COFHE looks at student debt levels and expectations of their college experiences, based on various surveys.

It also conducts an annual survey of first-year financial aid data, and publishes a biannual report.

While many of the results of the survey are not public information, the member schools are all privy to COFHE's findings.

"We don't talk about individual students," says Theodore Bracken, director of federal relations for COFHE. "But we try to track what's happening."

The member schools exchange data on tuition levels, student budget levels, the percentages of students on financial aid, average self help amounts, yield rates, application numbers and sources of grant aid for each of the member schools.

"It is a convenient way to assess where they are in relation to their competition and to make their own judgements about what, if anything, to do about that," Bracken says.

He stresses, however, that all data is "historical," meaning the schools only learn what each has already done, not what it will do in the next year, as was the case with overlap.

"It hasn't replaced the overlap group," Miller says, "but it does give you insight. You certainly can look at large trends."

Not only does COFHE give Harvard a sense of what its peers are up to, but the University uses the same formula for determining aid as hundreds of other schools in the nation.

Miller calls the Institutional Methodology (IM), a formula maintained by the College Board in Princeton, N.J., the "foundation" of need determination at Harvard.

Like the majority of the 400 schools who use the IM, Harvard does not base its decisions entirely on the calculations of the formula, but chooses to custom tailor award packages to individual family circumstances.

Nonetheless, the overlap schools subscribe to a common need formula, which accounts for the backbone of their financial aid policies. And since most of these schools are close to need-blind and strive to meet all demonstrated need, they are still able to achieve some degree of uniformity in their financial aid programs.

From Miller's point of view, this is hardly consolation, since he is deprived of the opportunity to "pick the brains of 25 people who do what I do."

The Justice Department pursued the overlap group under the Bush administration and, with a Clinton Justice Department, the schools might try to challenge the ban on collaboration.

But Miller says the current arrangement, for better or worse, is here to stay.

"I don't think anyone believes the Justice Department would allow us to reconstitute," he says.