Inconsistent Federal Guidance Caused Delay in Student Emergency Grants, NASFAA Survey Shows

Nearly 3 in 4 said the Department of Education’s recent guidance did not provide enough direction to disburse emergency grants to students in a timely manner.

May 18, 2020 — Higher education institutions are still struggling to disburse emergency aid grants to students allocated in the last federal coronavirus relief package, largely attributing their issues to confusing and inconsistent guidance from the Department of Education, a survey of NASFAA member institutions shows.

The survey was distributed to more than 2,600 institutions in early May, with 587 surveys submitted, resulting in a 23% response rate. Overall, 72% of respondents said guidance provided by the Department of Education did not provide enough direction to allow institutions to distribute emergency grants to students in a timely manner. 

The Department of Education on April 21 published new guidance that contradicted previous instructions to institutions and declared emergency aid grants provided under the Coronavirus Aid, Relief and Economic Security (CARES) Act be limited to Title IV-eligible students, creating a major hurdle in issuing the grants to students.

Notably, more than 80% of respondents across all sectors said the fact that Department of Education released multiple rounds of guidance regarding the CARES Act has either greatly or somewhat delayed their ability to disburse emergency grants to students. Without that guidance, less than 10% of member institutions who responded said they would have used that criteria on their own. 

Other notable findings include: 

  • Roughly 75% of member institutions surveyed — including both public and private two-year and four-year — said they would require a FAFSA on file for students to receive emergency grants
  • Over 40% of member institutions said they are using a combination of pre-identified students and applications to distribute CARES Act grants
  • Over 50% of respondents said the Department of Education's April 21 guidance limiting emergency grants to Title IV-eligible students greatly altered their plans, with only 3% saying it did not alter their plans at all
  • Less than one-third of respondents said they had disbursed emergency grants to students at the time of the survey
  • Of the member institutions still waiting to disburse emergency grants, 42% said they were waiting on additional guidance from Department of Education and 69% said they still developing policies and procedures for awarding the grants

The survey comes as the Department of Education continues to face criticism over its April 21 guidance, with the California Community Colleges System — the largest community college system in the country — filing a lawsuit against the Department of Education, alleging its reasoning for limiting funds to only Title IV-eligible students was arbitrary and capricious.

“Schools have been committed to getting these funds to students as quickly as possible, but implementation challenges have taken their toll,” said NASFAA President and CEO Justin Draeger. “Unfortunately, it’s the students who end up bearing the brunt of these challenges. We call on Congress and the Department of Education to continue working with colleges on finding and funding solutions to help students during this crisis.” 

For more information and resources on how the spread of the novel coronavirus is impacting student financial aid, please refer to NASFAA’s To request an interview with a NASFAA spokesperson, please email Director of Marketing & Communications Erin Powers.

The National Association of Student Financial Aid Administrators (NASFAA) is a nonprofit membership organization that represents more than 28,000 financial aid professionals at nearly 3,000 colleges, universities, and career schools across the country. NASFAA member institutions serve nine out of every 10 undergraduates in the United States. Based in Washington, D.C., NASFAA is the only national association with a primary focus on student aid legislation, regulatory analysis, and training for financial aid administrators. For more information, visit

Publication Date: 5/18/2020

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