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students participating in the programs than we had 1 year ago. So indeed, that program is working.

Likewise, our institutions have shown us that loan volumes and utilization rates in both SEOG and the college work-study program are directing these dollars to the students to which they were intended.

For this reason, we have submitted to you a series of recommendations which I would like to ask to have submitted into the record, and you will find that in these recommendations that we have three primary goals.

Our first goal is to provide a reasonable and continuing financial base for the existing grant and self-help programs to just assure current and future students that their goal of obtaining a postsecondary education will not be thwarted due to insufficient financial

resources.

In that regard, we have made recommendations that, No. 1, would provide annual step increases in basic grants. No. 2, we would increase slightly the threshold levels of the campus-based programs and add a threshold level for the SSIG program.

No. 3, we would address the award amounts in the various programs. No. 4, we would increase the authorization levels, and No. 5, we would establish a maintenance of effort level for State grant support to insure that there is not a cutback here in allowing the Federal-institutional-State partnership to erode.

Our second goal would be to provide more flexibility in the grant and self-help programs to adequately address the unique needs and circumstances that surround individual students. We would do this through several measures but among these would include, first, to increase the years of eligibility for students from the current 4-year limit up to the time that they have completed their baccalaureate degree or 5 years whichever is the least.

Second, we would eliminate all of the academic references that are contained in the various programs that cause differentiations and combine these into a single student eligibility section and use the definition that you enacted in the 1976 amendments dealing with satisfactory progress as determined by the institution as the primary criteria.

We would also include more flexibility in transferring funds between the various programs, particularly in the college workstudy program where it is very difficult for institutions to know exactly by year's end on an hourly basis how they are going to

come out.

And we have also suggested, as a fourth provision, that we would increase the loan limits in both the NDSL and guaranteed student loan programs, and we would also modify the asset protection level to provide more equity and to eliminate the problem that we currently find that we discussed at the family contribution schedules in regard to home equity. As you well know, with the inflation that is going on in regards to the current home equity, many of the students that we thought that we would assist that were in the middle-income families under MISAA are, in fact, today being denied because of the inflated paper money that is showing up under home equity. We feel an adjustment needs to be made in this reauthoriztion to alleviate that problem.

Our third goal would be to modify the administrative procedures which are burdensome and costly while still retaining the necessary safeguards to provide and insure program accountability and integrity.

We would do this first by eliminating the term "actual" in the cost of attendance. We would also eliminate the matching requirements on the SEOG which is really paperwork and is no longer necessary. We would eliminate the notarization requirement from the affidavit, retaining the affidavit but simply eliminating the requirement that students must go out and pay to have it notarized.

We would increase the administrative allowance, as has been pointed out earlier, to provide more support to the institutions to actually carry out the kind of mandates of validation and to eliminate fraud and abuse.

And last, but certainly not least, we would adopt reasonable language in the development of a single-need analysis in common form which will achieve the goals that we all want of simplification but at the same time maintaining the same kind of necessary discretion that institutions need to service the needs of students. And to that end, we have suggested some new language which you may well wish to consider in the event that you follow the direction that the House has gone in H.R. 5192.

At this point, Senator, I would like to conclude my remarks and just thank you for the opportunity of being here, and I would certainly offer our assistance as you go through the reauthorization, either to you or any other member of your subcommittee. [The prepared statement of Dr. Martin follows:]

TESTIMONY OF DALLAS Martin, EXECUTIVE DIRECTOR, NATIONAL ASSOCIATION OF STUDENT FINANCIAL AID ADMINISTRATORS

Mr. Chairman and Distinguished Members of the Subcommittee:

I am Dallas Martin, Executive Director of the National Association of Student Financial Aid Administrators, a non-profit association which represents over 1600 institutions of postsecondary education. It is indeed a pleasure to have the opportunity to appear before you today to discuss the Title IV student assistance programs and to present you with our thoughts on how these programs should be modified as you embark upon the difficult task of reauthorizing this important legislation.

During the past six months, our Association has carefully reviewed the existing legislation which governs these programs, and has compared this legislation with the actual operational and administrative practices which are involved at the campus, state, and regulatory levels. We have also reviewed actual cases in order to see how effectively individual students and parents are being served by the existing system. From this analysis, we have developed several legislative recommendations, which we sincerely hope will be incorporated into your final bill.

Most of our recommendations are designed to meet three specific

goals, which we believe are essential in order to insure that the programs continue to serve the needs of our citizens.

The first goal is to provide a reasonable and continuing financial base for the existing grant and self-help programs to assure current and future students that their goals of obtaining a postsecondary

education will not be thwarted due to insufficient financial resources.

To achieve this first goal, we recommend that all of the existing programs be extended through June 30, 1986. This will provide

program

stability and gives students an assurance that there will be a continuation

of these vital programs.

Experience has shown us that constant change and

modification only tends to confuse and frustrate students, parents, legislators,

counselors, and institutional personnel.

Further, we know that the

existing balance of grant, work and loan programs are meeting the needs While some modification is needed in the various programs,

of students.

we do not feel that radical modification is necessary at this time. Data on the programs will show that the fundamental purposes are being achieved. A good example of this was revealed last month when we reviewed the current Basic Grant statistics and compared them with the same figures of a year ago, prior to the passage of the Middle Income Student Assistance Act

(MISAA).

Overall, applications are already up by 400,000 compared to last year. However, the number of eligible students has increased by 900,000 students. Such data clearly illustrate that the purposes and legislative intent contained in MISAA is working. Likewise, the campus rates of utilization in the College Work-Study and SEOG program show that the MISAA expansion

is truly reaching the people it was designed to assist.

There are several other modifications, however, which we support in order to ahcieve this first goal. These include:

1.

2.

Provide annual step increases in the Basic Grant maximum award
to help parents and students keep pace with rising costs and the
effects of inflation. (Note: If such an approach is not adopted,
a substantial number of students will become ineligible from
year to year due to increases in their family incomes.)

Increase the threshold levels for the three campus-based programs
(SEOG, NDSL, and CWS) and establish a level for the SSIG program
which will insure that students will continue to have a proper
balance between grant and self-help funds in their aid packages.
As you know, the threshold levels were initially established in
1972. The decision by the Congress to enact this section has
proven to be a very wise decision in spite of attempts by
various Administrations to eliminate or ignore these provisions.
If institutions are to be able to provide equitable aid packages

to needy students, the continuance of threshold levels is essential.

TESTIMONY OF DALLAS MARTIN, EXECUTIVE DIRECTOR, National ASSOCIATION OF STUDENT FINANCIAL AID ADMINISTRATORS

Mr. Chairman and Distinguished Members of the Subcommittee:

I am Dallas Martin, Executive Director of the National Association of Student Financial Aid Administrators, a non-profit association which represents over 1600 institutions of postsecondary education. It is indeed a pleasure to have the opportunity to appear before you today to discuss the Title IV student assistance programs and to present you with our thoughts on how these programs should be modified as you embark upon the difficult task of reauthorizing this important legislation.

During the past six months, our Association has carefully reviewed the existing legislation which governs these programs, and has compared this legislation with the actual operational and administrative practices which are involved at the campus, state, and regulatory levels. We have also reviewed actual cases in order to see how effectively individual students and parents are being served by the existing system. From this analysis, we have developed several legislative recommendations, which we sincerely hope will be incorporated into your final bill.

Most of our recommendations are designed to meet three specific

goals, which we believe are essential in order to insure that the programs

continue to serve the needs of our citizens.

The first goal is to provide a reasonable and continuing financial base for the existing grant and self-help programs to assure current and future students that their goals of obtaining a postsecondary education will not be thwarted due to insufficient financial resources.

To achieve this first goal, we recommend that all of the existing programs be extended through June 30, 1986. This will provide program stability and gives students an assurance that there will be a continuation

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