Thoughts From a Past National Chair: Administering CARES Act Funding – Building a Plane While Flying in a Storm

Michael BennettBy Michael J. Bennett, associate vice president of financial assistance services at St. Petersburg College 

Since late March, my life has been consumed trying to administer $13.4 million in funding from the Coronavirus Aid, Relief, and Economic Security (CARES) Act that has been awarded to St. Petersburg College for students and institutional costs. I have been exhausted reading guidance around the clock from NASFAA and the Department of Education (ED), attending webinars of multiple organizations, reading articles from POLITICO, The Chronicle of Higher Education, and Inside Higher Ed, along with surfing through the big waves of internal task forces, lawyers, staff meetings, and addressing the opinions of others on our campus. 

NASFAA's Higher Education Emergency Relief Fund (HEERF) timeline provides an illustration of changes since March 5, 2020.

Colleagues have called late into the night, pleading to "please make it stop!"

I am blessed to work on a campus where our president, Board of Trustees, and senior leadership's strategy and desire was to deliver our institution's CARES Act funds to as many students as possible — and as quickly as possible — assisting our students with pandemic needs for food, housing, utilities, and other expenses.

From the beginning, administering CARES Act funds has felt like "building a plane while flying," and if that is not challenging enough, storms continue to appear in our flight path. We can effectively navigate through the storms, but this requires our willingness to examine what is causing the storms, and guidance from ED. NASFAA, as well as our regional and state associations, have done a wonderful job to help us avoid these "storms" where possible.

Financial aid administrators, despite their grit and talents, cannot administer the CARES Act funds without ED providing clear, timely written guidance. When questions are not being answered for weeks by those responsible, are being referred to a website of incomplete question-and-answer pages, or are being answered in pieces with several individuals (a version of "hot potato" and "maybe my colleague could answer this") on a webinar, we collectively know this approach simply does not work in a regulatory environment.

Even the Government Accountability Office (GAO) in a recent report highlighted the discrepancies in ED's communications. In response to a draft of the report, ED said there should have been "no question" about which students would be eligible to receive emergency aid, harkening back to its justification that it was following Congress' intent. Any school that abandoned its initial distribution plans after the April 21 guidance was released, "ignored the flexibility of [ED's] communications not being legally binding at that time," the report said.

But GAO backed a critique that many in the higher education community have leveled against ED: the agency didn't clarify that its guidance did not have the force and effect of law until one month later, on May 21. ED also "appears to intend its interpretation to be legally binding, as indicated by the issuance of the interim final rule," GAO concluded.

Dakota Tribal wisdom states: "When you discover you are riding a dead horse, the best strategy is to dismount." Changing the requirements, trying to declare that the "horse" is not dead, makes our efforts ineffective and does not reflect serving students or taxpayers.

To be three months into administering program of this magnitude and not have a defined, accessible reporting mechanism in place is unacceptable for administrators and taxpayers. Advising colleges to provide "detailed reporting" in case of audits but leaving said reporting to institutions — rather than developing a system — is not a partnership. To then state that there will be more surveys and data collections further burdens campuses and further delays financial aid administrators from distributing these critical funds to students.

This is not the intent of Congress, but an unfortunate result. For many students, aid delayed is access denied.


Publication Date: 7/2/2020

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