REPORT OF THE
NCAA DIVISION III FINANCIAL AID AND AWARDS COMMITTEE
1. ACTION
ITEMS.
a. Amend NCAA Bylaw
15.4.1.1 (Annual Electronic Report).
(1) Recommendation. Amend NCAA Bylaw 15.4.1.1 (annual
electronic report) to specify that an institution’s failure to submit the
annual report by the due date established by the NCAA Division III Financial
Aid and Awards Committee’s and approved by the Management Council will
result in a loss of eligibility for championships and grant programs.
(2) Rationale. Failure to submit the annual report
would likely be a secondary violation, and the NCAA enforcement services staff
would be limited as to what penalties may be imposed. In this situation, the enforcement staff
may impose an admonition letter and/or monetary fines against those
institutions. The committee
believed these penalties would not be meaningful to the membership. Thus, the committee agreed that
postseason sanctions and the inability to participate in Division III grant
programs will send a strong message to the membership that submitting the
annual report is an extremely important requirement. This penalty will not be handled by
enforcement services staff or the NCAA Division III Committee on Infractions.
(3) Budget
Impact. None.
b. Restricted Membership
Status – Failure to Submit Annual Report.
(1) Recommendation. Request the NCAA Division III Membership
Committee review whether an institution that fails to submit its annual report
should be moved to restricted membership status, consistent with Constitution
3.2.4.1 and 3.2.5.1.
(2) Rationale. The committee believed that institutions
that fail to submit their annual reports should be referred to the Membership
Committee for review and consideration of restricted membership status. This proposed penalty will reinforce the
importance of the legislated requirement of annually submitting the report.
(3) Budget
Impact. None.
c. Financial
Aid Review Reporting Timeline.
(1) Recommendation. Amend the reporting timeline to July 1
to September 30.
(2) Rationale. The committee reviewed the timeline
based on information from the division-wide pilot; annual notification of
institutions required to submit justifications; and workload and research needs
and determined that moving the window from June 15 - November 1 to July 1 -
September 30 was most appropriate.
This window still provides ample opportunity for financial aid
administrators to complete the reporting process and further ensures
notification prior to December 31 for all justification, thereby permitting any
institutional changes or amendments to their awarding policies and procedures
for the subsequent year. The
committee noted its intent to stress this issue during the 2005 Convention
discussion session.
d.
Acceptable
Variance between Gift Aid Awards for Student-Athletes and Other Students.
(1) Recommendation. Support a model that defines gift aid as
“total institutional gift and based on the lowest estimate of bias”
and a threshold variance of four percent.
Based on the pilot results, the four percent threshold would result in
approximately 10 percent of the division’s membership with an
unacceptable bias estimate requiring for them justification.
(2) Rationale. The Committee reviewed three statistical
models to analyze gift aid awards, which determine whether there is significant
statistical bias when awarding financial aid to student-athletes. NCAA research staff stressed the
importance of using one model to analyze the data. It was noted that a single model will
allow for a more transparent rule.
The committee reviewed the three different models based on different
definitions of gift aid. The choice
was ultimately based on a balance between accuracy, effect and philosophical
base. The model selected provides
the best means to identify a significant bias estimate in awarding aid to
student-athletes by using the lower confidence boundary of the bias estimate as
a proportion of the average financial need for student-athletes. This results in significance in terms of
statistical consideration and face validity. Further, with the implementation of a
threshold of the proportion, the model will result in a reasonable and
justifiable burden on
the
institutions, the committee and the NCAA national office staff. The committee decided, for the first
reporting year in 2005-06, to use model that defines gift aid as total
institutional gift aid based on the lowest estimate of bias. However, the committee will continue to
review data based on model one (total gift aid) and model two (sum of institutional
gift aid and state gift aid). The
Committee agreed to revisit this model on an annual basis to determine whether
any changes need to be made.
2. INFORMATIONAL
ITEMS.
a. Annual Electronic
Reporting Process – Review of the 2004 Division-Wide Pilot Results.
(1) Submission Numbers. It was reported that 227 institutions
participated in the 2004 division-wide pilot, which included 157,872 student
records. The breakdown of the
records included 17 percent student-athletes and 83 percent other students. NCAA research staff concluded that the
sample reflected statistical significance and was a representative sample of
the division in relation to the cost of attendance; campus enrollment; and
private versus public factors.
(2) Honorarium
Update. It was reported that 88
institutions requested the $1,000 honorarium. It was also noted there were technical
problems with the delivery of automatic e-mails to chief executive officers
regarding the honorarium. This may
have been caused by institutions’ spam filters. The committee agreed that institutions
that submitted data by November 1 will be contacted to apply for the
honorarium. The committee further
agreed that institutions reporting after November 1 will be contacted to apply
for the honorarium if an institution experienced technical problems or if the
chief executive officer believed they were eligible for the honorarium if the
data was submitted after November 1.
b. Review of the 2004
Division-Wide Pilot Findings.
The committee reviewed the 2004 division-wide pilot findings.
(1) Submission
process.
(a) Institutions
will be permitted to submit data via e-mail, CD-ROM or the Financial Aid Data
Management System (FADMS) during full implementation of the financial aid
reporting process; and
(b) The
committee directed staff to include case studies in the Users Manual, located
in the FADMS that will include narratives drafted by institutions that
participated in the division-wide pilot.
(2) Reporting
Issues.
(a) The
Combination of Zero Need and/or Zero Gift Aid. The committee noted while it is
important to capture each incoming student so the reporting represents an
incoming class in its entirety, the inclusion of records defined by zero need
and zero gift aid will skew certain report calculations and analysis of
data. The committee noted that
institutions must continue to report students who have zero need and/or zero
gift aid. This group will be accounted
for by the use of a specific statistical model.
(b) Accounting
for Students Who Do Not File a Free
Application for Federal Student Aid (FAFSA). The committee noted that institutions
must continue to report students who do not file a FAFSA; however, these
students will be separated in all reporting.
(c) Definition
of the Relevance and Accuracy of the Total Financial Aid Award and Work Study
Variables. The committee voted to
eliminate the category of total financial aid award from the report. Institutions will only submit gift aid
and federal work study and/or campus employment, if awarded by the financial
aid office, for each student-athlete and other students. The committee voted to include in the
reporting of work study, in two separate columns, federal work study and/or
campus employment, if awarded by the financial aid office. These variables will be captured as
yes/no questions.
(3) Report
Format.
·
Revisions to the Institution Report Format. The committee noted that there was an
issue for public institutions in that the report did not account for in-state
and out-of-state financial aid. The
committee noted that this issue will be addressed as a justification. The committee directed staff to amend
FADMS so the report will reflect institutional contact information, the name of
the
individual(s) that completed the report and the name of the individual(s)
responsible for the report.
(4) Review
Process - Filters for Staff and Committee Review of Data. The committee reviewed a number of
filters to shape the policy for review of institutions that have a statistical
bias that suggests a need for closer examination. The committee agreed to use the
following filters for the preliminary review:
(a) Proportionality
test (proportion of student-athletes of entering class compared to proportion
of total institutional gift aid awarded to student-athletes);
(b) Statistical
issues (e.g., sample size, confidence interval);
(c) Historical
review;
(d) Proportion
of student-athletes in incoming class;
(e) Gift
aid as proportion of cost of attendance;
(f) Packaging
methodology; and
(g) Additional
considerations (e.g., financial need bracket assessment, sport-by-sport
breakdown assessment).
The Committee agreed to review the filters on an annual basis and make
necessary adjustments.
(5) Communication
of Final Reports to Institutions.
The committee reviewed the communication process that was used for
participating institutions in the 2004 division-wide pilot. The committee agreed on the following
methods of communication during full implementation of the financial aid review
process:
(a) Each
institution with a statistically significant variance will receive written
notice of bias. However, not all of
these institutions will be required to go through the formal review and
justification process.
(b) Bias
estimates should be included in the preliminary reports available to
institutions after initial upload.
(c) The
final report, including the bias estimate, will be sent to institutions not
later than December 31.
(d) A
memorandum will be sent to those institutions that need to submit justifications.
It was noted
that the division-wide pilot was confidential, and served as a self-assessment
tool to assist the committee in determining an acceptable variance. In that regard, the committee agreed it
is at the institution’s discretion to share and discuss reports with its
conference office through financial aid administrators and chief executive
officers. The committee noted that
the national office can serve as the clearinghouse for the conference aggregate
data and compare such data to the national aggregate, if requested.
c. Formal Review
Process.
(1) Committee
Composition. The committee
agreed to form three working groups consisting of one chief executive officer,
one financial aid administrator and one athletics administrator that will be
responsible for reviewing institution reports that indicate a statistically
significant bias when awarding financial aid to student-athletes (i.e., Level
One Review).
(2) Protocol. The committee developed a formal review
process in flowchart form (Attachment), outlining data file upload through
committee review, justifications and possible report to the NCAA enforcement
services staff. The committee
agreed to the following timeline:
(a) July
1 through September 30 – Report submission window for institutions;
(b) October
1 through December 1 – Staff and subcommittee initial review using
predetermined set of filters (i.e., Level One Review);
(c) December
– Full committee review of institutional reports to determine whether
justifications are necessary;
(d) December
31 – Final reports and communication to institutions; request notice and
formal request for justification/corrective actions send to applicable
institutions (Level II review);
(e) February
1 – Institutional deadline for justification;
(f) March
– Committee meeting to review justifications (Level II review); and
(g) June
– Committee meeting to annually review the variance and filters.
The
committee agreed that when appropriate, it is within the committee’s
discretion to randomly review and request justifications from an institution
(e.g., team-by-team analysis, institution not included in the percentage of
variance). The committee further
agreed that there is no limitation on the number of institutions that may be
reviewed by random analysis.
(3) Role
of Enforcement Services Staff.
The committee reviewed the NCAA enforcement process. It was noted that the NCAA enforcement
services staff will handle investigations if the committee concludes that an
institution is not in compliance with Bylaw 15.4.1 (consistent financial aid
package). This bylaw deals with
competitive equity issues, and violations of this bylaw are appropriately
handled by the enforcement services staff and the Committee on Infractions. It was further noted that an institution’s
failure to submit the annual report pursuant to Bylaw 15.4.1.1 (annual
electronic report) is a secondary violation and the enforcement services staff
would be limited in penalties (e.g., admonition letters, monetary fines).
d. 2005 NCAA Convention
Presentation. The committee is
scheduled to present at the 2005 Division III Business Session from noon to 1 p.m.
Monday, January 10, 2005. The committee determined that Dan
Preston will present the introduction and conclusion, Eric Hartung will present
the findings from the 2004 division-wide pilot and Travis Feezell will present
the financial aid reporting/review process.
e. Membership
Communication. The committee
directed staff to send a memorandum thanking the institutions that participated
in the division-wide pilot, and a separate memorandum to those institutions
that did not participate outlining educational opportunities regarding the
financial aid reporting process.
The committee further directed staff to send a memorandum to the entire
membership outlining the reporting/review process and 2004 division-wide pilot
findings.
f. Membership
Education. The committee agreed
to use funds to explore educational opportunities for the membership such as
enhancements to the committee’s home page on the NCAA Web site, a best
practices document that will be posted on the home page and continued
communications with the community of institutional researchers and financial
aid administrators.
Committee Chair: Phillip
Creighton, Pacific University
Staff Liaisons: Susan Peal,
Membership Services
Stephanie
Quigg, Membership Services
The National Collegiate Athletic
Association
December 9, 2004 SSP/SLQ:jcw
