Reg. Busters

Presenters:

Bill Cheetham, Associate Vice-President For Enrollment -

LeMoyne College, Syracuse, NY

John View, Financial Aid Compliance Officer and Director of EOP

SUNY- ESF, Syracuse, NY

Why Regulations?

Chaos – The Webster’s Dictionary defines Chaos as: ‘Confusion’

Regulation – Defined by Webster as ‘control, adjust’

Congress Makes Federal Laws Follow

the bill as it moves through Congress

Reg Busting begins early

The reg busters should begin long before the lawmakers pass the bill and the president signs it.

News spreads fast – we should all be connected into our professional networks- the purpose being to receive data on pending bills –MAKE Comments Then

Early Reg Busting

Are you connected to IFAP for weekly updates?

Are you a member of a professional organization(s) – e.g NYSFAAA, et al

Legislative Advocacy Committees

List Serves?

Mentors and Kitchen cabinets

REG Busting Begins Early

Use a targeted approach – do not wait for the final bill, contact your legislative contacts as the hearings begin. Meet them in their home office Enlist and empower the support of those impacted by the change – studentsCombine the above for a forum on your campus

Reg Busting

You must have Factual Data to substantiate your position. Here say, innuendo or anecdotal stories or “Gee, someone told about someone who heard…”Be prepared to have the data challenged but if it is factual, then the data will speak for itself.Statistics Lie-Liars use statistics

Pro Active Reg Busting

Using the steps in the prior slide lays the Foundation for the after Passage work.

Ultimately a Regulation will be passed. It will go to the appropriate Department for more refinement. At that time, there are other vehicles to use for continued input.

Reg Busting After Passage

There are several tools that one can use to make further comments before final regulations are written.

NPRM – Notice of proposed Rulemaking – this process begins with the Dept. of Ed. Posting a notice(IFAP)

NPRM Example

On August 8, 2014 – DE- published a Notice of Proposed Rulemaking (NRPM) in the Federal Register that proposes rules that will apply to PLUS Loan program (Credit History). A PDF copy of the NPRM is attached to this announcement and is also available directly on the IFAP website under Federal Registers. Schools normally have 30 days to comment.

NPRM

The NPRM is your way of making direct comments into the federal review process to potentially have the impact and/or modification you are seeking

The department does read these comments and must respond, in writing in the Federal Register

Negotiated Rulemaking ToolHEA section 492 requires negotiation of proposed Title IV regulations

Negotiated Rulemaking Goals:

Advance Administration’s Management Reform Priorities

Promote Active, But Limited, Role for Federal Government:

• Empower citizens

• Ensure results through accountability

NegReg GoalsReduce expense and compliance problems

Reduce program operating costs through greater use of e-commerce

Simplify process and improve service

Improve program management and integrity

Who Does NEG REG

Negotiators represent coalitions of identified “constituencies” e.g Department, Schools, Students and others

Emphasis on “practitioner” negotiators

Anyone can submit their Name – it is allowed in the notice from the Department

From NASFAA Notice 9/3/14

Identifying Negotiators: Send your thoughts and suggestions about who from the field (including yourself) might be willing and able to represent the interests of our membership at the forthcoming NegReg sessions. These individuals would need to attend the meetings, become familiar with the topic under negotiation, and offer constructive comments during the session.

Neg Reg Process

Various teams are selected and then they come together – usually in Washington to negotiate the ‘rules’ regulations that will take the chaos and turn it into a control that allows us all to adjust, explain and implement the new law

Save Perkins – Now - Real

Perkins Program Expires in September 2015

Any Change Requires Government Action

Value of the Program

Purpose and Makeup of the Taskforce

What is being done?

Spreading the WordAssociation Membership

Other Associations

EOP and Financial Aid Directors

Government Relations and College Presidents

Student Government and Current Borrowers

Prospective Students and Parents

What is being done?

Taking ActionMeetings with Elected Officials

Letters From Colleges

Meetings/Trainings with Student Groups

Active Support of Senator Harkin’s Higher Education Affordability Act

What Must We Do?

Individual Communication

Encourage Campus Communication

Facilitate Student Communication

Enable Family Involvement

Get Involved in Saving the Perkins loan program

Why is this important?

New York has been one of the most active states in fighting for the Perkins Loan Program.

If you award Perkins and you loose the funds- what will you replace it with?

Other states are beginning to use NY as a model.

Contact from students and families is the most impactful!

Reg Busters – After the Regulation is Implemented

From a practical standpoint, once the regulations are implemented, the best way to deal with them are:Training Workshops –Continuous reading of the regulationsReach out and touch someone – It’s Ok to say – I don’t think I get – can you help or explain – 2 heads are better than one

Reg BustersI ain’t afaraid of no regs……

Reg Busters - Questions

Thank you for coming