> This letter constitutes The Ohio State University, Office of Student
> Financial Aid's response to the August 8, 2007 Notice of Proposed
> Rulemaking (NPRM) on General Provision issues.
>
> **[Consistent Definitions for Undergraduate Student, Graduate or
> Professional Student and First-Professional Degree for All Title IV
> Programs Sec. 668.2]{.underline}**
>
> As long as an institution can use its definition of academic year when
> determining the "third year", this proposed provision would pose no
> additional hardship on our institution*.*
>
> **[Loan Cancellation Notice and Affirmative Confirmation of A Loan
> Sec. 165 (a)]{.underline}**
>
> Ohio State currently requires active confirmation from a student that
> he or she accepts an awarded Title IV loan. This proposed provision
> would pose no additional hardship on our institution. In addition, we
> agree that 14 days is long enough for a student or parent to decide to
> cancel his or her loan and do not support increasing the time period
> for institutions not using affirmative confirmation.
>
> **[Treatment of Title IV Grant and Loan Funds if a Recipient Does Not
> Begin Attendance Sec. 668.21, 682.604, and 685.303)]{.underline}**
>
> Ohio State currently returns Title IV grant and loan funds if a
> student fails to begin attendance in classes. This proposed provision
> would pose no additional hardship on our institution.
>
> **[Post-Withdrawal Disbursements of Grant Funds Directly to a Student
> Sec. 668.22)]{.underline}**
>
> We support the proposed provision that removes the requirement to
> notify and obtain the student's permission prior to making a direct
> disbursement of any Title IV *grant* funds included in a
> post-withdrawal disbursement. However, we recommend increasing the
> time frame for this provision from 30 to 45 days to coincide with the
> time frame in which institutions must return unearned funds. Most
> institutions are looking at this process at the same time a R2T4
> calculation is being done so it makes sense to have the same time
> frame.
>
> **[Recovery of Unclaimed Title IV Funds Sec.668.161]{.underline}**
>
> While we understand the program integrity issues pointed out by the
> Dept, the proposed provision nevertheless poses an additional
> administrative burden on our institution. Currently, our business
> practice is to review, recover, and return Title IV funds on an annual
> basis, usually during down time in the year. We suggest amending the
> process so that recovery of unclaimed Title IV funds is only performed
> on an annual basis
>
> **[Electronic Disbursements, Use of Store-Value Cards, and Issuing a
> Check Sec 668.164 (c) and 668.165 (b)(i)]{.underline}**
>
> In this day of electronic communication, the requirement to issue a
> check as a method of disbursement of a student's credit balance feels
> like a return to an earlier or less developed condition or way of
> behaving. Institutions should be given the flexibility to **require**
> a student to authorize an electronic funds transfer into a bank
> account. The same practice is used by many employers for issuing
> employee pay checks. That is the direction in which the business world
> is moving and it doesn't make sense to prohibit institutions from
> following suit. Furthermore, we disagree with the Dept and don't see
> anything wrong with requiring a student to take specific actions to
> obtain his or her credit balance.
>
> **[Minor Prior-Year Expenses Sec. 668.164]{.underline}**
>
> We support the proposed provision that limits the use of current year
> aid to repay minor prior year charges of \$200 or less.