The second year of Division III financial aid reporting, which began July 1, brings with it heightened attention to signals that a school may be awarding significantly more financial aid to student-athletes than to nonathletes — including examination of aid awarded to participants in a specific sport.

The Division III Financial Aid Committee recently adopted three new "triggers" — in addition to the 4 percent variance threshold used by the committee last year — that could require an institution to justify aid awarded to student-athletes who enrolled for the first time during 2005-06.

Those additional triggers specifically focus on situations where overall institutional gift aid for student-athletes is within the 4 percent limit — in other words, does not exceed aid awarded to nonathletes with similar need at that institution by more than 4 percent.

"The committee concluded you could have a variance below 4 percent and still have some statistical outliers that are of concern," said Matt Banker, NCAA associate director of membership services and staff liaison to the committee. "The question is how do you pick up statistical outliers for institutions that are below 4 percent?"

The new triggers — also called filters — are an answer to that question.

"We’re authorized to use information that assists us in making sure that schools conform to the bylaws," said Dan Preston, dean of enrollment management at Linfield College and chair of the financial aid committee. "The 4 percent variance is only one of the possible measures."

‘Wide difference’

The new triggers, which were recommended by the NCAA research staff and employ data that already is being provided by schools, are:

nA wide difference (statistically, two standard deviations from the Division III mean) between student-athletes and nonathletes in the percentage of each group’s financial need that is covered with institutional gift aid.

"It’s statistically possible to be under the 4 variance but have a wide difference in the percentage," Preston explained.

nA wide difference (also, two standard deviations) in the proportion of student-athletes in a group of new students at an institution and the proportion of institutional gift aid awarded to student-athletes in that group.

"It’s statistically possible to be under the 4 percent variance and still have a wide proportionality difference," Preston said.

Bylaw 15.4.1-(d) states that "the percentage of the total dollar value of institutionally administered grants awarded to student-athletes shall be closely equivalent to the percentage of student-athletes within the student body."

"Proportionality is very clearly stated in the bylaws," Preston said, "and that’s why we’re adding that criterion."

nA wide difference (again, two standard deviations) between student-athletes in specific sports and nonathletes in the percentage of each group’s financial need that is covered with institutional gift aid.

"You can have an institutional variance under 4 percent, but have one or two targeted teams that could be out of compliance," Preston said.

Using the first year of reported financial aid data as a guide, Banker said the new triggers are expected to subject "two or three dozen" additional institutions to committee review — compared to 60 institutions that were reviewed last year.

Many of those additional reviews — perhaps two-thirds of institutions that show less than a 4 percent variance but are selected as a result of the new triggers — will involve sport-specific situations, the financial aid committee believes.

"This picks up one of the biggest concerns in Division III, based on feedback we’ve received — the possibility that institutions could be showing a variance of, say, 0 to 2 percent, or even show a negative variance, yet a couple of sports could be off the charts, and hidden within that overall variance number," Banker said.

"We want to respond to those concerns," Preston said. "We have the information, and it’s something the committee also is concerned about. You can’t have a wide variation in the proportion of money going to student-athletes and to others."

To maintain statistical validity, only teams with seven or more squad members will be subject to review, said Ann Kearns, NCAA assistant director of research for academic performance and governance.

All three of the new triggers are based on information that appears in the final detailed report that institutions receive after they submit data to the NCAA.

"We’re not asking for new information, and we’re not running numbers in a new way," Banker said. "We’re taking information that’s already in the report and saying, that’s another reason why we might ask for a full review."

Data relating to the first trigger (the comparison of percentage of need covered by institutional gift aid) can be found in Table 3 of the institutional report, while proportionality data relating to the second trigger can be found in Table 5 and sport-specific data relating to the third trigger can be found in Table 7.

"If something seems out of whack to an institution, there’s a possibility that it actually is out of whack," Kearns said, advising that school personnel review last year’s report and also monitor future reports for indications of problems.

"Institutions are welcome to call us to talk about the report, or to talk about any numbers that seem alarming," she said. "We obviously won’t know what would fall above the two standard deviations (in the next report) until we’ve collected all institutions’ data, but with some, we might be able to assume whether an institution might be subject to review."

Even institutions that are comfortable with data in the report should keep in mind that financial aid reporting has two purposes: enforcement of financial aid legislation, but also self-assessment. The reports are a tool that helps schools measure their own compliance with the Division III philosophy that student-athletes should be treated the same as other students on campuses.

"This mechanism isn’t intended to pick up every possible scenario of a potential violation under Bylaw 15," Banker said. "If institutions are under a 4 percent variance and aren’t picked up under any of the new filters, they still should be cognizant of their systems on campus, as well as such factors as how admissions and financial aid work together on campus. That should be a running responsibility."

Financial aid reports due by September 28

Division III institutions have until September 29 — the final Friday of the month — to report financial aid information through Division III's Financial Aid Data Management System.

This is the reporting program’s second year. It requires all Division III institutions to provide financial information to the NCAA for all new students — freshmen and transfers — who entered school during 2005-06.

Institutions participating in the program this year will receive a full report by December 1 indicating whether justification will be required either because aid to student-athletes exceeded aid awarded to nonathletes who demonstrated similar need by more than 4 percent, or because of new "triggers" of reviews that were adopted by the committee this year (see accompanying article).

Institutions required to provide justifications will be given a month longer than last year — from December 1 until February 1 — to present information to the committee. The committee will review those justifications during February and respond during March by accepting those justifications or forwarding cases to the NCAA enforcement services staff for processing as violations of Bylaw 15.