The COVID-19 Pandemic and Institutions of Higher Education: Contemporary Issues

The COVID-19 Pandemic and Institutions of Higher Education: Contemporary Issues

The COVID-19 Pandemic and Institutions of
January 27, 2021
Higher Education: Contemporary Issues
Benjamin Collins
There have been numerous reports of institutions of higher education (IHEs) experiencing
Analyst in Labor Policy
financial hardships as a result of the Coronavirus Disease 2019 (COVID-19) pandemic. This

report discusses and contextualizes issues related to IHEs’ stability and fiscal health during the
Joselynn H. Fountain
pandemic. It does not directly discuss health and safety factors that relate to the logistical
Analyst in Education Policy
operation of an IHE during the COVID-19 pandemic.

To provide background on the types of issues IHEs are facing, this report begins with a
Cassandria Dortch
discussion of IHE revenues and expenditures. While institutions’ revenue sources vary in
Specialist in Education
general, there are some reasonably clear patterns of variation across institutional sectors. Tuition
Policy
revenue is a major source of revenue for both public and private IHEs, although broadly

speaking, private IHEs (particularly proprietary IHEs) rely on tuition for a larger share of their
revenue than do public IHEs. State and local support account for a significant share of the

revenue at public IHEs, particularly for public two-year IHEs. While the specific effects of the
COVID-19 pandemic on IHE revenues are not yet clear, it is likely there will be declines in some sources of revenue for
many institutions. IHEs may also need to adjust their expenditure strategies to accommodate the circumstances brought about
by the pandemic.
Enrollment is a key factor in IHEs’ revenue, and changes to enrollment in light of the COVID-19 pandemic might have a
major impact on the financial stability of some IHEs. This report discusses how the pandemic may affect enrollment, with a
focus on the uncertainty and dynamic nature of the situation. While enrollment has increased in the past during several
periods of high unemployment, including during the Great Recession, it is not clear that the same pattern will occur in a
pandemic-induced recession. Preliminary data available at this time suggest there have been enrollment declines during the
COVID-19 pandemic.
State and local budget shortfalls are also a concern, as public IHEs rely heavily on revenues from these sources to support
general operations. State and local appropriations per student at public four-year IHEs have generally not rebounded to the
levels provided prior to the Great Recession, resulting in more reliance on tuition revenue.
Implications of expanded remote learning are discussed throughout this report. The section of the report dealing with
institutional finances, for instance, discusses how expanded remote learning could affect various forms of revenue and
institutions’ spending strategies. The enrollment section discusses how expanded remote learning may affect students’
enrollment decisions. The report also discusses administrative and regulatory issues that have emerged related to federal
student aid availability at IHEs that expand remote learning in light of the pandemic.
The report concludes with a discussion of congressional options for responding to the circumstances faced by IHEs in light of
the pandemic. The options considered are largely based on legislation enacted in response to the current situation and prior
disasters. For example, in March 2020 the CARES Act (P.L. 116-136) provided over $14 billion in emergency funds to IHEs
and postsecondary students to address needs directly related to disruptions caused by the pandemic. The CARES Act also
variously required or authorized the Secretary of Education to reduce institutional matching requirements for some federal
programs. Should Congress seek to provide further support, options could inclu de providing additional direct grants to
institutions, providing indirect support through intermediaries such as states, or expanding regulatory flexibility.
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Contents
Introduction ................................................................................................................... 1
Postsecondary Institution Finances .................................................................................... 2
Major Sources of Revenue at Institutions of Higher Education.......................................... 2
Tuition and Fees ........................................................................................................ 6
State and Local Funding ............................................................................................. 6
Federal Revenue...................................................................................................... 11
Auxiliary, Hospital, and Gifts and Endowments Revenue............................................... 11
Changes in Institutional Expenditures ......................................................................... 13
Enrollment and the COVID-19 Pandemic ......................................................................... 13
Historical Background and Recent Trends ................................................................... 14
The COVID-19 Pandemic and Enrollment: A Confluence of Factors ............................... 15
Enrollment Indicators for Fal 2020....................................................................... 15
Unemployment and Labor Market Effects on Enrollment ......................................... 16
Challenges in Interpreting Surveys ........................................................................ 17
Influence of Remote Learning on Enrollment ......................................................... 18
Enrollment of International Students ..................................................................... 19
Administrative and Regulatory Issues Related to Remote Learning ....................................... 20
Pre-pandemic Remote Learning ................................................................................. 20
HEA Title IV Institutional and Program of Education Eligibility Issues ............................ 21
ED Approval of Distance Education ...................................................................... 21
Correspondence Courses ..................................................................................... 22
State Authorization ............................................................................................. 22
Accreditation ..................................................................................................... 23
Recent Action and Further Congressional Considerations .................................................... 24
Direct Financial Support to Institutions ....................................................................... 24
Indirect Financial Support to Institutions ..................................................................... 25
Waivers and Flexibilities........................................................................................... 26

Figures
Figure 1. Revenue at Public Title IV Participating IHEs, by Source......................................... 4
Figure 2. Revenue at Private Title IV Participating Nonprofit and Proprietary IHEs, by
Source ........................................................................................................................ 5

Tables
Table 1. Average State and Local Appropriations per Full-Time Equivalent (FTE) Student
at Title IV Participating Public IHEs, 2004-2018 ............................................................... 9
Table 2. Enrollment in Title IV Participating IHEs by Control and Level and National
Unemployment Rate, 2004-2018 .................................................................................. 15
Table 3. Percentage of IHEs Offering Distance Education Opportunities, by Sector (Fal
2019)........................................................................................................................ 21

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Appendixes
Appendix. Background on IPEDS and Data Methodology for Postsecondary Revenue............. 27

Contacts
Author Information ....................................................................................................... 28

Congressional Research Service

The COVID-19 Pandemic and Institutions of Higher Education: Contemporary Issues

Introduction
Reports of institutions of higher education (IHEs) experiencing financial hardships as a result of
the Coronavirus Disease 2019 (COVID-19) pandemic have been widespread, and the financial
conditions caused or exacerbated by the pandemic may force some schools to modify their
operations significantly.1 This report identifies and discusses several factors that are relevant to
institutions’ fiscal health as impacted by the pandemic, including potential changes in revenue
and enrollment as wel as considerations related to remote learning.2
The CARES Act (P.L. 116-136) and the Consolidated Appropriation Act, 2021 (P.L. 116-260)
provided over $36 bil ion in emergency funds to IHEs and postsecondary students to address
needs directly related to the COVID-19 pandemic, including, but not limited to, transitioning
courses to distance education and providing grant aid to students for costs associated with
facilitating their educational pursuits such as food, housing, course materials, health care, and
child care. Additional y, the CARES Act reduced the financial matching requirement of some
grant programs.
Analyzing issues relating to IHEs and the COVID-19 pandemic while it is stil developing poses
a number of chal enges. First, the largely unprecedented nature of the current situation makes it
chal enging to define, contextualize, and interpret using traditional indicators. Second, education
data tend to lag by a year or more, so while pre-pandemic baselines can be informed by
rigorously produced data, discussion of more recent developments are informed by data that are
incomplete or otherwise less authoritative. Lastly, the decentralized nature of higher education
and the constantly evolving nature of the pandemic makes synthesizing available information
chal enging. As such, some elements of this report wil draw on data from prior years to frame
issues and discuss the potential effects of current circumstances rather than attempting to
precisely establish current conditions.
The report is organized as follows:
 an overview of institutional finances at different types of IHEs (i.e., public,
private nonprofit, proprietary), including discussions of the implications of
potential changes in different types of revenue for each type of IHE;
 discussion of enrollment trends at IHEs and potential effects of the pandemic on
enrollment, with a focus on the evolving nature of this issue;
 a description of expanded use of remote learning, and policy issues related to
remote learning, with a focus on the interaction of distance education and
programs authorized under Title IV of the Higher Education Act (HEA); and
 a discussion of recent congressional action in response to current circumstances,
including the CARES Act and the Consolidated Appropriations Act, 2021, as

1 See, for example, Shawn Hubler, “Colleges Slash Budgets in the Pandemic, With ‘Nothing Off -Limits,’” New York
Tim es, October 26, 2020, https://www.nytimes.com/2020/10/26/us/colleges-coronavirus-budget -cuts.html; Emma
Whitford, “New Round of Budget Cuts Hitting Personnel,” Inside Higher Education, October 7, 2020,
https://www.insidehighered.com/news/2020/10/07/colleges-running-out-budget -areas-trim-besides-personnel; Andrew
P. Kelley and Rooney Columbus, College in the Tim e of Coronavirus: Challenges Facing Am erican Higher Education ,
American Enterprise Institute, July 2020, https://www.aei.org/wp-content/uploads/2020/07/College-in-the-Time-of-
Coronavirus.pdf; Kery Murukami, “ Haves and Have-Nots on COVID-19 Protection,” Inside Higher Ed, June 25, 2020,
https://www.insidehighered.com/news/2020/06/25/wealthier-colleges-can-offer-more-protection-covid-19-cash-
strapped-peers.
2 T he term remote learning is used to refer collectively to the following commonly used terms: online education,
distance education, and correspondence courses.
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wel as potential policy options to further support or more precisely target
support to IHEs during the pandemic.
The COVID-19 pandemic is affecting IHEs differently, and they are responding in diverse ways.
This report aims to discuss scenarios that may be applicable to a wide range of institutions,
though not every issue it addresses wil be applicable to every institution. For example, the
discussions related to remote learning may be of limited applicability to institutions that are
conducting classes primarily or entirely in-person. Additional y, the focus of the report is
primarily on educational and financial issues faced by IHEs. Aside from consideration of their
relevance to educational and financial chal enges, the report does not explore health and safety
issues faced by IHEs during the pandemic.
Postsecondary Institution Finances
Since the beginning of the COVID-19 pandemic, there have been reports of significant losses of
revenue at IHEs.3 Additional y, IHEs that opened or planned to open their campuses in academic
year (AY) 2020-2021 (July 1, 2020-June 30, 2021) have reportedly invested in a range of
recommended measures in an attempt prevent the coronavirus from spreading.4 Historical y,
different types of IHEs have varied in their reliance on particular forms of revenue. Thus, the
effect of the pandemic on IHEs wil likely differ by certain institutional characteristics.
This section of the report analyzes major sources of revenue for different types of IHEs and
discusses the potential effects of the COVID-19 pandemic on those sources. It also provides a
brief discussion on institutional expenditures within the context of the pandemic.
Major Sources of Revenue at Institutions of Higher Education
IHEs realize revenues from a number of different sources, including tuition and fees, state and
local appropriations, federal appropriations and grants, private donors, auxiliary services, and
endowments.5 Revenue sources at public IHEs tend to differ by level (i.e., four-year, two-year,
less than two-year), while revenue at private nonprofit and private proprietary IHEs are consistent
across levels. Thus, when analyzing revenue for public IHEs, the data are disaggregated by four-
year and two-year or less IHEs (two-year or less IHEs are collectively referred to hereinafter as
two-year IHEs). Figure 1 provides the distribution of revenue sources at public IHEs that

3 See, for example, Victoria Yuen, “Mounting Peril for Public Higher Education During the Coronavirus Pandemic,”
Center for Am erican Progress, June 11, 2020, https://www.americanprogress.org/issues/education-postsecondary/
reports/2020/06/1/485963/mounting-peril-public-higher-education-coronavirus-pandemic/; Madeline St. Amour,
“Coronavirus News Roundup for April 21,” Inside Higher Ed, April 21, 2020, https://www.insidehighered.com/news/
2020/04/21/april-21-covid-19-roundup-revenue-losses-summer-enrollment-and-cannabutter; and Andrew P. Kelley and
Rooney Columbus, College in the Tim e of Coronavirus: Challenges Facing Am erican Higher Education , American
Enterprise Institute, July 2020, https://www.aei.org/wp-content/uploads/2020/07/College-in-the-Time-of-
Coronavirus.pdf.
4 See, for example, Kery Murakami, “Haves and Have-Nots on COVID-19 Protection,” Inside Higher Ed, June 25,
2020, https://www.insidehighered.com/news/2020/06/25/wealthier-colleges-can-offer-more-protection-covid-19-cash-
strapped-peers; Doug Lederman, “ COVID-19’s Forceful Financial Hit: A Survey of Business Officers,” Inside Higher
Ed, July 10, 2020, https://www.insidehighered.com/news/survey/covid-19s-forceful-financial-hit -survey-business-
officers; Victoria Yuen, “ Mounting Peril for Public Higher Education During the Coronavirus Pandemic,” Center for
Am erican Progress, June 11, 2020, available at https://www.americanprogress.org/issues/education-postsecondary/
reports/2020/06/1/485963/mounting-peril-public-higher-education-coronavirus-pandemic/.
5 Postsecondary revenue data were retrieved from the U.S. Department of Education, Integrated Postsecondary
Education Data System (hereafter referred to as IPEDS) for FY2018.
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participate in HEA Title IV programs (hereinafter referred to as Title IV-participating IHEs),6 and
Figure 2 provides the distribution of revenue sources at private nonprofit and proprietary Title
IV-participating IHEs. It is worth noting that tuition and fees revenues include federal student aid
(e.g., Pel Grants7 and GI Bil benefits8) that are used by students to pay tuition. These federal
student aid sources are thus excluded from calculations of federal revenue.
The sources of revenue and potential effects of the pandemic on each source are discussed in
more detail in the next few subsections. See the Appendix for a description of the methodology
used to calculate revenues and adjustments made to resolve differences in accounting standards
between public and private IHEs.9

6 T here have been reports of non-T itle IV participating IHEs facing financial difficulties, but such IHEs are not covered
in the data presented in this report.
7 For more information, see CRS Report R45418, Federal Pell Grant Program of the Higher Education Act: Primer.
8 For more information, see CRS Report R42785, Veterans’ Educational Assistance Programs and Benefits: A Primer.
9 Generally, private nonprofit and proprietary IHEs report finance data using accounting standards established by the
Financial Accounting Standards Board (FASB), while public IHEs generally use standards established by the
Governmental Accounting Standards Board (GASB). A small portion (about 1.5% of public IHEs) report using FASB.
T hose IHEs were excluded from the analysis.
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Figure 1. Revenue at Public Title IV Participating IHEs, by Source
FY2018

Source: CRS calculations using the U.S. Department of Education, Integrated Postsecondary Education Data System.
Notes:
“Other” for public four-year IHEs includes independent operations, sales and services of education activities, and other sources of revenue not separately identified;
federal student aid that students use to cover tuition and fees is included in tuition and fees revenue, and not federal fund ing.
“Other” for public two-year IHEs includes auxiliary enterprises, independent operations, gifts, investment return, additions to endowment, sales and services of
education activities, sales and services of hospitals, and other sources of revenue not separately identified; federal studen t aid that students use to cover tuition and fees
is included in tuition and fees revenue, and not federal funding.
CRS-4

Figure 2. Revenue at Private Title IV Participating Nonprofit and Proprietary IHEs, by Source
FY2018

Source: CRS calculations using U.S. Department of Education, Integrated Postsecondary Education Data System.
Notes:
“Other” for nonprofit IHEs includes state and local funding, independent operations, sales and services of education activities, and other sources of revenue not
separately identified; federal student aid that students use to cover tuition and fees is included in tuition and fees revenu e, and not federal funding.
“Other” for proprietary IHEs includes federal revenue, state and local funding, auxiliary enterprises, independent operations, gifts, investment return, additions to
endowment, sales and services of education activities, sales and services of hospitals, and other sources of revenue not separately identified; federal student aid that
students use to cover tuition and fees is included in tuition and fees revenue.

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Tuition and Fees
Tuition and fees reflect revenues IHEs realize from al tuition and fees assessed against students
for educational purposes, including grant and loan aid used by students to pay tuition.10
Tuition and fees provide most of the revenue for proprietary IHEs and are one of the top two
sources of revenue for public and nonprofit IHEs. Specifical y, in FY2018 tuition and fees
provided 92% of the revenue at proprietary IHEs (Figure 2), 30% at nonprofit IHEs (Figure 2),
23% at public four-year IHEs (Figure 1), and 25% at public two-year IHEs (Figure 1).
Student enrollment is one of the strongest drivers of tuition and fee revenue. As IHEs make
decisions around offering in-person classes or remote learning as the COVID-19 pandemic
continues to evolve, students are likewise making decisions on whether to enroll/re-enroll or
postpone to a later date (The uncertainty around student enrollment is discussed further in the
“Enrollment and the COVID-19 Pandemic” section of this report.) IHEs that experience declines
in enrollment are likely to experience declines in tuition and fees revenue.
Under normal circumstances, IHEs could consider adjusting marketing strategies or admissions
standards to sustain enrollment, or increasing tuition and fees charges in response to declines in
enrollment to make up for lost revenue. However, numerous IHEs are finding it necessary under
current circumstances to lower tuition and fees as classes move online, which could exacerbate
losses in tuition revenue.11 In some cases, IHEs have lowered tuition as a result of pressure from
students and parents who have asserted that online education is inferior to in-person instruction.12
Thus, IHEs seeking to maintain tuition and fee revenue are faced with balancing tuition reduction
with projected enrollment. For example, if a school offers widespread tuition discounts,13 it is
possible that it wil experience financial hardship in spite of consistent or even increased
enrollment.14
Given the reliance of public, nonprofit, and proprietary IHEs on tuition and fees, declines in
enrollment and/or tuition reductions are likely to have effects on IHEs across sectors.
State and Local Funding
State and local funding includes revenue IHEs realize through acts of a state legislative body,
revenue from appropriations by governmental entities below the state level, revenue from
education district taxes and other similar revenue that result from actions of local governments or

10 Institutional grant aid applied to tuition and fees is excluded from the tuition and fee revenue calculation.
11 Emma Kerr, “T hese Colleges Are Giving T uition Discounts T his Fall,” U.S. News & World Report, August 12, 2020,
https://www.usnews.com/education/best-colleges/paying-for-college/articles/these-colleges-are-giving-tuition-
discounts-this-fall.
12 Lilah Burke, “Rebates and Reversals,” Inside Higher Ed, July 24, 2020, https://www.insidehighered.com/news/2020/
07/24/some-colleges-discount -tuition-prices-online-fall.
13 T uition discounting is the practice by which colleges and universities “provide grant aid to undergraduates to help
them pay for all or part of the tuition and fees charged by the institution.” For more information, see Laura Horn and
Katharin Peter, What Colleges Contribute: Institutional Aid to Full-Tim e Undergraduates Attending four-year Colleges
and Universities, U.S. Department of Education, National Center for Education Statistics, NCES 2003 –157, Project
Officer: C. Dennis Carroll, Washington, DC, 2003.
14 See, for example, Emma Whitford, “Enrollments Could Rise While T uition Revenue Falls, Moody’s Says,” Inside
Higher Ed, June 4, 2020, https://www.insidehighered.com/quicktakes/2020/06/04/enrollments-could-rise-while-tuition-
revenue-falls-moody%E2%80%99s-says.
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citizens, and amounts reported as non-operating revenues from state and local government
agencies that are provided on a non-exchange basis.15
State and local funding is a primary source of revenue for public IHEs; however, their relative
reliance on it differs by level. Specifical y, public four-year IHEs realized 26% and public two-
year IHEs realized 59% of their revenue from state and local sources (Figure 1) in FY2018. State
and local funding comprised less than 1% of revenue at nonprofit IHEs (Figure 2). Proprietary
IHEs general y do not receive any state and local funding.
Several states have reported revenue declines as a result of the COVID-19 pandemic.16 Unlike the
federal government, state governments must routinely balance their operating budgets, typical y
every one or two years, by offsetting reductions in revenues with increases in revenues,
reductions in spending, or a combination of both unless other measures are available.17 During
economic downturns, state funding for higher education tends to decline at a greater rate than
other budget categories, which has led some to describe higher education as a balance wheel of
state budgets.18 One reason that states rely on higher education to balance their budgets is that
states have more flexibility to adjust higher education spending than they do with other budget
items that are subject to spending pressures (e.g., Medicaid, elementary and secondary
education).19 Also, unlike other entities that receive state funding, public IHEs have access to
additional forms of revenue, such as tuition and endowments, which could potential y offset state
funding reductions.
Ongoing declines in state appropriations for public IHEs after the Great Recession suggest that
economic downturns can have lasting effects on state funding for public IHEs, extending years
beyond a recession.20 As il ustrated in Table 1, public four-year IHEs experienced an inflation-
adjusted decline in state and local appropriations from 2009 to 2013, while enrollment general y
increased. By 2018, state and local appropriations were increasing, but had not yet reached pre-
recession levels. When funding is examined on a per full-time equivalent (FTE) student basis, it

15 Revenues provided on a non-exchange basis are those that are provided by the government to an entity without the
government directly receiving anything in exchange. See htt ps://www.gasb.org/st/summary/gstsm33.html.
16 See, for example, CRS Insight IN11394, State and Local Fiscal Conditions and COVID-19: Lessons from the Great
Recession and Current Projections; Center on Budget and Policy Priorities, States Grappling With Hit to T ax
Collections, October 5, 2020, https://www.cbpp.org/research/state-budget-and-tax/states-grappling-with-hit-to-tax-
collections; and Sophie Nguyen, Rachel Fishman, and Dustin Weeden, T he Impact of COVID-19 on State Higher
Education Budgets, October 20, 2020, https://www.newamerica.org/education-policy/reports/state-budget -cuts/?
utm_medium=email&utm_campaign=EdCentral%20580&utm_content=
EdCentral%20580+CID_4f93189ec412e64f5096ffd2294c2e1b& utm_source=Campaign%20Monitor%20Newsletters&
utm_term=how%20the%20COVID-
19%20pandemic%20has%20affected%20state%20funding%20for%20public%20higher%20education .
17 For more information, see CRS Insight IN11258, State and Local Fiscal Conditions and Economic Shocks.
18 See, for example, State Higher Education Finance, “New Report Finds State Funding Remains Below Historic
Levels as Public Colleges Brace for a Recession and Expected Budget Cuts,” FY2019 press release,
https://shef.sheeo.org/wp-content/uploads/2020/04/SHEEO_SHEF_FY19_Press_Release.pdf; and National Association
of State Budget Officers, A Guidebook on State Budgeting for Higher Education, 2015,
https://higherlogicdownload.s3.amazonaws.com/NASBO/9d2d2db1-c943-4f1b-b750-0fca152d64c2/UploadedImages/
Reports/Higher%20Education%20State%20Budgeting%20Guidebook.pdf .
19 National Association of State Budget Officers, A Guidebook on State Budgeting for Higher Education , 2015,
https://higherlogicdownload.s3.amazonaws.com/NASBO/9d2d2db1-c943-4f1b-b750-0fca152d64c2/UploadedImages/
Reports/Higher%20Education%20State%20Budgeting%20Guidebook.pdf .
20 See State Higher Education Finance, State Higher Education Finance, FY2019, https://shef.sheeo.org/wp-content/
uploads/2020/04/SHEEO_SHEF_FY19_Report.pdf.
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The COVID-19 Pandemic and Institutions of Higher Education: Contemporary Issues

was stil wel below the inflation-adjusted pre-recession level as state appropriations struggled to
keep pace with increases in student enrollment.
Public two-year IHEs similarly experienced inflation-adjusted declines in state and local
appropriations from 2009 to 2013 while enrollment increased to above pre-recession levels during
the same period. In subsequent years, appropriations began to increase while enrollment steadily
decreased. When state and local appropriations at public two-year IHEs are examined on a per
FTE student basis, it is evident that since 2012 a combination of increases in appropriations and
reduced enrollment has resulted in a steady increase in per FTE student funding that has
surpassed pre-recession levels in recent years. It is worth noting that more than one-third of the
decrease in enrollment from 2012 to 2018 is due to the reclassification of public two-year
institutions to public four-year institutions.21
Overal , these data suggest that state budget declines during the COVID-19 pandemic recession
may have lingering effects that public IHEs wil deal with for years beyond the recession.

21 Using IPEDS data on 12-month FT E enrollment, CRS estimates that 63 public two-year institutions with a combined
enrollment of approximately 373,000 were reclassified as public-four year institutions between 2012 and 2018.
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Table 1. Average State and Local Appropriations per Full-Time Equivalent (FTE) Student at Title IV Participating Public
IHEs, 2004-2018
(2018 dol ars)

Public Four-Year IHEs
Public Two-Year or Less IHEs
State and Local
12-Month FTE
State and Local
State and Local
12-Month FTE
State and Local
Appropriation
Student Enrollment
Appropriations per
Appropriations
Student Enrollment
Appropriations
Year
($000)
(000)
FTE Student
($000)
(000)
per FTE Student
2004
$53,719,789
5,685
$9,449
$23,278,508
4,209
$5,531
2005
$54,613,307
5,789
$9,434
$24,976,053
4,168
$5,992
2006
$55,553,343
5,850
$9,497
$25,848,230
4,146
$6,235
2007
$58,175,301
5,999
$9,698
$27,035,019
4,141
$6,529
2008
$60,989,997
6,179
$9,870
$27,396,075
4,310
$6,356
2009
$57,380,216
6,377
$8,998
$27,166,651
4,591
$5,917
2010
$54,358,906
6,796
$7,999
$25,923,844
4,993
$5,192
2011
$53,781,664
7,011
$7,672
$25,578,878
5,052
$5,063
2012
$48,919,452
7,101
$6,890
$24,290,534
4,808
$5,052
2013
$47,974,841
7,027
$6,827
$23,873,942
4,593
$5,198
2014
$50,934,172
7,114
$7,159
$24,793,172
4,459
$5,560
2015
$52,053,538
7,178
$7,252
$25,282,658
4,285
$5,900
2016
$53,280,256
7,298
$7,301
$26,654,139
4,146
$6,429
2017
$54,993,659
7,563
$7,272
$25,535,013
3,868
$6,602
2018
$56,800,879
7,657
$7,418
$25,748,460
3,751
$6,864
Source: CRS calculations using the U.S. Department of Education’s Integrated Postsecondary Education Data System, multiple years. Met hodology is described in the
Appendix of this report.
Notes: Finance data are based on an IHE’s fiscal year, while FTE student data are based on the academic year. Thus, in a given year there may be a mismatch between
the period of time covered for purposes of measuring FTE student enrol ment and for purposes of measuring state and local appropriations.
CRS-9

Dol ar amounts have been converted to constant 2018 dol ars based on the consumer price index for al urban consumers (CPI -U). The CPI-U is saved on the academic
fiscal year and is constructed by taking the average of the monthly CPI-U from July through June (e.g., the FY2018 index is the average of the monthly indices from July
2017 through June 2018.) When reporting finance data, IHEs report based on the institution’s fiscal yea r. As such, the fiscal year may differ across IHEs.
The number of FTE students is calculated based on the total credit and/or contact hours reported by the institution, which are then converted to an indicator for FTE
students. The 12-month FTE student enrol ment count includes al undergraduate, graduate, and first professional students served over a 12-month period.
State and local appropriations include amounts received by an institution through acts of a state legislative body (except grants, contracts, and capital appropriations),
revenues from appropriations by a governmental entity below the state level, education district taxes, and other similar revenues that result from actions of local
governments or citizens.

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Federal Revenue
Federal revenue reflects revenue received through federal programs for specific research projects,
operating expenses, and other purposes; and through amounts reported as non-operating revenues
from federal agencies that are provided on a non-exchange basis.22 For the purposes of this report,
funding that IHEs receive through the federal student aid programs (e.g., Pel Grant, Direct
Loans, GI Bil Benefits) are excluded from revenue and are instead counted as tuition and fee
revenue.23
Federal revenue (excluding student aid) comprises a relatively smal portion (less than 10%) of
revenue at public and private nonprofit IHEs (Figure 1 and Figure 2). Private proprietary IHEs
receive a negligible amount of federal revenue.24 Proprietary IHEs may separately receive
funding made available through the federal student aid programs that students use to pay for
tuition and fees. However, this revenue is not included in federal revenue, but is instead counted
as tuition and fee revenue.
Thus far, there have not been any indications of federal revenue decreasing as a result of the
COVID-19 pandemic. On the contrary, as previously noted, approximately $36 bil ion in
emergency federal revenue was provided to IHEs and postsecondary students through the CARES
Act (P.L. 116-136) and the Consolidated Appropriations Act, 2021 (P.L. 116-260). While non-
student aid federal revenue has historical y comprised a smal portion of total revenue, it is
possible that, at least in the short term, IHEs may become more reliant on federal funds, such as
those provided through emergency funding bil s.
Auxiliary, Hospital, and Gifts and Endowments Revenue
IHEs may receive revenue from sources in addition to those discussed above. Three sources that,
when combined, comprise a substantial portion of the revenue realized by public four-year and
private nonprofit IHEs are auxiliary enterprises, hospitals, and gifts and endowments. These
combined sources provided 32% of revenue at public four-year IHEs (Figure 1) and 50% at
private nonprofit IHEs (Figure 2) in FY2018. They provided 4% of revenue at public two-year
IHEs and less than 2% at private proprietary IHEs. Within the sectors, there are differences in the
relative reliance on these sources.
Auxiliary enterprises are revenues generated by entities that exist to furnish a service to students,
faculty, or staff, and that charge a fee that is directly related to the cost of the service. Examples
include residence hal s, food services, student health services, intercol egiate athletics, and
college stores. Projected revenue from auxiliary enterprises during the pandemic wil likely
depend on the reopening plans of IHEs. For example, IHEs that do not open residence hal s, or do
so in a manner that makes them available to fewer students, would lose some revenue generated

22 Definition retrieved from IPEDS 2018-2019 Data Collection System Finance Survey Materials, https://nces.ed.gov/
ipeds/use-the-data/annual-survey-forms-packages-archived?section=Finance.
23 Public IHEs generally include Pell Grants when reporting federal revenue, while nonprofit and proprietary IHEs have
the option to include Pell Grants in federal revenue or tuition and fee revenue. T o account for this difference, CRS
adjusted the federal revenue and tuition and fee revenue calculations according to IHEs’ treatment of Pell Grants. See
the Appe ndix for more information.
24 Proprietary IHEs do separately receive funding made available through the federal student aid programs. However,
this revenue is not included in federal revenue, but is instead counted as tuition and fee revenue.
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from residence hal s and associated food services (e.g., dining hal s), but could stil be responsible
for associated expenditures such as facilities maintenance or debt.
Approximately 73% of public four-year IHEs and 70% of nonprofit IHEs offer on-campus
housing and/or board (meal plans) to students, while 19% of public two-year IHEs and 2% of
proprietary IHEs offer such services. Thus, public four-year IHEs and nonprofit IHEs not fully
reopening residence hal s or offering more limited food services may experience a more
substantial impact on their total revenue.25 Additional y, some IHEs cancel ed their fal and winter
athletic programs for the 2020-2021 academic year.26 Others have greatly limited in-person
attendance at athletic events. Approximately 60% of public four-year IHEs are members of the
National Collegiate Athletic Association (NCAA), while 36% of nonprofit IHEs are NCAA
members. A recent report notes that for those IHEs participating in the major athletic conferences,
the revenue generated from athletic programs is essential for paying debt associated with athletic-
related facilities.27 Thus, while the revenue generated wil decrease if IHEs are not participating in
or are al owing only limited attendance at athletic events, they wil stil incur the associated
expenses.
Hospital revenues are operating revenues28 for a hospital operated by the institution and clinics29
associated with training.30 Early reports suggest that state restrictions on elective surgeries to
increase hospital capacity for COVID-19 patients resulted in a major loss in revenue at
hospitals.31 Roughly 7% of public four-year IHEs and roughly 2% of nonprofit IHEs reported any
hospital revenue in FY2018.32 Proprietary IHEs general y do not have hospital revenue. While on
average, hospital revenue comprised 15% of revenue at public four-year IHEs (Figure 1), of
those 7% reporting hospital revenue, it comprised 37% of total institutional revenue. Likewise,
for the 2% of nonprofit IHEs reporting any hospital revenue, it comprised 43% of total
institutional revenue. Thus, while declines in hospital revenue have likely affected a relatively
smal subset of public four-year and nonprofit IHEs, the effects on those IHEs that generate any
revenue from hospitals could be substantial. It is not clear if university hospitals were able to
recover those losses once states loosened restrictions.
Gifts, investment returns, and endowments include revenues from private donors for which no
legal consideration is provided; revenues derived from the institution’s investments, including
investments of endowment funds; and additions to endowments that are permanently
nonexpendable. Gifts, investment, and endowment revenue comprised 31% of revenue at private
nonprofit IHEs in FY2018 (Figure 2). Volatility in the stock market during the COVID-19
pandemic has caused some fluctuations in endowment values that may have implications for

25 Matt Zalaznick, “How to reconfigure residence halls for the COVID-era,” University Business, June 19, 2020.
26 Doug Lederman, “COVID-19 Roundup: A Domino Falls on Winter Sports,” Inside Higher Ed, October 9, 2020.
27 Moody’s Investor Services, “College Sports Postponements Dampen Revenue Prospects, though Interruption in Debt
Payments is Unlikely,” August 12, 2020.
28 Patient and contractual allowances are deducted.
29 Clinics associated with student health services programs are excluded.
30 Definition retrieved from IPEDS 2018-2019 Data Collection System Finance Survey Materials, https://nces.ed.gov/
ipeds/use-the-data/annual-survey-forms-packages-archived?section=Finance.
31 See, for example, Emma Whitford, “Pandemic Hits Academic Hospitals Hard,” Inside Higher Ed, May 4, 2020,
https://www.insidehighered.com/news/2020/05/04/university-affiliated-hospitals-suffer-huge-revenue-losses; and
Hospitals and Health System s Face Unprecedented Financial Pressures Due to COVID -19, American Hospital
Association, May 2020, https://www.aha.org/guidesreports/2020-05-05-hospitals-and-health-systems-face-
unprecedented-financial-pressures-due.
32 CRS calculations using IPEDS.
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IHEs’ endowment spending behavior. However, a recent survey found that most IHEs were
planning to maintain spending practices for FY2021.33
Changes in Institutional Expenditures
While much of the discussion on postsecondary finances since the COVID-19 pandemic began
has focused on revenue, some researchers have noted that institutional expenditures are also
likely to be impacted in a few key ways. First, IHEs may incur additional costs directly related to
the pandemic, including the increased technological costs associated with transitioning to remote
learning34 and the costs associated with implementing health and safety precautions to help
prevent the spread of the disease (e.g., instal ing protective barriers, redesigning dorms and/or
classrooms, COVID-19 testing and purchasing personal protective equipment for students and
faculty) for IHEs holding in-person classes. Some research indicates that the development of
online courses may cost more than in-residence courses, but there can be wide variation in cost
depending on the online design.35 Second, while there may be fewer people on campuses, IHEs
may stil incur costs for facilities, maintenance, security, debt, and other expenses. Lastly, while
some IHEs have reportedly implemented strategies to reduce expenditures (e.g., reducing staff
and enacting hiring freezes), it is unclear if these reductions wil offset the expected losses in
revenue.
Enrollment and the COVID-19 Pandemic
Enrollment is a key indicator of an institution’s stability and is a cornerstone of its financial
strategy. Enrollment is directly associated with tuition and other forms of revenue such as
auxiliary fees for room and board. Additional y, some states al ocate a portion of funding to
public IHEs on a per-student basis.36 If the COVID-19 pandemic leads to reductions in enrollment
at IHEs (or certain subsets of IHEs), it could result in unanticipated declines in tuition revenue
and state funding and jeopardize the operations and stability of the affected institutions.37 While
much of the discussion on this issue has focused on reduced enrollment, it is also possible that at
least some IHEs (or certain subsets of IHEs) wil experience increased enrollment in light of the
pandemic.

33 See National Association of College and University Business Officers (NACUBO), COVID-19 Endowment Impacts
and Stewardship Strategies, June 12, 2020, https://www.nacubo.org/Research/2020/COVID-19-Research/Q1-2020-
Endowment -Survey.
34 Di Xu and Ying Xu, The Promises and Limits of Online Higher Education, American Enterprise Institute, March
2019, pp. 20-21.
35 Ibid.
36 James Dean Ward, Cindy Le, and Elizabeth Davidson Pisacreta et al., The Strategic Alignment of State
Appropriations, Tuition, and Financial Aid Policies, Ithaka S+R, October 2, 2019, https://sr.ithaka.org/wp-content/
uploads/2019/10/SR-Issue-Brief-Strategic-Alignment -State-Appropriations-Tuititon-Financial-Aid-10022019.pdf; and
National Association of State Budget Officers, A Guidebook on State Budgeting for Higher Education, 2015,
https://higherlogicdownload.s3.amazonaws.com/NASBO/9d2d2db1-c943-4f1b-b750-0fca152d64c2/UploadedImages/
Reports/Higher%20Education%20State%20Budgeting%20Guidebook.pdf .
37 In cases where public funding is based on prior years’ enrollment, declines in support may lag behind actual
enrollment declines. T his may contrast with tuition revenue, which is a more real-time factor.
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Historical Background and Recent Trends38
Throughout the second half of the 20th century and into the first decade of the 21st century, total
postsecondary enrollment increased consistently. Total postsecondary enrollment peaked around
2011 and has declined somewhat since then.39 The peak enrollment may have been the
culmination of a long-term increase in enrollment rates (i.e., the share of individuals enrolling in
postsecondary education), possibly abetted by a short-term increase due to a high unemployment
rate.40 The overal size of the primary college-going population (age 15-24) was also slightly
higher in 2011 than in 2018.41
Table 3 presents recent trends in postsecondary enrollment and the national unemployment rate.
Since the enrollment peak around 2011, which follows the unemployment peak in 2010, the
largest enrollment declines were at two-year public institutions and proprietary institutions.
Enrollment at both public four-year institutions and private nonprofit institutions increased
between 2011 and 2018. Some of the shift in enrollment is due to sector reclassification of some
institutions over the period of review. For example, 67 public-two year institutions with a
combined FTE enrollment of approximately 424,000 students were reclassified as public-four
year institutions between 2011 and 2018.42 Thus, approximately one-third of the change in
enrollment at public-two year institutions was due to sector reclassification.

38 T his section uses two data sources. Data from the U.S. Census Bureau are used to discuss longer -term historical
trends and to contextualize the postsecondary population in the overall population, while data from IPEDS provides the
most detailed data on specific types of institutions. While this section uses both sources to offer a broader perspective,
their data are not directly comparable.
39 See United States Census Bureau, “CPS Historical T ime Series T ables on School Enrollment,” particularly table A -7,
https://www.census.gov/data/tables/time-series/demo/school-enrollment/cps-historical-time-series.html.
40 For historical data on postsecondary enrollment rates, see Digest of Education Statistics, T able 103.20 and T able
302.60, which are based on Census data. See also U.S. Census Bureau, “ Postsecondary Enrollment Before, During and
Since the Great Recession,” April 2018, https://www.census.gov/content/dam/Census/library/publications/2018/demo/
P20-580.pdf.
41 Students age 24 and under make up approximately 73% of undergraduate students and about 66% of total
postsecondary students. See Digest of Education Statistics, T able 303.50, based on IPEDS. In 2011, the total population
of the age 15-24 cohort was about 43.8 million. In 2018, it declined to about 42.9 million. See U.S. Census Bureau,
“National Population by Characteristics: 2010-2019,” https://www.census.gov/data/tables/time-series/demo/popest/
2010s-national-detail.html.
42 CRS calculations using IPEDS data on 12-month full-time equivalent enrollment.
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Table 2. Enrollment in Title IV Participating IHEs by Control and Level and National
Unemployment Rate, 2004-2018
12-month, ful -time equivalent students, in thousands

Enrollment

Academic
Year
Total, All
Public,
Public,
Public,
Private,
Private,
Unemployment
Ending
Sectors
Total
Four-Year
Two-Year
Nonprofit
Proprietary
(%)
2004
15,387
9,894
5,685
4,209
3,091
2,401
5.8
2005
15,479
9,957
5,789
4,168
3,053
2,469
5.3
2006
14,652
9,996
5,850
4,146
3,131
1,525
4.8
2007
15,010
10,140
5,999
4,141
3,148
1,723
4.5
2008
15,642
10,489
6,179
4,310
3,270
1,882
4.9
2009
16,687
10,968
6,377
4,591
3,413
2,306
7.6
2010
17,934
11,789
6,796
4,993
3,654
2,491
9.8
2011
18,455
12,062
7,011
5,052
3,739
2,653
9.3
2012
18,327
11,908
7,101
4,808
3,796
2,622
8.5
2013
17,588
11,620
7,027
4,593
3,781
2,188
7.8
2014
17,322
11,574
7,114
4,459
3,822
1,926
6.8
2015
17,184
11,463
7,178
4,285
3,811
1,910
5.7
2016
16,872
11,444
7,298
4,146
3,840
1,588
5.0
2017
16,773
11,430
7,563
3,868
3,859
1,484
4.7
2018
16,695
11,408
7,657
3,751
3,883
1,404
4.1
Source: IPEDS, see methodology in prior section; Bureau of Labor Statistics, national unemployment rate.
Notes: To align with academic year, unemployment rate is the average for the 12 months ending in June in the
specified year. For example, the unemployment rate for 2018 is for the 12-month period ending in June 2018.
The COVID-19 Pandemic and Enrollment: A Confluence of Factors
The COVID-19 pandemic coincided with enrollment changes in fal 2020 and may influence
enrollment in the coming semesters. A major chal enge in considering this issue is the broad reach
of the pandemic and the competing effects of many pandemic-related factors that may influence
students in different ways. Further, pandemic-related factors may have a concentrated effect on
enrollment at certain types of institutions, complicating some conclusions about the overal
relationship between enrollment and the pandemic.
Enrollment Indicators for Fall 2020
While IPEDS data for fal 2020 are not yet available, other indicators show a decline in overal
postsecondary enrollment, with significant variations by institution type, program type, and
student class level. As of November 19, 2020, the National Student Clearinghouse (NSC)
reported an overal postsecondary enrollment decline of 2.5% from the prior year. This marked an
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acceleration from fal 2019, when postsecondary enrollment declined 1.3% from fal 2018.43
Institutions reporting to the NSC account for approximately 97% of total enrollment at Title IV,
degree-granting institutions in the U.S.44
Between fal 2019 and fal 2020, enrollment among undergraduates declined approximately 3.6%.
The largest declines were at public two-year institutions (-10.1%). Undergraduate enrollment
declines from the prior year were considerably lower at public four-year institutions (-0.7%) and
private nonprofit four-year institutions (-1.4%). Undergraduate enrollment at proprietary
institutions increased 6.4%. The declines in undergraduate enrollment were offset somewhat by a
3.6% increase in graduate enrollment.45
The NSC data reported more concentrated declines in enrollment among first-time students.46
Among this population, enrollment across sectors was down about 13%. Compared to the prior
year, fal 2020 enrollment at public two-year institutions reported larger year-over-year declines
in first-time beginning students (-21%) than public four-year institutions (-8.1%) and four-year
private nonprofit institutions (-10.5%).47
Beyond the NSC data, other sources have corroborated overal enrollment trends by sector but
noted substantial variation among individual institutions within sectors. For example, many
public two-year institutions reported enrollment changes higher or lower than the national
average, while many four-year institutions reported little change or even an increase in
undergraduate enrollment.48
Unemployment and Labor Market Effects on Enrollment
Postsecondary enrollment increased during the extended period of high unemployment following
the Great Recession.49 Total enrollment peaked around 2011 and gradual y declined in the
subsequent years, coinciding with an improved labor market. In 2018, total postsecondary
enrollment was almost 10% below its 2011 peak. (See Table 2.) In prior recessions, the
relationship between unemployment and postsecondary enrollment was more nuanced.50

43 National Student Clearinghouse Research Center, “Current T erm Enrollment Estimates, Fall 2020,” December 2020,
T able 1, https://nscresearchcenter.org/wp-content/uploads/CT EE_Report_Fall_2020.pdf.
44 Ibid. Page 22 describes differences between the NSC data and IPEDS.
45 Ibid., T able 3.
46 Ibid. T he survey’s methodological notes define first-time students as those “who had no enrollment or degree and
certificate award records at T itle IV U.S. Institutions prior to fall 2020, unless the previous enrollment record was
before the student turned 18 years old or before the student graduated from high school (dual enrollment).” See notes
associated with T able 2.
47 Ibid., T able 2.
48 For example, a survey conducted by the Chronicle of Higher Education and partners published in October 2020
reported that about 50% of primarily associate’s degree-granting institutions had enrollment declines of more than
10%, while about 10% of similar institutions reported enrollment increases. In the same report, more than 65% of the
members of the Association of American Universities (a collective of 65 public and private research universities)
reported no change in enrollment or an increase. See Eric Kelderman, “We Haven’t Begun to Feel the Real Economic
Damage,” Chronicle of Higher Education, October 14, 2020, https://www.chronicle.com/article/we-havent-begun-to-
feel-the-real-economic-damage. Enrollment trends were similar in a survey of university presidents by the American
Council on Education that was published in December 2020 . See “ College and University Presidents Respond to
COVID-19: 2020 Fall T erm Survey, Part II,” acenet.edu/Research -Insights/Pages/Senior-Leaders/College-and-
University-Presidents-Respond-to-COVID-19-2020-Fall-T erm-Part-Two.aspx.
49 U.S. Census Bureau, “Postsecondary Enrollment Before, During, and Since the Great Recession,” April 2018,
https://www.census.gov/content/dam/Census/library/publications/2018/demo/P20-580.pdf.
50 One challenge in assessing the relationship between the labor market and postsecondary enrollment during prior
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The labor market during and following the COVID-19 pandemic is uncertain, though many
analyses suggest that relatively high unemployment may persist for several years.51 It is possible
that postsecondary enrollment in light of the pandemic labor market may ultimately mirror the
increase in the period following the Great Recession. It is also possible, however, that factors
specific to the COVID-19 pandemic could offset potential labor market effects. For example,
some IHEs’ shifts to remote learning and the general fluidity of institutions’ operations may make
it a less attractive option for unemployed workers who are at the margins of considering
enrollment. Further, the unique nature of the pandemic labor market may influence
decisionmaking. For example, if a large share of unemployed workers expect to return to jobs that
were interrupted by the pandemic, it may lead to lower-than-usual enrollment rates among the
unemployed.
Challenges in Interpreting Surveys
Various research entities have conducted surveys of students and other education stakeholders
with the goal of quantifying the effect of the COVID-19 pandemic, including on enrollment
prospects.52 The findings of these surveys have varied, sometimes dramatical y, based on when
they were conducted, how questions were posed, and other factors. As such, it can be difficult to
map survey results (particularly enrollment implications) against the actual combination of
circumstances that have emerged.
Another chal enge in interpreting surveys is that surveys that have been conducted for the first
time during the pandemic lack a pre-pandemic baseline. For example, the Pulse survey from the
U.S. Census Bureau asked about household members who may have changed their postsecondary
education plans since the onset of the pandemic.53 The survey found large numbers of households
with individuals who had canceled al plans to take postsecondary courses in the fal .54 It may be
misleading, however, to attribute the entirety of these cancel ations to the COVID-19 pandemic
because it is likely that some number of students cancel postsecondary education plans every
year. Without a baseline from prior years, it is difficult to estimate the independent effect of the
pandemic.

recessions is separating labor market effects from the ongoing enrollment increase through the 20 th century. Some
research focusing on recessions from 2001 and earlier has identified some relationship between the labor market and
postsecondary enrollment for certain types of students and certain types of institutions. For examples, see literature
review and historical data in Lisa Barrow and Jonathan Davis, “T he Upside of Down: Postseco ndary Enrollment in the
Great Recession,” Economic Perspectives, Federal Reserve Bank of Chicago, 2012, https://www.chicagofed.org/
publications/economic-perspectives/2012/4q-barrow-davis.
51 For example, the Congressional Budget Office (CBO) has projected an unemployment rate of 7.6% for 2021 and
6.9% for 2022. See CBO, “An Update to the Economic Outlook: 2020 to 2030,” July 2020, https://www.cbo.gov/
publication/56465.
52 See, for example, Eric Hoover, “COVID-19: T he Crisis that Launched 1,000 Student Surveys,” Chronicle of Higher
Education, March 30, 2020, https://www.chronicle.com/article/covid-19-the-crisis-that-launched-1-000-student -
surveys/.
53 For example, see U.S. Census Bureau, “Week 20 Household Pulse Survey: November 25 -December 7,” particularly
Education T ables 6 and 7, https://www.census.gov/data/tables/2020/demo/hhp/hhp20.html.
54 A challenge in interpreting Pulse Survey data is that data are not reported as individual prospective students, but
rather as the much larger “T otal Population 18 Years and Older in Households Where at Least One Adult Was Planning
On T aking Classes T his Fall From a Post High School Institution.” In the Week 20 survey cited in the prior footnote,
approximately 35% of the reference population was in a household where “all plans to take classes this fall have been
cancelled.”
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Influence of Remote Learning on Enrollment
In spring 2020, most IHEs made an unscheduled shift to moving their coursework to a remote
learning model.55 Many students expressed some level of dissatisfaction with their remote
learning experience and expressed a preference to return to in-person learning.56 This preference
may have impacted many schools’ initial plans to offer in-person classes in the fal of AY2020-
2021. Due to the pandemic, many IHEs have reduced their previously scheduled in-person class
offerings or even moved al of their educational programs to remote learning.57
The enrollment impact of expanded remote learning is unclear. It is possible that student aversion
to remote learning and the inability of institutions to offer certain courses remotely was a key
factor in some of the enrollment declines. Conversely, it is possible that improved remote learning
experiences, limited other options, and evolving views on the necessity of remote learning
partial y offset what could have been even larger enrollment declines.
Some of the chal enges with remote learning in spring 2020 were a product of an abrupt shift in
formats. Some evidence suggests that the sudden transition to remote learning by some IHEs at
that time did not employ state-of-the-art strategies, delivery, and accountability.58 In some cases,
the online infrastructure was inadequate, faculty were not prepared to redesign instruction, and
students were not prepared to learn remotely.59 In at least one survey, a majority of faculty
indicated that the quality of the transitioned courses suffered.60
With more time to prepare, remote courses in fal 2020 and later may be better received by
students than those in the spring of 2020.61 Many schools reported investments in technology and
training to improve the quality of their remote learning offerings. A limitation on these efforts to
improve remote learning is that, in at least some cases, remote learning is not possible or
practicable. For example, some state licensing bodies require that individuals fulfil a number of
practical hours to be eligible for initial licensure.62 Courses in the physical and life sciences that
require practice laboratory methods and protocols may not be able to be moved online.63

55 T he “Administrative and Regulatory Issues Related to Remote Learning” section discusses some of the variation in
remote learning models. T his section discusses remote learning more generally.
56 See, for example, Doug Lederman, “How College Students Viewed T his Spring’s Remote Learning,” Inside Higher
Education, May 20, 2020, https://www.insidehighered.com/digital-learning/article/2020/05/20/student-view-springs-
shift-remote-learning.
57 For regularly updated information on institutions’ reopening plans, see Chronicle of Higher Education’s ongoing
feature, Here’s Our List of Colleges’ Reopening Models, available at https://www.chronicle.com/article/heres-a-list-of-
colleges-plans-for-reopening-in-the-fall/.
58 R. Garrett, R. Legon, E.E. Fredericksen, and B. Simunich, B, CHLOE 5: The Pivot to Remote Teaching in Spring
2020 and Its Im pact, T he Changing Landscape of Online Education, 2020, https://encoura.org/project/chloe-5-the-
pivot -to-remote-teaching-in-spring-2020-and-its-impact/.
59 Ibid., p. 9.
60 Andrew P. Kelly and Rooney Columbus, College in the Time of Coronavirus: Challenges Facing American Hig her
Education, American Enterprise Institute, July 2020, p. 3, https://www.aei.org/research-products/one-pager/college-in-
the-time-of-coronavirus/.
61 Doug Lederman, “What Worked T his Spring? Well-Designed and -Delivered Courses,” Inside Higher Ed, July 8,
2020, https://www.insidehighered.com/digital-learning/article/2020/07/08/what -kept-students-studying-remotely-
satisfied-spring-well.
62 U.S. Department of Education, Office of Postsecondary Education, Guidance for interruptions of study related to
Coronavirus (COVID-19) (Updated June 16, 2020), March 5, 2020, https://ifap.ed.gov/electronic-announcements/
051520UPDATEDGuidanceInterruptStudyRelCOVID1 9May2020.
63 See, for example, Greta Anderson, “Feeling Shortchanged,” Inside Higher Ed, April 13, 2020,
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Student sentiment may be evolving toward an acceptance of remote learning. For example,
numerous surveys from early in the pandemic suggested that large majorities of students
preferred in-person classes and would change their plans if in-person classes were not offered at
their first-choice institution.64 However, more-recent surveys have shown students expressing
support for their schools not opening their campuses.65 Further, large shares of IHEs moving to
remote learning may reduce the possibility of a student moving to an IHE that offered in-person
learning if their first-choice IHE only offered remote learning.
Enrollment of International Students
International students, general y defined as students who are not United States citizens or
permanent residents and who came to the United States for the purpose of attending school,
account for approximately 5% of postsecondary enrollment (including both undergraduate and
graduate students).66 These students, on average, receive less institutional aid than domestic
students and therefore pay higher net tuition.67 The share of international students varies by
institution and some schools rely on these students more for revenue than others.68
While definitive data on the enrollment patterns of international students in AY2020-2021 are not
yet available, the COVID-19 pandemic may complicate the enrollment of international students
for several reasons. International travel restrictions may create chal enges for students traveling
between their institutions and home countries. International students are also subject to U.S.
immigration policy, and shifting policies during the pandemic could reduce the enrollment of
international students.69 Various pandemic-related factors, including schools shifting exclusively
to remote learning, could also make U.S.-based institutions less attractive for international
students.

https://www.insidehighered.com/news/2020/04/13/students-say-online-classes-arent -what -they-paid.
64 For example, a survey of high school seniors in April 2020 found that only 18% of respondents would not change
their plans if their college had a remote semester in fall 2020. Of the remaining respondents, 48% said they would defer
enrollment or look for a different school and 38% were uncertain. See McKinsey and Company, “ COVID-19 and US
higher education enrollment: Preparing leaders for fall,” May 21, 2020, https://www.mckinsey.com/industries/public-
and-social-sector/our-insights/covid-19-and-us-higher-education-enrollment-preparing-leaders-for-fall. Also see, for
example, Doug Lederman, “How College Students Viewed T his Spring’s Remote Learning,” Inside Higher Education,
May 20, 2020, https://www.insidehighered.com/digital-learning/article/2020/05/20/student -view-springs-shift -remote-
learning.
65 For example, an August 2020 survey found that 68% of surveyed students agreed or strongly agreed with their
school’s decision to not re-open for on-campus instruction in the fall. See SimpsonScarborough, “National Student
Survey, Part III,” August 2020, https://info.simpsonscarborough.com/hubfs/SimpsonScarborough%20National%20
Student%20Survey,% 20Pt.% 20III.pdf.
66 U.S. Department of Education, Digest of Education Statistics 2019, T able 306.10.
67 For example, data from the National Postsecondary Student Aid Survey report ed that at public four-year institutions,
undergraduate international students paid net tuition of more than $18,300 compared to about $8,300 for U.S. citizens.
Estimates were generated by CRS using the 2015 -2016 NPSAS sample and the NPSAS PowerStats tool on the
National Center for Education Statistics website. CRS cross-tabulated the variables for tuition and fees paid with
citizenship (which disaggregates “foreign or international student”) and the sector and control of the institution. Data
can be replicated at https://nces.ed.gov/datalab/index.aspx.
68 See, for example, Elizabeth Redden, “ A Bleak Picture for International Enrollment,” Inside Higher Ed, May 26,
2020, https://www.insidehighered.com/news/2020/05/26/colleges-expect -few-new-international-students-will-make-it-
their-campuses-fall. T his article cites an unspecified report from Moody’s that “ among the U.S. universities ... 36
percent rely on international students for more than 10 percent of their total revenue. ”
69 See, for example, Miriam Berger, “ T he pandemic has damaged the appeal of studying in the United States for some
international students,” Washington Post, July 23, 2020; https://www.washingtonpost.com/world/2020/07/23/
coronavirus-international-students-united-states-enrollment-reputation/.
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Administrative and Regulatory Issues Related to
Remote Learning
As a consequence of the COVID-19 pandemic, for health and safety reasons most IHEs offer or
make available more remote learning opportunities than they offered before the pandemic.
Remote learning refers to educational instruction with a separation in time, place, or both between
the student and instructor. Content may be delivered synchronously (i.e., students engage with an
instructor in real time) or asynchronously (i.e., instructors provide pre-recorded or pre-configured
content to students). Some IHEs and programs employ a mix of the models for different students
or different content. General y, remote learning must meet additional requirements compared to
in-person instruction for enrolled students to have access to federal student financial aid
programs, as authorized by Title IV of the Higher Education Act (HEA), as amended. HEA Title
IV authorizes the primary sources of federal student aid to support postsecondary education (e.g.,
Pel Grants and Direct Loans). HEA Title IV aid is a source of IHE tuition and fees and auxiliary
revenues.
This section of the report provides background on remote learning prior to the COVID-19
pandemic. It also describes the effect that the transition to more remote learning has on the ability
of IHEs to administer HEA Title IV aid, which plays a fundamental role in enabling students to
meet the cost of attendance. IHEs that offered al courses via remote learning prior to the
pandemic may not experience much change.
Pre-pandemic Remote Learning
Since at least the 1960s, Congress has passed several legislative provisions limiting student
access to federal education benefits while enrolled in remote learning in response to concerns
about its quality and benefit abuses.70 A 2019 analysis of studies of postsecondary online courses
at community colleges found that students in such courses were more likely to withdraw than
students in in-residence courses.71 In addition, a 2020 review of research indicated that higher risk
students have poorer academic outcomes from online courses compared to in-residence courses.72
In fal 2019, prior to the COVID-19 pandemic, about
Distance Education
49 IHEs (7 public, 17 private nonprofit, and 25
Distance education, which may be offered
proprietary), representing 3% of unduplicated
synchronously or asynchronously, uses the
postsecondary enrollment, offered all programs
internet or other specified technology to
completely via distance education.
deliver instruction to students separated
74 Over half of IHEs
from the instructor while ensuring “regular
offered some distance education opportunities (Table
and substantive interaction between the
3). For example, 97% public four-year IHEs and 89%
students and the instructor.”73
of public two-year IHEs offered at least some distance

70 For example, the Veterans Readjustment Benefits Act of 1966 (P.L. 89 -358) prohibited GI Bill benefits for on-the-
job or on-the-farm courses offered through open circuit television or radio and for programs of education leading to a
standard college degree offered through a majority of open circuit television or radio courses.
71 Di Xu and Ying Xu, The Promises and Limits of Online Higher Education, American Enterprise Institute, March
2019, https://www.aei.org/research-products/report/the-promises-and-limits-of-online-higher-education/.
72 T he Institute for College Access and Success, Untangling the Web: How to Monitor the Risks of Online Education ,
July 2020, p. 5, https://ticas.org/wp-content/uploads/2020/07/untangling-the-web.pdf.
73 HEA §103(7); 20 U.S.C. §1003(7); 34 C.F.R. §600.2.
74 CRS analysis of IPEDS, 2019 IHEs and 12-month unduplicated enrollment in AY2018-2019.
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education opportunities. In contrast, 3% of less-than-two-year IHEs offered some distance
education opportunities.75
Table 3. Percentage of IHEs Offering Distance Education Opportunities, by Sector
(Fall 2019)
Percentage Offering
Distance Education
Institutional Sector
Opportunities
Public, four-year
97%
Private nonprofit, four-year
75%
Private proprietary, four-year
76%
Public, two-year
89%
Private nonprofit, two-year
31%
Private proprietary, two-year
29%
Public, less-than two-year
7%
Private nonprofit, less-than two-year
5%
Private proprietary, less-than two-year
2%
Total
55%
Source: CRS analysis of U.S. Department of Education, Integrated Postsecondary Education Data System
(IPEDS) for AY2019-2020.
HEA Title IV Institutional and Program of Education Eligibility
Issues
For students to receive HEA Title IV aid for their enrollment in a program of education at an IHE,
the IHE and program must meet several eligibility criteria established by the HEA and
regulations. For a full description of HEA Title IV institutional and program of education
eligibility criteria, see CRS Report R43159, Institutional Eligibility for Participation in Title IV
Student Financial Aid Programs. Transitioning programs of education to a remote learning format
and offering remote learning may affect an IHE’s or program’s, and therefore a student’s,
eligibility for HEA Title IV aid. The following subsections briefly describe potential concerns
related to the transition to remote learning in four key areas.
ED Approval of Distance Education
Under the regular approval process, some institutions may be required to seek ED approval for
the use or expansion of distance learning programs;76 however, regulations and guidance are
unclear on the extent to which ED approval of distance education is typical y required. In
response to the COVID-19 pandemic, ED has provided flexibility to IHEs to use distance
education without ED approval, if required, for payment periods that overlap March 5, 2020, or

75 IPEDS.
76 U.S. Department of Education, Office of Postsecondary Education, Guidance for interruptions of study related to
Coronavirus (COVID-19), March 5, 2020.
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that begin on or between March 5, 2020, and December 31, 2020, or until the end of the
pandemic, whichever occurs later.77 The scope of effect of this flexibility is unclear.78
Correspondence Courses
For purposes of HEA Title IV, a correspondence course provides instructional materials and
exams to students who do not physical y attend classes at the IHE but does not provide “regular
and substantive interaction between the students and the instructor.”79 General y, an IHE may not
offer more than 50% of its courses as correspondence courses or enroll 50% or more of its
students in correspondence courses.80 The limitation on correspondence courses and
correspondence enrollment may affect the ability of some IHEs to transition to remote learning.
Such IHEs may have to offer courses via distance education or require some portion of in-person
interaction.
State Authorization
To protect students from fraud and abuse, an IHE offering postsecondary distance education or
correspondence courses must meet any of the requirements of the state (known as state
authorization) in which the IHE is located.81 In addition, an IHE offering postsecondary distance
education or correspondence courses to students located in a state in which the IHE is not
physical y located must obtain state authorization from the states in which the students are
located.82 In lieu of achieving authorization in multiple states, an IHE may participate in a state
authorization reciprocity agreement to offer the program of education.83 ED has waived the
requirement for state authorization from states in which distance education students are located,
for payment periods that overlap March 5, 2020, or begin after March 5, 2020, through the end of
the payment period that begins after the date on which the COVID-19 emergency is rescinded.84

77 U.S. Department of Education, Office of Postsecondary Education, Guidance for interruptions of study related to
Coronavirus (COVID-19), March 5, 2020; and U.S. Department of Education, Office of Postsecondary Education,
Updated deadlines for flexibilities related to Coronavirus (COVID-19), August 21, 2020.
78 Distance education programs offered by foreign IHEs, and those offered in whole or in part in the United States by
foreign IHEs, are generally ineligible to participate in the HEA T itle IV Direct Loan program. T he CARES Act (P.L.
116-136) authorizes ED to permit Direct Loan eligibility for such programs for the duration of a qualifying emergency.
79 34 C.F.R. §600.2.
80 HEA §102(a)(3)(A) and (B); 20 U.S.C. §1002(a)(3)(A) and (B). T he requirements do not apply to “technical
institute[s] or vocational school[s] used exclusively or principally for the provision of vocational education to
individuals who have completed or left high school and who are available for study in preparation for entering the labor
market” under Section 3(3)(C) of the Carl D. Perkins Vocational and Applied T echnology Education Act of 19 95 (34
C.F.R. §600.7(b)(2)). T he second limitation may be waived if an IHE offers a two -year associate’s degree or four-year
bachelor’s degree program and it demonstrates to ED that in the award year, students who were enrolled in
correspondence courses received 5% or less of the total FSA funds received by all of the IHE ’s students (34 C.F.R.
§600.7(b)(2)). ED, FSA Handbook, vol. 2, p. 103.
81 34 C.F.R. §600.9(c).
82 34 C.F.R. §600.9(c).
83 A state reciprocity agreement is “an agreement between two or more States that authorizes an institution located and
legally authorized in a State covered by the agreement to provide postsecondary education through distance education
or correspondence courses to students residing in other states covered by the agreement.” 34 C.F.R. §600.2.
84 U.S. Department of Education, Office of Postsecondary Education, Guidance for interruptions of study related to
Coronavirus (COVID-19), March 5, 2020; and Department of Education, Office of Postsecondary Education, “ Federal
Student Aid Programs (Student Assistance General Provisions, Federal Perkins Loan Provisions, Federal Perkins Loan
Program, William D. Ford Federal Direct Loan Program, and Federal- Work Study Programs),” 85 Federal Register
79856-79863, December 11, 2020.
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It is unclear whether IHEs that were formerly not offering distance or correspondence education
but are offering such education during the pandemic have consistently attained the appropriate
state authorization or are now participating in state authorization reciprocity agreements.
Accreditation
HEA Title IV participating IHEs must be accredited by an ED-recognized accrediting agency. Al
such agencies must regularly reevaluate IHEs or programs and ensure that programs of education
with a substantive change in the method of delivery continue to meet their accreditation
standards.85 To ensure the quality of educational programming, distance and correspondence
education programs provided by domestic IHEs are eligible for HEA Title IV participation if they
have been accredited by an accrediting agency that is recognized by ED to evaluate distance or
correspondence education programs, respectively.86 Accrediting agencies that accredit distance
education and correspondence courses must have standards that effectively address the quality of
the distance education and correspondence courses but are not required to (but may) have
separate standards, procedures, or policies for the evaluation of such coursework.87
ED has waived the requirement that IHEs offering distance education be accredited by an
accrediting agency recognized by ED to evaluate distance education programs, for payment
periods that overlap March 5, 2020, or that begin on or between March 5, 2020, and December
31, 2020, or until the end of the pandemic, whichever occurs later.88 In addition, ED has also
al owed accreditors that are recognized to evaluate distance education to waive their distance
education review requirements for IHEs that have developed distance education programs to
accommodate COVID-19 pandemic disruptions for the duration of the national emergency and
180 days thereafter.89 Final y, ED has waived the requirement that accreditors regularly review
(including for substantive changes) the IHEs or programs that they accredit for the duration of the
national emergency and 180 days thereafter.90 ED encourages accreditors to develop procedures
to review the new distance education programs.91 It is not clear to what extent some educational
programs now offered remotely meet the accrediting agencies’ standards. Also unclear is the
extent to which IHEs that are accredited by accrediting agencies not recognized by ED to
evaluate distance education programs are now offering such programs.

85 34 C.F.R. §602.22(a).
86 HEA §481(b)(3).
87 34 C.F.R. §602.16(d).
88 U.S. Department of Education, Office of Postsecondary Education, Guidance for interruptions of study related to
Coronavirus (COVID-19), March 5, 2020; U.S. Department of Education, Office of Postsecondary Education,
UPDATED Guidance for interruptions of study related to Coronavirus (COVID -19) (Updated June 16, 2020), May 15,
2020; and U.S. Department of Education, Office of Postsecondary Education, Updated deadlines for flexibilities
related to Coronavirus (COVID-19), August 21, 2020.
89 Department of Education, Office of Postsecondary Education, “Federal Student Aid Programs (Student Assistance
General Provisions, Federal Perkins Loan Provisions, Federal Perkins Loan Program, William D. Ford Federal Direct
Loan Program, and Federal- Work Study Programs),” 85 Federal Register 79856-79863, December 11, 2020.
90 Ibid.
91 U.S. Department of Education, Office of Postsecondary Education, UPDATED Guidance for interruptions of study
related to Coronavirus (COVID-19), April 3, 2020; and Department of Education, Office of Postsecondary Education,
“Federal Student Aid Programs (Student Assistance General Provisions, Federal Perkins Loan Provisions, Federal
Perkins Loan Program, William D. Ford Federal Direct Loan Program, and Federal- Work Study Programs),” 85
Federal Register 79856-79863, December 11, 2020.
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The flexibility to offer programs by distance education without accreditor review does not apply
to clock-hour courses that lead to licensure if the licensure body wil not accept the hours.92 In
addition, the waiver does not explicitly apply to correspondence courses.
Recent Action and Further Congressional
Considerations
As the ongoing effects of the COVID-19 pandemic on IHEs become clearer, Congress may
consider a variety of mechanisms to further support IHEs. This section of the report discusses
recent forms of assistance provided to IHEs, including direct and indirect financial support and
administrative flexibilities. As Congress continues to assess options for supporting IHEs during
the pandemic, the following may serve as models in designing or refining supports.
Direct Financial Support to Institutions
In response to natural disasters and the COVID-19 pandemic, supplemental appropriations have
been enacted for ED to provide direct grants to IHEs to defray expenses related to the covered
disaster or emergency.93 Congress and the Administration have the option to define the
distribution and use of funds under direct support grants.
For example, the CARES Act (P.L. 116-136) and the Consolidated Appropriation Act, 2021 (P.L.
116-260) provided direct financial support to IHEs through a Higher Education Emergency Relief
Fund (HEERF). Under the two HEERF programs, approximately $36 bil ion was appropriated for
al ocation to IHEs to address needs directly related to the pandemic through three types of
programs.
The majority of HEERF funds are distributed as direct grants to public, private nonprofit, and
proprietary IHEs and postsecondary vocational institutions based on their pre-pandemic relative
enrollments. The enrollments variously included Pel Grant recipients not exclusively enrolled in
distance education, Pel Grant recipients exclusively enrolled in distance education, non-Pel
Grant recipients not exclusively enrolled in distance education, and non-Pel Grant recipients
exclusively enrolled in distance education. Under P.L. 116-136, at least 50% of each direct grant
had to be used for emergency financial aid grants to students, while the balance had to be used to
cover institutional costs associated with significant changes to the delivery of instruction due to
the pandemic. Under P.L. 116-260, direct grant funds may be used to defray expenses associated
with the pandemic (including lost revenue, reimbursement for expenses already incurred,
technology costs associated with a transition to distance education, faculty and staff trainings, and
payroll); to carry out student support activities that address needs related to COVID-19; or to
provide for emergency financial aid grants to students.
A portion of HEERF funds are distributed to IHEs eligible to participate in programs for minority
serving institutions (MSIs) authorized under HEA Title III-A, Title III-B, Title V-A, and Title VII-
A-4.94 These P.L. 116-136 funds must be used for grants to students and/or to defray institutional

92 U.S. Department of Education, Office of Postsecondary Education, Guidance for interruptions of study related to
Coronavirus (COVID-19) (Updated June 16, 2020), March 5, 2020.
93 For examples of provisions passed in response to natural disasters, see CRS Report R42881, Education-Related
Regulatory Flexibilities, Waivers, and Federal Assistance in Response to Disasters and National Em ergencies.
94 For more information, see CRS Report R43237, Programs for Minority-Serving Institutions Under the Higher
Education Act.
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expenses. These P.L. 116-260 funds may be used in the same manner as direct grant funds under
P.L. 116-260.
The remainder of HEERF funds was made available to public and private nonprofit IHEs with the
greatest unmet needs related to the pandemic through the Fund for the Improvement of
Postsecondary Education Program (FIPSE) authorized under HEA Title VII-B.95 Under P.L. 116-
136, the Secretary of Education (the Secretary) was required to give priority to IHEs that did not
otherwise receive grants of at least $500,000 through the P.L. 116-136 HEERF direct grants and
MSI programs.96 These P.L. 116-136 funds must be used for grants to students and/or to defray
institutional expenses. These P.L. 116-260 funds may be used in the same manner as direct grant
funds under P.L. 116-260.
Indirect Financial Support to Institutions
In response to the COVID-19 pandemic recession,97 supplemental appropriations have been
provided to states to fund IHEs. Through this type of indirect support, Congress and the
Administration can choose to provide states some measure of discretion in the distribution and
uses of funds. State governments may be in a better position than the federal government to gauge
which public IHEs and perhaps which private IHEs are most in need of funding.
Under the CARES Act, state governors received $3.0 bil ion under the Governor’s Emergency
Education Relief (GEER) Fund that could be partial y used to support public IHEs. A governor
may choose to provide emergency funds to IHEs serving students within the state that he or she
determines to “have been most significantly impacted by coronavirus” to support these IHEs in
providing educational services and to support the “on-going functionality” of the IHEs. A
governor may choose to provide emergency funds to any other IHE within the state that he or she
deems “essential for carrying out emergency educational services” to students for activities
authorized under various laws administered by ED. Grants may also be awarded to IHEs for the
provision of child care and early childhood education, social and emotional support, and the
protection of education-related jobs.
Another example of providing indirect support can be found in the American Recovery and
Reinvestment Act of 2009 (ARRA; P.L. 111-5) which was enacted wel into the Great Recession
to promote economic recovery. ARRA Title XIV provided $53.6 bil ion in discretionary funding
for the State Fiscal Stabilization Fund, which included $48.3 bil ion provided to governors
through formula grants to each state. Each governor was required to use the funds for the support
of the state’s elementary and secondary education; public IHEs; early childhood education
programs and services, as applicable; and public safety and other government services, which
included assistance for elementary and secondary education and public IHEs; and for
modernization, renovation, or repair of public school facilities and IHE facilities. In part, ARRA
was attempting to protect education and other public sector jobs during a period of shortfal s in
state and local budgets, and also to invest in infrastructure projects and associated jobs.98

95 Eligibility for FIPSE, as authorized by HEA, is limited to IHEs as defined in HEA Section 101, and thus excludes
proprietary IHEs and post secondary vocational institutions.
96 For more information, see CRS Report R46378, CARES Act Education Stabilization Fund: Background and
Analysis.
97 T he recession is as measured by the National Bureau of Economic Research (NBER), https://www.nber.org/
cycles.html.
98 T he differences in the approach to providing educational assistance under the CARES Act and ARRA may reflect
differences in how the COVID-19 pandemic and recession were expected to affect the higher education sector of the
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Waivers and Flexibilities
In response to many prior natural disasters and to the COVID-19 pandemic, flexibilities and
waivers from federal program requirements have been provided to help support IHEs.99 Such
waivers may reduce the required amount of institutional matching funds such that IHEs that have
lost some revenues do not also lose federal revenue. Such waivers may also adjust operational,
administrative, or reporting requirements associated with some federal revenue to reduce IHE
burdens. Waivers and flexibility may continue to garner congressional consideration during the
pandemic.
Under the HEA, the Secretary has authority to waive certain IHE requirements under specified
programs when a disaster has been federal y declared or other exigencies occur.100 For example,
on a case-by-case basis, IHEs may be permitted to shorten the length of an academic year without
losing eligibility to participate in the Title IV student aid programs.101 The “HEA Title IV
Institutional and Program of Education Eligibility Issues” section of this report describes key
flexibilities offered to IHEs in response to the transition to remote learning as a result of the
COVID-19 pandemic. These flexibilities could be further extended or even expanded to
accommodate IHEs operations during the pandemic.
Other examples of waivers and flexibilities being employed include the responses to Hurricanes
Harvey, Irma, and Maria, and wildfires in 2017. The Further Additional Supplemental
Appropriations for Disaster Relief Act, 2018 (Division B, Subdivision 1 of the Bipartisan Budget
Act of 2018; P.L. 115-123) authorized the Secretary to modify required and al owable uses of
funds under the programs authorized by HEA Title III, Parts A and B, and Title IV, Part A,
Subpart 2, Chapters 1 and 2.
As a final example, the CARES Act requires that the Secretary waive the matching requirement
for public and private nonprofit IHEs under the Federal Supplemental Educational and
Opportunity Grant (FSEOG) and the Federal Work-Study (FWS) programs for funds made
available for award years 2019-2020 and 2020-2021.102

economy.
99 For more information, see CRS Report R42881, Education-Related Regulatory Flexibilities, Waivers, and Federal
Assistance in Response to Disasters and National Em ergencies.
100 A disaster is a “federally declared disaster” that is declared by the President to be a major disaster or emergency
under Section 401 or Section 501, respectively, of the Robert T . Stafford Disaster Relief and Emergency Assistance
Act (42 U.S.C. §§5170, 5191).
101 U.S. Department of Education, “ Non-Regulatory Guidance on Flexibility and Waivers for Grantees and Program
Participants Impacted by Federally Declared Disasters,” September 2018, https://www2.ed.gov/policy/gen/guid/
disasters/disaster-guidance.docx.
102 For an overview of the waivers and flexibilities provided through the CARES Act, see CRS In Focus IF11497,
CARES Act Higher Education Provisions.
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Appendix. Background on IPEDS and Data
Methodology for Postsecondary Revenue
Background on IPEDS
IHEs participating in student financial aid programs authorized under Title IV of the HEA are
required to complete the Integrated Postsecondary Education Data System (IPEDS) surveys.
IPEDS is a series of surveys conducted annual y by ED’s National Center for Education Statistics
(NCES) to gather institutional data on a variety of topics, including institutional finances. Data
used to determine the amount of revenue IHEs realize from major sources were obtained from the
IPEDS Finance component for FY2018, which are the most recently available data.
Data Methodology for Postsecondary Revenue
General y, private IHEs report finance data using accounting standards established by the
Financial Accounting Standards Board (FASB), while public IHEs general y use standards
established by the Governmental Accounting Standards Board (GASB).103 Because of the
differences in reporting standards, IHEs reporting under FASB may classify funds differently than
IHEs reporting under GASB. One notable difference is the treatment of Pel Grants disbursed by
the institution. Public IHEs reporting under GASB are required to include Pel Grants when
reporting revenue from federal grants and contracts. Private nonprofit IHEs and those public IHEs
reporting under FASB have the option to either include Pel Grants as federal revenue or treat
them as pass-through transactions and exclude them from federal revenue. As a result, in a case
where a GASB institution and a FASB institution each receive the same amount of Pel Grants on
behalf of their students, the GASB institution wil appear to have more federal revenue than the
FASB institution.104 To account for the difference in Pel Grant reporting, Pel Grant
disbursements were subtracted from the federal revenue calculation for public IHEs and for
nonprofit IHEs that did not treat Pel Grants as pass-through transactions. 105 Additional y, tuition
and fee revenue was adjusted to include discounts and al owances that had been applied to tuition
and fees.106 There could be other differences in reporting between IHEs using FASB or GASB;
thus, the less than 2% of public IHEs reporting under FASB were excluded from the analysis.107

103 A small portion of public IHEs report using FASB. In FY2018, there were 1,985 public IHEs, and 30 of them
reported using FASB.
104 See IPEDS Finance Survey T ips Scholarships, Grants, Discounts, and Allowances, https://nces.ed.gov/ipeds/report-
your-data/data-tip-sheet-reporting-finance-data.
105 T his approach is similar to that taken by the Delta Cost Project. See Delta Cost Project Database History, 1987 -
2011, https://www.deltacostproject.org/sites/default/files/database/DCP_History_Documentation.pdf.
106 T his approach is similar to that taken by the Delta Cost Project. See Delta Cost Project Database History, 1987 -
2011, https://www.deltacostproject.org/sites/default/files/database/DCP_History_Documentation.pdf.
107 T his approach is similar to that taken by NCES in the report Enrollment and Employees in Postsecondary
Institutions, Fall 2017; and Financial Statistics and Academ ic Libraries, Fiscal Year 2017 , https://nces.ed.gov/
pubs2019/2019021REV.pdf.
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Author Information

Benjamin Collins
Cassandria Dortch
Analyst in Labor Policy
Specialist in Education Policy

Joselynn H. Fountain

Analyst in Education Policy

Disclaimer
This document was prepared by the Congressional Research Service (CRS). CRS serves as nonpartisan
shared staff to congressional committees and Members of Congress. It operates solely at the behest of and
under the direction of Congress. Information in a CRS Report should n ot be relied upon for purposes other
than public understanding of information that has been provided by CRS to Members of Congress in
connection with CRS’s institutional role. CRS Reports, as a work of the United States Government, are not
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Congressional Research Service
R46666 · VERSION 2 · NEW
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