Central States Private Education Network
c/o Akerman LLP
750 9th Street, NW, Suite 750
The Victor Building
Washington, DC 20001
We Know Your Faced With Some Tough Decisions Right Now…
Hopefully, This Information Can Help You With Them!
Now more than ever, during these unprecedented times, the ability to communicate and share information within our community is even more critical.
All of us are facing new challenges and searching for answers to questions – many of which may not have a fully completed answer yet, or could have more than one answer based upon the unique characteristics of the type of institution, program, or oversight entities requirements.
To that end, and in keeping with our mission, CSPEN has prepared this email providing the most current and up-to-date information that we have been able to acquire from sources and resources here in Washington.
We share this information in the hopes that it will be of assistance to you and will continue to provide you with updates and addition information in future emails.
(Note: Apologies in advance for the length of this, but there is a great deal of information to share and we did our best to winnow it down to a manageable size. As you can imagine, there is always more out there, but we felt this was a solid start. Also please note the in the days ahead we will be sharing updates on other key groups information including Accrediting Agency Requirements and Support, Individual State Requirements, and Other Higher Education Organization’s latest insights.)
On Friday. March 13, 2020, the President announced that he would use his Executive Authority to suspend interest on student loans, not the monthly payments themselves, just the interest accruing on the loans.
“To help our students and their families, I’ve waived interest on all student loans held by federal government agencies and that will be until further notice,” Trump said. “That is a big thing for a lot of students right now, a lot of their schools have been closed.”
However, there are still questions about exactly how that will work and many, while appreciative of the gesture, are calling for much more than a freeze on interest.
Various advocacy groups are calling for the President and/or Congress to go much further suggesting among other things that:
- Regular monthly payments be eliminated throughout the length of the pandemic (and for some time beyond);
- Wage garnishment, Social Security withholdings, and tax refund seizures should be waived as well; and
- Automatic transition of loans into income-based repayment for a period of time to enable borrowers to get back on their feet after the pandemic has concluded.
Cabinet-level Agency Action
The U.S. Department of Education has established a new webpage entitled, COVID-19 (“Coronavirus”) Information and Resources for Schools and School Personnel.”
Building upon the March 4, 2020 letter that CSPEN shared with the community on March 6, 2020, the Department continues to urge all educational institutions to follow the updates provided by The Centers for Disease Control and Prevention (CDC) offers the most up-to-date information on COVID-19 along with their Guidance for School Settings.
To their credit, the Department has also compiled a group of “additional resources” highlight vital information of importance to institutions of higher education.
CSPEN recommends that you print out and thoroughly review all of this information as a reference tool and a source document you can use to help support the decisions and determinations you make.
Additional Resources for Higher Education Institutions:
- The Office of Postsecondary Education issued Information for Accrediting Agencies Regarding Temporary Flexibilities Provided to Coronavirus Impacted Institutions or Accrediting Agencies (March 17, 2020)
- U.S. Immigration and Customs Enforcement (ICE) issued guidance on Coronavirus Disease 2019 (COVID-19) and Potential Procedural Adaptations for F and M Nonimmigrant Students (March 9, 2020)
- The Office of Postsecondary Education issued Guidance for interruptions of study related to Coronavirus (COVID-19) (March 5, 2020)
- The CDC issued Interim Guidance for Administrators of US Institutions of Higher Education (IHE) to Plan, Prepare, and Respond to Coronavirus Disease 2019 (COVID-19) (March 2, 2020)
- Federal Student Aid issued Coronavirus Information for Students, Borrowers, and Parents.
The last of the five bullets listed above is a FAQ page that also contains a separate list of additional resources you may want to review.
Federal Government Websites for Additional Information
Here are some sites that you or your school may find useful:
- Coronavirus.gov — The Centers for Disease Control and Prevention offers this site, which features everything from prevention tips, common symptoms, and current updates on how many cases there are in the United States, to advice about travel and a list of frequently asked questions.
- USA.gov coronavirus page — USAGov shares how agencies across the federal government are responding to the outbreak.
- Federal student loan servicers — Our website lists servicer contact information for borrowers who want to ask questions, request a deferment or forbearance, etc.
- U.S. Department of Education COVID – 19 information for schools and school personnel
- Information for Financial Aid Professionals website (for postsecondary school financial aid staff; look for information in the “Letters and Announcements” section)
Perhaps most importantly, if you have questions, the Department has established a new email specifically for COVID-19 questions. It is COVID-192ed.gov.
The best place to track the latest information from the Department of Veterans Affairs is on their Education and Training webpage.
Upon review of their site you will note that VA Educational Services has hosted and continue to prepare to host a number of key COVID-19 Webinars. Here is a brief listing of the webinars that have already taken place and those coming up in the near future.
Previously Held VA Webinar for Beneficiaries:
COVID-19 Virus Concerns and How It Affects Your Benefits
March 12, 2020 1:30 PM
See our 3/12 Facebook post discussing Cornona Virus and its impact on your monthly housing allowance.
If you have questions about your specific circumstance, please contact the Education Call Center at: 1-888-442-4551 between 8 AM and 7 PM Eastern Time, Monday-Friday.
Upcoming VA Webinars for SCOs and SAAs
Rescheduled COVID-19 Informational Webinar – For State Certifying Officials (SCOs) to Discuss COVID-19 Impact
WHEN: Friday, March 27 | 11:00 AM & 1:00PM EST
AUDIENCE: SAAs & SCOs
Rescheduled COVID-19 Informational Webinar – For State Certifying Officials (SCOs) to Discuss COVID-19 Impact
March 18, 2020 1:30 PM
WHEN: Thursday, March 26 | 11:00 AM & 1:00PM EST
AUDIENCE: SAAs & SCOs
Please note that SAAs and SCOs are invited to attend either session. The same content will be presented at both sessions and webinar materials will be posted on the Education Service website shortly after the session.
One of, if not the best source, that CSPEN has found tied directly to the Department of Defense is “Military One Source” and the webpage they regularly update with the latest information on COVID-19.
On Friday, March 13, 2020, the Department of Homeland Security’s Student and Exchange Visitor Program (SEVP) published more detailed guidance on how it will offer flexibility in relation to rules that typically restrict international students from counting more than one online course toward the requirement that they maintain a full-time course of study.
As has been reported this evening in the media yesterday, last night the U.S. Senate passed the second, of what are currently three separate pieces of emergency legislation thus far focused on relief and support of the nation in response to the Coronavirus pandemic. Below is a brief summary of the legislation enacted, legislation pending enactment, and legislation being developed currently in under the urgency of the White House, with support from the House and Senate.
Emergency Funding Legislation
The initial “Phase One” legislation, H.R.6074 – The Coronavirus Preparedness and Response Supplemental Appropriations Act, 2020, was signed into law (P.L. 116 – 123) by President Trump March 6, 2020. The recently enacted law provides $8.3 billion in emergency funding for federal agencies to respond to the coronavirus outbreak. The emergency funds are shared amongst many Departments within Health and Human Services, Small Business, State, and the Agency for International Development. The programs funded by the bill address issues such as
- developing, manufacturing, and procuring vaccines and other medical supplies;
- grants for state, local, and tribal public health agencies and organizations;
- loans for affected small businesses;
- evacuations and emergency preparedness activities at U.S. embassies and other State Department facilities; and
- humanitarian assistance and support for health systems in the affected countries.
The “Second Phase” legislation, H.R.6201 – Families First Coronavirus Response Act, passed the U.S. House of Representatives last Saturday (March 14th) and the Senate late yesterday afternoon (March 18th) and is headed to the President’s desk for his approval, which has already been agreed to. Once enacted the new law (likely P.L. 116 -124) will provide paid sick leave and free coronavirus testing, expand food assistance and unemployment benefits, and require employers to provide additional protections for health care workers. The bill also includes provisions that
- establish a federal emergency paid leave benefits program to provide payments to employees taking unpaid leave due to the coronavirus outbreak,
- expand unemployment benefits and provide grants to states for processing and paying claims,
- require employers to provide paid sick leave to employees,
- establish requirements for providing coronavirus diagnostic testing at no cost to consumers,
- treat personal respiratory protective devices as covered countermeasures that are eligible for certain liability protections, and
- temporarily increase the Medicaid federal medical assistance percentage (FMAP).
On the horizon is yet a third $1 trillion stimulus bill being proposed by the Trump Administration, that is currently being widely discussed as necessary to jumpstart the economy, further protect individuals, small businesses, and targeted industries (airlines, travel and tourism, et. al.) who are seeing massive reductions in revenue as a result of the still spreading virus. The “Phase Three” legislation, as outlined in a two-page Treasury Department document, would provide:
- $500 billion in funding for “Economic Impact Payments”
This provision would authorize and appropriate funds for two rounds of direct payments to individual taxpayers, to be administered by the IRS and Bureau of the Fiscal Service.
- $250 billion to be issued beginning April 6
- $250 billion to be issued beginning May 18
Payment amounts would be fixed and tiered based on income level and family size. Each round of payments would be identical in amount.
- $200 Billion in funding under the “Exchange Stabilization Fund” for
- $50 billion is to be used to support sustained funding for the airlines; and
- $150 billion is to be used to support sustained funding for industries most impacted by the pandemic.
- $300 Billion in funding to support Small Business
The funds provided would be used to ensure continuity of employment through business interruptions, this provision would authorize the creation of a small business interruption loan program, helping to promote investment in new small business start-ups.
Two Other Possible Higher Education-related Proposal
- On Monday, March 16, 2020, Senator Jerry Moran (-KS) introduced, and successfully passed by voice vote, a bipartisan bill S. 3503.
Under the proposed legislation the Secretary of Veterans Affairs is granted new authority to treat certain programs of education converted to distance learning by reason of emergencies and health-related situations in the same manner as programs of education pursued at educational institutions.
“Student veterans relying on the GI Bill to attend college should not be stripped of their benefits because universities are moving to online classes to prevent the spread of the coronavirus,” Moran. “We must swiftly pass this bill to make certain that veterans still receive the benefits they’ve earned.”
CSPEN anticipates that the House will take up consideration of this bill upon their return to Washington and that the legislation will receive swift approval from both the House and the President. Without it, many veterans education benefits will be significantly reduced under existing GI Bill requirements.
- On Thursday. March 12, 2020 Senator Patty Murray (D-WA) has introduced S. 3489, the Supporting Students in Response to Coronavirus Act.
As introduced the legislation would provide more than $3 billion in new mandatory grant funding for both higher education and preK-12 education. It includes $1.2 billion for governors for to provide emergency preparedness and support grants for school districts and institutions of higher education, $1.2 billion in emergency financial aid for students facing unexpected needs because of coronavirus disruptions and response, $600 million to keep early care and education programs operating, and other provisions.
While nothing is certain, it is possible that some or all of this proposal could be incorporated into the “Phase Three” stimulus bill. We will have to monitor the status of this, and other proposals as the third bill is quickly drafted, amended, and likely enacted in the days/weeks ahead.
CSPEN Disclaimers & Suggestions
- CSPEN does not have all of the answers, but neither do the Federal or State legislators and regulators. We are all trying to navigate these uncharted waters together, and EVERYTHING IS VERY FLUID RIGHT NOW, so please keep in mind that things are subject to update, modification, revision, or perhaps even a reversal of direction as this all plays out.
- All the information CSPEN shares is sourced so that you can go back and refer to it when and as needed and, as if not more importantly, you have the ability to read and interpret it for yourselves. As there are currently, and we suspect will continue to be, differences in perspective and interpretations we try not to recommend positions or directions, merely provide you with the resources to make the determination best suited to your circumstances.
- And finally, and most importantly, none of the information CSPEN provides should take the place of conversations with the experts within your institution, legal counsel, third-party servicers who are here to support your institution and students, and state and national associations and organizations.
- As previously noted, CSPEN suggests that you start a COVID-19 File storing all of the correspondences and guidance receive – at both the state federal level – to refer to as needed/necessary.
- When making decisions, and to the degree possible, we don’t think you can go wrong by doing what is in the best interest of the student, that is as long as you do so in conjunction with our third suggestion.
- Whatever you decide to do…DOCUMENT IT, DOCUMENT IT, DOCUMENT IT (and it wouldn’t hurt to cross-reference it with your COVID-19 File information).
But don’t take our word on it, refer back to the Department’s March 5, 2020 guidance, where from the outset they recommend:
“We recommend that institutions document, as contemporaneously as possible, any actions taken as a result of COVID-19, including those actions described in this document.”