How Wagner Made 38 Equal 61


By Chuck Burton
Publisher/Managing Editor
College Sports Journal

PHILADELPHIA, PA. — Normally when an FCS school schedules a game against an FBS school it’s not very controversial.

But when Wagner announced they will be playing Syracuse in 2013, many fans looked at Wagner, and their NEC-mandated athletic scholarship level of 38, and saw some math that didn’t add up.

Syracuse fans were concerned that their athletic director was hoodwinked into scheduling a school that wouldn’t “count” when it came towards bowl eligibility because the Seahawks only are allowed to offer up to 38 athletic scholarships in their conference, the NEC.

After digging into the NEC and NCAA bylaws, however, I discovered that yes, indeed, it is possible for Wagner to count towards bowl eligibility yet still offer only 38 scholarships.


In other words, Wagner figured out how to make 38 equal 61 to count for bowl eligibility purposes.

Here’s how.

In order to fully explain what’s going on one needs to understand the following NCAA terms: counters and equivalencies.

A “counter” is a student-athlete who is included in the maximum award limitations of their sport if the student-athlete is receiving athletically related financial aid.  In other words, they “count” towards the maximum number of scholarships for the subdivision, which in the case of FCS is 63.

FCS is also considered an “equivalency sport”, which means, essentially, that the scholarships can be broken out in the form or partial rewards.  Unlike FBS football, which is a “headcount sport”, an FCS student-athlete can have some of their athletes receive a half-, third-, or some percentage scholarship in the sport.

So how does this relate to Syracuse?

The rule which allows the Orange to “count” a win against an FCS school as a bowl counter is as follows (Bylaw

Each year, a Football Bowl Subdivision institution may count one victory against a Football Championship Subdivision opponent toward meeting the definition of a “deserving team,” provided the opponent has averaged 90 percent of the permissible maximum number of grants-in-aid per year in football during a rolling two-year period.


The exact wording of the FCS scholarship limits shows up in


There shall be an annual limit of 30 on the number of initial counters (per Bylaw, an annual limit of 63 on the value of financial aid awards (equivalencies) to counters, and an annual limit of 85 on the total number of counters (including initial counters) in football at each Football Championship Subdivision institution.

If a school offers conventional aid up to the FCS maximum scholarship level of 63, there’s little to discuss – it’s widely assumed that those schools have rolling average that’s required.  However the NEC sets a conference-wide limitation as to the amount of football scholarships available.

From the NEC rulebook:

All NEC football playing institutions are permitted to award a maximum financial aid amount of 32 full athletic grants-in-aid on an equivalency basis. Beginning in 2009-10, grants-in-aid may be increased by no more than two per year, capping at 40 (2011-12 – 36, 2012-13 – 38 and 2013-14 – Policy Manual 169 Sport Regulations Football 40).

So in this season, the 2012-13 season, Wagner, by conference rules, can only offer 38 “full” athletic grants-in-aid, or, in other words, athletic scholarships.

But this does not mean that Wagner’s football team only has 38 kids receiving scholarship money.

NCAA Bylaw 15.02.3 states:

A “counter” is an individual who is receiving institutional financial aid that is countable against the aid limitations in a sport.

 And NCAA Bylaw 15.02.4 states:

“Financial aid” is funds provided to student-athletes from various sources to pay or assist in paying their cost of education at the institution.

Note the words “various sources”.  In order to be a counter, the Wagner football athlete doesn’t necessarily have to be getting his money from the athletic department – he could be getting a need-based scholarship through the financial aid office, or an academic scholarship from an endowed source.

Whether it’s an athletic scholarship, a need-based scholarship, or an academic scholarship, by receiving that aid they are considered a “counter” in the NCAA’s eyes and thus count towards the 63 limit.

Keep in mind, too, that the 90% of permissible maximum number of grants-in-aid for bowl eligibility does not specify that the source of that aid has to be an athletic scholarship.  The rule simply states that grants-in-aid (effectively, in this case, scholarship money, wherever the source) is offered, and that it’s 90% of the permissible maximum (or 56 1/2 grants-in-aid, to be exact).

And the final piece of the puzzle comes from NCAA Bylaw

In equivalency sports, each institutional financial aid award (per Bylaw to a counter shall be computed as follows:

(a) Once a student becomes a counter, the institution shall count all institutional aid (per Bylaw received for room, board, tuition and fees, and books up to the value of a full grant-in-aid. Exempted government grants per Bylaw 15.2.5 and exempted institutional aid per Bylaw specifically are excluded from this computation.
(Revised: 1/9/96 effective 8/1/96, 4/29/04 effective 8/1/04, 10/20/08)

(b) A fraction shall be created, with the amount received by the student-athlete (up to the value of a full grant-in-aid) as the numerator and the full grant-in-aid value for that student-athlete as the denominator based on the actual cost or average cost of a full grant for all students at that institution. Financial aid unrelated to athletics ability (see Bylaw 15.1) received by the student-athlete in excess of a full grant-in-aid shall not be included in this computation.
(Revised: 1/10/90, 4/29/04 effective 8/1/04)

(c) The sum of all fractional and maximum awards received by counters shall not exceed the total limit for the sport in question for the academic year as a whole.

This formalizes the order of the process.  The football student-athlete becomes a “counter” starting with the following school year once he’s a recruited athlete, he signs a national letter of intent to play at the school (or his first check clears the financial aid office) and he has a contract to receive financial aid to attend the school from any source.  Once he’s a counter, his financial aid counts towards the NCAA limit of 63 scholarships.

From the NCAA’s perspective, if Wagner is offering 38 athletic scholarships and 23 need-based scholarships, they have 61 athletes receiving financial aid, and therefore “count” for bowl eligibility for Syracuse.

However, that’s not the end of the story.


Read the NEC’s rule again:

All NEC football playing institutions are permitted to award a maximum financial aid amount of 32 full athletic grants-in-aid on an equivalency basis. Beginning in 2009-10, grants-in-aid may be increased by no more than two per year, capping at 40 (2011-12 – 36, 2012-13 – 38 and 2013-14 – Policy Manual 169 Sport Regulations Football 40).

That key adjective, “maximum”, is important.

“Financial Aid”, per the NCAA’s definition is:

funds provided to student-athletes from various sources to pay or assist in paying their cost of education at the institution.

The rule was not written as:

All NEC football playing institutions are permitted to award 32 full athletic grants-in-aid on an equivalency basis.


It specifically says a maximum financial aid amount of 32 – which most schools of the NEC have understood as the NCAA’s definition of financial aid, meaning funds provided from all sources, including need-based and academic aid.

It also does not mention need-based aid at all – though need-based aid for NCAA counter purposes does count.


Thouroughly confused, I wrote the commissioner of the NEC, Noreen Morris, to get a clarification.  Here is here response.


“The limit of 40 applies only to athletically related financial aid awarded to football student-athletes,” she said.  “As a result, the NEC football programs are permitted to combine athletically related aid (maximum of 40 equivalencies) with other countable aid not to exceed the NCAA equivalency maximum (63 equivalencies).  Other countable aid would include need-based, merit and/or academic aid.”


By this definition, Wagner successfully has found a way to make 38 athletic scholarships equal 61 countable scholarships – to offer 38 “athletically-related” scholarships and to offer 23 packages of “other countable aid” through the regular financial aid office.


But make no mistake, this is a fundamental reinterpretation of what the NCAA considers “financial aid”.

The only financial aid that “counts” for the NEC’s scholarship restriction is athletically-related financial aid.  When the NCAA defines financial aid for counter status, they define that as aid from any source.


This might come as a suprise to other current and former NEC schools who took the definition of “financial aid” to mean the NCAA’s definition.  And, as a result, iIt’s easy to see the remaining NEC schools coming up with the same trick to allow 20 or so athletes to go through the financial aid office to become “counters” as well.

And, at a stroke, this new definition of financial aid should, essentially, should make the wider FCS world think of the NEC as a full scholarship conference, no different than the Big South, Big Sky, or CAA. 


They may be “scholarship limited” in a technical sense, but not according to the definition of the NCAA – or perhaps, more importantly, Syracuse.