The School Voice in Common Policy

1. TheSchool Voice in Common Policy NASFAA 2006

2. Presenters • Moderator: Jacki Fairbairn of Great Lakes • Marilyn Ponti of Whitman College • Brenda Grady of USA Funds

3. School Voice in Common Policy • The PLAN: • A little history & structure lesson. • What is ‘common policy’? • Where does common policy come from? • What does common policy mean to schools? • What can schools do to help with the development of common policy?

4. Common Manual History • Common Manual published Dec 1995 • 23 guarantors subscribed initially • First policies effective April 1, 1996 • More than 900 policies developed & implemented • Almost 300 considered & not developed

5. Common ManualStructure • Governing Board with representatives of each guarantor • Meet monthly • Manage CM budget • Review, consider, approve all policies

6. Common Manual Structure • Policy Committee with 12 members • Meet weekly---sometimes more often • Meet via conference calls • Research, develop, review, refine, revise • Manage community comment periods • Provide final ‘commented’ proposal to Board for consideration

7. What Is Common Policy? • Sources of common policy: • Federal guidance: statute, regulations, Dear Colleague Letters • Business needs of schools, lenders, guarantors • Community ‘best practices’

8. Common Policy & the School • What does common policy mean to schools? • One policy for key transactions • One source to document the one policy • One method for helping direct policy

9. Common Policy & the School • Common policy also means: A meaningful way to participate in the policy-development process

10. Common Policy & the School • Where did those 900+ policies come from? • Federal statute, regulations and correspondence [Federal proposals] • Guarantor, lender and school assessments of best practices [Guarantor proposals] • Reorganization and Corrections

11. Common Policy & the School • “Federal Policy”: • Statutory changes (ex.: HERA) • Regulatory changes (ex.: Nov. 1, 2002) • Dear Colleague Letters and FSAH changes (ex.:GEN-06-05)

12. Common Policy & the School • “Guarantor Policy”: • Case law precedents • Best practices • Absence of federal guidance

13. Common Policy & the School • Reorganization and Corrections: • Reorganized borrower eligibility, loan certification and loan delivery per school recommendations

14. School Voice in Common Policy • How is common policy developed? • Policy proposal drafted • Who drafts it? [Could be a school] • Why do they draft it? • Where does it go after it’s drafted?

15. School Voice in Common Policy • Policy Committee consideration • Research all applicable resources • Consult with community experts regarding current practices, systems, etc. Refine text based on resources [Could be consulting with a school!] • Decide whether to go forward with the policy

16. School Voice in Common Policy • Comment process: • Distributed to community for comment (Public listserv, NASFAA, YOU?, etc.) • Subscribe to the Public Listserv: • Send your request to: "majordomo@michael.usagroup.com" • In the BODY of the E‑mail message type : "Subscribe Public“ • Do not type the quotation marks!

17. School Voice in Common Policy • Comment process continued: • Comment period usually 3 weeks • Comments returned to the PC • More research, discussions with community experts [Could be a school!] • Comment responses & revised policy finalized

18. School Voice in Common Policy • Final policy goes to Governing Board • Board reviews and assesses impact • Board meets monthly to consider and discuss proposed policies • Board votes on proposals---Requires a quorum in each meeting and a 2/3 approval for passage.

19. School Voice in Common Policy • Approved policies are published: • In about 10 days to public listserve • In each guarantor’s newsletter • In the monthly ICM update • In the annual CM paper and ECM versions

20. School Voice in Common Policy • How can a school participate? • Subscribe to the Common Manual public listserv • Check batch summary publication for key issues • Review proposed policies • If you identify an issue: • COMMENT

21. School Voice in Common Policy • Identify Omissions • If you can’t find it: • Is it missing? • In the wrong place? TELL US!

22. School Voice in Common Policy • If you find it and it doesn’t tell you all you need to know: • Is it because there is no federal guidance? Should there be? • Has common policy omitted a key element? TELL US!

23. School Voice in Common Policy And then what? • Do I have to write the policy? No. • Do I have to consult or find time to research? No.

24. School Voice in Common Policy • CAN I write the policy? YES • CAN I consult or research? YES

25. School Voice in Common Policy • What else can I do? • Participate in Workgroups • Share with Colleagues • Use the Common Manual

26. School Voice in Common Policy • If you use it to find information on loan delivery time frames, you may identify: • A great reference document that needs to be tied to the common policy statement

27. School Voice in Common Policy Reg Cite Link to Glossary

28. School Voice in Common Policy • If you use it to find information on loan delivery time frames, you may identify: • A part of the delivery process that is not covered by regs and that has created diverse policies in guarantor shops

29. School Voice in Common Policy • If you use it to find information on loan delivery time frames, you may identify: • Another document or historical change that needs to be added to the history appendix

30. School Voice in Common Policy History Appendix Cite

31. School Voice in Common Policy • Presenter Contact Information: • Marylin Ponti • pontimk@whitman.edu • Jacki Fairbairn Governing Board Chair • jfairbairn@glhec.org • Brenda Grady, Policy Committee Member • bgrady@usafunds.org

32. School Voice in Common Policy • Policy Committee Contact Information: • Dan Tryon, Policy Committee Co-Chair • tryond@michigan.gov • Carolyn Small, Policy Committee Co-Chair • carolyn.small@iowa.gov