COVID-19: Emergency Financial Aid for College Students under the CARES Act

What GAO Found

As of November 2020, the Department of Education (Education) had distributed $6.19 billion in grants to 4,778 schools (colleges and other institutions of higher education) that had applied for emergency student aid funds from the Higher Education Emergency Relief Fund (HEERF) established by the CARES Act, which was enacted in March 2020. After many schools closed their physical campuses in spring 2020 in response to COVID-19, Education provided these grants to schools, based on a statutory formula, to give emergency financial assistance (student aid) to students who incurred related expenses, such as for housing, technology, and course materials. The majority of these HEERF student aid funds have been awarded to public schools (see figure). The average amount Education awarded per school was about $1.3 million, while amounts schools received ranged from less than $2,000 to more than $27 million, with half of schools receiving awards of $422,000 or less. Education data show that, as of November 2020, schools had drawn down about 90 percent—or $5.6 billion—of their HEERF student aid funds. About 70 percent of schools had drawn down all of their student aid funds, and an additional 24 percent of schools had drawn down at least half.

Department of Education’s Higher Education Emergency Relief Fund (HEERF) Awards to Schools for Emergency Student Aid under the CARES Act, by School Sector

Notes: Schools of less than 2 years are included in the 2-year school categories above. The Department of Education also awarded about $24 million to 2-year private, nonprofit schools and about $1.7 million to the Commonwealth of Puerto Rico Department of Education. Sector-level figures do not add up to $6.19 billion because of rounding.

Schools used a variety of approaches to determine student eligibility and distribute funds to students. According to GAO’s analysis of a sample of school websites and data from Education, schools had distributed approximately 85 percent of all emergency student aid funds by fall 2020, with an average amount per student of about $830.

  • Determining student eligibility. Approximately half of schools reported that they required a completed Free Application for Federal Student Aid (FAFSA)—the form used to apply for federal financial aid—to determine student eligibility for HEERF student aid. For example, one school reported requiring students who did not have a FAFSA on file to complete one by June 2020 to be eligible for student aid. Other schools did not require a FAFSA to establish eligibility, according to their websites, but reported using alternative methods. For example, a 4-year public school reported that graduate students applying for emergency aid had the option of submitting a school-provided affidavit certifying they were eligible to receive federal financial aid, an option described in Education’s interim final rule on student eligibility.
  • Awarding funds to students. Schools reported using two main methods for awarding HEERF emergency student aid to students: requiring students to complete a school-developed application or using existing school records. Approximately 18 percent of schools used a combination of both methods. For example, a 4-year nonprofit school reported on its website that it awarded $300 to $500 to eligible students in its first round of funding based on existing student financial aid records, and then allowed students who had more expenses related to COVID-19 to apply for additional funding.
  • Determining award amounts. Schools reported using various factors to determine award amounts for HEERF-eligible students. Over half of schools reported on their websites that amounts were based on individual circumstances, such as students’ general financial need, access to essential items such as food or housing, or a combination of these factors. About 20 percent of schools also reported using full-time or part-time status to determine aid amounts. For example, a 4-year public school reported that it distributed grants, ranging from $150 to $1,000, to all eligible students based on their enrollment status and financial need based on students’ FAFSA information.

Why GAO Did This Study

In June 2020, GAO issued the first of a series of reports on federal efforts to address the pandemic, which included a discussion of HEERF student aid grants to schools. At that time, limited information on how schools distributed HEERF funds to students was available. This report provides additional information and examines (1) how HEERF emergency student aid funds were provided to schools under the CARES Act, and (2) how schools distributed emergency student aid to eligible students.

GAO analyzed Education’s obligation data as of November 2020, after Education had obligated most of the HEERF emergency student aid funds. GAO also analyzed information about HEERF student aid that Education requires schools to report on their websites by selecting a generalizable random sample of 203 schools for website reviews. These schools were representative of the more than 4,500 schools that received HEERF student aid funds as of August 2020. GAO also collected non-generalizable narrative details about how schools distributed funds to eligible students.

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Based on GAO’s review, Education has updated the information and CDC has begun to do so. GAO recommends that CDC ensure that, as it makes updates to its guidance related to schools’ operating status, the guidance is cogent, clear, and internally consistent. HHS agreed with the recommendation. Tracking Contract Obligations Federal agencies are tracking contract actions and associated obligations in response to COVID-19 using a National Interest Action (NIA) code in the Federal Procurement Data System-Next Generation. The COVID-19 NIA code was established in March 2020 and was recently extended until March 31, 2021, while a draft of this report recommending that DHS and DOD extend the code beyond September 30, 2020, was with the agencies for comment. 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Address Cybersecurity Weaknesses Since March 2020, malicious cyber actors have exploited COVID-19 to target organizations that make up the health care and public health critical infrastructure sector, including government entities, such as HHS. GAO has identified numerous cybersecurity weaknesses at multiple HHS component agencies, including CMS, CDC, and FDA, over the last 6 years, such as weaknesses in key safeguards to limit, prevent, and detect inappropriate access to computer resources. Additionally, GAO’s March 2019 high-risk update identified cybersecurity and safeguarding the systems supporting the nation’s critical infrastructure, such as health care, as high-risk areas. As of July 2020, CMS, FDA, and CDC had made significant progress by implementing 350 (about 81 percent) of the 434 recommendations GAO issued in previous reports to address these weaknesses. Based on the imminent cybersecurity threats, GAO recommends that HHS expedite implementation of GAO’s prior recommendations regarding cybersecurity weaknesses at its component agencies. HHS agreed with the recommendation. As of September 10, 2020, the U.S. had over 6.3 million cumulative reported cases of COVID-19 and over 177,000 reported deaths, according to federal agencies. The country also continues to experience serious economic repercussions and turmoil. Four relief laws, including the CARES Act, were enacted as of September 2020 to provide appropriations to address the public health and economic threats posed by COVID-19. As of July 31, 2020, the federal government had obligated a total of $1.6 trillion and expended $1.5 trillion of the COVID-19 relief funds as reported by federal agencies on USAspending.gov. The CARES Act includes a provision for GAO to report bimonthly on its ongoing monitoring and oversight efforts related to the COVID-19 pandemic. This third report examines key actions the federal government has taken to address the COVID-19 pandemic and evolving lessons learned relevant to the nation’s response to pandemics. GAO reviewed data, documents, and guidance from federal agencies about their activities and interviewed federal and state officials, as well as industry representatives. GAO is making 16 new recommendations for agencies that are detailed in this Highlights and in the report. For more information, contact A. Nicole Clowers at (202) 512-7114 or clowersa@gao.gov.
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Evidence collected during the pandemic suggests the prevalence of behavioral health conditions has increased, while access to in-person behavioral health services has decreased: Centers for Disease Control and Prevention (CDC) survey data collected from April 2020 through February 2021 found that the percentage of adults reporting symptoms of anxiety or depression averaged 38 percent. In comparison, using similar questions, CDC found that about 11 percent of U.S. adults reported experiencing these symptoms from January to June 2019. An analysis of CDC data found that the share of emergency department visits for drug overdoses and suicide attempts were 36 and 26 percent higher, respectively, for the period of mid-March through mid-October 2020 compared to the same time period in 2019. In a February 2021 survey of its members, NCBH found that in the 3 months preceding the survey, about two-thirds of the member organizations surveyed reported demand for their services increasing and having to cancel or reschedule patient appointments or turn patients away. The survey also found that during the pandemic, 27 percent of member organizations reported laying off employees, 45 percent reported closing some programs, and 35 percent decreased the hours for staff. Officials GAO interviewed from provider organizations offered anecdotal examples of problems with payments for behavioral health services, including examples suggesting that denials and delays were more common for these services than they were for medical/surgical services. However, most officials were not aware of published data that could confirm their concerns, and data from reports from two states on claims denials either did not support their concerns or were inconclusive. In addition, a report in one state that examined mental health parity—requirements that behavioral health benefits are not more restrictive than medical/surgical benefits—found that the rate of complaints associated with behavioral health services was notably lower than those for medical/surgical services. The lack of available data confirming stakeholder concerns could be related to potential challenges consumers and providers face in identifying and reporting mental health parity violations, as previously reported by GAO. Specifically, in 2019, GAO found that complaints were not a reliable indicator of such violations, because consumers may not know about parity requirements or may have privacy concerns related to submitting a complaint. GAO recommended that the federal agencies involved in the oversight of mental health parity requirements evaluate the effectiveness of their oversight efforts. As of March 2021, the agencies had not yet implemented this recommendation. Why GAO Did This Study Behavioral health conditions, which include mental health and substance use disorders, affect a substantial number of adults in the United States. For example, in 2019, an estimated 52 million adults in the United States were reported to have a mental, behavioral, or emotional disorder, and 20 million people aged 12 or older had a substance use disorder. Experts have expressed concerns that the incidence of behavioral health conditions would increase as a result of stressors associated with the COVID-19 pandemic. Even before the pandemic, longstanding questions have been raised about whether coverage or claims for behavioral health services are denied or delayed at higher rates than those for other health services. GAO was asked to examine several issues about the demand for behavioral health services, as well as coverage and payment for these services. 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According to a State official, Leahy approval of a security force unit is good for 1 year, and State must vet individuals again if their unit continues to receive support from State or USAID funding sources. Both U.S. agencies and implementing partners took a variety of steps in response to recent allegations of human rights abuses by overseas park rangers. For example, a State official in the Central Africa region told GAO that while the Democratic Republic of the Congo embassy's vetting program has very strict control mechanisms, the International Narcotics and Law Enforcement Affairs Bureau requested quarterly reports to facilitate a review of all assistance to park rangers to ensure that any reported activities were vetted according to Leahy Laws. USAID officials told GAO that in addition to continuing Leahy vetting, the agency's response included strengthening human rights training and conducting a site visit to a park in the DRC where human rights abuses had allegedly occurred. According to officials, the visit involved speaking with beneficiaries to further understand the allegations and efforts to assess root causes, mitigate impacts, and stop future occurrences, including making referrals to appropriate law enforcement authorities if warranted. FWS officials also stated that they take seriously allegations that U.S implementing partners have supported park rangers who have committed human rights abuses. Since June 2019, the Department of the Interior has approved no new awards to the World Wildlife Fund (WWF)—one of the implementing partners which has supported park rangers alleged to have committed human rights abuses. Moreover, the International Affairs program within FWS has put all new funding on hold since September 2019, pending a departmental review. Agencies are also implementing various changes in response to congressional directives on safeguarding human rights. For example, State officials told GAO that they have added language to all notices for countering wildlife trafficking awards that requires implementing partners to include social safeguards plans in their projects. The plans will articulate an understanding of how their work could negatively affect local communities. USAID officials stated that USAID has included provisions in new agreements with FWS that require adherence to the congressional directives. FWS officials also confirmed that they are cooperating with USAID in these efforts. Implementing partners—WWF, the Wildlife Conservation Society (WCS), and African Parks (AP)—have all conducted investigations to address allegations of human rights abuses by park rangers, according to officials from these organizations. They have also developed grievance mechanisms to report human rights abuses. For example, WWF has received 50 complaints in roughly the past year related to its project work, according to WWF representatives. WWF has responded to complaints of human rights abuses through this mechanism by reporting the allegations to relevant authorities and meeting with community representatives. U.S. agencies provide training and equipment for park rangers overseas to combat wildlife trafficking. From fiscal years 2014 through 2020, the U.S. government provided approximately $554 million to undertake a range of activities through federal agencies and in cooperation with implementing partner organizations in the field. Multiple non-governmental organization and media reports, however, have alleged that organizations that have received U.S. funds have supported park rangers engaged in combating wildfire trafficking who have committed human rights violations since the mid-2000s. GAO was asked to review human rights protection mechanisms related to U.S. efforts to combat wildlife trafficking. This report examines 1) what enforcement mechanisms agencies have to prevent U.S. funded efforts to combat wildlife trafficking from supporting human rights abuses and how they implement them, and 2) how agencies and implementing partners address allegations of human rights abuses. GAO spoke with agency officials and implementing partner representatives locally in person and overseas by phone, and collected and analyzed information related to program implementation. For more information, contact Kimberly Gianopoulos at (202) 512-8612 or gianopoulosk@gao.gov.
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    In U.S GAO News
    What GAO Found The budget for the Internal Revenue Service's (IRS) Taxpayer Advocate Service (TAS) declined by about 14 percent from fiscal years 2011 to 2020, when adjusted for inflation. For fiscal year 2020, TAS used most of its resources to assist individual taxpayers, known as case advocacy. TAS allocated about 76 percent of its $222 million budget and 86 percent of its almost 1,700 full-time equivalents to this purpose. The percentage of resources for case advocacy has decreased during the past decade—in fiscal year 2011 about 85 percent of the budget was devoted to it. For the same period, resources to address broader issues affecting groups of taxpayers, known as systemic advocacy, increased from 9 percent to 14 percent of the total budget. This shift is due in part to the reallocation of staff to better integrate systemic advocacy work and TAS's overall attrition rate more than doubling to 15.9 percent between fiscal years 2011 and 2019. Since 2011, TAS has received more than 2 million taxpayer cases, of which almost half were referrals from other IRS offices. TAS closed more cases than it received each year from 2012 to 2017, but its inventory has grown since fiscal year 2018, due in part to attrition in case advocacy staff and an increase in taxpayers seeking assistance (see figure below). Number of Taxpayer Cases Received and Closed, Fiscal Years 2011 to 2020 TAS has recently modified its two mandated reports to Congress by reducing their length and separately compiling legislative recommendations. It shortened its annual reports in part because the Taxpayer First Act reduced the required number of most serious taxpayer problems from “at least 20” to “the 10” most serious problems. GAO identified the following additional actions that could further improve TAS reporting. Report outcome-oriented objectives and progress. The objectives for the upcoming fiscal year that TAS included in its most recent report are not always clearly identified and do not link to the various planned activities that are described. Further, the objectives TAS does identify do not include measurable outcomes. In addition, TAS's reports do not include the actual results achieved against objectives so it is not possible to assess related performance and progress. Improved performance reporting could help both TAS and Congress better understand which activities are contributing toward achieving TAS's objectives and where actions may be needed to address any unmet goals. Consult with Congress and other stakeholders. TAS briefs congressional committees each year after publishing its annual report and solicits perspectives from stakeholders. TAS officials said they incorporate the perspectives into its objectives. However, TAS does not follow leading practices to consult congressional committees about its goals and objectives prior to publication at least once every 2 years. Thus, it misses opportunities to obtain congressional input on its objectives and performance reporting. Consultations would provide TAS opportunities to confirm if its goals incorporate congressional and other stakeholder perspectives and whether its reports meet their information needs. Publish updates on recommendation implementation status. By law, TAS's annual report must include an inventory of actions IRS has fully, partially, and not yet taken on TAS's recommendations to address the most serious problems facing taxpayers. If those recommendations take multiple years to implement, which some have as shown in the table below, updating the inventory would be required. 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