Numbers typically don’t tell a complete story, but data resulting from the first full year of financial aid reporting in Division III certainly are telling administrators at member institutions things they never knew before.

“Schools probably learned as much or more about themselves as the NCAA learned about the schools,” said Dan Preston, dean of enrollment management at Linfield College and chair of the Division III Financial Aid Committee, which is overseeing the groundbreaking compliance initiative that has emphasized education during the first year of required reporting.

“And,” he added, “if we can accomplish that and also measure compliance with our bylaws, that’s pretty successful.”

Using the 4 percent variance standard established last year to measure compliance, about 86 percent of 430 institutions demonstrated statistically that the institutional gift aid they awarded to newly enrolled student-athletes during the 2004-05 academic year was substantially comparable to aid granted to the general student body. In other words, only 57 institutions’ aid to student-athletes exceeded the aid awarded to the general student body by at least 4 percent, when comparing students with similar need.

That finding, however, really only sets the scene for 430 distinct stories.

“One of the things we needed to keep reminding ourselves on the committee, and we need to remind all of Division III, is this isn’t a comparison of how one school awards versus how another school awards,” Preston said. “It’s a comparison of how athletes and other students are awarded within an institution.

“It’s not how School A compares to School B; it’s how the nonathletes compare to the student-athletes at School A.”

Every Division III institution that participated in the process received a report last fall of its variance figure, accompanied by a detailed analysis of financial aid packaging for student-athletes compared to other students.

True to the reporting program’s intent, each report offers a snapshot only of that particular institution’s financial aid practices, and offers no specific insight into how amounts of aid awarded at that school compare to other Division III members.

However, aggregate data for the 430 institutions do at least provide a reference point for analyzing how a particular institution’s own variance compares with other Division III schools.

The aggregate data reveal a median variance of minus 3.15 percent. In other words, half of Division III institutions awarded an average of 3.15 percent or greater financial aid to nonathletes who enrolled for the first time in 2004-05, compared to aid awarded to student-athletes with similar need.

Analyzed further, the data indicate that about 70 percent of Division III institutions awarded less aid on average to student-athletes than they awarded to other students.

NCAA researcher Eric Hartung suggested how schools can use the data to evaluate their own placement among all Division III institutions — by determining percentile rank.

“About 10 percent of Division III schools are showing a variance at or above 5.52 percent, which means if an institution’s variance is 6 percent — it awarded 6 percent more aid to student-athletes than to the general student body — it ranks within the top 10 percent for variance,” Hartung said (see table, page 22).

“If an institution’s variance is a negative 5 percent — it awarded five percent less aid to student-athletes than to the general student body — it ranks just below the 40th percentile for variance. In other words, 40 percent of Division III schools have a variance lower than them, or 60 percent have a variance estimate higher than them.”

It also is possible to evaluate differences in aid awarded to student-athletes and nonathletes in average dollar amounts, although the wide diversity of Division III institutions’ size, funding and missions make it difficult to give those figures any meaningful context.

An institution posting a variance of -3.15 percent — the Division III median — awarded an average of $432 less in aid to student-athletes than it awarded to other students. However, Division III schools’ variances expressed in dollar terms range from negative $2,192, at the 10th percentile mark, to positive $847, at the 90th percentile mark, with the maximum variance reported at $2,878 (student-athletes received that much more on average than nonathletes at an institution at the top end of the range).

“Division III is wildly diverse,” said NCAA researcher Ann Kearns, commenting on things member institutions can assume from the reported results. “But I wouldn’t draw any other conclusions from one year of data.”

Members of the Division III Financial Aid Committee, however, readily agree about another finding from the program’s first year.

Most schools comply

“We can conclude that, at least by the method we’ve chosen (for measuring compliance), the vast majority of institutions are complying with the bylaws,” Preston said.

“We’ve discovered that very few schools award significantly different aid packages, or differential aid, to student-athletes,” he said. “And most of those schools are able to justify it, by showing awarding practices that don’t include athletics ability or participation.”

“That’s heartening,” added Debra Murphy, president of Nichols College and one of three institutional presidents serving on the committee. “We’re viewing Division III as we should: It’s student-athletes, and the student comes first.”

However, committee members also suggest that all Division III institutions — even those showing a variance well within the 4 percent limit — can learn a lot about their financial aid practices from the institutional reports they received last fall.

“That’s part of the educational process,” Murphy said. “None of us has been through this before. None of us likely has analyzed institutional grants in the way provided in the tables in those reports.”

The reports include analyses — comparing student-athletes and nonathletes — of average cost of attendance and financial need, as well as average institutional gift aid. They also feature analyses by levels of financial need (ranging from no need to more than $35,000) as well as sport-by-sport reporting of average gift aid and of financial need.

A close examination of the report may reveal potential problem areas even at institutions that generally are in compliance with Division III financial aid legislation.

“You could be close to the 4 percent variance, but then when you look at those tables, you could be way out of whack,” Murphy said. “That’s what schools probably should be more attuned to — to see if there are some more blatant issues that they don’t realize are there until they see it in print in those tables.”

If nothing else, the reporting process offers institutions an opportunity to broadly review how financial aid is being awarded to incoming students, suggested another president serving on the committee.

“Campuses periodically need to step back and take a good look at how their financial aid is being packaged in general — which is something I’d never done before,” said Dennis Hefner of State University College at Fredonia. “It should be a broad institutional review that includes the presidential level, to make sure that what is occurring is what we think is occurring.”

Admissions impact

The committee currently is reviewing cases of schools that exceeded the 4 percent variance limit. In December, 48 institutions were placed in Level II of the review process (illustrated in the flowchart on page 21) and asked to provide justification for their variance. Committee members met February 16-17 in Indianapolis to begin reviewing those reasons why student-athletes received greater aid.

The review process will not be completed until late March, but information submitted by schools already is pointing to factors that help explain why some institutions — oftentimes, probably inadvertently — awarded more aid to student-athletes than nonathletes.

“One of the things we’ve learned is that admissions offices are probably more directly involved in the aid process than what we had anticipated,” Preston said.

In several cases reviewed by the committee, institutions employing a “matrix” approach to awarding aid — using an independent admissions and financial aid rating to determine the aid amount — used the same criteria in awarding aid that were used in deciding whether to accept a student for admission to the institution.

In some cases, the amount of merit aid was determined by an admissions officer rather than a financial aid administrator, and criteria used in determining the recipient and the amount of the award clearly included such factors as participation in athletics or service as a team captain.

“While schools can take athletics participation into consideration for admissions purposes, they cannot consider it for financial aid purposes under Division III legislation,” said Dan Dutcher, NCAA Division III vice president. “When the admissions and financial aid processes blur, such as when the admissions office awards merit aid based on admissions criteria, it calls into question institutional understanding and compliance with this basic principle of Division III.

“It also seems to confirm the informal assumption that the division’s biggest financial aid challenge relates to merit awards, rather than need-based aid, and that we have an educational challenge in that regard.”

It’s a challenge that committee members already are embracing as they prepare for the second year of financial aid reporting, which begins July 1.

“We’ve spent a lot of time providing information to athletics directors, presidents and financial aid officers, but not to admissions staffs,” Preston said. “That’s something we can focus on in the future.

“We would use the methods we used with financial aid directors — including attending conferences, providing materials and various other things — to communicate with directors of admissions about NCAA bylaws and how they intersect with the admissions office, especially if that office does any kind of matrix rating or actually awards merit scholarships.”

NCAA staff liaisons to the committee will attend the national conference of the National Association of College Admissions Counselors in October as part of that effort.

Other reasons why

In other cases, variances resulted from interesting mixes of student demographics. Citing examples, Murphy said the committee reviewed cases where student-athletes tended to live on campus and attend classes during the day — factors that might justify more financial aid — while nonathletes tended to be commuter or night-class students.

“That’s where a lot of variances seem to come, and in many cases they were supportable by evidence,” she said.

Student-athletes also may receive more aid than other students for a reason that everyone agrees is positive — because they rank among the best students on campus.

That pattern also emerged in explanations that schools provided to the committee for variances in financial aid. Schools are not asked to provide academic profiles — including grade-point averages and standardized test scores — as part of the annual financial aid report, and therefore the committee saw such information only during the Level II review.

“At many schools, the academic profile of Division III student-athletes seems to differ significantly from the rest of the student body,” Dutcher said.

Academic achievement may explain why some student-athletes receive more aid, but observing that trend has ramifications beyond understanding why institutions package financial aid the way they do.

“It allows us to see what type of student-athletes we’re bringing in,” suggests Garnett Purnell, director of athletics at Wittenberg University and one of three athletics administrators serving on the committee.

“As athletics directors, we all like to think that the student-athletes we’re bringing in to the institution are similar to those who make up the general student body, or that their academic performance even exceeds that of the general student body,” he said. “And, at least in some cases we’ve reviewed, we’ve seen that.

“Sometimes, faculty have the perception that student-athletes are not necessarily students as well as athletes — that they are there for other things. This report is helping us see that, overall, our student-athletes are performing just as well as, if not better than, the general student body.”

Preston said the Division III task force that created and tested the financial aid reporting process decided not to include academic profiles among data requested from

institutions, because of concern that such information might be burdensome for schools to compile.

“In our task force discussions, we worked hard to find a balance between efficiency and effectiveness,” he said. “How could we effectively analyze schools and be as efficient as possible, and reduce the burden on the school?”

However, trends emerging from the first year of reporting — ranging from the impact of academic performance on aid packaging to other factors that may yet emerge from future reporting — eventually could prompt changes in how data are collected and analyzed.

“It’s an evolving process,” Preston said. “It probably will look at least slightly different five years from now, because we don’t think we’ve found the perfect process yet.

“It could mean a number of different things: It could mean asking for more or different information up front during data submission, or it could mean changing our analysis slightly, or reviewing different data elements. It could mean random selection of a percentage of schools each year, or it could mean a different variance limit.

“These are some options before us, now that we’ve done this once, to improve the process and make the analysis even better.”

Enforcement phase of process also puts focus on learning

The Division III Financial Aid Committee will decide by the end of March whether justifications provided by the 48 institutions involved in Level II reviews sufficiently explain variances in aid awarded to student-athletes and to other students.

The committee can approve an institution’s variance based on the justification, or it can accept the justification but stipulate that the institution’s data automatically be reviewed again next year.

Otherwise, institutions that are unable to justify a variance will have their cases referred to the NCAA enforcement staff for review — though committee members are quick to suggest that Division III members shouldn’t read too much into that action.

“If a member institution should get a call from enforcement, the first thing to remember is, don’t panic,” said committee member Garnett Purnell, director of athletics at Wittenberg University and an experienced compliance officer. “Regardless of misconceptions that are out there with regard to enforcement, they’re just there to gather information and make an evaluation of what actually happened.

“I’d say treat it just like an audit. Put all of your cards on the table and say, ‘This is what we have.’ Then they can give you an honest interpretation and assessment of what it is that you have to do. If you did something wrong, learn from that, correct the error and move on.”

Although it is up to the enforcement staff, rather than the committee, to determine whether a violation occurred, committee members believe that the overwhelming majority of cases referred for review likely will be classified as secondary violations.

And just like during the data collection and analysis phases of the reporting process, the enforcement phase also will focus primarily on education — at least in the near future.

“In the initial few years, the penalties will be focused on educational types of actions,” said Chris Strobel, NCAA director of enforcement for secondary infractions.

“We’re still determining what those actions may be, but they could include attendance at regional compliance seminars, or visits to the NCAA office to meet with staff who work with financial aid, or successful completion of a online test.”

That approach is consistent with the Division III Presidents and Management Councils’ desire for member institutions to use financial aid reporting as a learning opportunity, said Dan Dutcher, NCAA Division III vice president.

“The Councils have emphasized the principle that penalties should focus on education, especially during the first year,” he said.

Strobel suggested, however, that a situation that suggests continuing financial aid violations may result in tougher and more immediate penalties. As an example, he suggested that an institution could be required to submit a revised “matrix” for determining financial aid.

Names of institutions whose cases are referred to the enforcement staff will not be reported publicly, and findings of secondary violations typically are not publicly reported — unless a public release of information is made part of an institution’s penalty in accordance with NCAA Bylaws 19 and 32.

“If you honestly feel you were working within the guidelines, let enforcement help you out,” advised Purnell. “They’ll put you in a better position to keep a violation from happening again.”

Second reporting cycle begins

The 2006-07 financial aid reporting process will begin July 1 — the first day of a three-month period during which institutions are required to submit financial aid data for student-athletes and other students who enrolled for the first time during  the 2005-06 academic year.

In one slight change in the timeline for the process, institutions will be required to submit data by the last Friday of September beginning this year, rather than by September 30 as was required last year.

As a result, the deadline for the 2006-07 reporting process is September 29.

More information online

A wealth of information about the Division III financial aid reporting process — including a comprehensive “user’s guide” to the process and various educational tools — is available to Division III members at the NCAA Web site.

The information is accessible through the “Legislation & Governance” menu at www.ncaa.org, by clicking on “Committees” and then clicking on “Division III.” The Division III page includes a “Financial Aid Reporting Process” link, as well as links to other resources related to financial aid.