Covid-19 Justice Higher Education

Gen Z Begins Fightback for College Relief

By Greg Moses


College students last week gained tenacious footing and found ways to fight back against pandemics of disease and insecurity, but their struggle is still overlooked in the grand scheme of trillion-dollar rescues that focus on fruits, not roots of human flourishing.

After a month-long delay caused by a foot-dragging and mean-spirited Department of Education (ED), a few college students in the last days of April got federal help with the cost of housing, food, child-care, and course materials.

Based on applications they were finally able to file after 6pm April 29, about 2,000 students at Houston Community College received a total of $1.6 million over a 15-hour period, an average of $800 apiece. Half the money requested went into rent.

While this partial rescue of some Houston students was matched here and there, millions more students did not see CARES Act funding by May Day, because many colleges went into the weekend intimidated by an ED warning that more rules could be posted, maybe today, to further restrict the emergency relief funds that Congress passed into law Mar. 27.

Financial aid offices are feeling guarded about ED directives that first secured signed oaths of obedience and then promulgated startling edicts on an irregular schedule. Witness the case of the 13 FAQs that two weeks ago banned emergency relief for undocumented students, foreign students, and citizens who were not already FAFSA qualified for federal Title IV relief, such as Pell Grants. Democrats in Congress complained last week about the ED restrictions, but any wrangling at this point can only aggravate the issue of justice delayed.

National Student Fightback

Last week was also a week of emerging fightback as two national student interest orgs began to shake off shock waves that have stunned higher ed communities since President Donald J. Trump declared the COVID-19 pandemic a national emergency on Friday the 13th in March.

In an open letter to college and university leaders posted Apr. 27, Young Invincibles asked Harvard and Stanford to reverse what they did two weeks ago when the schools refused to accept federal money that was headed in their direction for emergency student relief. The campuses were bullied out of accepting the relief funds, when Trump and others argued that the campuses were rich enough to rescue their own students locally. Young Invincibles argued that federal funding rules would have allowed the schools to give CARES Act money to nearby campuses if there was not sufficient need among their own students.

“Harvard could have sent their money to Bunker Hill Community College,” says the letter, referring to published ED guidelines. “Stanford could have sent theirs to Bay Area community colleges. How could anyone who has followed education for the last three years entrust dollars Congress explicitly directed be put in the hands of students as fast as possible instead back in the hands of this Department of Education?”

President Trump and cabinet cadres aimed blazing attacks at well-endowed campuses for the offense of having federal funds given them to help students with emergency relief. As it turns out, the same rule makers who restricted the funds to FAFSA qualified recipients and who gave campuses the ability to share with neighboring campuses were—those very same rule makers–not interested in the speedy flow of relief according to the rules they made. Instead, they took the opportunity to shame well-endowed schools for having the wherewithal to be well-endowed in the first place.

A statement by Stanford on Apr. 22 totally dressed itself in the fast fashion of vicious resentments enunciated by Trump, et al. Stanford talked about its own identity in relation to “smaller colleges,” completely forgetting that half the money was mandated to go into the hands of students, not any college of any size, or that all of the money could have directly helped students with housing, food, child care, and technology.

Meanwhile, news out of California indicates that Stanford is likely engaging in predatory labor practices in the way it laid off workers. One rule of CARES Act funds requires institutions to preserve jobs as far as practically possible. So, how do we make the case that Stanford couldn’t have allocated millions in emergency relief for its students, allowing more people to cope with California rent notices, meanwhile shuffling some of its fungible “bigger university” money to workers, who, by the way, also have May rent, June food, and child care bills to pay.

Another example of pushback came from Student Defense, the National Student Defense Network, which filed a class action lawsuit on Apr. 30 against ED and its Secretary Elisabeth DeVos for unlawful garnishment of wages for student loan payments. ED had promised in a press release of Mar. 25 that wage garnishments would be stopped immediately, two days before the CARES Act banned the practice through Sept. 30. On the day Trump signed the CARES Act, DeVos addressed the President at a White House coronavirus task force press briefing and declared that garnishment had been stopped, “altogether.”

On Apr. 21, The Washington Post reported that ED was “dragging its feet.” Letters had not yet been sent to employers directing them to stop the garnishments. On Apr. 24, as the Student Defense lawsuit alleges, a paycheck was garnished belonging to 59-year-old home health care aide Elizabeth Barber, who is paying for an unfinished psychology degree, and whose earnings total about $20,000 a year. Barber and Student Defense are suing in behalf of all federal student loan borrowers “from whom the Department is garnishing wages in violation of the CARES Act.”

Distractions of Indignity

The Trump thump on the heads of world-historical campuses, combined with the petty indifferences of ED, are not only cruel tactics. Their cruelty has strategic effect, provoking controversies over petty cash while world-historical deals are cut, out of sight, denominated in trillions.

The CBO shared a few slides in preparation for its Apr. 28 briefing before the House Budget Committee, projecting that the US labor force will suffer an 18-percent depression-sized reduction in Q3. Real GDP will contract 12 percent in Q2. The federal deficit will run to $3.7 trillion in fiscal 2020, up from the $1 trillion widely expected before Spring Break.

As a result of this wartime-level deficit spending, not seen since 1945, the federal debt will rise from the 79 percent of GDP that we saw in 2019 to–wait for it–108 percent of GDP in 2021. That’s a virtual 30 percentage point rise in the national debt because of pandemic costs.

While a multi-trillion-dollar Trump pump in debt and deficit deployment is underway, he’s got his cabinet down in the weeds, bickering with us over chump change. I am not saying that the money is meaningless to the people who need it. I am not saying that Young Invincibles or Campus Defense should stop fighting for the dollars they can rescue. What I am arguing is that while we are engaged in those tactical battles, we have to maintain strategic capacities of analysis. Almost two months into this national emergency, no serious federal program for college relief has been dealt into the cards. We have not grasped the world-historical scope of our higher ed struggle.

No Money to Follow

Do the states have the capacity to support our college economies? Last Monday, the going estimate from the National Governor’s Association was that half a trillion in Congressional support would be needed to keep state budgets from collapsing. By Wednesday morning, the Center on Budget and Policy Priorities (CBPP), having previewed the CBO slide show, clarified the predicament.

States will be lucky to face $110 billion in shortfalls in 2020, says CBPP. Come 2021, we are looking at a $350 billion shortfall, the worst of the century–worse than the dot com bust of ’01 or the financial crisis of ’08. And if we do manage to get a handle on this pandemic, then the shortfall for 2022 will only be $190 billion. Total state shortfalls for the three-year war on COVID-19? $650 billion. Do we prime that pump today, or do we wait?

Take Texas for example. With an economy of a quarter-million college students, do you think Texas will step in and save its colleges from unforgettable cuts? The speaker of the Texas house is already requiring state agencies to cut budgets. If you think this is not a leading indicator, please go find me some flag-wrapped gun-toting protester who is planning to volunteer their personal income tax for the first time in Texas history. Either that–or assume austerity of the grim-season kind.

Roots for Gen Z

If states don’t step up, if the federal government doesn’t weigh in with a trillion-dollar deal, will we ask students to soak up tuition increases and bundle them into another generation of loans?

Forty percent of Americans ages 18 to 24 are hanging onto a college dream. Editor Scott Jaschik of Inside Higher Ed reports that consensus estimates are converging on a 20 percent decline in enrollment for four-year colleges come Fall 2020.

“In the meantime,” higher education expert Ben Miller of the Center for American Progress tells CounterPunch, “what I’m really worried about is what this remote learning environment is going to mean for students from traditionally underrepresented backgrounds. We definitely need to ensure that federal money goes to increase supports for these individuals.”

As Miller worries, the combination of economic trauma and technology-intensive solutions will surely aggravate social inequalities, hurting rising classes most among Black and Latinx communities, even as the US is emerging as a majority minority society.

The national flotilla of higher ed has been set adrift. We have an officially declared national emergency that has devolved into campus-by-campus recriminations. Every local battle over tuition and fees overlooks the compulsory pressure of global pandemic and internalizes the assumption that our struggles are not worth national relief. As a result, each and every campus will contribute to declining national labor participation. In the end, the objective futility of a campus-by-campus strategy will impair college opportunities for Gen Z across the board.

So where is national leadership in this struggle? Last week, Young Invincibles and Student Defense established a kind of bulkhead for a national student struggle. Under normal circumstances the timing is lousy. The last thing you want to see is student momentum only beginning to build as we head into final exams. Technology and social media may offer hope, that is, if it these methods can withstand onslaughts of resentment and discrimination that are already dominating trending discourse.

Are we seriously going to drift along into a COVID-19 solution for higher ed that will effectively offload the cost of this debacle onto upstream cargos of student debt? We are already in this moral equivalent of war together, as one Harvard professor nearly said. Are we going to fight to win it?

If this debate ever works its way to #trending, and if we are bold enough to talk in terms of trillion dollar deals, I hope we will consider the counsel of that world-historical educator, Confucius, who in his higher education mission statement of 500 BCE declared, “It cannot be, when the root is neglected, that what should spring from it will be well ordered. It never has been the case that what was of great importance has been slightly cared for.” While we make visible efforts to protect the earned fruits of Boomers, Millennials, and generations in between, it cannot be the case that we silently care slightly for the roots of Gen Z.

Greg Moses is editor of The Texas Civil Rights Review and a member of the Texas Civil Rights Collaborative.

Covid-19 Justice Higher Education

$50B for Higer Ed Relief will Help, if it Supports Underrepresented Students: Q&A with Higher Ed Expert Ben Miller

The Texas Civil Rights Review (TCRR) is doing incubator work on ideas to make a difference during the higher ed crisis precipitated by the COVID-19 pandemic. So we reached out to Ben Miller, Vice President for Postsecondary Education at the Center for American Progress.

We were drawn to Miller by something he said to Inside Higher Ed: “Everything’s really, really terrible for everybody.” We asked Miller a couple of big-picture questions.

TCRR: You suggest that perhaps relief to colleges should come in the state and local government installment. How much do you think is needed?

Miller: So I think the exact amount needed depends on the total amount provided to states for everything. The less you give states in total, the more your higher ed number probably needs to be, because that’s going to be the place for a lot of cuts.

In general, I think the National Governor’s Association request of $500 billion more for states is probably the minimum of what we need, at least assuming we get back to something looking like normalcy by late summer or early fall. We’ll probably need more if we go longer than that, which is totally possible.

So, at $500 billion total for states, $50 billion, give or take, for higher ed, is probably about right. I’m not sure it’s going to be enough for the whole of the crisis, but it could at least get us through the fall.

If you think about it, total state spending for public higher ed is about $96 billion. So $50 billion that can be spent over a couple of years is a meaningful level of assistance.

TCRR: Students are showing signs of resistance, but their tactics are focused on campus administrations. To us, this is like asking cities and towns to take the lead in paying for COVID-19 costs. Would a realistic federal relief plan for campuses be able to help reframe the campus costs of COVID-19 as a federal issue, not a campus-by-campus issue?

Miller: The student reaction on prices is tough. Those who are most vehement about pushback are at expensive private colleges, which makes sense, because their whole value proposition is that they provide that high-touch, in-person experience.

In the public space, my fear is we’ll see massive tuition spikes that aren’t really the schools’ fault. And that’s where you need the state money to avert those.

What the money won’t do is affect the perceived quality of teaching. I think a lot of students out there feel like even the best online option is not giving them equivalent value of the in-person experience. Part of that gets at the fact that the price of what they are paying for is not just the academics but the overall experience. That’s going to be a tough sell and sort of rests on the colleges to figure it out. Now, greater funding would help mitigate that price from going up. But, for those places that are already expensive, it won’t really help them.

In the meantime, what I’m really worried about is what this remote learning environment is going to mean for students from traditionally underrepresented backgrounds. We definitely need to ensure that some of that additional federal money goes to increase supports for these individuals.

Covid-19 Justice Higher Education

College Students Must Reject the Bait of Divide-and-Conquer Attacks on COVID-19 Relief

By Greg Moses


In a stormy week of denunciation and discrimination, the Trump administration sent a blaring announcement to America’s college students: you shall not be in this together.

Everything now depends upon college students resolving to believe different.

Wedges of denunciation and discrimination were hammered in this week, beginning Monday morning with a Huffington Post headline that read, “Harvard, America’s Richest University, Grabs Nearly $9 Million In Taxpayer CARES Aid.”

The word “grabs” gave an impression that Harvard made some special effort to secure its share of a $12.5 billion relief package for higher education that was included in the CARES Act, signed into law Mar. 27.

In fact, as Harvard attempted to explain for about a day, the money was allocated by a US Department of Education (ED) formula that proportioned the aid across 5,000 campuses according to a broad estimation of student financial need–-a formula that resulted in 350 campuses assigned more money than Harvard.

While the HuffPo column correctly reported that at least half of the COVID-19 relief money to Harvard “must be reserved for emergency financial grants to students”–-as mandated by the CARES Act for every campus–the column also speculated that “at least some of that money, which could be used to cover tuition payments and course materials, would also end up in Harvard coffers.”

The First Wedge: Resentment

Harvard attempted to push back the tide of resentment, beginning with a Monday evening statement to the Boston Herald that, “Harvard is actually allocating 100 percent of the funds to financial assistance for students to meet their urgent needs in the face of this pandemic.”

But the drumbeat of denunciation was joined by Treasury Secretary Steve Mnuchin, Education Secretary Betsy DeVos, and President Donald J. Trump (at a pandemic briefing, no less), forcing Harvard, Princeton, Stanford, and Yale to announce that their students would not be taking the money that Congress wanted them to have.

While the resentment of the HuffyPo and the bullies of Article Two might be defended as an attempt to keep the rich from getting richer during the pandemic, they chose a cruel line to draw against emergency aid to students. As if we don’t see what is happening with banks, bond holders, hedge funds, and business owners?

A financial-aid fact sheet at Harvard’s web site states that 55 percent of undergraduates receive needs-based Harvard scholarships. 20 percent of Harvard parents have total incomes less than $65,000, two-thirds of students work during the academic year, and 17 percent of about 6,600 undergraduate students are Pell Grant recipients who undergo rigorous means testing, federally regulated under provisions commonly known as Title IV.

By yanking back federal emergency relief from such students, the White House and its allies spiked an ugly but effective wedge against possibilities of cross-campus student solidarity. The Trump instinct for divide and conquer was achieved, once again, with astonishing speed and finality.

Another Week in Trump’s America

For a week that began with a question that no headline was asking–where the heck is that student relief money already?–the Monday morning spin achieved remarkable suspicion and resentment, practically justifying the administration’s slow rolling of emergency student relief in the first place.

Although ED promised “immediate” release of funds on Apr. 9–-funds that were authorized on Mar. 27–-the fact is that experts knowledgeable in financial aid were unable to verify on Apr. 16 that any of the funds had actually hit any campus.

We have one unconfirmed report from an expert source that money was beginning to hit campuses this week. By Thursday morning, it was estimated by our knowledgeable observer that about $750 million of the first $6.25 billion allotment had been distributed to “a few hundred” of the 51-hundred campuses, which would amount to a 12 percent distribution of emergency funds, four weeks after the CARES Act was passed.

Setting aside pre-emptive Sunday interventions of the Federal Reserve Bank on Mar. 15, compare the speed of distribution of funds for federal student emergency relief to the direct deposit of federal treasury checks or the support of federal small business loans. Treasury checks were hitting bank accounts by Apr. 13. The SBA ran out of $350 billion by Apr. 16, before ED even began to push a paltry $6 billion in “student emergency relief” out its door. And this is not half the scandal.

A Student in Need is a Student Indeed

This week’s voices of resentment have snapped the neck of Congressional intent, which was to meet needs of students, no matter where they go to school, or where they come from. The emergency aid was intended to find any student who was suddenly ejected from a dorm room or who was scrambling to make up wages disappearing from their own jobs or the jobs of families back home.

The timing of the attack was a maneuver of expert warfare, as new rounds of COVID-19 relief funding are being negotiated on Capitol Hill. The attack is a political chiller against relief efforts for American college campuses, exactly when those efforts demand unified pressure to force a paradigm shift in student support.

Wedge Number Two: Discrimination

Are we all in this together? As ED was beginning to trickle out the funds this week, the financial aid community was stunned by the release of a 13-question FAQ which, in effect, said to foreign students and undocumented Americans: no we are not with you, either.

Before Tuesday’s FAQ, financial aid experts believed that Congress intended to cast a wide net, at least with the “student” half of COVID-19 emergency relief. They were hoping to disburse the funds with short-form requests that would not be closely tied to more detailed Title IV federal financial aid requirements, although the law allows institutions to use their Title IV systems to disperse the funds.

In a FAQ that caught many by surprise, ED said that students eligible for this round of emergency relief must be eligible for Title IV–or “could be” eligible. What this means to scrupulous financial aid professionals is that if a student is not already on federal Title IV rolls, they will need to submit a time-consuming FAFSA application.

This is a more interesting twist of fate considering that a FAQ on the ED web site made it really difficult for Harvard money to go anywhere else except to Title IV students, even as the Secretary of Education—that same day!–was calling on Harvard to not take the money. Talk about your political squeeze play.

The surprise Title IV “clarification” has the effect of excluding foreign students and undocumented Americans. In fact, financial aid professionals were quick to allege that the Title IV clarification was aimed precisely at foreign students and undocumented students, especially the undocumented students who have achieved tentative legal status under the federal DACA program initiated the summer before the 2012 election.

Daggers for DACA

“I find this merciless and repugnant war on DACA students by this administration to be repulsive and over the top,” is how one financial aid expert put it, who went on to say:

“I just find that the lengths that the administration goes through to prevent any benefit from going to DACA students–who for all intents and purposes consider this their home, grew up here, stayed out of legal trouble, and are contributing members of society by serving in the military or going to college and paying taxes–just unfathomable. And when you add in the fact that other students, potentially eligible students, will also be harmed by this policy, it’s hard to wrap your mind around.”

Financial aid experts, like the one quoted above, worry that the FAQ-mandated Title IV restriction—in its effort to exclude foreign students and DACA students–will result in the emergency aid also being more difficult to get for student citizens. Here is a good, clear example of how whiteness, implemented by white elites, is waged at the cost of marginal white folks who not only support the regime at a cost to their livelihoods, but who then believe they were robbed of those same livelihoods by foreigners and undocumented peers.

More Tricky Details

In other news, experts were also surprised that the 13 FAQs excluded any students from COVID-19 relief funding if they were taking courses solely online at an institution where they could have been taking courses off-line. The money was intended by Congress to address disruptions caused by moving online from campus, says the FAQ, never mind if the online student is challenged by expenses resulting from COVID-19 job loss.

While financial aid experts knew that half of the $12 billion in COVID-19 funds for higher ed were earmarked for direct student relief, there was widespread perception that the other half of the funds might be applied to other expenses that supported students, such as unpaid campus bills.

For instance, some campuses quickly refunded dorm fees or other costs, partly under the impression that a federal relief package would help make up the loss to Spring semester budgets.

The assumption that the second half of funding would be available for campus relief, not direct student payment, is what in fact fueled resentment against those ill-fated Harvard funds.

In a promise typical of ED over the past weeks, FAQ number one, about the first half of the money, promises another set of FAQs that will cover the second half of the money, “shortly after making those funds available to institutions.” The promise ensures that campuses will have to hold the second round of money–at least until the new FAQs are released.

Perhaps the release of FAQs on Apr. 21 pertaining to the first half of funding therefore means that indeed some of the first-half funds were being released?

But Some Good Stuff, Too

It should be noted that some of the FAQs were inclusive. One provision, for example, makes clear that certain prisoners, released because of pandemic precautions, would be able to stay in the relief loop, even though their funding was tied to a prison program.

And if an institution would be interested in getting the second round of “institutional” relief, ED does require that they first participate in getting the first round of “student” relief out the door. It’s good to know, therefore, that about 12 percent of that student relief money has likely—this week of weeks–made it to some campuses somewhere.

Greg Moses is editor of the Texas Civil Rights Review and a member of the Texas Civil Rights Collaborative.

Covid-19 Justice Higher Education

No V-shaped Recovery for 2020 College Students or Grads

By Greg Moses

Op-Ed News

As we invest in V-shaped recoveries for businesses and their employees, we assume there is some hilltop of prosperity to get back to. For this year’s college students and graduates, we forget, there is still the first hill to climb.

I’m not blaming the tenured classes who have long forgotten their eleventh thesis. Nor am I blaming college presidents in their mirror stage of consciousness, gazing into that looking glass where everyone appears as a CEO.

I won’t even blame students themselves, who have no time to think about what just hit them as they are ordered off campus and told to log in for further instructions.

But somehow, America these days has fallen into a numb assumption that, even in the middle of this pandemic crisis, it can just keep its economy riding upon backpacks filled with student debt.

We instinctively rush to backstop other credit markets. We talk loud and fast about loan forgiveness to several other classes of worthy economic actors. Yet somehow we don’t give a second thought to young American scholars who carry heavy loads of debt for higher education.

Read between the lines of national policy discourse, and the thesis that prevails is preservation of the student-loan credit complex. When it comes to addressing the needs of this year’s college students and grads, debt forgiveness is too costly to imagine.

Readers removed from the policy kitchens of Washington, D.C., can get a whiff of what’s cooking for college students by inhaling a couple of articles archived Tuesday morning at the COVID-19 web center of the National Association of Student Financial Aid Administrators (NASFAA).

The first article is all about debt postponement. The second article begins with debt postponement sure enough. But the second article goes on to stir another pot where seasoned cooks are prepping debt cancellation and grants.

This is where you are invited to skip to the end and taste the finished dish, if you already agree that debt cancellation and grants are what we need to provide our most vulnerable 2020 college students and grads.

However, to begin our taste test of today’s polite policy palate, we begin with report number one that says NASFAA on Monday joined a coalition of higher education groups asking the US House of Representatives to extend and expand student-loan deferrals.

Student loan deferrals, authorized for six months under the recent CARES Act, should be extended to nine months, and instead of just deferring government-held loans, the pause in payments and interest accrual should be extended “to all federal loans, including commercially-held Federal Family Education Loans (FEEL) and Perkins Loans.”

Student loans should also be relieved of immunity from bankruptcy proceedings. And debt loads that are lifted by lawfully adjusting student loans should not be counted as taxable income.

As for any “large-scale debt relief initiative,” says the higher ed coalition, Congress can control that cost–if forgiveness is “targeted to borrowers who are financially distressed and face the greatest difficulty repaying their loans.”

The second Tuesday morning report from NASFAA begins with Congressional proposals by Sen. Mitt Romney (R-Utah) and Rep. Josh Harder (D-Calif.) to allow 2020 graduates to defer their student loans for three years.

Rep. Harder admits that the whole student loan system is “horribly broken.” But this is old news, and if there is a groundswell of outrage about it, nobody seems to know where. Romney and Harder kick the can of postponement. And who knows, maybe in three years we can revisit the issue under more favorable political realities.

With loan postponement strategies duly noted, the second NASFAA news report then turns to three think tanks, where the policy world seems to be setting a wake-up alarm.

The Economic Policy Institute’s (EPI) senior economist Elise Gould reminds us that our ability to expect debt liberation fell victim to the crisis of ’08, but did not recover. She warns that we should think twice before declaring any deadline for when the 2020 graduating class will be prepared to assume the classic position of loan re-payer.

Plus, federal response today needs to anticipate state budget cuts tomorrow, warns Gould. When pandemic austerity hits state legislatures, forcing reductions in college funding, the heaviest burdens will fall on low-income students.

Pell Institute for the Study of Opportunity in Higher Education director Margaret Cahalan spices our discourse with the G-word, grants. If we are thinking about first generation, low-income students, then we have to consider what has suddenly happened to their family support networks as a result of COVID-19. For these students, especially, loans will be long-term running weights that they can’t take off.

Finally, Council for Opportunity in Education (COE) president Maureen Hoyler says our economic attitude toward today’s students will have impacts on their ability to become tomorrow’s home buyers.

“The recent college graduates, who graduated in 2020 and 2019, certainly need to be looked at separately,” Hoyler said. “And everybody who was a Pell [Grant] recipient who was in loan repayment–that’s a group that needs to be looked at.”

Hoyler’s recipe helps policy makers identify students who have already qualified for federal grants as a good group to start with when it comes to spending frugally on outright debt relief.

Still, it may seem to the earnest reader that higher education policy is stuck with COVID-19 problems but constrained by pre-COVID fiscal thinking. Trillions of dollars have been speedily applied to other areas of the economy these recent weeks. When it comes to student loan debt forgiveness, or a truly supportive college grant program, why is everybody suddenly reaching for the frozen dessert of frugality?

PS: Front-line COVID doctor: We want student loan forgiveness, not hazard pay ABC News

Covid-19 Justice Higher Education

Waiting on ED: 13 FAQs Clarify CARES Act Relief Funding for College Students and Campuses

A Texas Civil Rights Review Interim Report
[With some inserts added in brackets, Apr. 23]

Financial aid experts thought they knew what they would do with federal money that Congress allocated under the CARES Act for emergency aid to college students. Like everyone else, they have been reading that COVID-19 relief funding from the Department of Education (ED) is only a day away.

Two weeks after the CARES Act passed, the emergency funds were going to be “immediately” released, a promise that reporters mistakenly treated as accomplished fact on Apr. 9. Then, the funds were going to be released “as early as” Apr. 15. And lately, on Apr. 21, ED posted 13 FAQs telling how–and how not–to use those funds, that is, when they are made available, which, seriously–and we mean it this time–could be soon.

If you’re not confused by any of the above, it’s because you haven’t been trying to figure it out.

Meanwhile, headlines have been stuffed with announcements about $1,200 CARES Act checks hitting taxpayer accounts as early as Apr. 13. And we are amply informed that $350 billion in CARES Act small business relief was spent by Apr. 16, prompting the Senate to vote on Apr. 21 for another $310 billion.

Now, approaching the one-month anniversary of the Mar. 27 CARES Act, we are still looking for a single headline that says, “College Student Receives Federal Emergency Relief for COVID-19 Hardship.”

In the 13 FAQs released Tuesday, ED holds the line on some of its earlier guidance, already widely anticipated, that the first half of the $12 billion relief fund must go to students, not to student accounts, even if students need money to pay accounts.

However, in a slight twist that caught experts by surprise, if the campus has already given money to students for COVID-19 relief in the form of cash payments [and if the money was given after passage of the CARES Act on Mar. 27], the campus may use the federal money to replenish that account, instead of giving the federal money to students.

Many campuses have already raised local emergency funds and paid them out for COVID-19 emergency relief. Often, these campus funds have run out before all requests were filled.

Experts were also hoping that Congress intended to cast a wider net with the student half of COVID-19 emergency relief so that it would not require cumbersome analysis of overall financial need or citizenship status. They were hoping to disburse the funds with short-form requests that would not be closely tied to Title IV federal financial aid, which is regulated under the cumbersome FAFSA system.

But in a catch that caught many by surprise, the recent FAQs say that students eligible for this round of emergency relief must be eligible for Title IV, or “could be” eligible. What this means to financial aid professionals is that if a student is not already on the Title IV rolls, a time-consuming FAFSA analysis will have to be applied.

In a closely related surprise, the Title IV “clarification” has the effect of excluding foreign students.

Likewise, on the question of undocumented students, most will be unable to access the funds because of Title IV resstrictions. The answer to FAQ 9 states that, “Students who have not filed a FAFSA but who are eligible to file a FAFSA also may receive emergency financial aid grants.” A fact sheet at state in turn that, “Most undocumented students aren’t eligible for an SSN; thus, they cannot complete the FAFSA form. However, DACA students with SSNs can complete the FAFSA form” (even though they are not eligible for federal financial aid.)

Experts were also surprised that the 13 FAQs excluded any students from COVID-19 relief funding if they were taking courses solely online at an institution where they could have been taking courses off line. The money was intended by Congress to address disruptions caused by moving online from campus, says the FAQ.

While financial aid experts knew that half of the $12 billion in COVID-19 funds for higher ed were earmarked for direct student relief, there was widespread perception that the other half of the funds might be applied to other expenses that supported students, such as unpaid bills.

Some campuses quickly refunded dorm fees or other costs, partly under the impression that a federal relief package would help make up the loss to Spring semester budgets.

The assumption that the second half of funding would be available for campus relief, not direct student payment, is what fueled harsh criticism of funds that would be directed through some of the well-endowed campuses, such as Harvard, Texas A&M, or the University of Texas. Harvard promised that it would apply all of the relief money to students.

Public criticism of emergency funds going to students at well-endowed universities were joined vith vigor by President Donald Trump, Treasury Secretary Mcnuchin, and Education Secretary Betsy DeVos, promting both Harvard and Stanford Universities to opt out of the program on behalf of their COVID-19 affected students.

In a promise typical of ED over the past weeks, FAQ number one promises another release of FAQs that will cover the second half of the money, “shortly after making those funds available to institutions.” The promise ensures that campuses will have to hold the second round of money at lest until the new FAQs are released.

Perhaps the release of FAQs on Apr. 21 pertaining to the first half of funding therefore means that indeed the funds have been released?