In addition, the Coronavirus Aid, Relief, and Economic Security (CARES) Act includes more than a dozen provisions aimed specifically at assisting students and IHEs struggling to cope with the enormous impact COVID-19 has had on campuses across the country (referred to as the “COVID–19 Pandemic Education Relief Act of 2020”). Some of the more noteworthy sections include:
- Relaxation of Rules for Financial Aid Repayments: Section 3508 includes four provisions relaxing federal financial rules for the period for which a student withdraws due to a qualifying emergency:
- waiver of institutional requirements for the return of Title IV funds;
- waiver of student obligations to return Pell Grants and other grant assistance;
- cancellation of obligation to repay Federal Direct Loans; and
- relaxation of leave of absence rules.
- Continued Payment of FWS to Students Unable to Work: Section 3505 permits IHEs to continue to make FWS payments to students for the period of time during which the student is unable to work (up to one academic year) because of a qualifying emergency.
- Waiver of matching requirement for Supplemental Educational Opportunity Grants (FSEOG) and Federal Work Study: Section 3503 waives the requirement for award years 2019-20 and 2020-21 that IHEs provide a non-federal share to match funds provided under the FSEOG and FWS programs.
- Use of Supplemental Educational Opportunity Grants for Emergency Aid: Section 3504 of the CARES Act permits IHEs to reserve FSEOG funds to award emergency financial aid grants to students for unexpected expenses caused by a qualifying emergency.
- Temporary Relief for Student Loan Borrowers: Student loan repayments are suspended through September 30, 2020, with no accrual of interest. (§ 3513).
- Exclusion from Federal Direct Loan Limit: For loans made under the Federal Direct Loan program (Title IV, Part D), the CARES Act directs the Secretary of Education to exclude from a student’s enrollment period any semester that the student does not complete due to a qualifying emergency. (§ 3506)
- Exclusion from Federal Pell Grant Limit: Similarly, any semester a student does not complete due to a qualifying emergency shall be excluded from the student’s Federal Pell Grant duration limit. (§ 3507)
- Satisfactory Academic Progress (SAP): IHEs may exclude attempted credits that were not completed from determination of whether student is making SAP. (§ 3509)
- Continuing Education at Foreign Institutions: Otherwise eligible programs at foreign institutions may be offered via distance education during a public health emergency. (§ 3510)
- HBCU Capital Financing: Section 3512 permits the deferment of repayments for certain loans to Historically Black Colleges and Universities (HBCUs).
- Service Obligations for Teachers: Section 3519 permits the Secretary to modify the categories of extenuating circumstances for recipients of TEACH grants who are unable to fulfill their service obligations. Teaching service that is interrupted as a result of a qualifying emergency shall be considered full-time service.
- Modification of Institutional Grants: Sections 3517 & 3518 permit the Secretary to waive or modify outcome requirements, current allowable uses of funds, and matching requirements for certain institutional grant programs.
Finally, the CARES Act includes many other components that may benefit IHEs (see overview of the Act here), such as major provisions addressing employment and healthcare, as well as economic development grants for which IHEs may be eligible. Leadership at IHEs should be mindful of these other elements as well when assessing the overall impact of the CARES Act on their institution.
For more information, please contact Jeffrey P. Metzler, Craig J. Saperstein, Barry D. Burgdorf, Roland C. Reimers, Sarah G. Flanagan or Jacob R. Sorensen.
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