Lay Down Your Burden: Help NASFAA Identify Burdensome Regulations

By Joan Berkes, Policy & Federal Relations Staff

It's time to lay down your burden – or at least write it down. NASFAA has yet another opportunity to identify burdensome regulations that, in the larger scheme of things, do not achieve an outcome worth the effort or cost. On June 22, the Department of Education (ED) published a request for comments in the Federal Register soliciting input from the public about regulations that should be repealed, replaced, or modified. Comments are due by Aug. 21, 2017. NASFAA plans to respond to this solicitation and is, in turn, asking members for their opinions.

Today's News will carry a series of short articles, of which this is the first, to ask member opinion on specific issues that tend to come up when regulatory burden is discussed. The recommended solution can be modification of the requirement or outright repeal, so consider whether a particular requirement is:

  • Unnecessary or unrelated to the proper administration of Title IV funds;
  • Outdated;
  • Duplicative;
  • Ineffective;
  • Out of proportion in terms of burden to its benefit;
  • Too complex to administer effectively; and/or
  • Too burdensome for students, thereby creating barriers to application, enrollment, or completion.

Remember to focus on regulations rather than the law. It can be challenging to separate requirements that result from regulatory initiatives from requirements that result from specific statutory imperatives.

For this first article, we ask that you assess verification regulations. For example, you might wish to consider which aspects are necessary to ensure proper distribution of Title IV funds, which aspects don't seem to yield significant results, and which aspects create unreasonable barriers for students. What improvements do you recommend?

Please give your recommendations either as a comment to this article, or in an email to [email protected], using subject line "Verification Reform."

Impetus for This Round of Regulatory Reform

ED's solicitation is the result of Presidential Executive Order 13777, which directed the various departments and agencies of the federal government to establish Regulatory Reform Task Forces charged with evaluating existing regulations and making recommendations regarding their repeal, replacement, or modification.

ED released its first report under this effort in May.

Historical Background on Burdensome Regulations

Identification of burdensome regulations has been an ongoing issue for many years now. Among the significant efforts in recent years to examine burden are the following:


Publication Date: 8/2/2017

Marguerite J | 8/3/2017 8:51:05 AM

The current regulations concerning R2T4 in modules are difficult to implement and cause undue hardship in the financial aid offices as well as the registrar's office.

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