrementally across a payment period has other benefits, as noted by Ware, Weismann, and McDermott (2013).

OIG Recommendation 1.1 Require schools that offer distance education to verify the student’s identity as part of the enrollment process through means such as high school diploma, transcripts, and test scores before issuing a secure login and passcode.
OIG Recommendation 1.2 Require state auditors to review the above stated requirement that schools are verifying the identity of distance education students.
OIG Recommendation 1.3 Require more frequent disbursements of Title IV funds to coincide with the timing of institutional and other charges.

Strengthening identity verification prior to enrollment in distance education is reasonable and the initial administrative burden would likely be on the academic programs offering the distance education programs. Technological solutions for identity verification could make the process efficient. State auditors to reviewing these processes appears reasonable on the surface, but since it would be for Title IV purposes, the financial aid office would be involved, requiring additional burden on financial aid administrators. Furthermore, the academic integrity of a program should rest with the academic program and its accreditors. As Russ Poulin writes, financial aid fraud and academic integrity should not be confused with each other as “such a quality issue is appropriate for accrediting agencies to address and is a separable issue from deterring financial aid fraud.”

Incremental disbursements may benefit low-income students by ameliorating poor financial management or by reinforcing positive student behavior, such as staying enrolled to receive full aid eligibility. The OIG asserts incremental disbursements can reduce fraud, which is reasonable to encourage. However, it requires considerable additional administrative burden on the part of a financial aid office, especially with regard to Return of Title IV calculations and ensuring eligibility at time of disbursement. Return of Title IV processes would become increasingly complicated and are already consistently found to be one of the most vulnerable areas of compliance (see the Top 10 Audit and Program Review Findings). Multiple disbursements would be occurring throughout the term, requiring very tedious processes to ensure accuracy and documentation of attendance prior to disbursement (the rules change when you disburse prior to the beginning of a term, which is allowed, and disbursing funds after the first day of classes as noted in Volume 4, Chapter 1 of the 2013-2014 Federal Student Aid Handbook, pg 4-27). And, what potential problems could this cause for students who legitimately need more money at the beginning of the term for educational expenses versus later in the term? Would financial aid administrators be given the authority of professional judgment to disburse aid earlier than the newly required scheduled disbursements? As Ware, Weismann, and McDermott (2013) suggest, further research needs to be conducted regarding the impact on such a policy shift. I would suggest this be encouraged, but not required, and tested thoroughly, especially through the Department’s Experimental Sites initiative prior to considering full implementation.

Finding No. 2 - Current Regulations Defining Attendance at an Academically-Related Activity Should Also Apply to Student Eligibility and Disbursement Requirements

In this section, the OIG comments that the definition of attendance only appears in the regulations under Return of Title IV processing (for students who withdraw) and goes on to describe the list of activities that may be considered academic attendance, which is listed in the regulations (34 CFR §668.22(1)(7). The regulations also describe what activities may not be considered academic attendance, such as logging in to an online class without active participation. The OIG considers this insufficient since academic attendance should be determined when a student initially receives Title IV aid, not just for those who withdraw. The OIG also noted that three of the schools allowed faculty members to define attendance on their own, but that faculty members were not responsible for knowing Title IV regulations. Additionally, the OIG found that “none of the eight schools [...] retained adequate evidence of a student’s academic attendance, as required in regulation that became effective July 1, 2010 to support the student’s withdrawal date.”

OIG Recommendation 2.1 Amend the regulations to cross-reference the definitions of “academic attendance” and “attendance at an academically related activity” in 34 CFR § 668.22(1)(7).
OIG Recommendation 2.2 Issue further guidance to clearly explain what is considered acceptable evidence to support a distance education student’s academic attendance and last date of attendance.

Cross-referencing the definition of academic attendance and issuing further guidance is a superficial recommendation. No school under review was found to be properly applying the regulations, which demonstrates the complexity and burdensome nature regarding gathering attendance information, especially for schools who do not require instructors to take attendance. The OIG infers that faculty are incapable of providing attendance information, or at least be permitted to define it (and most faculty would probably agree that it’s not their job), but under what circumstances would it be incumbent upon a financial aid administrator to question the academic integrity of a faculty member who states a student has attended? Is it possible the attendance requirements are too rigorous? How many students who begin attendance might be disadvantaged because the institution cannot document said attendance and therefore require repayment post-withdrawal when the student may very well have attended and participated in academic activity? Furthermore, compliance with the attendance regulation, in general, requires an extreme amount of data collection and storage regarding every student because you will not know who will withdraw, officially or unofficially. These sentiments seem indicative of a disconnect with the OIG, the Department, and practitioners, whereas on one hand, there is the presumption that all students are attempting to defraud the government and on the other, that all students are attempting to pursue an education.

Finding No. 3 - Cost of Attendance Components for Distance Education Students Should be Revised

The OIG states in this section that “no distinction is to be made between on-campus or distance education programs when determining a student’s cost of attendance” per section 472 of the HEA, which also limits the cost of attendance for students who are enrolled in programs of correspondence study. Those imposed restrictions limit the budget to only include tuition and fees and, only if required, books, supplies, travel, and room and board costs during times of required residency. The OIG asserts that “only components that directly relate to a student’s educational expenses should be included in cost of attendance budgets” and that “schools need to apply cost of attendance budgets based on students’ characteristics.” According to the OIG, “specific circumstances should dictate a student’s Title IV award” and cites section 484(1)(2) of the HEA, permitting a financial aid officer to reduce Title IV aid for a student if it’s determined that distance education results in a reduced cost of attendance, through the use of professional judgment.

OIG Recommendation 3.1 Specify that a school’s cost of attendance budget for a student include only costs that reflect actual educational expenses (would require Congress to amend section 472 of the Higher Education Act of 1965, as amended).
OIG Recommendation 3.2 Explain to schools that a distance education student’s cost of attendance budget should not include expenses not incurred and that a financial aid officer can exercise professional judgment on a case-by-case basis and reduce a student’s Title IV aid by reducing the cost of attendance budget for a student.

The intention behind these recommendations is on point, but the recommendations themselves are poorly explicated. Distance education programs should, essentially, be treated the same as correspondence programs. The only difference is the amount of instructor interaction. It is reasonable to expect a limited COA for both correspondence and distance education students. This requirement would also not be too burdensome for institutions, so long as there is not the expectation of a limited COA for students who are enrolled in a combination of on-campus and distance education courses. The recommendation is written to include only costs that reflect actual educational expenses, but the cost of attendance is meant to be a standardized cost across a class of students. It is unreasonable to expect financial aid officers to create a cost of attendance budget specific to each individual student and circumstance. It is unclear if this is what the OIG is actually recommending. Instead, developing a cost of attendance for a category of students is permissible and reasonable. The second recommendation is unreasonable because, as the Department affirmed in its response, while schools have the ability to exercise professional judgment, “the law limits such discretion to be exercised only on a case-by-case basis, rather than across an entire category or class of students.” The OIG revised their recommendation to specify on a case-by-case basis; however, in any such circumstance where a financial aid administrator were to reduce a budget would attract extreme scrutiny and likely be accused of discriminatory practices. Professional judgments are usually made in such cases where a student has hardships that require an increased cost of attendance, not to single out students in order to reduce their Title IV aid. And, under what circumstances would a financial aid officer have sufficient information to know a student’s actual costs that necessitates reduction? Even institutional charges change throughout a term as students add/drop coursework and many required textbooks are bought at off-campus bookstores or through online vendors. Again, it’s unclear whether the OIG is referring to an individual student or to a category of students.

Finding No. 4 - FSA Could Improve Its Monitoring of Schools’ Compliance by Targeting Its Reviews on High-Risk Areas

In this section, the OIG maintains that FSA program reviews could be more effective and fail to target the highest risk areas. The OIG also notes that FSA itself has identified distance education as one of the highest risk areas in FY2010 and FY2011, yet fails to target reviews in this area. In its review of the eight schools for this report, the OIG found that none of the schools “properly determined and documented students’ academic attendance in accordance with the requirements promulgated in 34 CFR §668.22(c)(3) as of July 1, 2010. When reviewing schools, FSA samples its files from the general population, which is insufficient in targeting high risk areas of fraud. The OIG found that FSA has failed to come to similar conclusions on a consistent basis, inferring they must not be either targeting the high risk areas or not following procedures.

OIG Recommendation 4.1 Sample students from specific high-risk areas, such as distance education.
OIG Recommendation 4.2 Analyze the results of program reviews conducted and if the reviews are not identifying attendance issues, research why and provide training to staff.

It would be reasonable to review the areas that have been found to be at highest risk for fraud, which is probably why program reviews have been widely inconsistent. Few schools have been cited with attendance issues by FSA, but the OIG happened to conclude that every school it reviewed failed to comply with the attendance regulations (it is important to note that the OIG judgmentally selected the schools for this audit; two from each of the following sectors: 4-year public, 2-year public, private nonprofit, and proprietary). This problem could be resolved through these recommendations. However, what is also disturbing is the amount of time it takes FSA to complete a program review, which the OIG fails to mention. Reports have shown that it could take over a decade to complete a program review. As Michael Stratford from Inside Higher Ed writes, “it’s a case of either colossal inefficiency or supreme accountability.” I’d like to say it’s probably both. And, FSA should not only target the files it would like to review at schools, but also target the scope of its review rather than conducting a full review of each school selected for a program review. Much like the Department conducts targeted verification of student-submitted information on the Free Application for Federal Student Aid (FAFSA), FSA should reduce the overly ambitious scope for each program review. In an effort to increase transparency and accountability, FSA should release data on its completed and active program reviews. If stakeholders can access the data, the reviews could be more informative and effective in improving compliance.

Finding No. 5 - More Useful Data on Distance Education Is Needed to Adequately Assess Risk and Direct Monitoring Efforts
Under this section, the OIG asserts that the Department cannot adequately manage its programs in the current educational environment without data to analyze characteristics, trends, and risks. Due to the increased enrollment in distance education, the OIG states the Department needs to take steps now to design a plan to collect the necessary data, which would help policy makers and program managers better understand the educational environment and identify needed statutory and regulatory changes to protect students and taxpayers.

OIG Recommendation 5.1 Collect data, monitor growth, assess risks, and formulate strategies specific to the distance education environment.
OIG Recommendation 5.2 Incorporate the above-recommended data collection into FSA’s risk assessment procedure.

These recommendations are reasonable. Education data is important and it’s unfortunate it has taken this long to come to this conclusion. The Department agreed to these recommendations and agreed to send comments and recommendations to NCES for updated data elements in IPEDS (although, it would take years). This would be helpful to many other constituents rather than just the Department, especially researchers and policy analysts.


Under these recommendations, students and institutions will be held to higher standards of accountability and higher levels of scrutiny. Students legitimately wanting to pursue an education in distance education programs at lower risk institutions, such as those with negligible (by comparison) default rates, would have a more difficult time navigating through unnecessary barriers. Although, a lot of what is recommended makes sense, but while the OIG cited in its report that the eight schools it reviewed disbursed nearly $222 million to more than 42,000 students, it failed to identify or estimate how much of that is estimated to have been received fraudulently. We know from the report that it identified fraud rings through its review, so how much (in dollars) fraud was identified? To what extent should institutions, students, state auditors, and the Department expect additional administrative burden and comply with institutionalized bureaucratic red tape in order to mitigate risks? It might be incumbent upon the Department to scrutinize intentionally abusive practices amongst a certain sector or group of schools who recruit low-income students with the promise of jobs unlikely to become salaries. But, as we know with gainful employment regulations, these groups lobby Congress as well as they deceptively recruit students. And, although the Department has the statutory authority to deny Title IV funds to school who misrepresent themselves, the Consumer Financial Protection Bureau seems to be the only federal agency willing to fight this battle, which, by the way, includes one of the schools reviewed in this audit.

The OIG cited attendance issues at all eight of its schools, yet only recommends increased training and scrutiny with regard to program reviews. The larger issue here is the complexity and burdensome nature regarding gathering attendance information. And, although attendance regulations are already in effect, research needs to be conducted to identify whether such regulation actually reduces fraud.

While many of these recommendations make sense, neither the OIG nor the Department have provided sufficient information to show whether this actually mitigates risk and how much it impacts individual students and their attempt to legitimately pursue an education. While it was a thoughtful report and approach, I would suggest additional empirical research through randomized sampling be performed using these recommendations to identify their impact. This might be possible through the Experimental Sites initiative if the Department allowed experiments with randomized trials. The impact of some of these changes would need to be known rather than simply hypothesized.

Finally, I agree with Poulin’s sentiment that “we should all be in the business of helping the Department battle against those stealing money that is earmarked for needy students.” While I disagree with several items in this report, I support the prevention of fraud so long as it is not at the expense of students attempting to pursue an education.

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