When an issue is quite complex and no simple solutions are at hand, sometimes it's a good idea to take a step back and regroup.

The Division III governance structure did just that this fall when the Presidents Council withdrew Convention Proposal No. 46 from consideration. That proposal would have created a mandatory financial aid audit in the division, and the Presidents Council agreed with the Management Council that there were just too many issues left unresolved to move forward with the legislation.

The group that has been charged by the Councils with resolving those issues -- the Division III Financial Aid Audit Task Force -- had its first in-person meeting February 20, and that group is moving steadily on a timetable that calls for the presentation of legislation to the membership at the 2003 NCAA Convention.

While there's still much work to be done, it's clear that the task force is closely examining issues of concern -- to the membership and to the Councils -- with an eye toward creating a workable financial aid audit procedure for the division.

At the end of a Division III pilot financial aid audit program last fall, there were nearly as many questions remaining as there were answers learned and issues resolved. Audits at 19 participating institutions had ranged widely in cost -- from $800 to $ 5,500 -- and there were questions regarding the audit's frequency, scope and end results.

For example, if the audit was to examine the aid awarded to student-athletes against the aid awarded to students who were not athletes, what was considered a permissible variance? What would happen to an institution if the variance could not be explained? Would there be an enforcement process? How many financial aid files should be examined, and should they be the files only of first-year students? What about transfer students?

With each step toward the audit, there had been questions, and now every step seemed to overturn yet another rock with new questions underneath.

>When the Presidents Council agreed to withdraw the 2002 Convention proposal that would have created the audit process, members of the Council realized that the time had come to look at everything in a new way. So the Council directed the Division III Administrative Committee to appoint a special task force to do just that.

The task force, chaired by Kevin LaGree, president of Simpson College and a member of the Division III Presidents Council, has a full plate. It is examining all of the previous information uncovered by the Division III Financial Aid Committee, as well as the results of the 2001 pilot audit program, feedback from discussions at the 2002 Convention and additional input from the Management and Presidents Councils.

The task force likely will address the following issues:

Audit scope, size and frequency.

Acceptable variances between aid for student-athletes and those students who are not athletes.

Auditor origin (external or internal) and related issues.

Review of audit results, including the frequency of the review and the designation of the appropriate governing body for review.

Costs of the audit, both to the institutions and to the Association.

Enforcement process.

Strength in diversity

One aspect that makes the task force unique is its composition. The task force is composed of 17 members (including two ex officio members, Bette Landman, chair of the Presidents Council and president of Arcadia University; and Christopher Walker, chair of the Management Council and faculty athletics representative at the University of Redlands). Seven of those members are presidents; four are athletics directors; four are financial aid officers at member institutions; and two are faculty athletics representatives. Six of the 17 are members of the Division III Management Council and five are members of the Division III Presidents Council.

LaGree said including presidents, athletics directors and financial aid officers on the task force has worked well.

"Each has an important perspective and a critical role to play if we're to create an accountability procedure that works," he said. "We need all three perspectives for different reasons. And of course there also is overlap in the three interests, but each has a different angle of sight on the problem. The ability to see from all three angles helps us avoid an accounting procedure that is foolish or flawed in some way."

LaGree said presidents are interested in a process that will serve as a tool for self-examination of their institutions and also help create an atmosphere of trust among institutions in the division.

"For example, I want results that will show me, as president of an institution, that we are complying with the intent and also the rule of law (of the bylaw)," LaGree said. "As presidents, we want to have that way of testing accountability, much like we currently can test other areas of the university now for accountability, in annual reports and the like."

LaGree notes that the division's current legislation calls for compliance and institutional accountability. The process the task force is working on now would help ensure presidents that they were in compliance.

"What the bylaw calls for is self-accountability," he said. "And we're working on a process that would assist us with that and also provide for a way to share the data with each other to build trust among institutions in the division."

Adding financial aid officers to the task force who are from conferences that conduct similar financial aid audits also has been eye-opening and beneficial in many ways, LaGree said.

"A number of conferences already meet and share data among their financial aid officers, and in one conference, if there is a variance (of aid between student-athletes and non-student-athletes) the financial aid officers have to submit reasons why in writing," he said, noting that the conferences have found that the sharing of data in that setting simply solves the problem.

LaGree also points out that having financial aid officers and athletics administrators on the task force helps when it comes to compiling accurate and useful data in a thoughtful way.

"To meet the needs of financial aid officers and athletics directors, the process needs to not be onerous and require an unreasonable amount of paperwork," he said, noting that the task force is not looking toward the use of an annual external audit. "We want helpful, good information, and we want it at a reasonable cost, both in terms of dollars and time."

One way to accomplish those goals of simplicity and usefulness may be to pursue some type of electronic reporting system that is perhaps Web-based or on CD-ROM.

Early consensus

With much to do and little time to do it, the task force began work in earnest not long after the Convention in January. Again, having the different groups all at the same table has helped.

"We moved quickly in our first meeting and found a number of areas of consensus," LaGree said. "What's left now are more the nuts-and-bolts type of questions."

In its in-person and conference call meetings, the task force has agreed on several issues that will be reported to the Councils at their upcoming April meetings and are likely to emerge as formal recommendations to the Division III Management and Presidents Councils by those groups' summer meetings.

The task force will recommend that:

The review of all incoming first-year students and all transfer students is necessary, as is a sport-by-sport breakdown of the data.

The audit should be performed annually, and the task force favors an electronic type of submission to the NCAA. The idea would be to develop an electronic submission vehicle that also was compatible with existing financial-aid software packages in common use on campuses.

The audit should be performed by internal auditors who have no involvement with athletics.

Some consistency be maintained between what financial aid officers are reporting to the federal government and what the NCAA asks of them. This is one of the issues being examined by a subcommittee of the task force, which is composed entirely of financial aid officers.

Another issue still being researched includes the appropriate role of the Division III Financial Aid and Awards Committee, which may be asked to review the audit information, perhaps on an as-needed basis or perhaps on some type of rotation.

Also under review is the question of what is an appropriate variation between the aid given to student-athletes and the aid given to students who are not athletes. The task force, in consultation with the NCAA research staff, is examining whether there may be ways to statistically determine what an appropriate variation might be.

At this point in the process, though, all signs are that the appropriate people are examining the issues and asking the right questions.

"I came away from our first meeting really encouraged by our progress," LaGree said. "It's a difficult and complex task (to examine all of these issues) and we knew that going in. What has made the difference has been having all of those different perspectives in the same room and the same time. All of the right questions get asked, and many of them get answered quickly."

Sounds like that step back was really a step in the right direction.

Division III Financial Aid Audit Task Force