By Owen Daugherty, NASFAA Staff Reporter
As colleges and universities work to get emergency funds into students’ hands as quickly as possible during the global COVID-19 pandemic, they’ve also been meticulously documenting each step of the process along the way to comply with federal reporting requirements, according to several schools that NASFAA interviewed.
With the roughly $14 billion allocated to higher institutions under the Coronavirus Aid, Relief, and Economic Security (CARES) Act came reporting requirements from the Department of Education (ED), mandating that schools must publicly post via their website a variety of items, including the total amount of funds received, the total amount that has been distributed to students, the total number of students who have received an emergency financial aid grant. Schools are also required to show how they determined which students did, or will receive emergency financial aid grants and how much funding they did, or will receive, among other things.
For each member institution that NASFAA spoke with, the looming possibility of an audit was a recurring concern, as well as the fact that confusing and often conflicting guidance from ED created obstacles and in some cases slowed down getting the money to students.
Andrew Hammontree, the director of financial aid at Francis Tuttle Technology Center, a small technical school in Oklahoma City, said it made the most sense to give every student enrolled in a career training certificate program a block grant, without requiring them to submit an application.
To determine the amount each student would receive, Hammontree said his office calculated the cost associated with the program for each week, and gave each student a grant equal to the cost for the total weeks of closure. In this case, because the school closed for two weeks, they gave each student a $700 grant.
“We felt like we should pay the expenses that are related to the students’ cost of attendance for that two-week period [when] we were closed,” he said. “If students had excessive need above the $700, they could apply to the emergency grants application that we've got on our website.”
Hammontree posted his school’s reporting requirements in PDF form on the institution’s COVID-focused webpage. He said it will be updated every 45 days, in accordance with ED’s requirements.
For Francisco Valines, director of financial aid at Florida International University (FIU), being located in hurricane-prone Florida meant the school had emergency response plans in place and students were already accustomed to going to the school’s website to find up-to-date information and resources.
FIU created a COVID-specific webpage, complete with an FAQ document detailing financial aid implications, refunds, and information about the CARES Act. On the FIU homepage, a large banner appears at the top directing students to the COVID-specific page, where the school’s required reporting elements and the emergency relief grant application are hosted. Students were required to submit an application in order to receive an emergency grant.
Initially, ED indicated that institutions were required to submit their first report 30 days from the date the institution signed the certification and agreement form. In following guidance, ED changed that date to 30 days from when the institution received its student portion of the Higher Education Emergency Relief Fund (HEERF).
But because of confusion surrounding the 30-day reporting requirement, Valines said to cover his bases he still posted information within 30 days of signing the certification form.
“We felt like we just wanted to be extra conservative,” he said. “Because there was a lot of talk and concern about getting the funds to students quickly, but also making sure you follow whatever guidance there was.”
Valines said FIU formed a task force composed of high-level officials at the university so the school could best address all the disruptions that came from the pandemic, and so it could properly follow all reporting requirements and guidance from ED.
“We got the guidance from [ED] on what they wanted on the webpage,” he said, referring to the reporting requirements. “We tried to stick to that pretty strictly, but also kind of adding what we thought would be helpful for people to understand.”
Brent Tener, the director of financial aid at Vanderbilt University, said his office posted the university’s required reporting elements online the day after ED’s interim final rule (IFR) — which doubled down on its position that only Title IV-eligible students can receive the funding — was publicly released. Tener added that the IFR didn’t impact how Vanderbilt distributed the grants though, since the university had already decided to use Title IV eligibility as a determining factor and disbursed its money to students within days of receiving it.
“I know that some schools are still trying to work their way through this, and the money will be really helpful to students when they get it, but we wanted to concentrate on getting the money in the students’ hands,” he said, adding that Vanderbilt did not use an application to determine which students would receive the funding.
However, even before Vanderbilt received CARES Act funding, it published an application for students so they could receive hardship emergency funding from the university — something Tener said was able to help more than 1,000 students.
Hammontree, Valines, and Tener all said that no matter what steps they took to distribute the funding to students, they did so knowing an audit could be coming.
“Ultimately, I'm the one that may have to defend this to an auditor or a program reviewer,” Hammontree said. “Every decision I make is based on what I think an auditor will think. I've dealt with auditors enough to know that you have to have your ducks in a row.”
Publication Date: 6/23/2020