Key Concepts

Before rushing in to change anything about the way your institution manages FWS, take the time to educate yourself about both the federal regulations governing the program and determine a few things about how FWS operates at your institution.

Who Controls or Manages FWS at Your Institution?

Institutions of higher education can be structured very differently from one campus to the next, but in almost all cases, the office that manages FWS is called either Financial Aid or Student Employment (or some variation on one of these). In many instances, the Student Employment area is located within the larger umbrella of Financial Aid.

 

Financial Aid

Financial Aid (sometimes called Student Aid or Financial Affairs) helps students afford to attend school, and nearly all Financial Aid professionals think of their primary objective as providing access to education. Financial Aid professionals counsel students on the various options students have for how they will pay for their tuition and related expenses.

Students (and/or their families) complete a federal form called the Federal Student Financial Aid Application (FAFSA) to help the institution determine whether students are eligible — based on their income and assets — to receive any help in paying for their education. Based on the FAFSA, the Financial Aid office puts together each student’s financial aid package.

Elements of the financial aid package generally include loans (which students start paying back to the government, institution, or private lender when they are no longer in school); grants or scholarships (funds from the government or institution that students do not have to pay back); and work-study awards (a contract with the institution that allows students to be employed in certain positions to earn money while in school). Professionals in Financial Aid offices are generally well trained in interpreting financial options for students, counseling students about paying for their education, and completing the paperwork that accompanies those processes.

 

Student Employment

Student Employment (sometimes called Campus Employment) refers to the group that helps link students with employers both during school and after graduation. Student Employment specifically manages work programs such as Federal Work-Study. At a small institution, Student Employment may be one or two people who work within the Financial Aid office. At other institutions, Student Employment may be a stand-alone office that also coordinates opportunities such as internships and co-operative education. Sometimes Student Employment is located in the institution’s Human Resources department.

A review of your institution’s website, phone directory, or catalogue will probably clarify who manages FWS. You can also call your Financial Aid office to ask to find out with whom you need to meet to learn more about your institution’s systems and processes for managing the community service element of FWS.

In this document, references to “Financial Aid” are meant to include whomever at your institution manages FWS. If your institution uses a different name, simply substitute that where this term appears.

 

What Is Work-Study?

This document will focus on Federal Work-Study, but be aware that many institutions also participate in State Work-Study programs or offer work-study jobs paid entirely by the institution (Institutional Work-Study). State and Institutional Work-Study programs generally do not have the same regulations for community service, so ask how those programs work at your institution, if they exist.

 

Federal Work-Study Background

The FWS program, regulated by the U.S. Department of Education, was created by the federal government in 1964 as a part-time employment program for low-income students. Its most important purpose was and is to increase access to higher education by providing work opportunities for students who need wages in order to attend college or university. FWS is generally just one part of a student’s overall financial aid package. Most FWS students at colleges and universities work on campus in various positions within academic departments, the cafeteria, the library, or other areas.

 

Community Service and Federal Work-Study

Revised language in the Higher Education Act in 1965 clarified that work performed by FWS students was to be “for the institution itself or work in the public interest for a public or private nonprofit organization.” So from the early days of the program, community service has been part of its purpose. In 1994, a new mandate required 5% of the total FWS funds received by an institution be used for community service positions. In 2000, the mandate was increased to 7% and a new provision required the institution to employ at least one student in a tutoring or family literacy program.

 

Understanding the “7% Mandate”

The current 7% mandate refers to the percentage of the total amount of FWS funds received by the institution that must be used to pay wages to students in community service positions. It does not mean that 7% of the number of students must be in community positions. Depending on the total amount of FWS received by your institution, 7% may result in only a few community service positions, or it may mean hundreds.

 

 

Federal Regulations

The following text offers portions of the actual federal regulations governing FWS that relate to its purpose and definitions. To simplify things, this edited version includes only language that directly relates to the community service portion of FWS.

 

Department of Education, Office of Postsecondary Education

Part 675 – Federal Work-Study Programs

 

§ 675.1 Purpose

(a) The Federal Work-Study (FWS) program provides part-time employment to students attending institutions of higher education who need the earnings to help meet their costs of postsecondary education and encourages students receiving FWS assistance to participate in community service activities.

 

§ 675.2 Definitions

Community services: Services which are identified by an institution of higher education, through formal or informal consultation with local nonprofit, governmental, and community-based organizations, as designed to improve the quality of life for community residents, particularly low-income individuals, or to solve particular problems related to their needs…

 

§ 675.18 Use of funds

(g) Community service. (1) For the 2000-2001 award year and subsequent award years, an institution must use at least seven percent of the sum of its initial and supplemental FWS allocations for an award year to compensate students employed in community service activities. In meeting this community service requirement, an institution must include at least one –

(i) Reading tutoring project that employs one or more FWS students as reading tutors for children who are preschool age or are in elementary school; or

(ii) Family literacy project that employs one or more FWS students in family literacy activities.

 

§ 675.8 Program participation agreement

To participate in the FWS, an institution of higher education shall enter into a participation agreement with the Secretary. The agreement provides that, among other things, the institution shall –

…(d) Award FWS employment, to the maximum extent practicable, that will complement and reinforce each recipients’ educational program or career goals;

…(f) Inform all eligible students of the opportunity to perform community services and consult with local nonprofit, governmental, and community-based organizations to identify those opportunities.

These portions of the regulations clearly show that community service positions are important to the program. Additional portions of the regulations found in Part 675 that relate to community service FWS are found later in this document.

 

The “Spirit” of the Regulations vs. Common Interpretations

One of the greatest challenges in working effectively with others at your institution on FWS is the different ways people interpret portions of the regulations related to community service. A good way to determine whether a FWS position meets the community service requirement is to consider who is most affected by the work of the position — the community at large or the campus community? The Federal Student Aid Handbook (updated each school year) notes that positions may be on or off campus but specifies that “on-campus jobs can meet the definition of community services, provided that the services are open and accessible to the community… A service is considered open to the community if the service is publicized to the community and members of the community use the service.”

Despite this requirement, some institutions count on-campus positions that do not substantially serve the community at large in calculating the percentage of FWS funds allocated to community service. They may rationalize that these positions are located somewhere on campus that has community contact, such as the library, gymnasium, or theater box office. Generally, however, these sorts of positions do not reflect the spirit of the 7% mandate. It is critical that you have a dialogue with colleagues in the Financial Aid office and other offices on campus to formalize the criteria you will use to define appropriate community service positions.

 

Enforcement

The 7% mandate is a federal regulation, not a law, but it is enforceable. Institutions that do not follow the regulation run the risk of being penalized by the Department of Education — for example, by losing a portion of FWS in the following year. In the past few campuses have been held to account, but in May 2007, the Department of Education sent a formal letter to financial aid professionals spelling out the regulation’s requirements and clarifying avenues for enforcement:

 

“An institution that participates in the FWS Program that fails to meet one or both of the FWS community service requirements for the 2007-2008 Award Year, or in subsequent award years, will be required to return FWS Federal funds in an amount that represents the difference between the amount that the institution should have spent for community service and the amount that it actually spent.Ê Further, an institution that is out of compliance with the FWS community service requirements may be subject to a Limitation, Suspension, and Termination (L, S, & T) proceeding, where the institution could be denied future participation in the FWS Program, and possibly other Title IV, HEA programs, and/or subject to a substantial fine.” 

In addition, an institution’s own external auditors may also examine whether the institution’s FWS program is in compliance, including whether the community service positions appear to comply with federal regulations and definitions.

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