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HEOA and the Life of an Aid Officer

What the impact of this new legislation will be for financial aid offices
University Business, Nov 2008

ON AUGUST 14, 2008, LIFE as financial aid officers knew it changed drastically. That day, President Bush signed the Higher Education Opportunity Act (HEOA) into law, setting into motion many changes that will directly affect operations in the financial aid office as well as operations in other offices on campus. The law touches just about every office on campus, including admissions, athletics, bookstore, campus security, career services, disability services, registrar, student activities, veterans’ affairs, and academic areas.

Will increased student access and affordability ultimately be achieved? This remains to be seen.

Heather McDonnell, director of Financial Aid at Sarah Lawrence College (N.Y.), summarizes the far-reaching impact of the new law. “Once again, financial aid is the catcher for all the higher education concerns of the U.S. Congress. So much of my time is devoted to tracking compliance with campus offices that have absolutely nothing to do with getting students the resources they need to succeed at being college students,” she says.

Certainly, coordination among various offices will be critical to ensure that compliance with the regulations and eligibility for Title IV financial aid remains intact. For some higher ed institutions, a committee approach may be best for understanding the law and establishing an action plan for compliance.

At other IHEs, these efforts may be left to a single person to coordinate (aid directors, this means you!). Financial aid directors have a clear “front and center” role, regardless of the approach. Whether they are new to the profession or are veteran aid administrators, and regardless of institution type (public vs. private, nonprofit vs. for-profit, four-year vs. two-year), these administrators are being called to exercise extraordinary leadership. Although negotiated rulemaking, specific guidance, and interpretation will take some time, organizations such as the National Association of Student Financial Aid Administrators (NASFAA) and the American Council on Education (ACE) have already begun to provide training sessions and reference documents. These actions will continue throughout the fall as many state and regional associations conduct their annual conferences and workshops. Our advice: Get involved! Get educated! Get ahead!

Initial reaction to the signing of the HEOA is a mixed bag. The regulations include burdensome new reporting and disclosure requirements, attempts to simplify the financial aid application process, provisions to provide transparency of college costs and net price, and attempts to address issues in student lending.

However, while the legislation includes provisions to increase the Pell Grant and provide loan forgiveness programs, Congress must complete a separate process in order to appropriate funding to support such initiatives. Consequently, whether or not increased student access and affordability will ultimately be achieved remains to be seen.

As Kristi Jovell, director of financial aid at Suffolk University Law School in Boston, notes, “The inclusion in the HEOA of several programs providing loan forgiveness for public interest lawyers is exciting for me as director of financial aid at a law school committed to assisting our students who pursue public service careers. Admittedly, these provisions will be more exciting if the programs actually receive funding.”

Below is just a sampling of some of the new disclosure and reporting requirements that fall within the scope of several offices on campus and must be provided to the Department of Education, current and prospective students, and student loan borrowers.

--Textbook costs. Schools must disclose required textbook information, such as the International Standard Book Number (ISBN) and retail prices.

--Federal code of conduct. Each year schools must inform all employees who have responsibilities relating to student loans about the information contained in a new federal code of conduct.

--College affordability and transparency lists. The U.S. Department of Education will publish annual national lists naming the top 5 percent of institutions with the highest tuition and fees, the highest net price, the largest percent increase in tuition and fees, and the largest percent increase in net price. These institutions must submit a written report that includes reasons for the increases and the steps that will be taken to reduce costs.

--Net price calculator. The DOE must develop, within one year, a net price calculator for its website. Schools must add the calculator (or one modeled on it) to their own websites along with a statement that students must file the Free Application for Federal Student Aid (FAFSA) to receive federal aid as well as a link to the application.

--Consumer information. The DOE will post 27 categories of information about each IHE participating in Title IV aid on its College Navigator website ( Examples of the information include data on applications, admissions, enrollment, ACT and SAT scores, male and female students, instate and out-of-state students, racial and ethnic groups, disabled students, degrees awarded, cost of attendance, financial aid, campus safety, and more.

--Campus safety information. In addition to the current crime statistics reporting requirements, the regulations expand the categories of hate crimes and require the institution to prepare an on-campus housing fire safety log, policies regarding vaccinations and immediate emergency response, and procedures for evacuation and missing person notification. In addition, IHEs must determine the number of drug-and-alcohol-related violations and deaths on campus or during school-related activities that have been reported to campus officials.

--Need analysis. At IHEs where students participate in co-op programs, the new law excludes any income earned from work in these programs when calculating the estimated family contribution (EFC). “Prior-prior year” is back in the forefront, as the new regulations allow the use of the second preceding tax year information to simplify the FAFSA application process, which may include data sharing between the IRS and the U.S. Department of Education with the taxpayer’s permission.

Other issues in the legislation are related to student and institutional eligibility, program specific provisions, and veterans and military personnel provisions.

As Rachel Gordon, director of Financial Aid at Alvernia University (Pa.), appropriately states, “As excited as we are to see a bill such as HEOA passed that includes provisions for increases in federal financial assistance and full disclosure for students and their families, I am concerned about the apparent increased administrative burden on aid offices. Educating our students on financial responsibility and providing them the resources to reach their education goals is the number one priority of aid administrators. These new provisions and regulations will shift our focus to the administrative burden of the programs rather than the students the programs are intended to assist.”

Stay tuned. In the coming months, the DOE will convene negotiated rulemaking committees to draft regulations on these legislative changes. Financial aid administrators, as campus officials and student advocates, should participate and provide feedback. Whether through state, regional, or national professional associations, aid administrators will need to capitalize on opportunities to get informed and accept a leadership role on campus.

Like it or not, the financial aid office is the “hub” of the HEOA. Still, the director will need the support and attention of senior management to ensure campuswide compliance with the new regulations.

Kathy Kurz and Jim Scannell are partners in the enrollment management consulting firm Scannell & Kurz. Samantha Veeder, formerly the director of Financial Aid at Hobart and William Smith Colleges (N.Y.), is the firm’s senior consultant. They can be reached via their website,

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