The Need for Expert Counsel and Assistance
With continuing increases in postsecondary educational costs, and the growing
complexity and frequent changes in technology and governmental regulations, today's
schools face numerous demands and burdens related to the administration of student
financial aid. While many schools have developed sufficient "in-house'' capabilities
to cope with these burdens effectively, others are experiencing a growing need for outside
counsel and assistance.
The process of finding and working with consultants, however, may itself give rise to
problems and confusion. Because of the high demand for financial aid consultant services
and the significant amount of money that is at stake, schools need to carefully evaluate
each consultant's qualifications, resources, and advertising claims.
A judicious, informed approach to hiring a consultant is vital because the hiring of a
consultant does not relieve an institution of any of its legal obligations in
administering the federal student aid programs.
This document is intended to offer some basic guidelines to assist you in locating,
evaluating, and selecting qualified consultants. It also defines the terms of their
employment and helps you to work with them effectively. NASFAA cannot, of course, make
specific hiring recommendations, nor do we maintain a list of financial aid consultants,
but we hope that this information will help you avoid any possible pitfalls and
difficulties, and at the same time, maximize the benefits you receive.
Types of Consultant Services
There are various types of consulting services, each of which involves a different
level of activity and different time frames for performing services. For example:
1. A consultant may be hired to operate a school's aid program on a continuing basis
with the assistance of regular personnel. Such an arrangement requires frequent visits by
the consultant over an extended period of time.
2. A consultant may be employed to provide broad direction and training to a school's
staff. In this capacity, the consultant serves as an instructor and counselor until the
school's employees have developed sufficient competence to handle the financial aid
process without assistance. This type of service would require heavier expenditures of
time at the outset, diminishing steadily until the objective is achieved.
3. A consultant may be employed to address a specific problem, or to review a school's
financial aid programs and recommend improvements. Such an arrangement normally calls for
only a few visits with narrowly defined goals.
It is important to note that there are circumstances under which the Department of
Education considers a consultant to be a third party servicer. The definition of a third
party servicer appears in Section 668.2 of the federal regulations. Generally, such a
servicer is involved in administering some aspect of a school's participation in the
federal student aid programs. As a result, the relationship between a school and a
consultant who is considered to be a third party servicer is more closely supervised and
dictated by the U.S. Department of Education.
Evaluating Your Own Needs and Expectations
Obviously, the first step in considering whether you need to hire a consultant is to
assess your school's current and future needs, and your ability to meet those needs with
existing and future resources.
The following list contains a sample of some of the factors you might want to consider
when assessing your needs and goals.
Considerations |
Resources
|
Institutional mission and goals |
Budget: current and future |
Current compliance requirements |
Staffing levels: current and future |
Future compliance requirements |
Computer technology and support |
Current and future technological
requirements |
|
Size of student body |
|
Size and complexity of financial aid
programs |
|
Dollar amount of aid administered |
|
Having weighed and considered these factors you will be prepared to make a tentative
decision regarding the level of consultant involvement that makes sense in your specific
situation. Ask yourself:
- What goals should be set?
- What time period may be involved?
- What level of expense is affordable?
With these preliminary judgments, you will be ready to initiate discussions, and deal
more effectively with consultant candidates.
Locating Qualified Consultant Candidates
Professional consultants and consultant firms are in operation throughout the country
today. There are also many individuals who represent themselves as such, but whose
credentials and abilities do not support their claims. While there is no "approved''
list of qualified student aid consultants available from any source, you may want to
explore a number of avenues, including:
1. Contacting schools similar to your own to see if they have used consultants and, if
so, for what purposes. Ask whether or not their experience was satisfactory. Reliable
referrals are frequently available from such sources.
2. Asking your school's accrediting agency for consultant referrals.
3. Contacting other consultants whose background is known to you, but who may not
themselves be available to assist you, to see if they can recommend qualified colleagues.
4. Requesting information from your state or regional association or a Regional Office
of the U.S. Department of Education.
You should keep in mind that information provided cannot necessarily be interpreted as
an endorsement of an individual consultant.
Evaluating the Qualifications of Consultant Candidates
Before initiating any substantive discussions with candidates, it is wise to request
their credentials and references from previous employers, especially from institutions
similar to your own. In reviewing the credentials of candidates for a consultant position,
some minimum standards apply:
1. The consultant should be able to show at least three years of recent
experience with student aid processes at a school (or schools) similar to your own. It is
important to note that work with community colleges, for example, may not adequately
qualify a consultant to serve a proprietary school at which student progress is measured
in clock hours or vice versa.
2. The consultant's prior experience should embrace all aspects of the student aid
programs administered by your school, and should be broad enough to permit an informed
overview of your total operation.
3. The consultant should show that his or her skills have been kept up-to-date through
participation in recent training programs and through active membership in state,
regional, and national associations. Such activities reflect professional commitment.
4. The consultant's own educational background should be appropriate. A bachelors
degree should be considered minimal, and in many instances, a masters degree may be
desirable.
5. The consultant should provide written documentation of his or her work in a
consulting capacity for other schools. Detailed personal inquiries to former employers
should be permitted to aid you in your evaluation.
Interviewing a Consultant
Once you are satisfied that your basic criteria have been met, the prospective
consultant should be interviewed in depth. The interview should provide you with
satisfactory answers to the following questions:
- Is the candidate thoroughly familiar with the required student aid processes at your
school?
- Is the candidate's previous financial aid office experience appropriate to the tasks you
have in mind?
- Is the candidate's knowledge of student aid delivery techniques and requirements
thorough and up-to-date?
- Can the candidate fulfill specialized needs that your assignment will call for such as:
- application processing and tracking?
- staff training?
- automation and data processing?
- coordination of financial aid office and business office functions?
The prospective consultant's attitudes and personal characteristics should also be
evaluated.
- Is the candidate's manner business like, yet courteous and patient?
- Does the candidate communicate effectively, both orally and in writing?
- How thorough is the candidate in eliciting details of your operations and how capable is
he or she of absorbing and analyzing them?
- Does the candidate project confidence and show concern for ethical practices?
When you are satisfied with these criteria, you may proceed to the questions of cost
and compensation.
Arrangements for Consultant Compensation
Payments to student aid consultants vary widely, depending on the services required,
the frequency of contact, and the complexity of the project. In the case of a specific,
closed-end assignment, a single fee may be negotiated on a project or per diem basis. In
other instances, a basic hourly, weekly, or monthly retainer may be arranged for time
commitments and services defined in the consultant's contract.
For an extended period of time, or for more broadly defined services, certain
allowances to cover contingencies and cost limitations may be appropriate. In any event, a
great deal of grief and friction can be avoided by making sure that there is a clear
understanding between you and the consultant from the very beginning.
At this writing, rates for consultant services generally range upward from $300 per
day, with somewhat lower rates for extended services. In addition, it is common for
consultants to be reimbursed for any transportation expenses, meals, and lodging incurred
in the performance of their services, as well as for any materials or outside clerical
work provided. Any limits on these expenses should be specified in writing before a
consultant is employed.
No payments prior to the performance of services should be agreed to. In the case of a
long-term project, payments at specified intervals while the work is in progress are
customary. For shorter projects, payment is usually made on the consultant's submission of
a final written report.
Drawing Up a Sound Consultant Contract
A clear and complete contractual agreement between the school and the consultant is
essential. Good practice would suggest that such a contract include the following:
1. Specific goals to be accomplished.
2. Frequency of the contact and/or period of employment.
3. Method, amount, and timing of compensation, and any limitations or contingent fees
negotiated.
4. Method, amount, and timing of expenses, with clear limitations.
5. Requirements for periodic progress reports and/or a final report; to whom they
should be submitted, in what form, in what degree of detail, and when they are required.
6. Provisions for office or staff support.
7. Location of and access to records and documents; safeguards to be taken by the
consultant to protect all records and maintain their confidentiality.
8. Consultant's responsibility for attending and representing the school at biannual
audits, program reviews, and other governmental inquiries.
9. Fulfillment criteria for the consultant's performance to be evaluated.
10. Provisions for the termination of the contract in the event you are dissatisfied
with the consultant's performance.
In addition to these good practices, if the consultant is considered to be a
third-party servicer, as defined in Section 668.2 of the federal regulations, the U.S.
Department of Education requires that certain agreements be included in the contract.
These agreements are outlined in Section 668.25(c) of the regulations. In addition,
Section 668.25(e) of the regulations specify that a school must inform the Department of
Education whenever it enters into, modifies or terminates a contract with a third-party
servicer.
It is usually a good idea to have your institution's legal counsel examine the contract
before it is signed by either party.
Working Effectively with a Consultant
If the proper groundwork is laid, you should be able to approach your relationship with
a consultant with a sense of confidence that your best interests are being served.
Remember, though, that it is up to you to maintain control through on-going communication
and by keeping up-to-date on all the consultant's activities. While the consultant may be
the expert, it is your school's money and welfare at stake.
If you are dissatisfied or uncertain of the consultant's progress and competence,
discuss your concerns frankly with the consultant and with your associates. If the problem
cannot readily be resolved, consider terminating your contract with the consultant and
hiring someone with whom you are more comfortable.
Published as a service to postsecondary educational institutions by NASFAA, the
National Association of Student Financial Aid Administrators.
We hope that this information will prove useful to you in managing your financial aid
program. It's a complex component of your institution's operations and perhaps one of the
most important for its well-being and its service to the community. NASFAA is here to
help.
NASFAA is a nonprofit association of postsecondary institutions, individuals, agencies,
and students, who are interested in promoting the effective administration of student
financial aid in the United States. Based in Washington, D.C., for close liaison with
federal agencies and legislators, NASFAA provides a wide range of professional services,
training, communications, and support for the student aid community.
September 1997