This weekly update from the government relations office at the American Association of Community Colleges (AACC) provides the latest on what’s happening in Washington and how AACC is advancing policies to support community colleges and students. Send questions, feedback and more to: kgimborys@aacc.nche.edu.
- TRIO, Distance Education, Return of Title IV Funds NPRM published in Federal Register
- GAO releases report on student food insecurity and SNAP
TRIO, Distance Education, Return of Title IV Funds NPRM published in Federal Register
This week, the Department of Education (ED) released the Notice of Proposed Rulemaking (NPRM) to amend existing regulations on distance education, return of Title IV funds (R2T4), and eligibility for Federal TRIO programs. A key step in the regulatory process, the NPRM was published after the American Association of Community Colleges (AACC) and other stakeholders provided formal oral comments to the Office of Management and Budget (OMB). That feedback opportunity came after a lengthy negotiated rulemaking process earlier this year. AACC members were present as negotiators during those sessions.
While the negotiated rulemaking tables covered a number of topics related to program integrity and institutional quality, only those regarding distance education, R2T4, and TRIO were advanced through this NPRM. The Department has not yet advanced rules on state authorization, cash management, and accreditation.
The NPRM extends eligibility for Federal TRIO Programs to undocumented students, reflecting the consensus reached by negotiators during the final rulemaking session. AACC enthusiastically supports this change.
Negotiators did not reach consensus on distance education and R2T4 language, giving the Department the ability to craft their own proposals. While AACC welcomes several of the proposed changes, including many aimed at making the R2T4 process easier for financial aid offices, others raise significant questions and concerns. AACC opposes the proposed change eliminating Title IV eligibility for asynchronous online programs measured in clock hours. AACC also opposes proposed language requiring institutions to take attendance for online courses for the purpose of calculating a withdrawal date for R2T4.
The publication of the NPRM in the Federal Register kicked off a 30-day comment period, with comments due on August 23, 2024. AACC will submit formal written comments reiterating our concerns and will ask its members to do the same. The rules must be published in final form by November 1 to take effect next July.
GAO releases report on student food insecurity and SNAP
On Wednesday, the Government Accountability Office (GAO) released a new report on Supplemental Nutrition Assistance Program (SNAP) uptake among eligible college students. Using data from the National Postsecondary Student Aid Survey (NPSAS), the researchers estimate that 3.8 million college students, or 23 percent, experienced food insecurity, with 2.2 million of those students reporting multiple instances of skipping meals because they could not afford food. By matching NPSAS data with the rules governing SNAP eligibility for college students, the GAO found that 59 percent of students who reported experiencing food insecurity and met income and eligibility requirements for SNAP benefits did not report receiving the benefits in 2020.
The rules governing SNAP eligibility for college students are among the most complicated for receipt of any federal benefit. In addition to meeting the program’s eligibility requirements around income, household size, and citizenship, students enrolled at least half-time are ineligible unless they meet a specific exemption. These exemptions include working at least 20 hours a week, caring for a child under the age of six, and participating in federal or state work study. Because the rules are so complex, many students and administrators have the impression that students are wholly ineligible. This notion depresses uptake among eligible college students and contributes to the “SNAP Gap” found by GAO researchers.
AACC strongly supports efforts to simplify SNAP eligibility for college students and facilitate greater program participation. While securing any SNAP expansions in the upcoming Farm Bill reauthorization will be politically challenging, AACC will continue to raise awareness of food insecurity for community college students and opportunities to support student success.