the school voice in common policy nasfaa 2006 nasfaa 2006

TheTheSchool Voice in School Voice in Common PolicyCommon Policy

NASFAA 2006NASFAA 2006

PresentersPresenters

Moderator: Jacki Fairbairn of Moderator: Jacki Fairbairn of Great Lakes Great Lakes

Marilyn Ponti of Whitman CollegeMarilyn Ponti of Whitman College

Brenda Grady of USA FundsBrenda Grady of USA Funds

School Voice in School Voice in Common Policy Common Policy

The PLAN:The PLAN:– A little history & structure lesson.A little history & structure lesson.– What is ‘common policy’?What is ‘common policy’?– Where does common policy come Where does common policy come

from?from?– What does common policy mean to What does common policy mean to

schools?schools?– What can schools do to help with the What can schools do to help with the

development of common policy?development of common policy?

Common Manual Common Manual HistoryHistory

Common ManualCommon Manual published Dec 1995 published Dec 1995 23 guarantors subscribed initially23 guarantors subscribed initially First policies effective April 1, 1996First policies effective April 1, 1996 More than 900 policies developed & More than 900 policies developed &

implementedimplemented Almost 300 considered & not Almost 300 considered & not

developeddeveloped

Common ManualCommon Manual StructureStructure

Governing Board with Governing Board with representatives of each guarantorrepresentatives of each guarantor– Meet monthlyMeet monthly– Manage CM budgetManage CM budget– Review, consider, approve all Review, consider, approve all

policiespolicies

Common ManualCommon Manual StructureStructure

Policy Committee with 12 membersPolicy Committee with 12 members

– Meet weekly---sometimes more oftenMeet weekly---sometimes more often– Meet via conference callsMeet via conference calls– Research, develop, review, refine, Research, develop, review, refine,

reviserevise– Manage community comment periodsManage community comment periods– Provide final ‘commented’ proposal to Provide final ‘commented’ proposal to

Board for consideration Board for consideration

What Is Common What Is Common Policy?Policy?

Sources of common policy:Sources of common policy:– Federal guidance: statute, Federal guidance: statute,

regulations, Dear Colleague Lettersregulations, Dear Colleague Letters– Business needs of schools, lenders, Business needs of schools, lenders,

guarantorsguarantors– Community ‘best practices’Community ‘best practices’

Common Policy & Common Policy & the School the School

What does common policy mean What does common policy mean to schools?to schools?– One policy for key transactionsOne policy for key transactions

– One source to document the one One source to document the one policypolicy

– One method for helping direct policyOne method for helping direct policy

Common Policy & Common Policy & the Schoolthe School

Common policy also means:Common policy also means:

A meaningful way to A meaningful way to participate in the policy-participate in the policy-

development processdevelopment process


Where did those 900+ policies come Where did those 900+ policies come from?from?– Federal statute, regulations and Federal statute, regulations and

correspondence [Federal proposals]correspondence [Federal proposals]

– Guarantor, lender and school assessments Guarantor, lender and school assessments of best practices [Guarantor proposals]of best practices [Guarantor proposals]

– Reorganization and CorrectionsReorganization and Corrections


““Federal Policy”:Federal Policy”:– Statutory changes (ex.: HERA)Statutory changes (ex.: HERA)

– Regulatory changes (ex.: Nov. 1, Regulatory changes (ex.: Nov. 1, 2002)2002)

– Dear Colleague Letters and FSAH Dear Colleague Letters and FSAH changes (ex.:GEN-06-05)changes (ex.:GEN-06-05)


““Guarantor Policy”:Guarantor Policy”:– Case law precedentsCase law precedents

– Best practicesBest practices

– Absence of federal guidanceAbsence of federal guidance

Common Policy & the Common Policy & the SchoolSchool

Reorganization and Corrections:Reorganization and Corrections:

– Reorganized borrower eligibility, Reorganized borrower eligibility, loan certification and loan delivery loan certification and loan delivery per school recommendationsper school recommendations

School Voice in Common School Voice in Common PolicyPolicy

How is common policy How is common policy developed?developed?

– Policy proposal draftedPolicy proposal drafted

Who drafts it?Who drafts it? [Could be a school] [Could be a school] Why do they draft it?Why do they draft it? Where does it go after it’s drafted?Where does it go after it’s drafted?

School Voice in School Voice in Common PolicyCommon Policy

Policy Committee considerationPolicy Committee consideration

– Research all applicable resourcesResearch all applicable resources– Consult with community expertsConsult with community experts

regarding current practices, systems, regarding current practices, systems, etc. Refine text based on resources etc. Refine text based on resources [Could be consulting with a school!][Could be consulting with a school!]

– Decide whether to go forward with Decide whether to go forward with the policythe policy


Comment process:Comment process:– Distributed to community for comment Distributed to community for comment

(Public listserv, NASFAA, YOU?, etc.)(Public listserv, NASFAA, YOU?, etc.)

Subscribe to the Public Listserv:Subscribe to the Public Listserv:– Send your request to: Send your request to:

"[email protected]""[email protected]"– In the BODY of the E‑mail message In the BODY of the E‑mail message

type : "Subscribe Public“ type : "Subscribe Public“ – Do not type the quotation marks!Do not type the quotation marks!


Comment process continued:Comment process continued:– Comment period usually 3 weeksComment period usually 3 weeks– Comments returned to the PCComments returned to the PC– More research, discussions with More research, discussions with

community experts [Could be a community experts [Could be a school!]school!]

– Comment responses & revised Comment responses & revised policy finalizedpolicy finalized


Final policy goes to Governing Final policy goes to Governing BoardBoard– Board reviews and assesses impact Board reviews and assesses impact – Board meets monthly to consider Board meets monthly to consider

and discuss proposed policiesand discuss proposed policies– Board votes on proposals---Requires Board votes on proposals---Requires

a quorum in each meeting and a 2/3 a quorum in each meeting and a 2/3 approval for passage.approval for passage.


Approved policies are published:Approved policies are published:

– In about 10 days to public listserveIn about 10 days to public listserve

– In each guarantor’s newsletterIn each guarantor’s newsletter

– In the monthly ICM updateIn the monthly ICM update

– In the annual CM paper and ECM In the annual CM paper and ECM versionsversions


How can a school participate?How can a school participate?

– Subscribe to the Subscribe to the Common ManualCommon Manual public listserv public listserv

– Check batch summary publication for key issuesCheck batch summary publication for key issues

– Review proposed policiesReview proposed policies

– If you identify an issue: If you identify an issue:

– COMMENTCOMMENT


Identify OmissionsIdentify Omissions– If you can’t find it:If you can’t find it:

Is it missing?Is it missing? In the wrong place?In the wrong place?

TELL US!TELL US!


If you find it and it doesn’t tell you all If you find it and it doesn’t tell you all you need to know:you need to know:

– Is it because there is no federal guidance? Is it because there is no federal guidance? Should there be?Should there be?

– Has common policy omitted a key Has common policy omitted a key element?element?

TELL US!TELL US!


And then what?And then what? Do I have to write the policy?Do I have to write the policy?

No.No.

Do I have to consult or find time to Do I have to consult or find time to research?research?

No.No.


CAN I write the policy?CAN I write the policy?

YESYES

CAN I consult or research?CAN I consult or research?

YESYES


What else can I do?What else can I do?

– Participate in WorkgroupsParticipate in Workgroups– Share with ColleaguesShare with Colleagues– Use the Use the Common ManualCommon Manual


If you use it to find information on If you use it to find information on loan delivery time frames, you loan delivery time frames, you may identify:may identify:

– A great reference document that A great reference document that needs to be tied to the common needs to be tied to the common policy statementpolicy statement


Reg CiteReg Cite

LinkLink to to GlossaryGlossary



– A part of the delivery process that is A part of the delivery process that is not covered by regs and that has not covered by regs and that has created diverse policies in guarantor created diverse policies in guarantor shopsshops



– Another document or historical Another document or historical change that needs to be added to change that needs to be added to the history appendixthe history appendix


HistoryHistory

AppendixAppendix

CiteCite


Presenter Contact Information:Presenter Contact Information:– Marylin PontiMarylin Ponti

[email protected]@whitman.edu

– Jacki Fairbairn Governing Board ChairJacki Fairbairn Governing Board Chair [email protected]@glhec.org

– Brenda Grady, Policy Committee Brenda Grady, Policy Committee MemberMember [email protected]@usafunds.org


Policy Committee Contact Policy Committee Contact Information:Information:

– Dan Tryon, Policy Committee Co-ChairDan Tryon, Policy Committee Co-Chair [email protected]@michigan.gov

– Carolyn Small, Policy Committee Co-Carolyn Small, Policy Committee Co-ChairChair

[email protected]@iowa.gov

the school voice in common policy nasfaa 2006 nasfaa 2006

Documents

school common policy

common policy nasfaa

sources of common policy

development of common

school guarantor policy

school federal policy

policy proposal

direct policy slide