Today’s Students Need Continued Policy Reforms in Response to COVID-19

To support today’s students during and as a result of the COVID-19 pandemic, Congress and the Department of Education must take critical steps by removing outdated and burdensome barriers to begin to repair our workforce through higher education.

Specifically, policymakers must look to three areas where policy change can have the biggest impact in light of the COVID-19 pandemic:

  • Reskill adults through postsecondary education to re-enter the workforce;
  • Update financial aid rules to account for our current economic environment; and
  • Support today’s students’ learning at home.

Higher Learning Advocates proposes the following initial nine policy solutions below and will continue to build upon this initial set of recommendations in the coming days. To learn more about Higher Learning Advocates’ thoughts on policy solutions already passed through the CARES Act, click here.



Policy Solution #1: Expand the Child & Dependent Care Tax Credit to benefit students with dependents
The Child and Dependent Care Tax Credit is a nonrefundable tax credit available to offset taxpayers’ employment-related expenses for the care of a qualifying dependent—including a dependent child under the age of 13, a dependent who is physically or mentally incapable of caring for themself, or a spouse who is physically or mentally incapable of caring for themself.

6.6 million Americans claim this credit each year for employment-related expenses to assist in caring for a child/children. Eligible expenses include care of the qualifying dependent—including at-home and provider-based, as well as summer camps.

Individuals who care for a child or children or other dependents who are enrolled in higher education also need the same services, which could include dependent care while attending classes or studying and related academic activities, like time spent commuting, professors’ office hours, and advising sessions.

As seen after the 2008 economic downturn, enrollment in undergraduate programs spiked 14 percent and three million Americans enrolled or re-enrolled in higher education between 2008 and 2010. We can expect similar or higher numbers of Americans turning to higher education as the result of our current economic crisis. As such, the Child and Dependent Care Tax Credit should be amended to allow individuals to claim the credit for education-related expenses.


Policy Solution #2: Reset Satisfactory Academic Progress (SAP) for returning students
Satisfactory Academic Progress (SAP) is a requirement set forth by the Higher Education Act (HEA) and further defined by individual institutions of higher education (IHEs) to identify the criteria students must meet in order to remain eligible for federal student aid. Typically, to meet SAP requirements, students must meet a minimum grade point average (GPA), or its equivalent, and complete a minimum number of courses or credits.

Millions of students’ lives have been upended by the COVID-19 pandemic and Congress has already signaled its understanding that students’ may fail to meet SAP at this time and should not be penalized under financial aid rules. The CARES Act, signed into law on March 27, would waive SAP for students affected by the COVID-19 pandemic.

On top of the new accommodation, Congress should expand flexibility for today’s students by creating a SAP reset for those who have failed SAP in the past but have not been enrolled for the previous two years. In addition, ED should set up a robust outreach campaign to notify students that their financial aid eligibility will not be revoked because of failing SAP as a result of the COVID-19 pandemic.


Policy Solution #3: Get Americans Back to Work Through High-Quality, Short-Term Postsecondary Programs
As our economy recovers from the COVID-19 pandemic, getting unemployed Americans back to work will be priority number one. Postsecondary education has a strong role to play, but certificate programs linked to in-demand career fields will be especially important. Research shows that approximately 94 percent of certificates awarded are in career-oriented fields. Additionally, research indicates that certain short-term certificate programs can lead to significant wage gains.

Oftentimes, certificate programs do not neatly fit into the financial aid rules set forth by the Higher Education Act—some certificate programs may be shorter than the required 600 hour program length to be eligible for students to use federal student aid to attend. 

It’s now more important than ever that policymakers allow short-term programs that demonstrate high-quality outcomes to be eligible for federal student aid programs. This change would allow a broader number of Americans—including the nearly 17 million Americans who are already unemployed—to access training directly linked to jobs. Congress should immediately take up and pass the JOBS Act, introduced by Senators Kaine and Portman, to prepare for the rebuilding of the American economy. 


Policy Solution #4: Allow Federal Student Aid to be Used for Prior Learning Assessment
Prior learning assessment (PLA) is a process by which a student’s prior work and learned skills are evaluated for the purposes of determining academic credit. Due to the COVID-19 pandemic, nearly 17 million Americans are facing unemployment and will, at some point in the near future, return to job seeking. PLA could play a powerful part in allowing individuals’ prior learning to be counted as academic credit toward a credential or degree that holds value in the workforce. 

In 2014, the U.S. Department of Education (ED) announced an experimental site to allow participating institutions of higher education to use federal student aid to cover all or a portion of PLA. Evidence shows that students who receive PLA are 2.5 times more likely to complete their degree or credential than students who do not, and cost savings per student who takes advantage of PLA can range between $1,600 and nearly $6,000.

ED should seek to expand the number of institutions participating in the PLA experimental site in order to benefit a greater number of Americans who may be returning to postsecondary education as a result of becoming unemployed during the COVID-19 pandemic.


Policy Solution #5: Remove Pell LEU Barrier for Low-Income Students Re-entering Higher Education
The Pell Grant is a federal means-tested program that offers postsecondary financial aid in the form of a grant to be used for eligible expenses, including tuition, fees, and related expenses. One-third of today’s students receive a Pell Grant, which amounts to about $28.8 billion annually.

The Higher Education Act (HEA) limits the amount of Pell Grant funds a student can receive over their lifetime—known as the Lifetime Eligibility Usage (LEU)—to the equivalent of six academic years, or twelve semesters. In addition, the Pell Grant may not be used by a student who has previously received a bachelor’s degree.

There are currently 36 million Ameicans with some college credit but no credential or degree. As nearly 17 million Americans have become unemployed as the result of the COVID-19 pandemic, a greater number of individuals will likely be turning to higher education to seek a degree or credential that leads to employment. In the 2008 economic downturn, 3 million Americans returned to higher education to seek re- or up-skilling and to help propel them to employment quickly. Undergraduate enrollment spiked 14 percent from 2007-2010 and first time, credential-seeking enrollment for adults over the age of 21 grew by 21 percent in 2008.

It is critical that financial aid be available to assist Americans returning to higher education in this unprecedented time. As such, Pell LEU limits should be reset for individuals who have reached the maximum allotted amount and those who already hold a degree or credential. For an individual to be eligible for a reset, they must be affected by the COVID-19 pandemic, and only remain eligible for a maximum of an additional four semesters’ worth of credits.



Policy Solution #6: FAFSA + Prior-Prior Year
Students use the Free Application for Federal Student Aid (FAFSA) form to determine their eligibility for federal grants, loans, and work-study programs to help cover the cost of college. The FAFSA determines a student’s expected family contribution (EFC) which, along with the student’s year in school and cost of attendance at their chosen school, is used to reflect how much a student can afford to pay for college. A student’s EFC is based on income, assets, family size, and the number of family members who will attend college the same year.

The U.S. Department of Education (ED) in 2015 began allowing individuals to use prior-prior year tax information to complete the FAFSA to help increase accuracy of financial aid determinations and preparedness by students and families. As of April 9, approximately 16.8 million individuals have become unemployed. From March 13 to March 20, FAFSA completion rates took the second-largest dive this year, dropping 0.7%. Presumably, students and their parents are unsure of their personal employment and financial circumstances, and may be unsure how to proceed in completing the FAFSA. Prior-prior year data may not be applicable; and prior-year data may not even be applicable since many Americans’ financial situations are likely to have changed.

ED should issue guidance and provide robust consumer communications for FAFSA filers to inform them of the proper steps to follow if their financial information has recently changed and how to use their most up-to-date financial information.


Policy Solution #7: Provide flexibility through financial aid professional judgement
In general, schools may be reluctant to use professional judgement because using it too much impacts their risk-model, which can then trigger a program review. After the 2008 recession, ED provided guidance to institutions that they could use as proof of a student’s unemployment benefits to use professional judgement and change data items related to a student’s income to $0. ED also agreed to adjust its risk model to account for the increased use of professional judgement during this time.

ED should issue guidance similar to what was issued in 2009 to allow institutions to extend these professional judgement guidelines to students impacted by the COVID-19 pandemic.



Policy Solution #8: Expand Broadband Connectivity for Today’s Students in College
Access to technology is crucial for college students: In one study, 96 percent of students reported that they used the internet for school work, and another study found that 88 percent of college students said that they have a laptop for school. However, online learning from home, where students aren’t able to access campus Wi-Fi, can pose barriers to student success. A 2019 study conducted by Microsoft found that approximately 162.8 million Americans don’t have broadband internet, and this lack of access to high-speed internet disproportionately impacts rural areas, low-income communities, and tribal nations. Even when families have access to the internet through a mobile device, data plans that are capped per month and spotty Wi-Fi connections can make data-intensive online learning—such as watching videos or attending online lectures—challenging for students. Although not having a laptop or living in a broadband desert are challenges, the most common reason given for not having high-speed access is the cost of services.

The federal E-Rate program helps low-income schools and libraries provide connectivity for elementary and secondary students. As more postsecondary students have to turn to online courses and need connectivity for academic activities like advising during the COVID-19 pandemic, policymakers should provide an additional appropriation to and expand the E-Rate program to meet the new needs of postsecondary students. Specifically, $1 billion should be dedicated to E-Rate—in addition to the $2 billion proposed by House Democrats for E-Rate for K-12—to enable institutions of higher education to facilitate mobile broadband hotspots to needy students. Priority should be given to institutions that enroll a high percent of Pell-eligible students. 

In addition to expanding access through E-Rate, policymakers should make changes to the federal Lifeline program to better connect postsecondary students to online courses, materials, and activities. Lifeline eligibility rules should be expanded to allow students who qualify for the Pell Grant program to also qualify for Lifeline. Further, appropriations to Lifeline should be increased to allow for a $50 per month voucher to qualifying individuals to go toward broadband services, including internet  connectivity and mobile broadband.


Policy Solution #9: Expand Access to Open Educational Resources (OER)
Not only do students face high prices for course textbooks and materials, they may no longer have physical access to bookstores or libraries in light of the COVID-19 pandemic, or they may have left their materials on campus during spring break, not knowing that they would not return. At community colleges, textbook costs can account for up to 80 percent of the cost of attendance, and a study found that 70 percent of college students said that they skipped buying textbooks due to the price. Instead, students may rely on sharing a classmate’s textbook, borrowing a copy of the text from the professor, or renting textbooks through the campus library.

Open educational resources (OER) are digital media, textbooks, and other materials that have been made available to the public—including college students—under an open license on a free and accessible platform. Institutions that have adopted OER courses or programs have seen higher engagement, retention, and completion rates. Faculty and institutions are interested in adopting OER, but the start up costs and finding sustainable funding streams can pose barriers to its implementation.

In FY 2018, Congress authorized the Open Textbooks Pilot program at the U.S. Department of Education (ED), which allows institutions to expand access to open educational resources for high-enrollment courses or in-demand fields. ED is currently updating the Open Textbooks Pilot program rule, and we are supportive of the Department’s proposed changes to allow high-enrollment courses to include those in a “recognized postsecondary credentialing pathway”. We are likewise supportive of ED’s intent to broaden the definition of an “open textbook” by extending qualifying materials to other learning exercises, technology-enabled experiences (e.g., simulations), and adaptive support and assessment tools. We also support increased appropriations to the program to support a greater number of students seeking open educational resources in light of the COVID-19 pandemic.