NASFAA Submits Comments On ACG/SMART And General Provisions NPRMs

NASFAA submitted on Wednesday comments and questions on the Academic Competitiveness and National SMART grant programs NPRM and the General Provisions NPRM published in the Federal Register on Aug. 7 and 8 respectively.

NASFAA encourages members to review the comments and questions and write to the Department to ensure that the concerns of financial aid professionals are well represented. Comments on the ACG/SMART grant NPRM are due Today.

In regard to the ACG/SMART grant NPRM, NASFAA expressed disappointment that the Department chose not to make students in certificate programs eligible for the grants and that the Department did not change the frequency of calculating the SMART GPA which must be calculated each term rather than yearly.

"We understand that although the Department admitted that the law could be interpreted either way, it is a policy decision of the Department to exclude certificate programs, and so they remain ineligible," wrote NASFAA President Dallas Martin in a cover letter for the comments. In addition, "the statutory language can just as well be interpreted as meaning that a GPA for SMART purposes is also determined on an annual basis for each academic year. Such an approach would cut the administrative burden with all the attendant timing issues and caveats regarding missing grades in half for each academic year."

NASFAA expressed support for the proposed regulations governing the General Provisions and federal student aid programs. In his cover letter, Martin noted that institutional processes vary and are legitimately creative and urged the Department to consider various institutional approaches that meet the spirit of the regulations.

"An example of this would be providing flexibility in recognizing what constitutes active confirmation of loans," Martin wrote.

Martin praised the Department for the process used to develop the General Provisions NPRM.

"The negotiated rulemaking committee that developed this NPRM demonstrates how effectively the process can work," he wrote. "We appreciate the Department's responsiveness to concerns raised by non-federal negotiators and its commitment to working with all negotiators from the higher education community to develop workable solutions to the variety of issues in this NPRM."

Posted 09/06/07 to www.NASFAA.org. Redistribution to non-NASFAA institutions is prohibited. Please submit Web Site questions or comments to Web@NASFAA.org.