Higher One Disbursement Services. Multiple Financial Aid Disbursements to Increase Student Success and Reduce Fraud

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1 Higher One Disbursement Services Multiple Financial Aid Disbursements to Increase Student Success and Reduce Fraud White Paper March 2014

2 Summary Several institutions are testing the idea of disbursing financial aid in more than one installment instead of in a single lump sum, and preliminary reports are promising. Mt. San Antonio College in California, for example, is participating in the Aid Like a Paycheck pilot launched by the MDRC and Institute for College Access and Success. In part based on this experience, the college has implemented a new, three-installment disbursement schedule for all of its financial aid recipients. Charter Oak State College in Connecticut, a mainly online college, and Harrisburg Area Community College in Pennsylvania also instituted a multiple disbursement schedule as a means to avoid potential financial aid fraud and reduce bad debt. While implementation of a multiple disbursement strategy has been relatively straightforward, the colleges identified a few administrative challenges to overcome, including: Modifying existing administrative processes and systems; rolling out on a larger scale would require more automated solutions to reduce manual processing Developing policies and more automated systems to track and demonstrate student enrollment and engagement Ensuring changes are effectively communicated to students, faculty and staff Understanding data and data collection requirements at the outset to be able to answer research questions and/or evaluate program success later on Another option worth exploring is whether the same goals could be accomplished after refunds are disbursed to student accounts, although this may require regulatory changes as current rules have strict timelines on when students must receive their financial aid refund money. Providing an option to allow students to automatically budget their funds availability could help students manage their refunds more effectively. Providers of higher education management and financial payment systems may be looked to for assistance in: Developing software solutions to gauge and report active engagement Offering integrated money management, financial literacy tools, and mobile solutions to make it easier for students to manage their money and increase their prospects of success Enhancing data analytic capabilities to allow colleges and universities to easily assess the outcomes of the program Sponsoring opportunities for sharing best practices and dialogue on improving financial aid delivery and outcomes 2

3 Report Using financial aid as a lever to improve student success is gaining momentum. One concept being put to the test is the idea of multiple disbursements of financial aid, sometimes referred to as incremental aid. Under this strategy, Pell grants and/or other financial aid funds are disbursed gradually over a semester or term instead of in a lump sum. Financial concerns are increasingly becoming a major factor in student persistence and retention. As a 2009 Public Agenda survey Multiple disbursements of aid may found, the number one reason students reported for leaving school mitigate some of this stress by without completing their degree or program was financial. They providing students with a reliable had to make more money to cover the costs of their education, and source of financial aid over the the stress of trying to balance both school and work had become course of the semester or term. too overwhelming. 1 Multiple disbursements of aid may mitigate Disbursing aid gradually also some of this stress by providing students with a reliable source of may provide further incentive for financial aid over the course of the semester or term. Disbursing students to stay enrolled in order to aid gradually also may provide further incentive for students to receive their full financial aid award. stay enrolled in order to receive their full financial aid award. In addition, if student loan funds are received more gradually, students might realize later in the semester that they do not require all the loan money they originally accepted and could return some of those funds. This holds the potential of decreasing overall loan debt down the road. The most widely known project testing this concept is Aid Like a Paycheck which was launched in 2009 by the MDRC and The Institute for College Access and Success. The project was piloted at Mt. San Antonio College (Mt. SAC) in California and Triton College in Illinois; two community colleges with relatively low tuition and at which lower-income students typically receive large financial aid refunds. In this experiment, a small group of students received their residual aid every two weeks as a way to help them better manage their money and progress academically. Mt. SAC, for example, saw this project has an opportunity to test a new, innovative approach that would be beneficial to their students by helping them to learn to budget and manage their funds throughout the semester. In its recently released policy brief, the MDRC expressed optimism that the project holds promise for helping students maintain enrollment as an incentive for receiving their full aid package. This, in turn, may reduce the likelihood that students leave college before completing the term and having to pay all or part of this money back. One of the primary questions the pilot sought to answer is whether such a system could be implemented successfully at a college. It appears that the pilot has verified that this is the case; at least on the small scale level. Administrative reaction also has been positive and students who participated in the pilot indicated that the program helped them spend their money more effectively and allowed them to focus more on their studies. 3

4 Implementation on this small scale appears to have been relatively straightforward, with pilot schools adjusting their existing disbursement systems to accommodate the changes. Some of these process modifications were accomplished through partial automation and some through manual processing, and required additional staff hours to ensure the project moved along according to schedule. Rolling this out on a much larger scale would require more permanent modification of systems to overcome these challenges and minimize the burden on financial aid, student accounts and other line staff. As the pilot project was part of a research effort into the efficacy of a different disbursement system, there were a few minor issues that had to be addressed. For example, Mt. SAC indicated that it would have benefited from knowing upfront what kinds of data would be required to answer the research questions posed by MDRC. As such, there were several modifications to existing systems that had to be made along the way; changes that took time to develop and implement. For example, during the latter stages of the pilot, the college was asked for actual disbursement dates and refund amounts, along with GPA information. Financial aid staff at the college was able to facilitate this request by working diligently with the Bursar and IT departments. As a funded research pilot site, these types of questions may not have been anticipated in the early stages of the project, but certainly should be given more consideration in any plans to expand on a broader scale with more institutions. In addition, as with any major change in policy and procedure, it is important to communicate effectively and build coalition support among students, faculty and staff about the program goals, benefits and requirements. From a regulatory standpoint, multiple disbursements align with current Department of Education (ED) rules and regulations which allow colleges to pay a student at such times and in such installments as it determines will best meet the student s needs. In part based on its experience with Aid Like a Paycheck, Mt. SAC has since changed its policies to implement a new disbursement schedule for all financial aid recipients. The new schedule issues disbursements in three installments: first disbursement, 10 days before start of the term (20%); second disbursement, at census date/freeze (40%); and third disbursement at 50 percent of term (40%). With the goals of helping students better manage their money and reducing overpayments/return of funds, the school was anticipating some initial push back from students, but that has not been the case. The new process was wellcommunicated through the student portal and in award notifications that included the disbursement dates and amounts. Staff and student response to the new approach has been very positive. In addition, it is showing some encouraging results, such as fewer requests for emergency loans. The new schedule for all financial aid recipients issues disbursements in three installments 20 % 40 % 40 % FIRST DISBURSEMENT SECOND DISBURSEMENT THIRD DISBURSEMENT 10 days before the start of the term at census / freeze date at 50% of term 4

5 Multiple disbursements also have been heralded as a means to increase efficiency, prevent fraud and reduce waste in the federal financial aid system. In 2011, the ED issued a Dear Colleague letter concerning fraud prevention in distance education programs (DCL Gen-11-17). The letter included recommendations to modify disbursement rules for students participating exclusively in distance learning courses and programs, including making more frequent disbursements of Title IV funds so that not all of the payment period s award is disbursed at the beginning of the period. Acting on this guidance, Charter Oak State College in Connecticut modified its disbursement policies effective in the spring Although its experience with fraud was low, the online college wanted to proactively adopt some of these recommendations. Many students were spending their refund dollars upfront, leaving no funds for later on to add a module or another course, and counseling of students to hold on to their refunds had not always been effective. At Charter Oak State College, many students were spending their refund dollars upfront, leaving no funds for later on to add a module or another course, and counseling of students to hold on to their refunds had not always been effective. The college developed a new policy, inclusive of full semester and modules courses, and implemented two disbursements instead of one for the payment period. The first disbursement is credited against all tuition and fee charges first, so the amount of the first refund (if any) for most students tends to be small. While there was some initial concern that this may present a hardship for students, the college reports that the results have been positive. The school has seen a decrease in the number of accounts sent to collections and a decrease in outstanding receivables as result of these changes. One of the other issues for this online college was developing policies and systems so that students in essence earn their financial aid awards, as ED rules specify that simple tracking of student logins alone is not enough. These policies spell out what students have to do to effectively demonstrate that they are enrolled/actively engaged. This may include things such as submitting an assignment, completing a computer-assisted module, and participation in threaded discussions. Such tracking has created some administrative pain points, particularly since it has been largely a manual process (e.g. using a large spreadsheet), and must involve faculty as well as financial aid staff to implement properly. The college indicated a desire for a software solution that would allow faculty to easily document last time of attendance for return of Title IV funds (R2T4) calculation purposes, and that would integrate that information with its student information system. This also would be beneficial in identifying at-risk students and other retention efforts. At Harrisburg Area Community College in Pennsylvania, the major impetus for moving to a multiple disbursement policy was the rise of bad debt levels. This was a result of trying to get money back from students who stopped attending before completing the required 60 percent of the term. Disbursements at the college are now made two times per term. Some students may not receive any refund in first disbursement after tuition and required fees are deducted, but they are permitted to charge against their remaining balance in the bookstore to obtain required books and educational materials at the start of the semester. Administrator comments were similar to those heard at Charter Oak State: having to determine engagement and actual enrollment status during the term has presented some administrative challenges. 5

6 Disbursing financial aid in more than one installment is indeed showing some initial promise, but another idea worth exploring is whether the same money management goals could be accomplished after financial aid is disbursed to the student s account. Although current ED regulations have strict timelines on when students must receive their refund money once credited to their accounts, a school is to permitted to hold credit balances if it obtains voluntary authorization from the student (or parent, in the case of PLUS loans) upfront. 2 Perhaps students could voluntarily agree to have their refunds disbursed on a regular schedule throughout the semester. This would avoid multiple drawdowns and perhaps other administrative steps for the school, but would necessitate additional accounting and cash management requirements if not already in place. A variation on this theme for schools that may utilize third-party refund disbursements services would be to explore the feasibility of adding a voluntary opt-in feature that would allow students to choose to have their funds made available on a regular schedule throughout the semester instead of all at once. This certainly would help ease the administrative burden for the school, and might empower students to take a more proactive role in managing their money. In either case, providing an option to allow students to automatically budget their credit balance availability could help students learn to budget their refunds more effectively to last the full term. It also might help ensure that students have sufficient funds available to return to the school in the unfortunate event that they not complete the required 60 percent of the term. In summary, incremental disbursements is an idea that would benefit from testing on a broader scale. Providers of higher education management and financial payment systems may be looked to for assistance by developing software and other solutions that minimize administrative burdens for financial aid, student accounts and other line staff. This assistance may also include: Developing solutions, particularly for schools with large online course offerings, to appropriately gauge and report active student engagement Offering integrated money management, financial literacy tools, and mobile solutions to make it easier for students to manage their money and increase their prospects of success Enhancing data analytic capabilities to allow colleges and universities to easily assess the outcomes of the program Sponsoring opportunities for sharing best practices and dialogue on improving financial aid delivery and outcomes 1. Public Agenda. With Their Whole Lives Ahead of Them U.S. Department of Education Federal Student Aid Handbook: Volume 4 Processing Aid and Managing FSA Funds. Washington, D.C: U.S. Department of Education. 6

7 Initial Reactions from the Financial Aid Community A draft of this white paper was presented at the Southern Association of Financial Aid Administrators at their annual conference in February Session attendees participated in a focus group-like discussion about the merits and potential drawbacks for implementing a multiple disbursements policy on a broader and/or institutional scale. All of the participants agreed that the concept of providing multiple disbursements was good idea and worth testing further. Among the advantages for students, 90 percent of the participants thought it would help them budget their money more effectively, and 80 percent saw merit in the concept of students having to earn their financial aid. Somewhat surprisingly, 70 percent did not agree that it would reduce stress for students or decrease the request for emergency loans. This may be explained by the number one disadvantage perceived for students the potential for no refund in the first disbursement. Participants felt that this could potentially increase stress for students and may lead to an increase in the need for emergency loans at the beginning of the term. One participant suggested that perhaps tuition and fees could be billed in two installments to ensure that students received at least some refunds in the first disbursement. The other drawback was the concern that the changes would be very confusing for students. Ensuring a good communication plan is in place before and during implementation was seen as very important. From an institutional perspective, a large majority of the participants (80%) thought this change would have a positive impact on student success and retention, and 80 percent felt it would help reduce fraud. The group was split, however, on whether this would result in a reduction in accounts receivable (funds due back to the institution when a student withdraws). Almost all of the participants indicated that administrative/it changes and more staff hours would be required to implement on a large scale. However, only a few indicated that the actual process of drawing down funds multiple times would be too costly a deterrent, as they already do multiple disbursements for a variety of reasons and programs. In terms of resources required, the highest priority item was a robust communication plan and media strategy, followed by technical support and additional staff. About 70 percent of the participants agree that there was merit in considering the option of holding credit balances and having vendors providing opportunities for students to choose to have their refunds distributed in multiple stages. Lastly, when asked about how to evaluate whether changing to a multiple disbursements policy is making a difference, participants suggested tracking the change in the number of withdrawals, retention and graduation rates, changes in amount of bad debt, and the amount of funds returned at end of the term or semester. 7

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