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thoughtful attention and analysis. It would be more cumbersome, but perhaps it also would be more precise to suggest that we begin to think theoretically and analytically of universities as "large, complex, highly decentralized organizations of academic and administrative professionals". It is the professional autonomy of expert administrators which shapes so many of the university's internal policies, and many of the policies of the national higher education associations. Left on their own, with inadequate program guidance from federal program officers — and there seems to be general agreement on that point — and with little or no overarching institutional policy to guide them, many, perhaps most student aid directors necessarily have formulated their own formal or informal policy to administer the program. This is not objectionable. It is unavoidable. The student aid profession and the major institutional associations have long defended institutional and professional discretion to the Congress.

But there does seem to be, in many of the nation's leading universities, an unusual, and perhaps imprudent informality in the policy structure. The report of the Association of Graduate Schools described the situation this way:

"Given that support for graduate students springs from so many different rationales, serves so many different functions, and is distributed within universities with so little coherent policy, it is not surprising that on occasion the fundamental purpose of it all gets lost. The cumulative effect of these diverse practices is in many universities a non-system of student support that can be justified only on the grounds that it exists."

In these days of heightened sensitivity to the need to be accountable for public funds and to consumer interests, one wonders how well current university policies and practices would fare if they were subjected to scrutiny of Congressional committees or the Government Accounting Office. Additional legislation or regulations governing the administration of the Work-Study or other aid programs are not, or should not, be necessary. But, if institutions do not pay more careful attention to these policies and their implications, they may invite a Congressional reassessment of the concept of professional discretion and institutionally based program administration.

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The AAU Graduate deans have offered a reasonable suggestion:

"Our general judgment is that every university should keep a careful eye on its student support policies, and that a strong case can be made for exploring in detail the relevance of financial need to every form of aid. We recommend that all universities put together a financial aid package that is consistent with the kinds of support available, and with the student's financial need and personal circumstances as well as their scholastic ability and career goals. Under such an arrangement the extent to which need affects the amount and kind of financial aid will continue to vary widely from field to field and university to university. This is not objectionable. What matters is that financial aid decisions be based on reasonable criteria consistently applied within each institution;

All in all graduate support policies would be more logical, equitable and economical if there were a greater degree of institutional awareness, and prompt attention to correct anomalies. This requires a central mechanism

VOL. 7. NO. 3, NOVEMBER, 1977

with university wide authority to review current practice, consider the underlying issues, and make generally binding decisions. The capacity of some institutions to define and administer student support policies is weak.” Such strong university-wide mechanisms are necessary if a sense of order is to be imposed on university aid policies and programs. Otherwise the programs will continue to be vulnerable to attack by students, particularly graduate and professional students, and perhaps by the Congress.

This leads to a concluding point: If Congress were now to debate whether to make graduate and professional students eligible for the Work-Study program, I expect there might very well be a different outcome. Interviews with several key House and Senate committee staff members left the unmistakable impression that, if given the opportunity, some now would flatly oppose the award of Work-Study funds to graduate and professional students. Others would be cautious at best. A key House committee staffer summed it up.

"Graduate education has just not been a matter of concern over the last six to seven years. The members are not aware of graduate and professional education. Congressional attitudes are conditioned by what they hear in their districts and they don't hear much from graduate students. They, therefore, don't sense a great crying need out there for more funds, including Work-Study funds, for graduate students. If Work-Study funds shifted out of some states to others with greater graduate student enrollments, or if it were claimed that undergraduate needs weren't being met, a political issue would arise. Proceed cautiously."

Another staff member said graduate education is frequently described by members and staff as “removed, esoteric, foolish and unimportant.” It is, in his opinion, particularly subject to harsh attacks on the House and Senate floors. Therefore, if given the opportunity he would advocate Work-Study aid for graduate and professional students only in selected and highly focused manpower shortage areas.

Not all staffers, however, held that view. One influential staffer said: "I would be interested to know if universities with unmet graduate need are returning Work-Study unspent. If so, we should kick some butts."

Political support for Work-Study as a graduate and professional aid program has been diminished by the generally unfavorable Congressional mood regarding Federal support for graduate students. But, as one staff member pointed out. "Legislatively, Work-Study for graduate students is a dead issue. The law is written to allow institutions to do it and they may do so - provided others don't begin to complain that poor kids are losing Work-Study funds to rich graduate students."

The task ahead for universities is to inform their Congressmen and Senators, and particularly those members of the authorizing and appropriations committees, of the continuing value of Work-Study for undergraduates and of the grow ing need and potential among graduate and professional students. It is a story which remains to be told effectively to the Congress. Most members of Con

THE JOURNAL OF STUDENT FINANCIAL AID

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gress have been elected since Work-Study was established. Over half the members of Congress have been there six years or less. Few know the program's his tory. The only members to hear direct testimony on the graduate and profes sional aspects of the program, Congressmen O'Hara and Dellenback, have left the Congress. If Congressional champions are not found, the graduate and professional dimensions of Work-Study could be endangered precisely at the time of their greatest promise.

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VOL. 7, NO. 3, NOVEMBER, 1977

ATTACHMENT B

Association of American Universities

Office of Federal Relations

June 2, 1978

The Honorable Ernest L. Boyer

Commissioner of Education

Office of Education

400 Maryland Avenue, S.W.

FOB-6, Room 4181-D

Washington, D.C. 20202

Dear Dr. Boyer:

Final regulations for the Federal College Work-Study program, we understand, are now being processed by your staff. We are writing to ask that the regulations be amended to permit universities the option of compensating graduate and professional students on a salary basis. Current regulations require that students aided with work-study funds be paid hourly wages. Time cards, or comparable record-keeping and reporting mechanisms, must be used by students and work reports must be certified by their supervisors.

Undergraduate students typically hold work-study jobs in libraries and food service departments where hourly wage reporting is reasonable and appropriate. For them current regulations and time-keeping systems are entirely satisfactory. Many graduate and professional school students, however, are employed as junior professionals; they often are colleagues to faculty and serve as teaching and research assistants. For many of these students and their faculty supervisors, hourly time reporting is an impediment to the use of the work-study program. The requirements are burdensome and impractical and they are generally held to be inappropriate for junior professionals serving in academic positions. In these cases, the use of the work-study program would be eased if universities, within the limits of proper supervision and accountability, had the option to compensate graduate and professional students, where appropriate, on a salary basis.

To take account of the special circumstances posed by graduate and professional students we suggest the deletion of the word "salary" in the second section of 175.19(a) and the addition of the following new sentence:

"Work by graduate and professional students which is otherwise
eligible employment is not made ineligible solely because com-
pensation is on a salary basis."

The Honorable Ernest L. Boyer
Page Two

June 2, 1978

The associations listed below join in this letter and urge that the final regulations be modified to incorporate this change.

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American Association of State Colleges and Universities

American Council on Education

Council of Graduate Schools in the United States

National Association of State Universities and Land-Grant Colleges

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