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Advocacy and Action


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Amid a number of new regulatory shifts, NACUBO has enhanced its advocacy member offerings to include new, detailed slide decks that will help business officers communicate about college access, why college costs what it does, and the value of higher education to internal and external campus audiences.

Free Infographics on Advocacy Challenges, Opportunities

“I want to recruit you to be advocates for higher education. NACUBO is asking you to use your stories and your data, from across your enterprise, to demonstrate how you’re meeting, and likely exceeding, the value proposition that your college or university offers students, communities, states, and the nation,” said Susan Whealler Johnston, NACUBO president and CEO, at the 2019 annual meeting.

Johnston’s call for engagement came soon after NACUBO released three new slide decks to accompany its 2019 Perceptions and Priorities statement. The three decks, totaling more than 50 PowerPoint slides, are focused on three separate concerns highlighted in the statement:

  • Household income is not keeping pace with the cost of college access.
  • Providing quality higher education requires significant investment.
  • Higher education provides a lifetime of value.

“I was grateful to share a different narrative with the assistance of NACUBO’s resources,” said NACUBO’s immediate past board chair, Lynne Schaefer, vice president for finance and administration at University of Maryland, Baltimore County, at the annual meeting when she spoke about her use of the slides with her own board members. Schaefer also urged attendees to be more visible and coordinated in communicating the value of higher education.

New Title IV Privacy and Data Security Audit Checks

Under a new Office of Management and Budget (OMB) requirement, institutions will be audited for compliance with the Safeguards Rule of the Gramm-Leach-Bliley Act (GLBA).

Higher education institutions have long been expected to comply with the Safeguards Rule, which is meant primarily to safeguard customer information at financial institutions, but this is the first time that oversight of college and university compliance has been codified as part of the Department of Education’s Title IV audit process.

The stated audit objective is to “determine whether the institution designated an individual to coordinate the information security program; performed a risk assessment that addresses the three areas noted in 16 CFR 314.4 (b) and documented safeguards for identified risks.”

OMB’s suggested audit procedures to ensure compliance are:

a. Verify that the institution has designated an individual to coordinate the information security program.

b. Verify that the institution has performed a risk assessment that addresses the three required areas noted in 16 CFR 314.4 (b), which are(1) employee training and management; (2) information systems, including network and software design, as well as information processing, storage, transmission, and disposal; and (3) detecting, preventing, and responding to attacks, intrusions, or other systems failures.

c. Verify that the institution has documented a safeguard for each risk identified from step b.

While the public had a small window to offer comments, significant changes to this audit objective were not expected. Resources to aid institutions with information security best practices and GLBA compliance can be found on the privacy and data security resources page on the NACUBO website.

Advisory on Financial Responsibility Standards

NACUBO’s advisory on financial responsibility standards outlines actions that all colleges and universities should take to comply with the Department of Education’s financial responsibility standards, which established new triggering events and went into effect on Oct. 17, 2018. The report includes supplemental information based on updates posted by ED in March 2019 and June 2019.

The Department of Education’s financial responsibility standards (Subpart L of 34 CFR 668) are intended to ensure that institutions that participate in the federal financial assistance programs are able to meet their financial obligations and provide the resources necessary to offer their educational programs and comply with ED rules.

NACUBO is both monitoring and advocating for further changes to the standards. NACUBO remains concerned that if ED does take action, both nonprofit and for-profit institutions will be in danger of false financial responsibility failures.

The free advisory is available on the borrower defense page on the NACUBO website.

NACUBO CONTACT Liz Clark, vice president, policy and research, @lizclarknacubo


Related Topics

“I want to recruit you to be advocates for higher education.”

Susan Whealler Johnston, NACUBO president and CEO