The Scale of Emergency Aid Requires More

By Elizabeth Salinas, Juana H. Sánchez and Viviann Anguiano -

As COVID-19 continues to impact students, teachers, families, colleges, and universities across the country, HCM Strategists is working to provide essential thought leadership on the range of issues in the field of education.

Our expert policy staff has launched a new series to identify emerging education policy ideas and practices aimed at addressing COVID-19. Stay tuned for more in HCM’s new series addressing COVID-19 concerns in education, and use #EdAfterCOVID19 to join the conversation on social media. Read more

The economic devastation caused by COVID-19 and the resulting potential impact on college enrollment raises the stakes for emergency aid, especially for students of color. As the academic year winds down, higher education leaders are quietly taking stock of enrollment, and it’s not just projected declines in the numbers of entering freshmen and international students that they are worried about. Recent polls indicate that currently, enrolled students will be far less likely to continue to the next term due to the devastating and prolonged economic impact of COVID-19.

This pandemic has especially impacted students of color, as reflected in recent data. A national poll conducted by Strada Public Viewpoint found that Black and Latinx Americans were more likely to have lost a job, work hours, or income. A third of Latinx and a quarter of Black students reported having to cancel education plans or delay college enrollment. The Education Trust and Global Strategy Group further found that 84% of currently enrolled Black students and 81% of currently enrolled Latinx students are concerned about their ability to stay on track. While 82% of respondents indicated that emergency financial aid would help them stay in school, just 37% indicated that their college or university currently offers this type of support.

Congress anticipated this challenge and moved quickly in the early weeks of the pandemic to designate over $6 billion as a set-aside for emergency grant aid for college students under the federal Coronavirus Aid, Relief, and Economic Security (CARES) Act. Unfortunately, colleges and universities across the country have struggled to get these funds into the hands of students who need it most due to a variety of administrative roadblocks, chiefly the confusing and contradictory guidance issued by the U.S. Department of Education.

As Congressional leaders have reiterated, the CARES Act was intended to provide widespread relief, and the bill did not impose student eligibility limitations so that colleges would not be bogged down in red tape while getting dollars out the door. Education Secretary Betsy DeVos initially said colleges would have discretion over their funds. Yet, the Department has since issued a series of conflicting guidelines to needlessly and cruelly restrict any student who has not demonstrated Title IV (federal financial aid) eligibility from receiving emergency aid, causing confusion and further delaying student relief. For example, the Department’s initial guidance was issued eleven days after colleges could apply for emergency funds. A month later, in response to lawsuits out of California and Washington, the agency updated its guidance, stating it “lack(s) the force and effect of law”. The agency’s multiple rounds of guidance greatly or somewhat delayed awarding emergency aid according to 80 percent of financial aid administrators in a recent survey.

The agency recently issued an interim final rule asserting that going forward all recipients of emergency grant aid must demonstrate eligibility for federal financial aid. This makes it particularly difficult for an institution to provide emergency aid to any student who has not filed a FAFSA, even if they are eligible to file one, because a FAFSA is the only way for a college to confirm whether a student is eligible for federal aid. Many veteran students, for example, do not submit a FAFSA because they utilize federal GI Bill benefits to pay for college. Students who utilize tuition waivers through college promise programs might also bypass FAFSA filing, making it harder for them to receive federal emergency aid funds.

The Department’s interim final rule also excludes an estimated 8 million students, including students who have struggled academically and those who have defaulted on their loans. For these students, their ability to stay in college may largely hinge on their ability to receive just-in-time financial support.

Perhaps most callously, the Department’s actions have repeatedly meant to deny CARES Act emergency aid to undocumented immigrant students. The Center for American Progress estimates that undocumented students helped their colleges bring in as much as $132.6 million in CARES Act funding, for which they are now deemed ineligible. That’s because 25 percent of the formula dollars are based on individuals who did not receive Pell Grants and were not enrolled exclusively online, which presumably includes a large number of the estimated 454,000 undocumented students in higher education. The agency’s interim final rule cites what’s known as the public charge rule as the basis for excluding undocumented students from relief, not its own guidance.

Undocumented students are particularly vulnerable as they are often left out of state assistance as well; half of all states permit colleges and universities to charge undocumented students higher tuition rates and just 7 states allow undocumented students to qualify for some type of state financial aid.

The fate of undocumented students receiving emergencyaid remains dire, even as a federal judge in California has temporarily blocked the agency’s interim final rule in its entirety. Notably, this ruling applies only to community colleges in California and does not apply to the institutions where 80 percent of undocumented students are enrolled.

Collectively, federal guidance has only compounded difficulties that higher education institutions already face in their ability to expediently award emergency aid to students with the greatest needs. Before the health crisis, colleges were just beginning to address unmet needs in a systematic way. HCM Strategists recently documented pre-COVID efforts by state and system leaders to address non-tuition expenses like food, housing, and childcare. Before COVID, about half of community college students and about a third of students at four-year institutions faced food or housing insecurity. The Hope Center found that number increased to 60% of all students in April and May of this year. Additional need warrants additional investment–but how funds are distributed also matters. Below, we lay out recommendations for both federal and state policymakers:

Recommendations for Federal Policymakers 

  • Congress should direct significant additional federal stimulus funds for emergency aid, and higher education more broadly, by using a better formula to allocate aid to states. This would ensure funds are equitably distributed to public institutions of higher education that are already experiencing a financial blow from state budget cuts and serve a greater share of vulnerable students– who desperately need emergency aid.
  • Congress must also not allow the Department to add extralegal requirements that intend to exclude undocumented immigrant students. In fact, the Supreme Court’s recent decision to maintain the Deferred Action for Childhood Arrivals program gives the Department reason to recognize that these individuals are in the country and should not be excluded from receiving emergency aid.

Recommendations for State Leaders

  • State leaders should assess gaps holistically and target emergency aid funding to the lowest-resourced institutions that enroll the greatest number of high-needs students, further reinforcing the strategic opportunity for federal policymakers to direct funds to states.
  • State policymakers should align emergency aid to their larger affordability strategy and integrate information on other financial relief programs. For example, the California State Legislature passed a measure in 2017 that requires the Student Aid Commission to notify Cal Grant recipients who meet eligibility requirements for TANF about their potential eligibility for CalFresh (the local name for SNAP).
  • States can look to established emergency aid programs in Minnesota, North Carolina, and Wisconsin for ideas on how to structure programs, including eligibility criteria, application process, and award size. For example:
    • Minnesota prioritizes allocation of state funding to institutions with the highest need student populations. Institutions with demonstrable homeless student populations can apply for state funding under the Emergency Assistance for Postsecondary Students (EAPS) Grant Program, which they can then use to provide emergency grants of up to $1,000 to cover basic needs like housing and food.
    • Wisconsin set system-wide student eligibility requirements, which are tied to the federal Expected Family Contribution (EFC). Students with an EFC of less than $5,000 who attend any Wisconsin Technical College System or two-year campus of the University of Wisconsin system are eligible for up to $500 in emergency aid.
    • North Carolina’s Finish Line Grants program also provides up to $1,000 in funding to community college students. Students can apply through their college or through an NCWorks Career Center. Funding is distributed by local Workforce Development Boards and typically happens within three business days of a student submitting all required documentation.
  • In establishing eligibility criteria for non-federal funds, states should ensure students can receive emergency aid regardless of immigration status. For example, California is poised to direct $15 million in state General Funds to provide emergency aid to undocumented students attending public postsecondary institutions in the state.

Federal and state policymakers should act with urgency to prevent a generation of talent from getting sidelined. Additional investment in emergency aid and strategic deployment of that aid will help more students reach graduation and become part of our economic recovery story.

Viviann Anguiano is an associate director of higher education at the Center for American Progress. Elizabeth Salinas and Juana H. Sánchez are senior associates at HCM Strategists.

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