Ms. Sarah Flanagan Vice President, for Governmental Relations, National Association of Independent Colleges & Universities Supporting Document
- Public Hearing Home
- Access & Retention, Panel of Experts
- Quality & Accountability, Panel of Experts
- Public Testimony, Panels 1 - 3
- Public Testimony, Panels 4 - 6
- Public Testimony, Panels 7 - 8
NAICU HEA POSITION SUMMARY
- ACCESS must remain the central tenet of the HEA. The basic student financial aid programs work, providing grants, loans, and work-study to needy students. However, much still needs to be done to make a college education accessible to all. In addition to increased federal funding, we need to encourage active student aid partnerships with states, colleges, and private foundations, giving renewed attention to the campus-based programs and LEAP.
- PELL GRANTS remain the foundation of a student's aid package. They should remain need-based, exclude merit components, and be available equally to students at each class level. Congress should consider additional grant funds for the poorest Pell families (those with negative EFC).
- SEOG (Supplemental Educational Opportunity Grants) is a highly underappreciated student aid program and needs to be restored to its original status. SEOG was designed as a partner program to the original Pell (BEOG) program, to ensure supplemental grant aid for the neediest Pell students. As SEOG funding staggers, the program now provides far too few of these families the aid they need. Increasing support for SEOG is an economically sound way to ensure the poorest Pell recipients receive more grant aid without having to increase grants for all Pell students.
- CAMPUS-BASED PROGRAMS (The Supplemental Educational Opportunity Grants (SEOG), Federal Work Study (FWS), and Perkins Loan Program) should be supported, their authorized funding levels increased, the institutional funding formulas maintained, and flexibility to transfer funds among the programs increased.Since these programs require a percentage match from the institution they create a vital partnership between colleges and the federal government in addressing the access problem. These programs might better be referred to as "Institutional Partnership" programs.
- LEAP (Leveraging Educational Assistance Partnerships) needs to be reviewed to ensure that it provides adequate incentives to states to be full partners in helping to address access issues. Recently, a few states have made tremendous strides in ensuring that low-income students have full access to post-secondary education. But many states have decreased their support for low-income students, shutting down state aid programs or diverting resources to merit aid. Congress needs to review the LEAP program to ensure it provides adequate incentives to states who partner with the federal government in making college affordable for all students.
- LOAN limits need to be raised. The borrowing limits in federal loan programs have not changed since 1992. Institutions have been increasing their institutional aid, but many students, especially those at private colleges, need to borrow more expensive, private loans because federal loan limits are insufficient. Low-cost loans are a key component of access, and annual and cumulative loan limits should be increased to provide students with the least expensive loans possible. Despite concerns with student debt, borrowing is often preferable to working more hours than is manageable while going to school. Congress should also drop the up-front loan fees that students are charged and look for ways to make repayment more manageable for borrowers.
- TRIO AND GEAR UP provide important information, support, and preparation for low-income and minority students who are under-represented in higher education. Early intervention programs are an essential component in ensuring that underserved populations learn how to make the dream of a college education a reality.
- NEED ANALYSIS is fundamentally sound but needs some minor updating. Congress should rationalize the consideration of assets, to reflect the recent development of new, tax-advantaged college savings plans. Several other modifications may be needed to promote better use of the simple need test, remove inappropriate questions (such as the drug questions), reduce the number of state questions, and ensure that student work does not unfairly reduce aid eligibility. Financial Aid Officer discretion should be retained.
- APPROPRIATE ACCOUNTABILITY for federal education programs is a legitimate federal responsibility. Taxpayers invest billions of dollars each year in the federal student aid programs. Legislators have a responsibility to ensure that this money is spent wisely. However, accountability measures must have a clear purpose related to the federal role and produce information that is both understandable and useful in measuring the effectiveness of the federal programs. Institutional accountability measures must recognize the diverse missions of our nation's post-secondary schools and the historic role of accreditation. Federal "one size fits all" measures will not work. For information on current college accountability measures, visit the NAICU website at http://www.naicu.edu/ and click on the accountability icon.
- COLLEGE COMPLETION RATES could be a useful accountability measure but obtaining comparable, complete data presents a number of challenges. For example, using six year graduation rates alone obscures the importance of four and five year rates. Institutional rates will vary according to mission and the types of students served. Successfully tracking students who transfer is also problematic. Any attempts to track individual students must be kept within the confines of the national student aid data system to protect student privacy.
- STUDENT PRIVACY RIGHTS need to be reviewed in light of an increased federal interest in student performance data and in the post 9-11 environment. As interest in measuring student success grows, public officials are asking for student data that appears to violate privacy protections provided by the Family Educational Rights and Privacy Act (FERPA). Congress needs to review and balance concern for privacy with its interest in information, and provide institutions with clear guidance on what is both legal and appropriate.
- REPORTING AND DISCLOSURE REQUIREMENTS unrelated to student aid are overwhelming colleges and adding significantly to institutional program costs. Since the early 1990s, the federal government has put new reporting and disclosure requirements on colleges, such as crime statistics and graduation rates, voter registration form distribution, and pass rates on teacher certification examinations. If colleges do not provide these reports and information, their students will not be eligible for federal student aid. Colleges receive no financial assistance to carry out these mandates. Many of these reports are overly complex, costly to produce, and underutilized by the public. These mandates should be reviewed, perhaps by an outside group, and then simplified, made more user-friendly, or eliminated. The Department of Education should publish an annual compliance calendar to make it easier for schools to produce reports, and a master calendar should be implemented to ensure that colleges have adequate time to collect, analyze and report data.
- COMMUNITY SERVICE REQUIREMENTS in the Federal Work Study (FWS) program should not be increased. Several proposals have circulated to raise the current community service requirement in the FWS program from 7 percent to as much as 50 percent. This is not good policy. It focuses responsibility for community service exclusively on needy students and the financial aid office. Instead, the federal government should promote campus-wide efforts through better funding of the higher education portion of the Learn and Serve Program under the Corporation for National and Community Service. For more information on the extensive community service activities already underway on college campuses nationwide, we encourage you to visit http://www.campuscares.org/.
- COMPETITION IN THE LOAN PROGRAMS is essential. The competition between the direct loan program and the Federal Family Education Loan Program (FFELP) has resulted in better service to borrowers. Both programs should continue. In addition, care should be taken to preserve competition within the FFEL (bank) program itself. Many small non-profit lenders, who turn their federal subsidies back to students, are feeling squeezed by aggressive marketing by the dominant FFELP banks and lenders.
- TRANSFER OF CREDIT is an institutional decision that goes to the heart of a college's responsibility as an educational institution. Some for-profit schools are advocating a proposal to force every college in the country to accept the credits of their students who transfer. While students from any sector may face problems transferring credits, this problem cannot be solved by federal mandate. However, the federal government could increase articulation through a competitive grant program.
- DISTANCE EDUCATION is being developed by schools in all sectors and offers a new and innovative means of delivering higher education. Much has been learned about distance education since the last reauthorization. Many early programs have shut down, while others have expanded. For most colleges and universities, the student aid rules that eliminated the program scandals of the late 1980s have not proven a barrier to promoting distance education or other innovations in time and place. As Congress reviews its student aid rules, they should utilize mechanisms like the Distance Education Demonstration Program to balance innovation with appropriate oversight.
- GRADUATE AND INTERNATIONAL EDUCATION need greater federal support. The growth in science and technology, the aging of the professoriate, and the current crises in the world, have called attention to the need for additional financial support for graduate and professional students and for students who are engaged in various aspects of international studies. We encourage federal support for international education and recommend strengthening federal support for graduate and professional education.
- COLLEGE AFFORDABILITY is a continuing concern as incomes for lower-income families continue to stagnate. Private colleges have increased grant aid for families, particularly those of modest means. But such support takes an increasing share of institutional operating budgets. Also, many low-income families, unaware of this generous grant aid, may not even consider a private college even when it is the best fit for their child.
- TEACHER EDUCATION is important to private colleges and we are interested in working with Congress to improve preparation and reward innovation. During the past decade, there has been a growing federal interest in the quality of teacher preparation. The Title II report cards, authorized in 1998, provide some useful information, but we believe it is limited in its applications. We are interested in working with Congress to improve federal efforts in this area.
- NEGOTIATED RULEMAKING should allow for appropriate representation from the college community. Negotiators who are selected to serve should be legitimate representatives of the sector they are chosen to represent, with a demonstrated ability to communicate on issues of importance to their constituency.