https://www.financialaidservices.org/wp-content/uploads/2023/04/Blog-image-designs-01.jpg 1312 2500 Julia Francis https://www.financialaidservices.org/wp-content/uploads/2023/08/FAS-Stacked-Logo-02-300x127.png Julia Francis2023-04-11 14:46:152023-04-12 12:40:03Is Financial Aid a Process or an Experience?
https://www.financialaidservices.org/wp-content/uploads/2023/02/Techie_Speed-2.png 396 938 Ken Garrett https://www.financialaidservices.org/wp-content/uploads/2023/08/FAS-Stacked-Logo-02-300x127.png Ken Garrett2023-02-08 08:14:522023-02-08 08:17:02The Need for Speed
By: Robert Heil, CEO
Students expect a combination of personalization with the speed that they experience from Amazon or DoorDash. Without that speed, students are less likely to stay engaged with you, and less engagement leads to recruitment and retention challenges. This can be especially challenging for financial aid and student accounts offices where speed + quality + accuracy must be delivered at scale.
Whether it be wait times, responding to their initial inquiry, offering admission first, or processing aid faster and sending an offer notice first–students reward speed.
If students love speed, what does speed love? Efficiency.
Providing a more efficient enrollment experience for students and parents must be a critical element in your comprehensive enrollment management strategy. No amount of marketing can offset an inefficient process. This is the pitfall too many campuses fall in. You can spend (or waste) hundreds of thousands of dollars on enrollment marketing, yet your greatest competitive advantage may be uncovering the efficiency and organizational capability needed to deliver customization and speed at scale.
You may not consider your financial aid and student accounts offices as major brand influencers, but you should. Mistakes and complications damage your brand. Your brand is not driven by US News & World Report rankings. Your brand is shaped by the student experience you deliver. When students and parents receive a streamlined, accurate experience, you strengthen your brand every time.
Websites that do not load in less than 6 seconds are usually abandoned. In the same vein, dissatisfied students will go elsewhere. Outside of academics, no other two offices on campus shape the student experience more than the financial aid and student accounts offices. Do your strategic investments in recruitment and retention reflect that?
Without speed + accuracy + quality, you are operating at a disadvantage.
Here are two ways we are helping our clients:
At FAS, we’ve spent 32 years mastering a model connecting the best people, processes, and systems to help our clients gain a competitive advantage. Our Outsourced Processing service combines our consultants, analysts, industry-leading practices, lean process methodology, and meticulous quality controls. These coupled with our technology platform provides the speed, accuracy, and quality your students expect. Using this service, your financial aid office can process aid exponentially faster with accuracy giving you a major competitive advantage with recruitment and retention.
Want to know where you stand? Our Organizational Capability Reviews for financial aid and student accounts offices can measure your business processes against best practices to discover where the major efficiency gains can be found. How well are you optimizing technology? How do your staffing levels stack up against benchmarks from peer institutions? Where can you improve the student experience? Don’t think of it as an audit. The goal is not to point out mistakes. The purpose is to find opportunities. We are “peer educators”. Our consultants come alongside to teach, coach, and roll up their sleeves to help.
To learn more, contact FAS to uncover how you can strengthen your financial operations, optimize enrollment, and enhance the student experience.
https://www.financialaidservices.org/wp-content/uploads/2023/01/Outsourcing39.jpeg 788 940 Ken Garrett https://www.financialaidservices.org/wp-content/uploads/2023/08/FAS-Stacked-Logo-02-300x127.png Ken Garrett2023-01-24 13:53:242023-01-24 13:53:24Reap the Benefits of Outsourcing
By: Jennifer Vaden, Student Business Services (SBS) Consultant
Many institutions have been feeling the pinch since the pandemic hit, with resource scarcity becoming commonplace. The question of how to accomplish more with less is getting tougher to answer. Meanwhile, students and parents expect a high level of service and support. This has created an environment in which colleges and universities must be creative with the financial and human resources we have to meet student and parent demands. Now is the time to reap the benefits of outsourcing.
Outsourcing a service to a third-party vendor can position an institution to improve operational efficiency, reduce overall costs, and enhance flexibility for its employees. Even though the word “outsourcing” may elicit a negative reaction as some inevitably link it to the act of laying off workers, outsourcing does not have to be all or nothing. Outsourcing can be approached as a partnership utilizing both institutional and third-party resources to significantly improve a service that is vital to students and parents. Many shared student services teams have embraced these partnerships to better meet customer service demands.
The first step is to assess which operational tasks, such as customer service, credit balance refunds, or financial aid verification, may be good candidates for outsourcing. Before exploring a partnership, however, it is imperative to start with what you know, namely, what is your data telling you. Achieving a high level of service and operational efficiency often requires a deep understanding of trends in volume, needs, and student and parent behavior as well as the productivity and capacity of your employees to meet those service demands. Today’s students live in an on-demand world in which waiting more than five seconds to receive a response can feel like a lifetime. Students and parents expect shorter wait times as they believe that the service level should be commensurate with the high costs associated with attending an institution of higher learning.
At one private four-year research institution, the business peaks align with the start of the Fall and Spring semesters, registration periods, and our yield season in April. Outside of these peak times, student and parent service demands tend to level out considerably. This presents a staffing conundrum. During peak times, far more staff are needed than are currently employed on the team to meet the higher demand for our services; however, in non-peak times, current internal staffing levels can meet the lower demand. Based on a thorough data analysis, it was clear that supplement staffing was needed for phone coverage. This would lower wait times and reduce complaints that sometimes were escalated to senior staff or even the presidential level.
Consequently, the institution engaged a third-party vendor to manage incoming calls rather than hiring additional benefited (W2) employees. The specific department was designed or resourced to staff seasonally whereas third-party vendors and servicers specialize in staffing for shifts in volume and activity. A third-party vendor can help you reach an optimal level of staffing to meet operational needs during the high, and shoulder, seasons.
Given the financial constraints facing many institutions, outsourcing a service is a decision worth considering especially if the demand for that service fluctuates throughout the academic year. The internal costs to hire, train, and retain benefited employees can be substantial. Budgetarily, direct costs to cover salary and fringe benefits for additional staff positions can add up rather quickly, making it more difficult to obtain the funding required to meet demands.
Outsourcing can be a viable alternative. The cost of a contract with a third-party vendor should typically be less than what an institution would need to budget to hire internally to meet the demand during peak times. In the instance mentioned above, the annual cost equates to approximately four internal frontline staff positions. However, the third-party vendor easily scales the staffing coverage beyond four positions to easily meet peak season demands. Bringing the service back in-house would cost nearly twice as much and result in overstaffing outside of peak times.
When factoring in the time and allocation of managerial staff to onboard and train new employees, the indirect costs quickly mount up. Moreover, complex learning curves often create situations where new employees are not able to significantly contribute for some time, requiring current employees to pick up the slack. This can increase burnout among current employees.
In this case, the third-party vendor is responsible for hiring, onboarding, and training their staff to support the client’s institutional needs. The institution supports the vendor as needed to ensure the content and quality are up to standards. This arrangement generally frees up managers to focus on more pressing service issues and reduces the burden that would otherwise fall on current employees. Considering the direct and indirect costs, outsourcing is a pragmatic solution.
Establishing a partnership with a third-party vendor can also provide you with the flexibility to focus on more than just day-to-day operational needs. There are important nonoperational needs that require managers to take their teams offline. Meetings, staff training and development, and campus events are a few of the reasons that operations may need to close temporarily. With a third-party vendor, operations can continue uninterrupted while you can dedicate time to grow and support your staff members. This flexibility benefits the leadership level as well. You now have the bandwidth to focus on the greater vision for the student experience because operational needs are being met efficiently and effectively.
Consider outsourcing operational needs to a third-party vendor when the data suggests it’s a smart option and your leadership asks you to be more creative with resources. Achieving cost savings, enhancing efficiency, maintaining compliance, and boosting flexibility are only a few of the benefits that await you when you embrace outsourcing as a viable solution.
If you’re just beginning to consider outsourcing, pinpoint the most time-consuming tasks. What takes your staff’s attention away from direct service to students? Most often, it’s back-office processes ranging from the Return of Title IV Funds (R2T4) to reconciliation and verification. All these functions are required by federal regulations. Outsourcing them to a trusted partner gives you peace of mind that you’re in compliance and the added efficiencies give you a real operational advantage. Contact FAS to learn how outsourcing is key to strengthening financial operations, optimizing enrollment, and enhancing the student experience.
https://www.financialaidservices.org/wp-content/uploads/2022/11/Staffing-pointing.png 788 940 Ken Garrett https://www.financialaidservices.org/wp-content/uploads/2023/08/FAS-Stacked-Logo-02-300x127.png Ken Garrett2022-11-17 08:26:212022-11-17 08:26:21Administrative Capability, a Mammoth Challenge in Financial Aid’s Staffing Crisis
By: Bob Covey-Robbins, Consultant
What does it mean for an institution of higher education to be administratively capable? Why is it important? Whose job is it to ensure that a school complies with administrative capability requirements?
Administrative capability is carefully evaluated when a school’s application for certification or re-certification is reviewed by the Department of Education. The school must demonstrate administrative capability. 34CFR§668.16 extensively outlines the conditions for administrative capability. In short, it means that the institution has the people, expertise, systems, technology, policies, and procedures to effectively manage Federal Student Aid programs.
The institution must designate someone to be responsible for administering FSA programs, but it also must ensure that the person is supported by an adequate number of staff needed to effectively administer the programs. There is no specific formula for determining the number of staff needed. It must be determined by the number of students applying for financial aid, the various financial aid programs the school administers, the technology used, and how much administration is automated.
Many schools are currently struggling to maintain an adequate number of staff to remain in compliance with the daunting number of Title IV statutory and regulatory requirements. According to a US Chamber of Commerce article, today, there are 2.9 million fewer people in the workforce than there were in February 2020, and even if every unemployed person were to gain employment, there would still be a labor shortage (Ferguson, 2022).
Has the financial aid office workload lessened with declining enrollment? Many would say that it has actually increased since the COVID-19 pandemic started. Expanding the modality of financial aid counseling to include remote advising, administering HEERF funds with its frequent changes in federal guidance and reporting requirements, and more recently, the addition of Fresh Start student loan default relief. The number of students seeking a Fresh Start at a school can bring a significant increase to the financial aid office workload.
Declining enrollment has led to decreases in operating budgets, making it even more difficult to retain valuable staff as more attractive employment opportunities arise outside of higher education administration. Creating entry-level financial aid office positions may add staff, but those staff need extensive training, supervision, and coaching as they become proficient in their new role. For many schools, the cost of new aid officer training programs offered by state, regional, and national associations is out of reach.
The harsh reality for many financial aid offices is that they are facing the perfect storm of increased demand for services, staffing vacancies, continuous audit pressures, shrinking budgets, and, ultimately, concern about maintaining the school’s eligibility to participate in federal student aid programs.
To provide the needed services to help families with financing higher education, while maintaining legislative and regulatory compliance, more schools are seeking interim staffing solutions. Services can range from filling a financial aid director’s role to outsourcing daily financial aid processing tasks. For many schools, using a trusted partner for interim staffing and outsourcing processing tasks provides a more cost-effective means to providing quality student service, while maintaining compliance and making a valuable contribution to the school’s enrollment management efforts.
https://www.financialaidservices.org/wp-content/uploads/2022/11/Remote-Work.png 788 940 Ken Garrett https://www.financialaidservices.org/wp-content/uploads/2023/08/FAS-Stacked-Logo-02-300x127.png Ken Garrett2022-11-15 08:17:492022-11-15 09:14:53Working Well Together, Even When You’re Apart
By: Joyce Sonenberg, Senior Consultant
Monday morning, the start of a new workweek. Off goes the alarm, and off you go. Comb your hair, throw on some clothes, grab a coffee, check that all is right with the world, and head off to the office. The office? Wait a minute. Where is the office? The office may be in the corner of your bedroom, the empty spot in the basement, or the remains of what used to be the linen closet. The fact is the office can be anywhere. Because, in this world, you are a full-fledged remote worker.
If you are a remote employee, you are far from alone. If you currently are not working remotely, chances are that you may soon be. The U.S. Bureau of Labor Statistics estimates over 25 percent of all Americans will be working remotely by 2025, which translates to over 36 million people. That’s a whopping 87 percent increase compared to pre-pandemic figures. Other research suggests even higher increases as workplace dynamics continue to evolve. Regardless of the numbers, sooner or later you may find that your office is just down the hall—the hall in your home, that is. Working remotely can be chaotic, stressful, and frustrating. It can also be very satisfying, rewarding, and unleash a level of professional creativity that can change the trajectory of your career. Let’s aim for the latter. Here are a few tips to consider as you head to your office.
Maintain a professional workstation.
Be organized. Practice the time-honored cliché, “A place for everything, and everything in its place.” Run your home office just like you would your location office. Keep your stock of office supplies at an acceptable level. Have adequate amounts of printer ink, paper, notepads, pens, pencils, staples, and zip drives. Remember, you oversee the office supply department. Unnecessary trips to the office supply store are inefficient and waste time and money. Make sure you have up-to-date technology. Your home computer may be a bit less sophisticated than what you are accustomed to in the on-site office, but you should be able to come fairly close. If you need two monitors, then get two monitors. If you need a dependable audio headset, then get one. You can’t expect to work efficiently without the proper tools. Check with your internet provider to ensure your connection speed and capacity can handle your needs. Create a practical workstation or desk that provides ample elbow room for notepads, calendars, your keyboard, and your mouse. Don’t forget a comfortable office chair as you will be spending many hours in it. Choose your home office area to be in as distraction-free an environment as possible. Often easier said than done, but it will benefit both you and your family members in keeping the peace. Re-organize at the end of the day so you are ready to start fresh in the morning. You’ll thank yourself for it each day.
Present a professional image.
Okay, so you don’t have to dress like you are making a presentation to the Board of Directors. However, you are a professional, working with other professionals, from your professional office. True…a home office, but a professional one, nonetheless. So, business casual at the least? Yes. T-shirt and sweatpants? No. If you look and feel professional, you will demonstrate professional work behaviors which can directly impact your relationships with students, parents, and other staff. Remember, remote workers reside from coast-to-coast, time zone-to-time zone, and even globally. Look good and be at the top of your game.
Maintain your focus.
Treat remote work like a real job, because it is. When you are in your home office, you are at work so schedule your day appropriately. Use and pay attention to your calendar. Keep your supervisor informed of personal, sick, or vacation days. If you are a director, maintain a schedule for your staff and share it with them.
Even though you are working from home, you may still require daycare. We love the little ones, but we do not typically bring them to the office. Household chores like laundry, shopping, lawn care, and home maintenance are distractions that are not part of a normal workday, so schedule them for your off days. Sure, you can load the dishwasher, but accomplish this task during a scheduled coffee or lunch break. It’s easy to get bumped off task when working remotely from home.
Stay connected with your staff.
Staff can’t just pop into your office and “touch base” with you like in the past. Likewise, you can’t as easily provide directives or clarification face-to-face either. It’s more important than ever to stay connected with your staff. Reach out to them often. Keep them in the loop. It isn’t difficult to achieve this, you just need to use different methods or tools. Hold regularly scheduled brief daily check-up meetings at the beginning or end of each business day. Informal individual or group end-of-the-week chats can help to build both trust and teamwork and assist staff to become more comfortable and efficient with the remote environment. There are several reliable platforms available for use in this approach. ZOOM and Microsoft Teams are commonly found in most offices. Use them to share both your and the staff’s calendars, assignments, and directives. Email and conference calls are very useful and time-tested methods. Remember, you’re not functioning as a hermit. You are still working with your team. Engage them often and encourage them to do the same.
Stay connected with your students.
Students are the reason you are there. Providing quality service to students while working remotely often requires extra effort. Make sure you reach out to the students often and assure them they will receive the same level of attention as if they were standing at the front counter of the campus FA office. Develop staff schedules that clearly identify email and telephone response responsibilities, both for receiving and returning student and parent inquiries. It may be particularly important to monitor staff performance in this regard. Take the time to review the financial aid office portion of the school website and clarify any confusing instructions, confirm contact phone numbers, and email addresses, and important dates on the calendar.
Final Considerations. Whether you’ve elected, or have been directed, to work remotely, it doesn’t appear to be a work style that is on the decline. Regardless of which resource is cited, most indicate a steady growth in U.S and international remote workers. Is it right for you? Of course, only you can decide. There are many areas to consider when contemplating a remote employment position.
Control of your work schedule is a strong attraction for those considering a remote position. While it is convenient in some respects, that flexibility does not mean the remote workforce is made up of slackers. Remote workers say they often average 45 – 55+ hours on the clock per week. A significant number of remote workers reported they felt obliged to work more than 8 hours a day and often worked 10 to 12 hours a day, frequently putting extra time in on weekends. Many workers acknowledged that knowing when to shut down and disengage was one of the biggest challenges they encountered while working remotely. Scheduling breaks, taking a walk, eating properly, and prioritizing time with family are important considerations. On the flip side, workers generally stated they felt more focused on their responsibilities, experienced less job-related stress, and are 35 to 47 percent more productive. Remote workers often reported an increased sense of self-esteem and professionalism.
Would you like some help navigating the new realities of work? Perhaps it’s time to reevaluate how your staff and office are structured. Contact us for a no-obligation consultation.
https://www.financialaidservices.org/wp-content/uploads/2022/09/Consulting-Corner-team.png 788 940 Ken Garrett https://www.financialaidservices.org/wp-content/uploads/2023/08/FAS-Stacked-Logo-02-300x127.png Ken Garrett2022-09-30 14:13:352022-09-30 14:24:51Welcome to FAS’ Consulting Corner
Welcome to FAS’ Consulting Corner! In conjunction with launching our new website, we want to use this space to share relevant information with financial aid and student business services practitioners. It’s a safe and reliable place to get the latest news on what’s happening in financial aid and student finance all around the country. We’ll tackle issues from maintaining rigorous compliance standards and leveraging technology, to giving your students the best possible experience. Our consultants are thought leaders with a combined 1,600 years of experience in their respective fields. Higher Education is an industry that’s always in motion. There is always something new to talk about, so check back often. We’re adding fresh content all the time. Whether you’re considering services, need guidance or resources, or just want to connect with FAS, we’ve got something for you.
https://www.financialaidservices.org/wp-content/uploads/2022/09/front-counter-interaction.png 788 940 Ken Garrett https://www.financialaidservices.org/wp-content/uploads/2023/08/FAS-Stacked-Logo-02-300x127.png Ken Garrett2022-08-22 09:12:482022-09-30 09:23:05Win-Win Approach to Dealing with Difficult Students
One size does not fit all when it comes to working with students and their needs surrounding how to finance and pay for their education. Every student interaction brings unique circumstances, capabilities, and concerns to the table. While in many cases questions are easily answered and issues resolved, other times students or parents are not able to meet institutional requirements or are dissatisfied with the answers they’ve received.
Dealing with difficult customers is not unexpected particularly at the start of a new academic year. Whether it’s financial aid packages that don’t meet expectations, not being allowed to register for classes because of an outstanding balance, getting conflicting information from different offices, or just not being able to reach institutional staff by phone or email, this stressful time of year can impact student retention, outstanding receivables, or just engender bad feelings about the institution.
At a time when quality service is more than an expectation, staff and supervisors face the wrath and ire of many customers. Depending on the time of year and institutional deadlines or organizational structures, these customers are not only students and their parents, but may extend to prospective students, alumni, faculty members, or even colleagues in other institutional offices. With enrollment, financial and workforce pressures on colleges and universities, maintaining service delivery standards and satisfaction can challenge both staff and senior leadership.
To maintain quality service standards, institutions now must also factor in needs related to diversity, equity, and inclusion (DEI) that have moved into the forefront of the higher education experience. Treating your students and constituents with a consistent approach should not mean that every experience and interaction is similar. At the same time, it’s important to respect and note how differences in culture, knowledge, and experiences may require different styles and techniques in service delivery and counseling.
That’s why it is important that we “listen to hear” what our customers are saying and how we subsequently respond to their needs. Not only is it critical to be timely and accurate in responding, but it’s also vital that someone owns the customer’s issues and concerns. Too often, failures to listen, understand, and answer these concerns creates escalated conflicts and complaints.
Using every customer interaction to anticipate other questions/concerns and educate students on what to do (and how to do it) can lead to more on-time payments, higher satisfaction levels, reduced complaints, and increased student success.
https://www.financialaidservices.org/wp-content/uploads/2022/09/financial-education-puzzle-pieces.png 670 934 Ken Garrett https://www.financialaidservices.org/wp-content/uploads/2023/08/FAS-Stacked-Logo-02-300x127.png Ken Garrett2022-07-22 12:40:192022-09-30 14:26:37Financial Literacy – An Essential Part of Student Success
Providing students and their families with the skills and tools to understand personal finance and money management has largely fallen to colleges and universities. While fourteen states have enacted legislation mandating personal finance training in high school, more than two-thirds of the country still lacks any formal training or education programs for students or parents.
Many people don’t know where to turn for guidance or direction when they need assistance in completing a FAFSA to apply for financial aid, how to save for college or use payment plans to help finance an education, or even how to create a budget. Both traditional students and older adults returning to school often seek out resources to figure out how to pay for college and, later, to repay their student loans.
By default, colleges have become the last resort for acquiring this knowledge. Identifying and managing financial issues has become a key element in the recruitment and retention of students. Admissions recruiters, financial aid counselors, and student account representatives often are thrust into roles as financial counselors, even if their own knowledge is lacking. With a glut of available information on how to pay for a college education and limited resources to digest and disseminate the data, staff may be ill-equipped to offer time-consuming counseling to students and families while trying to deal with the other aspects of onboarding and maintaining enrollments.
Best practice institutions have developed separate offices to assist students with financial wellness education or have partnered with firms that provide web-based programs and knowledge-driven modules to help them learn the various aspects of personal finance, from student loans and credit cards to budgeting and credit scores.
Institutions need to have an executive sponsor for these programs and place ownership under a single office or group of individuals who will prioritize providing access to personal finance programs and resources.
If an institution does not want to create a separate department, financial wellness programs could be hosted by numerous departments, including but are not limited to financial aid, bursar or student financial services, enrollment management, career services, housing, new student orientation, and dean of students. Admissions, alumni relations and development offices help maximize program exposure and provide a value-added service for prospective and former students and interested parties.
Because students often are more comfortable talking with their peers, a program that incorporates trained student employees to share financial information can help build trust and confidence while also building a triage process to determine when counselors or other full-time staff need to handle more complex issues.
Providing a well-rounded education for today’s students requires a holistic approach to helping them achieve personal success, both now and tomorrow. Offering financial wellness resources will not only help students reach their personal goals – it also may give them the tools to pay their bills in full and on time!
https://www.financialaidservices.org/wp-content/uploads/2022/09/College-Transcript-1.png 788 940 Ken Garrett https://www.financialaidservices.org/wp-content/uploads/2023/08/FAS-Stacked-Logo-02-300x127.png Ken Garrett2022-03-30 08:15:562022-09-30 12:44:31Have Administrative Holds Become a Hot Button Issue?
Institutions of higher education have traditionally used sanctions such as preventing future class registrations and withholding academic transcripts when students owe delinquent account balances. Depending on the schools’ policies, or sometimes state law or regulations, such sanctions may be triggered for any amount due or at a higher dollar threshold that is formula-driven or set arbitrarily.
Short of referring these debts to an outside collection agency or other entity to recover outstanding balances, these holds have provided colleges and universities with a low-cost and easy-to-implement remedy to force students to pay in full or reach out for assistance.
However, recent coverage in the media (for instance, Hechinger Report and Inside Higher Ed) focusing on the large number of students whose financial problems have forced them to delay completion of their educations has raised attention to use of these types of sanctions. A 2020 study by Ithaka S+R on impacted students with “stranded credits” portrayed a scenario where financially-challenged students had little, if any, opportunity to receive their degrees. They could not continue their educations or transfer credits because of outstanding student debt which, in some cases, amounted to only a few dollars.
The issues raised by transcript withholding led the California legislature to enact a law in 2020 prohibiting all institutions from blocking transcript requests because of outstanding balances owed. Washington and Louisiana have since enacted comparable legislation and a number of other states are considering doing so. At the same time a bill was proposed recently in New York, both the State University of New York (SUNY) and City University of New York (CUNY) systems stopped sanctions using transcripts.
In addition to complaints from current and former students, schools now may be subject to complying with new laws and regulations governing their internal operations. So, what should colleges and universities be doing today to mitigate the impact?
Some ideas to consider include:
- Review existing policies and procedures governing use of holds and restricting student services. Are you restricting transcripts or registration for any amount or reason (i.e., tuition vs. parking or library fines) that money is owed? Consider your current dollar threshold for service restrictions and determine how, or if, it has been reviewed or changed in recent years (besides pandemic management).
- Involve your institution’s attorney in the review process. Having counsel look at or help create an appeal process that is consistently managed can ensure a transparent and fair practice. Creating differing rules or interpretations for every student situation not only can lead to criticism, but could create the perception of a UDAAP, which refers to unfair, deceptive, or abusive acts or practices by those offering financial services (including higher education), which is illegal under the Dodd-Frank Act of 2010.
- Weigh whether your state or district has implemented or is considering legislation or new rules. Work with your government affairs office or lobbyist to take the temperature on how institutional restrictions are viewed by legislators and regulators. Educate officials on what the impact of eliminating holds might be on the institution.
- Investigate opportunities to create and use debt reduction or forgiveness programs. Resolving small balance debts can be a “win-win,” eliminating minor amounts owed, while creating a positive experience for a student whose continued attendance results in additional revenues earned. Student success stories not only can breed positive press for an institution, but may even result in additional enrollments and donations.
At a time when colleges and universities are questioned as to whether they are sufficiently accessible or affordable, using service restrictions that block students from continuing or using their educations will remain under close scrutiny. How a school deals with this issue will not only impact collections but could also influence future revenue streams and enrollments.
https://www.financialaidservices.org/wp-content/uploads/2022/09/data-secutiry_lock4.png 788 940 Ken Garrett https://www.financialaidservices.org/wp-content/uploads/2023/08/FAS-Stacked-Logo-02-300x127.png Ken Garrett2022-02-26 08:57:422022-09-30 09:08:32Safeguarding Students’ Information Now Requires Stricter Oversight
The Federal Trade Commission (FTC) issued a final rule on December 9, 2021, amending the customer information safeguard requirements under the federal Gramm-Leach-Bliley Act (GLBA), also known as the “Safeguards Rule.” Since 1999, the GLBA has set the standards for maintaining customer data for financial institutions, including colleges and universities that participate in the Title IV federal student aid programs.
While the revised Safeguards Rule took effect on January 10, 2022, schools will have until December 2022 to implement most of the required changes in the rule. Some of the notable mandates include:
- Concentrating program oversight under a single qualified individual rather than shared by a team or group of employees. While this oversight likely will be centered under an institution’s information technology department, look for the school’s chief information security officer (CISO) or chief information officer (CIO) to be the responsible party.
- Ensuring that information security programs are based on a written risk assessment that looks at “foreseeable internal and external risks to the security, confidentiality, and integrity” of any consumer (student) information held by the institution. Written documentation is now a mandatory requirement under the Rule.
- Designing information security programs to control assessed risks that include eight specific types of safeguards:
- Monitoring and testing of internal controls and procedures regularly to protect against actual and attempted hacks of information systems.
- Overseeing and assessing service providers when contracting for outside services. This will include actual periodic assessments of vendor systems by the institution.
- Reporting annually to the institution’s board about its information security program and compliance with the updated Safeguards Rule.
Because higher education institutions are frequent targets of hackers and victims of data breaches, a strong and well-understood infrastructure and program to maintain and protect student information is critical. These programs require institution-wide accountability. It is vital that all employees be aware of changes and take responsibility to protect personal data.