1. 1

2. NCAA Division III Financial Aid Reporting Program and Self-Assessment 2012

3. Overview Introduction Legislation The Reporting Program Conducting a Self-Assessment 3

4. Session Goals Gain a greater understanding of the financial aid reporting process and the philosophical tenets as well as the legislative structure supporting this process. Provide a method of conducting an audit on your campus to ensure adherence to these philosophical tenets and legislative requirements Start a dialogue between members schools and the national office to facilitate greater understanding, compliance, and effectiveness of the reporting process. 4

5. Legislation

6. A member institution shall not award financial aid to any student on the basis of athletics leadership, ability participation or performance. NCAA Division III Philosophy Statement 6

7. Bylaw 15.4.1 – (a) Consistent Financial Aid Package: Must be consistent with the institution’s policy for all students and satisfy four criteria: 1.Shall not consider athletics leadership, participation or performance. NCAA Bylaw 15.4.1-(a) 7

8. Bylaw 15.4.1 - (a): Example Men’s Basketball Alumni Award Description: $2,000 financial aid award for a promising Freshman member of the varsity men’s basketball team. Issue: Athletics participation is a criterion for the award. 8

9. Bylaw 15.4.1 - (a): Example Activities Grant Description: $1,000 grant for any incoming Freshman who participated in at least three extra-curricular activities in high school. Valid activities include, but are not limited to, student government, music, athletics, community outreach, and art. Issue: Athletics participation is potentially considered for the grant. 9

10. Bylaw 15.4.1 - (a): Example Admissions Rating Formula Description: An admissions rating formula includes the following elements: academic ability, extra-curricular activity involvement, essay, interview, desirability to attend. Participation in high school athletics is a valid extra- curricular activity among other activities. The calculated admissions rating is then used to place the student in a financial aid awarding matrix which would determine the amount of institutional gift aid awarded. Issue: Athletics participation is considered in the admissions rating which is then used to determine the amount of institutional gift aid the incoming student may receive. 10

11. Bylaw 15.4.1 – (b) Consistent Financial Aid Package: 2. The financial aid procedures used for student- athletes are the same as the existing official financial aid policies of the institution. Bylaw 15.4.1-(b) 11

12. Assessment of Non-Need-Based Institutional Gift Aid Complete audit of awards – Merit, leadership and other scholarships – Criteria – Procedures – Rating forms – Marketing materials Bylaw Connections: 15.4.1(a), 15.4.1(b), 15.4.5, 15.4.6 12

13. Assessment of Non-Need-Based Institutional Gift Aid Application process. Personnel determining award recipients. Role of financial aid office, admissions, scholarship committees, school foundations. Bylaw Connections: 15.4.1(a), 15.4.1(b), 15.4.5, 15.4.6 13

14. Assessment of Non-Need-Based Institutional Gift Aid Key Questions – Is participation or ability in high school or college athletics, or team captain included as a criterion or consideration in published financial aid materials? – Is participation or ability in high school or college athletics, or team captain considered in the award decision? Bylaw Connections: 15.4.1(a), 15.4.1(b), 15.4.5, 15.4.6 14

15. Bylaw 15.4.1 – (c) Consistent Financial Aid Package: 3. The financial aid package for a particular student- athlete cannot be clearly distinguishable from the general pattern of all financial aid for all recipients at the institution. Bylaw 15.4.1-(c) 15

16. Assessing 15.4.1 – (c) Distinguishable Pattern of Awarding 16 Recipients of an Award of Circumstance Year of Initial Enrollment Total Awardees Athletes n% 09-10232087 08-0911982 07-0844100

17. Assessing 15.4.1 – (c) Layering of information. – What are the policies and procedures behind the pattern? Is there a particular award behind the pattern? Is athletics considered explicitly or implicitly? – Is the pattern concentrated in a particular sport or sports or among a defined group of student-athletes? – Is there a significant dollar amount advantage for the group of student-athletes over other student-athletes and/or other students? 17

18. Bylaw 15.4.1 – (d) Consistent Financial Aid Package: 4. The percentage of the total dollar value of institutionally administered grants awarded to student-athletes shall be closely equivalent to the percentage of student-athletes within the student body. Bylaw 15.4.1-(d) 18

19. Assessing 15.1.4 - (d) Proportionality Difference 19 Total Students Total Student- Athletes Proportion Student- Athletes Total Institutional Gift Aid Total Institutional Gift Aid for Student- Athletes Proportion Institutional Gift Aid for Student- AthletesDifference 949919.59%$1,660,859$269,97816.26%6.67%

20. Assessing 15.4.1 – (d) Layering of information. – What are the policies and procedures behind the difference? Is there a particular award behind the difference? Is athletics considered explicitly or implicitly? – Is the difference concentrated in a particular sport or sports or among a defined group of student-athletes? – Is there a significant dollar amount advantage for the group of student-athletes over other student-athletes and/or other students? 20

21. 15.4.1 Assessment Review 1.Substantive. Is the policy free of athletics consideration? Is the process the same for all students? 2.Impact. Does the policy advantage student-athletes? 21

22. Bylaw 15.4.5 Athletics Involvement: Athletics department personnel should not influence directly or indirectly, a student-athlete’s financial aid package. Official Interpretation 8/2/89 22

23. Bylaw 15.4.5 Athletics Department staff members are prohibited from: Arranging or modifying the financial aid package for students-athletes; Serving on member institution’s financial aid committees; Being involved in a review of a student-athlete’s financial aid package; and Sending a list of PSAs to the financial aid office. Bylaw 15.4.5. Official Interpretation 9/19/05 23

24. Bylaw 15.4.5: Example Student-Athlete List #1 Description: Each recruiting cycle, the coach generates a list of prospective student-athletes that is submitted to the admissions office. The list is prioritized with the most desirable prospects at the top of the list and used by admissions in making admissions determinations. The same list is then submitted to the financial aid office where it is used, in part, to determine financial aid awards. Issue: The list of prospective student-athletes submitted by the coach to admissions is used to potentially arrange or modify the financial aid package for student-athletes. 24

25. Bylaw 15.4.5: Example Student-Athlete List #2 Description: Each recruiting cycle, the coach generates a list of prospective student-athletes that is submitted to the financial aid office. The list is reviewed by the financial aid office to determine the status of required financial aid application documents. The status is then shared with the coach who works with the prospective student to ensure all required financial aid documents have been submitted. Issue: The list described here is for administrative purposes as opposed to being used to potentially arrange or modify the financial aid package for student-athletes. 25

26. Financial Aid Reporting Process

27. Annual Reporting Process Division III member institutions are required to participate in the reporting process each academic year. Allows for the comparison of financial aid packages of freshmen and transfer student-athletes with the aid packages of other freshmen and transfers with similar financial need. Division III Financial Aid Committee is oversight group. NCAA staff does not disclose the identity of any school in the review process to the public or the committee. 27

28. Level I Review Committee will review an institution if: Variance estimate is above 4%. Difference in proportion of financial need met by institutional gift aid is a statistical outlier. Proportionality Test result is a statistical outlier. Sport-level outliers. Previous conditional review outcome or referral to NCAA enforcement by the committee. 28

29. Level I Review Outcome The Financial Aid Committee’s Level I review will result in one of three outcomes: 1.No action. 2.No action but a conditional review in the next cycle. 3.Move institution to a Level II review. 29

30. Level II Review Outcome Institution’s opportunity to explain their financial aid report. The Financial Aid Committee’s Level II review will result in one of three outcomes: 1.No further action. 2.No further action but a conditional review in the next cycle; or 3. Forward to NCAA enforcement for institutional noncompliance with Division III financial aid legislation. 30

31. Enforcement Referral FAC will forward institution’s case with recommendations for appropriate penalties to enforcement. Enforcement staff may process the referral as a secondary violation or conduct an additional investigation, as necessary. 31

32. Self-Assessment

33. Summary Compilation and presentation of the institution’s policies and procedures for administering student financial aid. Involve all key personnel on campus when compiling the responses. The Division III Financial Aid Committee and NCAA staff are available for assistance. The two-part test: – Consideration of athletics in policies and procedures. – Impact of those policies and procedures. 33

34. Resources Policies and Procedures Worksheet School Profile Report Review History and Trend Report Financial Aid Reporting Program Users Guide Division III Bylaw 15 Athletics Director Conference Commissioner NCAA Staff Division III Financial Aid Committee 34

35. Checklist Self-Assessment model in place. Holistic approach – key constituents involved. The Two-Part Test is employed: – Policies and Procedures – Impact Ongoing monitoring system. Use of available resources. 35

36. 36