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Aurora Institute

It’s a Crazy Hot Mess…or Everything You Need to Know about Financial Aid

CompetencyWorks Blog

Author(s): Chris Sturgis

Issue(s): Federal Policy, Modernize HEA

SpockThis is the second in a series of posts based what we learned at the Competency-Based Education Network’s (CBEN) CBExchange in October. Click here for the first post.

William Pena’s closing comments to his presentation on financial aid at the CBExchange  sponsored by CBEN, AACU, ACE, and Educause was “It’s a crazy, hot mess. And I love it.” It tells you a lot about what to expect if you are the financial aid administrator of an IHE developing a CBE program, doesn’t it!

William Pena is the Associate Vice President of CBE Financial Aid at Southern New Hampshire University. According to his bio, he has previously served in the Wisconsin State Technical College and University systems; including leading the University of Wisconsin’s financial aid initiatives relating to competency-based education, direct assessment programs, and the Department of Education’s 2014 Experimental Sites Initiatives.

In other words, he knows a lot about financial aid and competency-based education.

There is no way I can capture everything he shared with us. In fact, I think it would require us to Spock-it and do the Vulcan mind meld to learn everything Pena knows, especially since he himself told us there isn’t one place to find out everything you need to know about CBE and financial aid. So I’m going to draw as much as I can into this blog – to see if we can make it a little bit easier to get on top of this all-important issue.


Federal Student Aid (FSA) Handbook (2015-16): The most recent handbook has been updated to include some of the information released by the Department of Education relating to CBE programs. The handbook is helpful for the overview and definitions. Pena pointed out that you will will want to read the colleague letters, as many of the nuances found there have not been integrated into the handbook.

  • GEN-130-10 written March 19, 2013 regarding Applying for Title IV Eligibility for Direct Assessment (Competency-Based) Programs
  • GEN-14-23 written December 19, 2014 regarding CBE Programs Questions and Answers

Experimental Sites Initiative Website: Pena referred to this 77-page guide with just a bit of sarcasm, “as a really good read.” This website is important to read, as it provides more insight into the landscape and additional options for program development. Pena said that there are four things you need to get up to speed on regarding the Experimental Sites, including program participation agreement amendment process, satisfactory academic progress, intent to enroll, and regular and substantive interaction.

Milestones and Critical Topics

Pena walked us through his advice about how to prepare for addressing the financial aid issues that will arise in developing a CBE program:

In the Conceptual Phase

Early involvement of financial aid administrator will pay off in the long run:

  • Be sure to get financial aid involved as early as possible, even in listen-only mode. It will make a difference in the long run.
  • Your financial aid administrator may have to do extensive research and networking to build the knowledge for CBE in addition to other annual/cyclical financial aid regulatory changes. Make sure they understand and are recognized for this, as it can be a substantial investment of their time.
  • The earlier you begin communication with your financial aid administrator, the more time there is to assimilate and gain buy-in.

In the Development Phase

As early as you can, begin to identify and discuss the key issues, including:

  • Credential/degree level
  • Course-based CBE vs direct assessment
  • Curricular and instructional delivery (mode, pace, structure) including standard term, non-standard term, or no term. The no term structure is the most complicated
  • Credit-hour equivalency and the full-time definition
  • Academic progress, including satisfactory academic progress, academic standing, grading basis, repeats, incompletes, open-entry/open-exit, and grade level.
  • Recording and documenting student engagement (distance ed)
  • Open source vs required materials
  • Written arrangements with third party content or assessment providers and with other schools
  • Interruptions in enrollment (withdrawals, leave of absence)

Operational Planning

As you prepare for moving to operations, it becomes very important to involve all the parties that might have any role and to over-communicate so everyone knows the timelines:

  • Technical considerations including financial aid systems, manual workarounds, staffing impact, and impact on non-cbe program offerings and financial aid functions
  • Knowledge, experience skills, particularly for programs with a no term structures
  • Impact on non-FSA programs (institutional, state private, etc)
  • Admissions processes and timelines
  • Registration processes and timelines
  • Program launch timeline and the FSA award year

Approvals and Deployment

Pena highlighted that you need to receive approval from your accreditor before you solicit DOE approval. When applying for the Department of Education Title IV Approval for direct assessment programs, be prepared that it might take six to nine months.

I know just about each one of these bullets requires a post to better explain it. We are seeking people who have this kind of expertise to write blogs or be interviewed by us so that we can make it easier to understand this process.

And thanks to William Pena for a fantastic presentation and for CBEN for making it all possible!

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