Noah Morris runs the Ontario Student Assistance Program (OSAP). He is the unfortunate soul who has the unenviable task of implementing Dalton McGuinty’s promise to give students 30% tuition rebates if they came from families with less than $160,000 in family income. It may have been popular electorally, but in policy terms it’s got “ugly” written all over it.

The government could have implemented this through the OSAP system by just cutting cheques to student aid recipients. But no: somebody in the Premier’s office had half-read some research about low-income students not always applying for student aid, and so decided they should avoid OSAP and make it universal. So who should cut the cheques in this brilliant scheme? The universities and colleges, of course! When students hand over their tuition money, institutions will hand back a rebate cheque. What could be simpler? Or more visible?

Great idea – until you realize institutions have absolutely zero idea about students’ incomes unless they apply for student aid. So we’re back to square one, except that now the government has shifted the administrative burden to institutions. Under the circumstances, COU’s “we’re sure keen to work with you” throne speech response was a model of turning the other cheek.

Did I mention the nightmarish interaction effects with federal programs? If the award is treated as a tuition waiver, two things happen. The first is that students’ recorded costs will fall, which means the students’ eligibility for student aid is reduced. The province can tweak OSAP rules to ignore the grant in the resource calculation, but it can’t force the federal program to do the same; since provincial remission programs are based on joint borrowing, the waiver may in fact be offset by a reduction in students’ eligibility for the province’s OSOG grants.

A fee-waiver approach also means that students will receive fewer tax credits. Assuming the program costs roughly $400 million, Ottawa will save $60 million a year in its tax credit programs at students’ expense.

Treating the awards as grants would eliminate the tax credit problem, but would require changing a lot of OSAP rules in order to avoid a situation where the new grant isn’t pushing out other aid dollar-for-dollar. It’s do-able – but again, there’s no reason to think Ontario will be able to shield students from clawbacks from the federal program.

So – an administrative nightmare plus nasty program interactions; just your run-of-the-mill trainwreck that results from designing public policy on the back of a cocktail napkin. And it’s OSAP’s Noah Morris that has to make it all work.

He deserves everyone’s sympathy.