"Jim Shane, Michael Dunn, Wild Wild West 1968"

CBS Television. Licensed under Public Domain via Wikimedia Commons

Urban KASFAA April 8 – 10, 2015

You Can Tell a True Cowboy by the Type of Horse He Rides...

with Blake Cauble-Johnson & Benjamin Howard-WilliamsUniversity of Kansas Financial Aid & Scholarships

ETHICS BEST PRACTICES

KASFAA Spring 2015 - Ethics Best Practices 2

Statement of Ethical Principles

• Aspirational – guiding policies and behaviors.

Code of Conduct

• Prescriptive – enforceable basic expectations.• Enforcement Procedures Effective July 1, 2015

“Exploring Ethics”

• Regular series of ethics scenarios & conversations.

KASFAA Spring 2015 - Ethics Best Practices 3

Purpose: “Ethical principles are personal and organizational standards of behavior expected of professionals who exercise specialized knowledge and skill…This expertise comes with responsibility—a set of ethics that should govern the decisions and actions of all financial aid professionals.” (nasfaa.org – Ethics Q&A)

KASFAA Spring 2015 - Ethics Best Practices 4

Statement of Ethical Principles

• Advocate for students.

• Manifest the highest level of integrity.

• Support student access and success.

• Comply with federal and state laws.

• Strive for transparency and clarity.

• Protect the privacy of financial aid applicants.

KASFAA Spring 2015 - Ethics Best Practices 5

Code of Conduct – Personal Gain/Conflicts of Interest

Item 1: No action will be taken by financial aid staff that is for their personal benefit or could be perceived to be a conflict of interest.

Item 2: Information provided by the financial aid office is accurate, unbiased, and does not reflect preference arising from actual or potential personal gain.

Item 5: Financial aid professionals will disclose to their institution any involvement, interest in, or potential conflict of interest with any entity with which the institution has a business relationship.

KASFAA Spring 2015 - Ethics Best Practices 6

Code of Conduct – Providing Information

Item 3: Institutional award notifications and/or other initially provided materials shall include the following:

1. A breakdown of individual components of the institution's Cost of Attendance, designating all potential billable charges.

2. Clear identification of each award, indicating type of aid, i.e. gift aid (grant, scholarship), work, or loan.

3. Standard terminology and definitions, using NASFAA's glossary of award letter terms.4. Renewal requirements for each award.

Item 4: All required Consumer information is displayed in a prominent location on the institutional web site(s) and in printed materials, easily identified and found, and labeled as “Consumer information.”

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Code of Conduct – Enforcement Provisions

Finding of Violation OR Dismissed

NASFAA Complaint Evaluation 1) Code Violation? 2) Frivolous/Inconsequential? 3) Jurisdiction?

Ethics Commission Investigation*

Ethics Commission Hearing

Appeal Hearing

SANCTIONS“Marshall Kent, Ben Gage, Maverick 1958" ABC Television. Licensed under Public Domain via Wikimedia Commons

KASFAA Spring 2015 - Ethics Best Practices 8

Code of Conduct – Enforcement Provisions

*Confidentiality: “…the commission reserves the right to keep the Complainant’s identity confidential throughout the entire process, including the hearing process (if one is commenced), upon a clear showing of risk to the complainant if the Complainant’s identity were revealed to the Respondent.” NASFAA Code of Conduct Enforcement Procedures Step II, Section C, Part 1, Subpart b.

Sanctions:I. Statement of Concern

I. Private letter to respondent.

II. Statement of ReprimandI. Private letter to respondent.II. May require corrective action.

III. Temporary Suspension – PublicI. Posted on NASFAA website.II. May require corrective action.

IV. “Permanent” Suspension – PublicI. Posted on NASFAA website.II. Can apply for re-admission after 5 years.

Image by Gary Denham via Flickr Used under a Creative Commons License

KASFAA Spring 2015 - Ethics Best Practices 9

"John Wayne, Marsha Hunt, Born to the West 1937"

Public Domain

Whatta ya gonna do, pilgrim?

ETHICS SCENARIOS

KASFAA Spring 2015 - Ethics Best Practices 10Based on NASFAA’s “Exploring Ethics” Series – 12.17.14 Issue + NPR Story: “College Rape Case Shows A Key Limit to Medical Privacy Law”

Sharing Student Data / Information:Use of the Student Record against the student.

• Student has filed a lawsuit against the university, alleging mishandling of a sexual assault perpetrated by another student. After the assault, Student withdrew from classes. In order to receive financial aid, Student must submit a SAP appeal. Student references the assault in the appeal narrative and includes medical records from a therapist as support documentation. The inclusion of medical records in the SAP appeal packet will destroy the privilege between the student and the therapist.

What do we say to the student / family?What do we say to our administration?

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Debt Conversations: Student’s dream is to attend USA Univ. COA: $25,000/year.

• Average academics, minimal scholarship of $1,000/yr• AGI: $62,000, EFC: 4323, Pell Eligibility $1,425• Gap: $15,075 to $17,075 (depending upon year)• Potential Student Debt upon graduation: $27,000• Potential Parent Debt upon graduation: $63,300• Family of 4, younger sibling to start college in 2 years.

What do we say to this student / family?

Based on NASFAA’s “Exploring Ethics” Series – 03.16.15 Issue

KASFAA Spring 2015 - Ethics Best Practices 12Based on NASFAA’s “Exploring Ethics” Series – 10.29.14 Issue

Award Letter Transparency: Current letter includes Grants, Scholarships, Loans & Work Study

• Student at USA University - $25,000 COA, $2,425 in gift aid• Award letter showed an out of pocket cost of $0• $5,500 Fed Direct Loans – Accepted Max• $4,500 in Federal Work Study – Didn’t get a job 1st semester• $12,575 Parent PLUS Loan – Parents denied, took $4,000 add’l unsub• Nov 1 - $6,585.50 balance past-due, can’t enroll for spring.

What do we say to this student / family?What do we say to our administration?

KASFAA Spring 2015 - Ethics Best Practices 13

Ya’ll wanna take this outside? CONTINUING THE CONVERSATION

Inside the Yellow Aster Saloon, Randsburg, California, ca.1900Public Domain

bit.ly/KASFAA-Sp15-Ethics

Interested in a KASFAA Ethics Commission? Discussing ethics issues via a new listserv? Have other ideas to share?