[Wsssc] CARES and Tuition

Matthew Campbell MCampbell at pierce.ctc.edu
Fri Apr 17 16:29:40 PDT 2020


Sorry I missed this topic yesterday. I am including some additional information and resources that might help further your contemplation about what this might look like in practice. This topic has been discussed quite a bit with another group I’m connected to and the general tenor has been strong opposition to using funds to either “pay down” outstanding balances or to direct pay to the institution.

The reasoning is that the grant specifically indicates that you cannot use the funds to reimburse the institution (“Recipient shall not use the advanced funds to reimburse itself for any costs or expenses, including but not limited to any costs associated with significant changes to the delivery of instruction due to the coronavirus and/or any refunds or other benefits that Recipient previously issued to students”);
and that the funds are to be distributed to the student (Recipient agrees to promptly make available emergency financial aid grants from the advanced funds directly to students for their expenses related to the disruption of campus operations due to coronavirus, such as food, housing, course materials, technology, health care, and child-care expenses”). It is notable that they do not indicate tuition; it isn’t an exhaustive list, but something as fundamental to higher education as tuition seems to be intentionally not included.

There are also reporting requirements that include criteria used (“how the amount of each grant was calculated, and any instructions or directions given to students about the grants”); so, if you are adding conditions for distributing funds that require them to (re)pay the institution (or direct-pay the institution), that may be seen as a violation of those terms. There do seem to be some interpretations that it would be okay if the student requested that you apply the funds directly to their account, which reflects the guidance Joe describes below about requiring student approval/direction to do so.
Great information about this can be heard in this NASFAA podcast (144)(especially at 14’18”, but it’s all quite good):
https://www.nasfaa.org/off_the_cuff_ep144
Some additional conversation can be heard on the previous podcast (143)(especially around the 24min mark). Other good info therein as well.
https://www.nasfaa.org/off_the_cuff_ep143
Note: the podcast participants are institutional personnel and NASFAA staff, not DOE folks, so opinions/interpretations are presented, not direct DOE guidance …but the risk analysis is quite useful.

Best,
Matt

Matthew Campbell, Ed.D. (he/him/his)
Vice President, Learning & Student Success
Pierce College Puyallup


From: wsssc <wsssc-bounces at lists.ctc.edu> on behalf of WSSSC <wsssc at lists.ctc.edu>
Reply-To: Joe Holliday <jholliday at sbctc.edu>
Date: Friday, April 17, 2020 at 10:23 AM
To: WSSSC <wsssc at lists.ctc.edu>
Cc: Scott Copeland <scopeland at sbctc.edu>
Subject: [Wsssc] CARES and Tuition

CAUTION: This email originated from outside Pierce College. Do not click links or open attachments unless you have confirmed this is an authentic message from sender and know the content is safe. If you are unsure, contact the Help Desk at 253-964-6373 or email Helpdesk at pierce.ctc.edu
Colleagues: Christina, Chio and I discussed this yesterday after the WSSSC call. Regarding the use of CARES Act emergency aid for tuition and fees, if colleges choose to disburse aid directly to students and not apply the funds directly to tuition and fees, they should consider the impact if the student never pays their tuition and fees and they are referred to collections.  Colleges may want to consider getting student approval to automatically apply funds towards outstanding tuition and fees to avoid a potential collections problem in the future.

                             [Joe]
[Compass]

Joe Holliday

Director, Student Services

Washington State Board for Community and Technical Colleges

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