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During its weekly telephone town halls, NACUBO is asking its members to respond to flash polls on emerging topics of concern to business officers in light of COVID-19. Results are collected during the telephone town hall and through the week. 

NACUBO’s May 5 flash poll focused on the emergency grant aid for students at institutions of higher education provided by the CARES Act Higher Education Emergency Relief Fund. Colleges and universities have begun to distribute the more than $6 billion available, but our survey results show that compliance obligations have made distribution of aid difficult. College and university business officers remain concerned about students adversely affected by the coronavirus pandemic but are unable to access these federal funds due to the rules established by the federal government. 

NACUBO received 262 valid responses to the May 5 poll: 144 four-year private non-profit institutions, 67 four-year public institutions, 37 two-year public institutions, and 14 institutions categorized as “other.”


Our open-ended question for this poll asked, “What other student emergency grant-related challenges or concerns have emerged on your campus since the onset of the COVID-19 pandemic?” Three key issues emerged:

  1. College and university administrators remain concerned about students who are ineligible for the CARES Act emergency aid; this includes international students, Deferred Action for Childhood Arrivals (DACA) students, and online students.
  2. Compliance burdens associated with the aid have sowed confusion and slowed the ability of colleges and universities to expeditiously distribute the aid. 
  3. Higher education business officers are concerned about magnitude of the pandemic, the economic outfall, and the long-term impacts on their institution.

1. Ineligible Students. Only students who are or could be eligible to participate in Title IV programs may receive emergency financial aid grants, according to an FAQ from the Department of Education. Essentially, students who have completed a FAFSA or are eligible to do so can receive the grants. The criteria include but are not limited to: U.S. citizenship or eligible non-citizenship; a valid Social Security number; registration with the Selective Service (for male students); and a high school diploma or GED. This results in ineligibility for DACA students and most international students. Additionally, ED guidance notes, “students who were enrolled exclusively in online programs would not have expenses related to the disruption of campus operations due to coronavirus.” Many business officers were disappointed by this criteria and responded to the poll, commenting: 

 “International Students moved off-campus for health, but unable to work elsewhere due to visa issues.” “International students need aid so using donor funds for this need.”
 “DACA and international student needs which are unmet by the CARES Act.”
“Our online students have been hurt by COVID as much as the on ground and we are not able to help that due to no funds.”
“Online exclusive students were excluded and they are working adults usually who actually have been impacted more by the virus than our traditional aged population due to job losses.”

2. Compliance Burdens. ED issued initial CARES Act aid information on April 9 but did not release the more the detailed guidance for emergency aid grant dollars until April 21. Some schools had already initiated distribution plans that needed to be revised after the release of the April 21 guidance.

“The biggest challenge we faced was quickly creating and rolling out a grant process, only to have additional ED guidance make us backtrack on what we had already done. Some students had already been ‘approved’ through the initial program only for additional ED guidance to make them ineligible.  We had to rework our entire program.”
“Disbursement of the funds to students is challenging. It requires support and collaboration from various areas including Financial Aid, Bursar, Fiscal Affairs, and Information Technology.”
“Changing ED guidance, creating a fair distribution plan, afraid of running afoul of ED's guidance that might come up in future after awards have been made.”
“Changing guidance from Dept. of Ed. that narrowed the scope of allowed disbursement.”
“timing on the delay on guidance = delay in helping students”
“Primarily the confusion on how to disseminate given the fed strings attached released weeks after the fact and the logistics of ensuring appropriate documentation is established to ensure reporting to feds, while still not knowing what the requirements will look like.”

3. Pandemic Impacts. NACUBO’s April 28 flash poll focused on issues related to Fall 2020 enrollment. Respondents expressed concerns about the unpredictability that surrounds planning and budgeting for the fall, and those sentiments were again expressed in the open-ended responses to this poll. 

“Reopening the campus.” 
“The magnitude of the financial impact if we cannot open in the fall term will be much larger than the impact of closing the spring term early.”
“Hesitation from students on registering for fall classes until they know if they will be in person.”
“Housing for fall, what social distancing rules will be in place.”
“Loss of summer revenue”
“Additional emergencies that may arise in the next 4 months as we try to re-open.”
“Enrollment decline concerns.”

Tuition revenue and net revenue from services such as housing, dining, bookstores, parking, and more all support an institution’s general operating budget. For public institutions, state appropriations are an additional source of support—and may be tied to enrollment. While some colleges may be able to offer extensive online educational offerings, this may not produce adequate revenue for some colleges and universities to operate. 

Most schools budget their operations based on the revenue they anticipate. Colleges and universities will have to adjust academic offerings and they also will need to find a way to cover the costs affiliated with building and facility maintenance, security, and more if enrollment declines significantly in the fall.


Ken Redd

Senior Director, Research and Policy Analysis


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