February 6, 2006
Dear Madam Secretary:
I am writing on behalf of the National Association of Student Financial Aid Administrators (NASFAA), representing more than 2,800 members and 12,000 financial aid professionals, to share comments and offer our assistance as the Department of Education works to implement S.1932, The Deficit Reduction Act of 2005 (the Act).
We know that implementing the many provisions of this Act in an expeditious and consistent manner will be a challenge for both the Department and NASFAA member institutions. Therefore, drawing on our long and mutually-beneficial relationship over the years, we have focused our comments specifically on provisions in the Act which affect the student aid delivery system.
As you know, many of the provisions affecting the student aid delivery system are effective July 1, 2006the beginning of the 2006-07 award yearyet the 2006-07 Free Application for Federal Student Aid (FAFSA) is currently in use by students and their families and the Central Processing System is already fully operational. With this in mind, we understand that making changes to the CPS at this point could have a disruptive effect on the delivery of aid to needy students. However, we know that the Department will strive to implement the Act's provisions in a manner that maintains the integrity of and ensures consistency of the student aid programs, and is mindful of the impact of changes on students and institutions.
We would therefore propose that consideration be given to using different approaches to making changes to the paper FAFSA versus the electronic FAFSA on the Web (FOTW).
For electronic filers who have not yet completed their 2006-07 applications, we urge the Department to quickly make needed modifications to the FOTW to accommodate the Simplified Needs Test and Automatic Zero modifications as well as the changes to the treatment of active duty military personnel, 529 plans, and family-owned small businesses.
We also suggest that the Department consider utilizing the CPS to communicate directly with paper filers to inform them of the statutory changes. Applicants could be instructed to make corrections in relevant data items based on the revised statute. If possible, include a coded Student Aid Report (SAR) for the student to use. Changes made to affected data elements on that coded SAR could be assumed to be a result of the legislative changes; a comment to that effect on the resultant Institutional Student Information Record (ISIR) would eliminate the need for schools to consider the revisions a possible source of conflicting information.
This same type of direct communication and coded corrections would also be needed with electronic applicants who filed before changes are made to the FOTW form.
We believe that this type of approach is essential to make certain that students are systematically informed of these important changes and have a consistent way to make necessary corrections with a minimum of processing disruptions at their schools and the CPS. While we believe the aforementioned suggestions are workable, we would be pleased to assist you in any way that would be helpful.
By working together, we can ensure that needy students across the country receive the student aid funds for which they are eligible. Please feel free to contact us at your convenience so we can assist in minimizing the disruption for all parties.
Sincerely,
Dallas Martin
President
Posted February 7, 2006 on www.NASFAA.org, the Web Site of the
National Association of Student Financial Aid Administrators (NASFAA).
Copyright 2006. Redistribution to non-NASFAA institutions is prohibited
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