ED-2020-SCC-0122-0138
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Peter
Goss
peter.goss@pcc.edu
Portland Community College
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I appreciate the scope of
what the Department is trying to do, but similar to my comments
on the initial draft, I think this collection really works only
in the context of imagining a single distribution point and
method.
The picture quickly starts to become muddled
(and thus yield unreliable and almost certainly misleading data)
when trying to capture multiple disbursements, potentially using
multiple methods, over a longer range of time.
I can
see there is guidance here intended to address this problem in
the footnotes of #8, but from my view it merely bakes in certain
problems. It's going to be a significant amount of labor to
reproduce to fit this format. Moreover, I am skeptical the
resulting output is going to reflect what we actually did, much
less be comparable across other institutions.
In broad
strokes, in spring and summer quarters PCC funded 100% of
eligible students; fall we funded roughly 2% of eligible students
because the fund had been nearly expended. Since we did spend a
non-zero amount we will have to include those fall counts in the
total per the instructions, and the average counts will be skewed
in a misleading fashion.
#10 is complicated in myriad
ways and is the item I have the most concern about how we can
pull this data.
For one, as a community college it's
not atypical for students to have multiple declared simultaneous
programs. If a student completed their associates spring but
withdrew in fall from their certificate program, do we report
that as both a completion and a withdrawal?
Likewise,
if the students received HEERF funds in spring, but not
summer/fall and withdrew fall for financial reasons, it appears
we report them as withdrawn even though that would suggest the
CARES funds were not effective even when they likely were and
additional funding may have helped that student persist.
I
do greatly appreciate that #9 appears to mirror the format of the
current quarterly reports, and that it appears ED did make some
tweaks to #5 and #6 to better reflect data from schools using
multiple methods.
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No
change.
ED
appreciates the commenter’s response to updates regarding
item #9.
On
Item #10 and as noted in the response to comments on the 60-day
notice:
ED
acknowledges that institutions may choose to make HEERF Emergency
Grant disbursements at different times. The institution should
designate the students’ Pell or enrollment status based
their status at time of the first HEERF Emergency Grant
disbursement.
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ED-2020-SCC-0122-0142
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Brostrom@ucop.edu
University of
California
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Item 8 Table, Page 5
‘HEERF Amount Disbursed (18004(a)(1) Institutional Portion)
Question: “What was the amount of the Institutional Portion
of HEERF that was used to recover the cost of reimbursing
students for room, board, tuition, or fees?”
Comment:
The table requires reporting on Pell grant / Non-Pell grant
recipients for both the student aid portion and the institutional
portion. The HEERF institutional funds were used to reimburse for
losses at the institutional level. According to ED guidance, the
institutional funds are eligible for use to supplement emergency
grants to all students. However, this table requires reporting on
the institutional funds that are used to reimburse the
institution for housing and dining refunds be parsed to fit
within the same reporting structure as the emergency grants (UG
Pell/non-Pell). Is the intent of reporting in this manner to
limit the use of institutional funds to reimburse refunds
provided to only Title 4 or Pell eligible students? The
University has a concern that the table implies certain
limitations on the use of the funding - after the refunds have
already been issued nearly 8 months ago - when the initial
guidelines that were provided were far more flexible in general.
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No
change. ED does not intend to limit the use of HEERF (a)(1)
Institutional Portion funds for reimbursements to Pell-eligible
students. Funds may be used to reimburse Pell grant recipients
and/or non-Pell grant recipients and should be reported in the
appropriate columns for each category in the table in question 8.
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ED-2020-SCC-0122-0144
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Mary Jean Sullivan
Hollins
Collee
corrissmj@hollins.edu
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I'm a financial aid
administrator at a small liberal arts university with a high
percentage of Pell recipients. For question # 3 of the proposed
data collection form, my university started out with an
application process. Then, after we made two groups of emergency
fund disbursements, we still had funds leftover. So, we
identified students with high-need who should have applied but
didn't (including unemployed students and/or high-risk students,
such as homeless students and orphans) and offered them funds.
However, this form assumes that only one method of determination
was used. It might be helpful to not make this question so
fixed/static. I suppose I'd pick the option for "we used an
application" but that wouldn't give you the full story. You
know what I mean? As time went on, the application was helpful in
the beginning but we needed to use another strategy to assist
some of our neediest students who wouldn't speak up.
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No
change. The data collection instrument already allows grantees to
report other methods of determination.
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ED-2020-SCC-0122-0045
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Post-Sec
Data
Mamie
Voight, senior vice president of research and policy at the
Institution for Higher Education Policy (mvoight@ihep.org or
202-587-4967).
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Maintain and expand
data disaggregation.
Identifying
the number of students and dollar amounts of emergency aid
awarded through HEERF is a core component of the proposed data
collection, and differentiating between funding to graduate and
undergraduate students, Pell recipients, and full- and part-time
students (question 6) will be essential in understanding who
benefits from the emergency federal aid. The Pell disaggregate is
especially important because it will provide information on how
much emergency aid went to students who were in an economically
precarious position even before the onset of the pandemic. Pell
recipients are likely to have been further burdened by COVID-19’s
economic and educational impact, so transparency about the extent
of the support these students received will be of paramount
importance to the higher education community in the years to
come.
In
addition to the disaggregates already included in the form,
PostsecData strongly urges ED and OMB to require data to be
disaggregated by race/ethnicity. The pandemic has
disproportionately impacted the health and economic well-being of
Black, Indigenous, and Latinx students, along with their families
and broader communities, so disaggregating data on student
emergency grants by race and ethnicity is critical to
understanding the extent to which the federal funding is tackling
these inequities. While this recommendation would require adding
columns and permutations to the existing structure, institutions
should have student race/ethnicity information readily available
due to other required reporting (such as the IPEDS collection).
Add
overall spending on emergency financial aid to students to the
quarterly report.
We
appreciate the addition of quarterly reporting on the
institutional portion of HEERF; however, these reports exclude
the emergency financial aid grants to students provided by the
Coronavirus Aid, Relief, and Economic Security (CARES) Act. We
recommend the addition of an overall category in the quarterly
form that reports on the total amount of funds awarded by quarter
to students for emergency aid. This will provide needed insights,
in a centralized location, on how institutions allocated
financial aid to students throughout the year. We included an
example of this question in revised question 9 in the Appendix.
Collect
more detailed completion and withdrawal rates and employment
figures.
PostsecData
appreciates the addition of students “still enrolled”
and “completed” to revised question 10 and recommends
that ED and OMB consider how to incorporate a comparison group to
gauge withdrawal rates of students who did not receive financial
support. Existing or forthcoming data from IPEDS would not
necessarily provide comparable data or be measured within the
same timeframe to appropriately contextualize outcomes of HEERF
recipients.
Similarly,
revised question 10 asks for the number of full-time equivalent
(FTE) positions in 2018, 2019, as of the start of the pandemic,
and at the end of the most recent reporting period. We believe
this information will provide valuable insight into how
institutional capacity has been impacted by the pandemic and
associated stimulus funding provided through HEERF. However, we
recommend that ED and OMB adjust the reporting requirements to
include separately the number of FTE instructional staff,
non-instructional staff, and student undergraduate and graduate
employees. Each of these categories serves a unique function for
universities, and these categories are aligned with IPEDS
reporting requirements, moderating the additional burden in
reporting more detailed employment figures. This more granular
information would provide a way to assess how the distribution of
staffing has changed in the aftermath of COVID-19.
Include minor edits to
questions on emergency financial aid grants to students and
consider collecting information about institutional data-sharing
and use policies.
PostsecData
strongly supports data collection examining the processes
institutions use to allocate emergency financial aid grants to
students under HEERF and believes this data will be extremely
important in evaluating these funding strategies in response to
the pandemic. PostsecData would like to thank ED for including
changes to revised question 5, and we further recommend that
institutions report on whether students were required to submit
documentation of their difficulty in meeting expenses, as well as
any new academic requirements put in place for emergency fund
eligibility.
In
the interest of student privacy, PostsecData would also encourage
collection of information regarding whether institutions
communicated with students about how their data would be
collected, secured, and shared and for what purposes. We have
included a suggestion for how this question might be framed in
the Appendix.
The
undersigned members and partners of PostsecData encourage OMB and
the Department to adopt these recommendations as they finalize
institutional guidance for reporting under HEERF.
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No
change. The only new comment was about the question on emergency
financial aid to students. This comment is covered by the
question which
asks institutions for their “instructions, directions, or
guidance” on disbursement/eligibility for emergency student
financial aid grants.
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