VOLUME 3 - 2021

ED COVID-19 HANDBOOK 

Strategies for Safe Operation and Addressing the Impact of COVID-19 

on Higher Education Students, Faculty, and Staff

COLLEGE

OPEPD-IO-21-03 

This Volume of the ED COVID-19 Handbook is based on the most recent Centers for Disease Control (CDC) 

Guidance issued as of June 4, 2021. For the most recent CDC guidance issued after the release of this Volume – and 

how to consider the strategies included in this Volume within the context of the most up to date CDC guidance – 

please visit: https://www.cdc.gov/coronavirus/2019-ncov/community/colleges-universities/considerations.html
2 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

U.S. Department of 

Education

Dr. Miguel Cardona

Secretary of Education

Office of Planning, 

Evaluation and 

Policy Development

Donna Harris-Aikens

Acting Assistant 

Secretary

June 2021

This report is in the public domain. Authorization 

to reproduce it in whole or in part is granted. 

While permission to reprint this publication is not 

necessary, the citation should be U.S. Department 

of Education, Office of Planning, Evaluation and 

Policy Development, ED COVID-19 Handbook, 

Volume 3: Strategies for Safe Operation and 

Addressing the Impact of COVID-19 on Higher 

Education Students, Faculty, and Staff, Washington, 

DC, 2021. This report is available on the Department 

of Education’s website at https://www2.ed.gov/

documents/coronavirus/reopening-3.pdf.

Availability of Alternate Formats

On request, this publication is available in alternate 

formats, such as Braille or large print. For more 

information, please contact the Department of 

Education’s Alternate Format Center at 202-260-

0818 or via e-mail at alternateformatcenter@ed.gov.

Notice to Limited English Proficient Persons

If you have difficulty understanding English, you 

may request language assistance services for all 

publicly available Department information. These 

language assistance services are available free 

of charge. If you need more information about 

interpretation or translation services, please call 

1-800-USA-LEARN (1- 800- 872-5327) (TTY:

1-800-877-8 339), email us at Ed.Language.

Assistance@ed.gov, or write to U.S. Department

of Education, Information Resource Center, 400

Maryland Ave., SW, Washington, DC 20202.
3 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

TABLE OF 

CONTENTS

INTRODUCTION.........................................................................4

SAFE PRACTICES FOR IN-PERSON LEARNING.................9

SUPPORTING HIGHER EDUCATION IN NAVIGATING 

ONLINE LEARNING IN A PANDEMIC....................................18

BROADBAND AND DEVICE ACCESS FOR 

HIGHER EDUCATION STUDENTS, FACULTY, 

AND STAFF .................................................................................25 

BASIC NEEDS SUPPORTS FOR STUDENTS ........................31

STUDENT CAREGIVERS...........................................................40

MENTAL HEALTH NEEDS OF STUDENTS AND STAFF.....44

COMMITMENTS TO THE COMMUNITY..................................50

AVAILABLE FEDERAL FUNDING AND FLEXIBILITIES .....52
4 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

INTRODUCTION

Every student in 

America deserves a 

high-quality education 

in a safe environment.

EXECUTIVE ORDER 14000

SUPPORTING THE REOPENING AND

 CONTINUING OPERATION OF SCHOOLS AND 

EARLY CHILDHOOD EDUCATION PROVIDERS

President Biden is committed to seeking and 

providing the necessary resources to support 

the safe operation of institutions of higher 

education (IHEs) and addressing the ongoing 

impacts resulting from the COVID-19 pandemic 

on higher education students, adult education 

students, faculty, and staff. As stated in 

Executive Order 14000 (hereinafter referred to 

as Executive Order), Supporting the Reopening 

and Continuing Operation of Schools and 

Early Childhood Education Providers, every 

student in America deserves a high-quality 

education in a safe environment. The BidenHarris Administration strongly believes that 

increasing capacity for safe in-person learning 

as soon as possible is essential for students 

seeking to learn in such a setting. Further, 

the Administration recognizes the unique 

challenges faced by IHEs, students, faculty, and 

staff during these unprecedented times and 

strives to provide resources and other supports 

to overcome these challenges. This includes 

the historic funding provided to IHEs under 

the American Rescue Plan (ARP).

All students, but particularly those in 

underserved communities, including students 

from low-income backgrounds, students of 

color, and students with disabilities, have 

faced numerous adversities surrounding their 

postsecondary educational experiences since 

March 2020, in addition to the direct health 

impacts from the virus itself. Disparities across 

communities have been exacerbated and 

further exposed by the COVID-19 pandemic, 

and these disparities have shown that some 

underserved students are less likely to have 

access to internet services, technological 

devices, and supports required to participate 

in remote or hybrid learning, while other 

students may be enrolled in programs of 

study for which this option is not feasible. 

Meanwhile, due to ongoing financial distress 

or uncertainty, students and families may not 

have the ability to afford other associated 

costs of attendance including basic needs 

such as housing, food, child care, and health 

insurance. Further, students across higher 

education may be experiencing ongoing 

trauma associated with the COVID-19 pandemic 

including job loss, heightened stress from 

being an essential worker, full time caretaking 

of family members, losing loved ones, racial 

injustice, discrimination experienced by students 

with disabilities, or experiencing other mental 

health impacts. Unfortunately, the underlying 

data confirm that these realities have taken a 

toll on postsecondary education enrollments, 

particularly among American Indian or Alaska 

Native, Black, and Latino (or Hispanic) students, 

as college-going rates continue to drastically fall.1

Similarly, IHEs have undertaken significant 

Disparities across communities 

have been exacerbated and further 

exposed by the COVID-19 pandemic.
5 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

operational changes and borne great financial costs to continue supporting students amidst rapidly 

changing health and economic conditions. For example, effectuating a rapid transition to remote 

learning beginning last spring was a historic undertaking that continues to evolve today. While online 

learning has been a well-established modality for some programs at IHEs, this was not the primary 

mode of educational delivery for many IHEs. This transition required additional financial resources, 

increased and enhanced technology, and rapid cycles of learning and adaptation for students, 

faculty, and staff. IHEs have also undertaken changes to their physical infrastructure to facilitate 

social distancing and implement enhanced mitigation protocols and testing regimes. Throughout the 

COVID-19 pandemic, faculty and staff have been on the front lines of these changes and have done 

so in the face of physical, mental, and emotional exhaustion, risk of exposure to COVID-19, wage cuts, 

job loss, loss of child care, and expanded responsibilities including for their own children’s in-home 

schooling.

These themes have repeatedly surfaced through the U.S. Department of Education’s (Department’s) 

engagement with various higher education, career and technical education (CTE), and adult 

education partners pursuant to the Executive Order. Based on feedback across 15 listening sessions 

with institutions, students, and 40 key stakeholder organizations, Volume 3 of the Department’s 

COVID-19 Handbook (Handbook) was developed with the express intent of providing initial answers 

to some of the most pressing questions for colleges, students, and families facing these challenges. 

The Handbook shares implementation stories and relevant information from the field. In doing 

so, the Administration recognizes the diversity of our Nation’s postsecondary students, ranging 

from the full-time, on-campus recent high school graduate, to the returning student seeking retraining through online, part-time programming while balancing work and family, to the immigrant 

seeking English language skills, civics education, job training, and a high school equivalency with 

postsecondary on-ramps.

Additionally, the Administration recognizes the considerable diversity of IHEs seeking to serve 

the spectrum of students across higher education. This document is intended to be used as an 

informational resource, with the understanding that described practices may not be universally 

applicable, feasible, or responsive to the particular circumstances of an institution’s student 

body, mission, geography, or surrounding community. The Department 

understands that a one-size-fits-all approach will not work in 

responding to and recovering from the COVID-19 pandemic and 

therefore trusts IHEs will continue to make responsible decisions 

in the best interests of their respective student populations 

and their communities. The Department will support IHEs in 

their efforts and effective use of funding through the Higher 

Education Emergency Relief Fund (HEERF), which has 

made approximately $76 billion available to IHEs through 

three relief bills.

1

 National Student Clearinghouse. (2021). National Student Clearinghouse Research Center’s Regular Updates on Higher Education Enrollment. Retrieved from: https://nscresearchcenter.org/stay-informed/.
6 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

In Volume 3 of this Handbook, a series to support the safe reopening and operation of K-12 schools 

and IHEs, the Department will address several priority areas of interest to the higher education 

community with an eye towards both a response and a recovery that leaves our Nation’s students 

and IHEs stronger than before the COVID-19 pandemic began. These priorities include:

 Practices to aid IHEs in implementing the Centers for Disease Control and Prevention (CDC) 

Guidance for Institutions of Higher Education (IHEs) and resources by identifying common 

prevention strategies and providing examples of actions IHEs can take with HEERF grant 

funding;

 Institutional responses to ongoing challenges and potentially lasting impacts on underserved 

populations, including the transition to online learning and the provision of basic needs;

 Ways in which IHEs have already been and can continue to be sources of support to their 

communities’ ongoing response and recovery from the pandemic;

 A catalog of the resources and administrative flexibilities offered to IHEs as they address 

rapidly changing conditions and needs on the ground, including resources that support both 

students and IHEs under the ARP.

Other than statutory and regulatory requirements referenced in the document, the contents of this 

volume do not have the force or effect of law and are not meant to bind the public. This document 

is intended only to provide clarity to the public regarding existing requirements under the law or 

agency policies.

In addition to Volume 3, the Department continues to provide resources on specific strategies 

to address the extraordinary disruption and impacts created by COVID-19 for students, faculty, 

staff, and surrounding communities—especially for underserved students and communities that 

preliminary data suggest have been hit hardest by the COVID-19 pandemic. This includes recently 

launching the Safer Schools and Campuses Best Practices Clearinghouse, which highlights lessons 

learned and best practices that can help IHEs identify opportunities to best use ARP funds to 

support students, faculty, and staff during the COVID-19 pandemic and as they start on the journey 

ahead to reengage with students who have temporarily opted out of postsecondary education. IHEs 

can send examples of lessons learned and best practices to Bestpracticesclearinghouse@ed.gov.

The Department continues to provide resources on specific 

strategies to address the extraordinary disruption and 

impacts created by COVID-19 for students, faculty, staff, 

and surrounding communities—especially for underserved 

students and communities that preliminary data suggest 

have been hit hardest by the COVID-19 pandemic.
7 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

The Department welcomes input from all partners on this volume as well as input 

on these and other topics to include in the development of additional informational 

resources. Please email input and suggestions to COVIDHandbookHE@ed.gov.

CIVIL RIGHTS REQUIREMENTS

IHEs have important responsibilities under federal civil rights laws that reinforce efforts to advance 

equity, including obligations not to discriminate based on race, color, national origin, sex, and 

disability. Below are brief summaries of some of these laws. For more information, please see the 

Department’s Office for Civil Rights website.

Race, Color, National Origin: Title VI of the Civil Rights Act of 1964 (Title VI) is a federal civil rights 

law that prohibits IHEs and other entities receiving federal financial assistance from discriminating 

based on race, color, or national origin in connection with any of their programs or activities. This 

includes academic offerings, other educational programming, and extracurricular activities, including 

athletics.2

Sex: Title IX of the Education Amendments of 1972 (Title IX) prohibits sex discrimination, including 

sexual harassment, by IHEs that are recipients of federal financial assistance.3 Some key issue areas 

in which recipients have Title IX obligations are: recruitment, admissions, and counseling; financial 

assistance; athletics; sex-based harassment, which encompasses sexual assault and other forms 

of sexual violence and harassment of lesbian, gay, bisexual, transgender, and queer (LGBTQ+) 

students; treatment of pregnant and parenting students; discipline; single-sex education; and 

employment.

Disability: Section 504 of the Rehabilitation Act of 1973 and Title II of the Americans with 

Disabilities Act of 1990 (ADA), as applicable, require IHEs to provide academic adjustments, 

auxiliary aids and services, and reasonable modifications to policies, practices, and procedures 

where necessary to enable students with disabilities to have an equal opportunity to participate.4

Under these laws, IHEs are not required to provide a modification, academic adjustment, or 

auxiliary aid or service where doing so would impose an undue burden or cause a fundamental 

alteration to the IHEs’ services, programs, or activities. Please note that the two statutes have 

different scopes: Section 504 prohibits discrimination on the basis of disability by recipients of 

federal financial assistance; Title II of the ADA prohibits discrimination on the basis of disability 

by state and local government entities, including public postsecondary institutions. For more 

information on these laws, visit www.ed.gov/ocr. For more information about Title II and Title III of 

the ADA, visit www.ada.gov.

The Higher Education Emergency Relief Fund (HEERF) has made 

approximately $76 billion available to IHEs through three relief bills.

2 42 U.S.C. 2000d, 34 CFR Part 100 (Title VI). 3 20 U.S.C. 1681—1688, 34 CFR Part 106 (Title IX). 4 29 U.S.C. 794, 34 CFR Part 104 (Section 504); 42 U.S.C. 12131—12134, 28 CFR 

Part 35 (Title II of the ADA). This document references obligations and the regulations under Title II of the ADA at 28 CFR Part 35, which are under the jurisdiction of the 

Department of Justice. Title III of the ADA applies to certain private, postsecondary institutions. The Department of Education plays no role in enforcing Title III; for more information please contact the Department of Justice.
8 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

Legal Disclaimer

This document contains resources that are provided for the user’s convenience. The inclusion 

of these materials is not intended to reflect their importance, nor is it intended to endorse 

any views expressed, or products or services offered. These materials may contain the views 

and recommendations of various subject-matter experts as well as hypertext links, contact 

addresses and websites to information created and maintained by other public and private 

organizations. The opinions expressed in any of these materials do not necessarily reflect 

the positions or policies of ED. ED does not control or guarantee the accuracy, relevance, 

timeliness, or completeness of any outside information included in these materials. For the 

reader’s convenience, this posting contains examples of potentially useful products, including 

applications, as well as methodologies utilized by IHEs, states, and localities. Inclusion of such 

information does not constitute an endorsement by ED or a preference for these examples as 

compared with others that might be available and be presented. Additionally, this discussion 

should not imply an endorsement of any organization, curriculum, or learning model.
9 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

SAFE PRACTICES FOR IN-PERSON LEARNING

Over a year into the COVID-19 pandemic, increasing institutional capacity to safely operate 

with in- person learning is more critical than ever to support high-quality learning and 

postsecondary experiences for students while maintaining institutional stability. Although 

the extent of in-person learning and on-campus residential living has varied, IHEs across the 

country invested substantial financial and staff resources to continue to provide high-quality 

and equitable education safely during a global pandemic with constantly shifting challenges.

More effective prevention strategies are available now than before the previous school year. Testing 

is also more accessible. Vaccinations, the leading prevention strategy to protect individuals from 

COVID-19 and help end the COVID-19 pandemic, are now widely available at no cost to people 

living in the United States. In light of these changing dynamics, CDC has updated its guidance for 

IHEs, supplementing previous resources, including recent testing guidance specifically for IHEs. The 

updated guidance reflects recent updates regarding fully vaccinated individuals and distinguishes 

between IHEs where everyone is fully vaccinated and IHEs that have a mix of students, faculty, 

and staff who are fully vaccinated and not fully vaccinated. As we continue to learn more, CDC will 

continue to update their guidance. IHEs can visit CDC’s landing page for colleges and universities

for the most up-to-date guidance on safe operations.

IHEs can also continue to learn from each other. The Department has published a request for 

IHEs (and other educational partners) to submit lessons learned and examples of best practices for 

operating safely during COVID-19 in order to assist ED in establishing a Safer Schools and Campuses 

Best Practices Clearinghouse. ED strongly encourages IHEs to respond to this request so that 

examples of the great work IHEs have undertaken can be highlighted and disseminated more 

broadly. 

In addition, the American College Health Association (ACHA), in partnership with CDC, 

established the Higher Education COVID-19 Community of Practice (HECCOP) to bring together 

people from all areas of campuses to talk about strategies to reduce the spread of COVID-19. 

Through peer-to-peer collaboration, discussion, and information sharing, HECCOP helps its 

members build knowledge, develop expertise, and solve problems aimed at reducing SARS-CoV-2. 

HECCOP recently published a list of examples of innovative practices designed to foster a campus 

culture that promotes safe behaviors.

5 See CDC’s definitions of “fully vaccinated campus” and “mixed campus” at: https://www.cdc.gov/coronavirus/2019-ncov/community/colleges-universities/considerations.html.
10 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

KEY CDC PREVENTION STRATEGIES

The following identifies key prevention strategies and highlights how HEERF grants can be used 

to support implementation of these strategies. IHEs should carefully review the CDC guidance 

for information on the range of prevention strategies most applicable to their situation, based on 

whether they will have fully vaccinated campuses or not.5 Given the rapidly evolving nature of 

this pandemic, IHEs should continue to closely follow CDC and their state and local public health 

departments for the most up-to-date information about COVID-19.

To maintain safe operations for in-person learning, IHEs should consistently implement and layer 

multiple prevention strategies. This begins with developing, reviewing, and updating Emergency 

Operations Plans (EOPs) in collaboration with public health authorities, students, faculty and staff, 

IHE-based health center personnel, and other key partners. The EOPs should be updated to include 

key considerations related to COVID-19, including the institution’s plan for monitoring community 

transmission, developing the criteria the institution will use to determine when a change in 

operations is warranted, and describing the institution’s implementation of prevention strategies to 

reduce transmission on campuses. IHEs should post publicly the details of the EOPs that students, 

employees, and the broader community need to understand the risks in their community and 

the safety protocols with which they must comply. The Readiness and Emergency Management 

for Schools (REMS) Technical Assistance Center has developed a web toolkit on emergency 

management for IHEs and state higher education agencies. A key component of the toolkit is to 

assist IHEs in developing high-quality EOPs.

IHEs should be sure to review the CDC’s Guidance for IHEs for the most recent information 

regarding COVID-19 prevention strategies. According to the updated guidance, IHEs where 

everyone is fully vaccinated can return to full capacity in-person learning without requiring 

or recommending masking, physical distancing, or screening testing, but should continue 

implementing other prevention strategies.6 IHEs where not everyone is fully vaccinated should 

implement and layer evidence-based prevention strategies, including offering and promoting 

COVID-19 vaccination.

 Offering and Promoting COVID-19 

Vaccination

 Consistent and Correct Use of Masks

 Physical Distancing

 Handwashing and Respiratory Etiquette

 Maintaining Healthy Environments 

(improved ventilation and routine cleaning)

 Testing for COVID-19

 Contact Tracing in Combination with

Isolation and Quarantine

 Maintaining Healthy Operations 

(communications, supportive policies, 

and health equity)

The following describes how IHEs can support the successful implementation of these prevention 

strategies, including with their HEERF grant funding. Section 2003(5)(A) of the ARP requires IHEs 

to use a portion of funding that is not reserved for student grants to “implement evidence-based 

practices to monitor and suppress coronavirus in accordance with public health guidelines.” IHEs 

can review the practices below, along with those described in Section D of the HEERF III FAQs to 

identify strategies that meet this standard.

6 Note: except where required by federal, state, local, tribal, or territorial laws, rules and regulations, including local business and workplace guidance.
11 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

 

1. Offering and Promoting COVID-19 Vaccination

COVID-19 vaccination is the leading prevention strategy IHEs can use to return to normal 

operations. COVID-19 vaccines have been proven safe and effective in clinical trials and in realworld conditions. Fully vaccinated people are at low risk of symptomatic or severe infection, 

and a growing body of evidence suggests that fully vaccinated people are less likely to have 

asymptomatic infection or transmit the virus that causes COVID-19 to others. Detailed information 

on the effectiveness of the COVID-19 vaccines is available in this CDC Science Brief. IHEs with fully 

vaccinated students, faculty, and staff can refer to CDC’s Interim Public Health Recommendations for 

Fully Vaccinated People.

One way IHEs can facilitate high levels of vaccination on campuses is by providing safe on-site 

vaccination to their communities. IHEs often have space available in large open areas such as 

parking lots and athletic fields that are ideal for large vaccination campaigns. Many IHEs, particularly 

community colleges, Historically Black Colleges and Universities (HBCUs), Tribally Controlled Colleges 

and Universities (TCCUs), and minority serving institutions (MSIs) such as Hispanic-serving institutions 

(HSIs) and Asian American and Native American Pacific Islander-serving institutions (AANAPISIs) 

have deep connections to their communities and can leverage these connections to ensure equitable 

distribution of vaccines. They can also play a key role in providing accurate information on the safety 

and effectiveness of the vaccine and build vaccine confidence by acknowledging and addressing their 

communities’ concerns. Indeed, many IHEs are already actively assisting in this communication effort.

Depending on their academic programs, IHEs may also have access to health practitioners 

who can help administer vaccines. On May 11, 2021, the President announced a new initiative 

to establish on-site vaccination clinics through partnerships between community colleges and 

pharmacies. Building on that effort, on June 3, 2021 the White House and the Department 

announced the COVID-19 College Vaccine Challenge, an invitation to IHEs across the country 

to commit to taking key action steps to boost vaccination rates at college communities 

throughout the country and help end the pandemic.

IHEs can consider verifying the vaccination status of their students, faculty, and staff. 

Administrators can determine vaccine record verification protocols, in accordance with state and 

local laws. For more information, IHEs should review CDC’s COVID-19 Vaccination Toolkit for IHEs.

HEERF: With the HEERF grant funding provided for institutional uses,7

IHEs can boost vaccination rates on campus by covering the cost of:

 Establishing vaccination sites on campus;

 Providing paid time off for faculty or staff to get the vaccine;

 Offering counseling for students, faculty, and staff who are hesitant to get the vaccine;

 Conducting educational messaging campaigns to build vaccine confidence among 

students, faculty, or staff, including in other languages commonly spoken by these 

individuals.

7 That is, funding that is not allocated for emergency grants to students under Assistance Listing Numbers (ALN) 84.425E, 84.425Q, and certain absolute priorities under 

84.425S. 
12 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

2. Consistent and Correct Use of Masks

Another key prevention strategy is to encourage the consistent and correct use of masks. One 

analysis found that statewide mask mandates were associated with a 5.6% decline in COVID-19 related 

hospitalizations of individuals between the ages of 18 and 64 years.8 Additional research on the 

effectiveness of mask use in reducing transmission of SARS-CoV-2 is available in this CDC Science Brief.

When people who are not fully vaccinated correctly wear a mask, they protect others as well as 

themselves. Consistent and correct mask use by people who are not fully vaccinated is especially 

important indoors and in crowded settings, when physical distancing cannot be maintained. 

Administrators should encourage people who are not fully vaccinated to wear a mask consistently 

and correctly.

Although masks do not need to be worn by fully vaccinated persons, IHEs can be supportive of 

students, faculty, and staff who choose to wear a mask for any reason, whether as a personal choice 

or because they have or a loved one has a medical condition that may increase their risk. In areas 

with substantial to high transmission, IHEs with mixed populations of people who are vaccinated 

and unvaccinated may consider requiring mask use by all people present on campus, including 

vaccinated students, faculty, staff, and visitors.

In general, masks should have two or more layers of washable, breathable fabric covering both 

the mouth and nose (with a nose wire to prevent air from escaping out of the top of the mask) 

without any open gaps. IHEs can maximize mask compliance by ensuring that masks are made 

available to all students, faculty, and staff. A study by CDC’s National Institute 

for Occupational Safety and Health found that employees were twice 

as likely to use masks and personal protective equipment (PPE) 

when it was provided by the employer.9

The narrow set of individuals who cannot safely wear masks 

due to a disability or workplace safety issue should not 

be required to wear a mask. However, a student with a 

disability who cannot safely wear a mask and who is not 

fully vaccinated might still be able to attend school safely 

if other prevention strategies are followed, including, for 

example, physical distancing and masking for individuals 

who are not fully vaccinated but work or learn alongside the 

individual with a disability. In these instances, instructors and 

school administrators must keep in mind their responsibilities 

and obligations under federal disability rights laws and should also 

consider some of the adaptations and alternatives recommended by CDC.

Masks make it more difficult for individuals who are deaf and hard of hearing both to understand 

speech and to understand sign language because they obscure the lips and part of the face. In order 

to maintain a safe environment that meets the communication needs of students who are deaf or 

8 Joo H, Miller GF, Sunshine G, et al., (2021 Feb. 12). Decline in COVID-19 Hospitalization Growth Rates Associated with Statewide Mask Mandates — 10 States, March–October 

2020. MMWR Morb Mortal Wkly Rep 2021;70:212–216. DOI: http://dx.doi.org/10.15585/mmwr.mm7006e2. 

9 Billock RM, Groenewold MR, Free H, Haring Sweeney M, Luckhaupt SE., (2021, Feb. 19). Required and Voluntary Occupational Use of Hazard Controls for COVID-19 Prevention 

in Non–Health Care Workplaces — United States, June 2020. MMWR Morb Mortal Wkly Rep 2021;70:250–253. DOI: http://dx.doi.org/10.15585/mmwr.mm7007a5. 
13 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

hard of hearing, IHEs must ensure that communications with people with disabilities are as effective 

as communications with others. This includes providing auxiliary aids and services where necessary 

to afford individuals with disabilities an equal opportunity to participate in, and enjoy the benefits 

of, an IHE’s service, program, or activity. In determining what types of auxiliary aids and services are 

necessary, an IHE must give primary consideration to the requests of individuals with disabilities. For 

example, it might be effective to have the instructors and staff in the individual’s class wear a clear 

mask or a cloth mask with a clear panel. If no such mask is available, instructors should consider 

alternatives such as written communication or closed captioning. CDC does not recommend the use 

of face shields as a substitute for masks because of concerns about their efficacy.10

HEERF: With the HEERF grant funding provided for institutional uses, IHEs can provide 

masks or PPE to faculty, staff, and students. IHEs could also pay for costs associated with 

mask campaigns designed to increase mask use on campuses. The HEERF ARP FAQs

provides more information on required and allowable uses of funds. IHEs should also 

note the Federal Emergency Management Agency (FEMA) has announced that public 

assistance applicants, including IHEs, can seek FEMA reimbursement for safe reopening 

activities such as the provision of masks and PPE.

3. Physical Distancing

Physical distancing means keeping space of at least 6 feet (about 2 arm lengths) between people 

who are not from your household in both indoor and outdoor spaces. IHEs where everyone is fully 

vaccinated prior to the start of the semester can return to in-person learning without physical 

distancing. But IHEs without a fully vaccinated campus will have mixed populations of vaccinated 

and unvaccinated students, so people who are not fully vaccinated should continue to practice 

physical distancing. Operationally, IHEs with mixed populations of students could implement the 

following approaches to modify their classroom layouts but must ensure physical accessibility for 

individuals with disabilities:

 Use outdoor spaces to hold classes when weather permits and as class content allows;

 Space seating/desks and CTE equipment/labs at least 6 feet apart. For lecture halls, tape off 

seats and rows to ensure at least 6 feet of distance between seats;

 Host classes in larger rooms to allow for physical distancing;

 Turn desks to face the same direction (rather than facing each other), or have students sit 

spaced at least 6 feet apart on only one side of tables; and

 Provide physical guides (such as tape on floors or sidewalks and signs on walls) to ensure 

that people remain at least 6 feet apart and/or to create “one-way routes” in hallways.11

IHEs with mixed populations could also explore scheduling changes to minimize foot traffic in and 

around classrooms, such as offering more sections of courses (e.g., offering additional sections in 

10 See CDC Guidance for Wearing Masks and the following CDC-funded research: William G. Lindsley, Francoise M. Blachere, Brandon F. Law, Donald H. Beezhold & John D. 

Noti,(2021). Efficacy of face masks, neck gaiters and face shields for reducing the expulsion of simulated cough-generated aerosols. Aerosol Science and Technology, DOI: 

10.1080/02786826.2020.1862409. 

11 IHEs should be mindful of their obligation to ensure equal access to individuals who are blind or have low vision in the use of signage and should consider additional ways of 

providing this information, such as adding braille to signs or providing a tour to describe the physical guides to the individual. 42 U.S.C. 12132; 42 U.S.C. 12182; 29 U.S.C. 794.
14 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

the evenings or on weekends) or adjusting class start and end times so students arrive and depart 

at staggered times.

These IHEs should take some of the same approaches with other public spaces such as dining halls, 

student centers, or libraries. IHEs should try to conduct gatherings, events, and activities virtually. 

IHEs should strongly discourage large in-person events and gatherings, including off campus.

A key challenge IHEs face is how to maintain physical distancing in communal living settings. 

CDC has provided resources in its Guidance for Shared or Congregate Housing and in its updated 

guidance to IHEs.

HEERF: With the HEERF grant funding provided for institutional uses, IHEs can conduct 

activities (such as those described above) to modify classrooms to make them safer for inperson learning. IHEs can use HEERF grants12 to pay for costs associated with implementing 

physical distancing guidelines on campus. IHEs may also seek FEMA reimbursement for 

some activities associated with physical distancing.

 

4. Handwashing and Respiratory Etiquette

According to CDC, IHEs should facilitate health-promoting behaviors such as hand-washing and 

respiratory etiquette to reduce the spread of respiratory illnesses, including COVID-19. For example, 

IHEs could ensure that sink functionality, along with ample supplies of hand soap, tissues, and other 

essentials for proper hand hygiene and respiratory etiquette, are maintained throughout the campus. 

IHEs should ensure that where handwashing is not possible, hand sanitizer that contains at least 

60% alcohol is widely available, as recommended by the CDC.

HEERF: With the HEERF grant funding provided for institutional uses, IHEs can support 

clean and sanitary campus environments by purchasing hand sanitizer and handwashing 

stations that can be placed throughout the campus.

5. Cleaning and Maintaining Healthy Facilities

In combination with efforts to promote behaviors that reduce transmission, IHEs should consider 

improvements they can make to facilities, including plans for routine cleaning and measures to 

increase and improve ventilation. 

Cleaning: IHEs should develop routine cleaning plans that prioritize cleaning high-touch surfaces 

and areas that are used most frequently and those that entail intensive hands-on engagement 

with equipment, such as in CTE or STEM labs. IHEs should provide individuals responsible for the 

cleaning and disinfection of facilities with the appropriate PPE and access to the information they 

need to know from these plans in a language they understand. 

12 See Question #23 of the HEERF ARP FAQs for information on unallowable uses of HEERF grant funding.
15 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

Ventilation: Since the virus spreads more readily between people indoors than outdoors, improving 

air flow to reduce the concentration of viral particles can help reduce risk in indoor environments. 

CDC recommends a wide array of strategies to improve ventilation in buildings, ranging from 

opening windows and doors and using fans to installing high efficiency particulate air (HEPA) fan/

filtration systems. More information is available on CDC’s Ventilation in Buildings page.

HEERF: With the HEERF grant funding provided for institutional uses, IHEs can make 

updates to ventilation systems to improve the safety of classroom buildings and support 

in-person learning. This includes both new costs as well as defraying prior expenses 

incurred. For example, colleges could use their HEERF grants13 to improve HVAC systems 

in campus buildings or to set up temporary tents designed to support outdoor instruction. 

IHEs may also seek FEMA reimbursement for some activities associated with cleaning and 

disinfection of certain campus facilities.

 

6. Testing for COVID-19

Testing: People who are fully vaccinated do not need to undergo screening testing. If a fully 

vaccinated person is exposed to someone with COVID-19, they do not need to be tested if they do 

not develop any symptoms. If they experience any COVID-19 signs or symptoms, they should get 

a COVID-19 test. IHEs with fully vaccinated campuses do not need to conduct screening testing. 

Among IHEs with mixed populations of individuals who are fully vaccinated and those who are not, 

individuals who are fully vaccinated can be exempted from screening testing.

Diagnostic Testing: All IHEs should have a plan to isolate and test symptomatic individuals. IHEs 

operating with students in residence should make space available for COVID-19 positive individuals 

to isolate.

Screening Testing: According to recent research, about half of transmission may be attributable 

to asymptomatic individuals.

14 Yet, a recent CDC analysis of spring 2021 testing protocols at over 

1,800 public and private non-profit 4-year IHEs found that slightly over half did not publish a testing 

protocol that provided for screening testing of asymptomatic individuals.

15 Furthermore, a National 

Institutes of Health-funded study estimates that 96% of infections could be prevented on campuses 

with routine testing.16 Accordingly, CDC recommends IHEs with mixed populations of individuals 

who are fully vaccinated and those who are not, should:

Implement entry screening testing at the beginning of the term. Individuals given the entry test 

should be required to receive a negative result prior to accessing campus; and Given sufficient 

capacity, provide serial screening testing17 for asymptomatic and unvaccinated individuals 

13 See FAQs #23 and 24 at: https://www2.ed.gov/about/offices/list/ope/arpfaq.pdf. 

14 Johansson MA, Quandelacy TM, Kada S, et al.,(2021, Jan. 7). SARS-CoV-2 Transmission From People Without COVID-19 Symptoms. Retrieved from: https://jamanetwork.com/

journals/jamanetworkopen/fullarticle/2774707. 15 CDC, (2021, April 9). COVID-19 Stats: College and University COVID-19 Student Testing Protocols, by Mode of Instruction (N = 

1,849) — United States, Spring 2021. MMWR Morb Mortal Wkly Rep 2021;70:535. DOI: http://dx.doi.org/10.15585/mmwr.mm7014a5. 

15 CDC, (2021, April 9). COVID-19 Stats: College and University COVID-19 Student Testing Protocols, by Mode of Instruction (N = 1,849) — United States, Spring 2021. MMWR 

Morb Mortal Wkly Rep 2021;70:535. DOI: http://dx.doi.org/10.15585/mmwr.mm7014a5. 

16 Losina E, Leifer V, Millham L, Panella C, Hyle EP, Mohareb AM, Neilan AM, Ciaranello AL, Kazemian P, Freedberg KA., (2021 Apr;174(4):472-483. doi: 10.7326/M20-6558. Epub 

2020 Dec 21). College Campuses and COVID-19 Mitigation: Clinical and Economic Value. Retrieved from: https://pubmed.ncbi.nlm.nih.gov/33347322/. 

17 Screening testing is intended to identify infected individuals without symptoms (or prior to development of symptoms) who may be contagious so that measures can be 

taken to prevent further transmission.
16 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

without COVID exposure to reduce transmission. CDC notes that such a strategy is particularly 

recommended if community transmission is moderate (10-49 new cases per 100,000 persons or 

a nucleic acid amplification test [NAAT]18 positivity rate of 5-7.9% or higher in the last 7 days) or 

higher. At substantial levels of transmission (50-99 new cases per 100,000 persons or 8-9.9% NAAT 

positivity in the last 7 days) or high levels of transmission (100 or more new cases per 100,000 

persons or 10% or above positivity rate in the last 7 days), IHEs should 

implement serial testing at least 2 days a week. At moderate levels, IHEs 

should test at least once a week. County level data are available on 

the CDC website.

IHEs where everyone is fully vaccinated do not need to 

implement screening testing. Consistent with CDC’s Interim 

Public Health Recommendations for Fully Vaccinated People, 

fully vaccinated people at IHEs with mixed populations of 

individuals who are fully vaccinated and individuals who are 

not fully vaccinated do not need to participate in entry or 

serial screening testing.

Schools without the capacity to implement universal serial 

testing can still reduce transmission by testing a random sample 

of students, faculty, and staff. Alternatively, IHEs can implement 

pooled testing, in which the test is conducted on the combination of 

samples from multiple individuals.

Symptom Screening: For all IHEs, regardless of vaccination status, one approach to identifying 

persons with the virus before they can transmit it is to encourage students, faculty, and staff to 

perform daily health screenings for infectious diseases, including COVID-19, and to stay home or 

seek medical care if any symptoms are identified. CDC’s COVID-19 self-checker tool can be used 

for self-symptom screening. It is important to recognize the limitations of symptom screening, 

such as underreporting of symptoms, as well as the fact that asymptomatic and pre-symptomatic 

individuals can carry and transmit SARS-CoV-2.

HEERF: With HEERF grant funding provided for institutional uses, IHEs can undertake 

the following activities related to symptom screening and testing (note that this list is not 

exhaustive):

 Implementing a symptom screening system;

 Implementing a diagnostic or screening testing strategy, such as setting up a testing 

site, purchasing tests, or hiring additional personnel to administer tests;

IHEs may also seek FEMA reimbursement for some activities related to COVID 

diagnostic testing.

18 NAATs are tests that identify the presence of the virus’ genetic material. These tests are more accurate than antigen tests, which detect viral proteins. They are also 

distinct from antibody tests, which detect the body’s response to past infections.
17 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

7. Contact Tracing in Combination with Isolation and Quarantine

Prompt collaboration between IHEs and health departments in the implementation of case investigation 

and contact tracing can effectively break the chain of transmission and prevent further spread of the 

virus in the IHE setting and the surrounding community. All COVID-19 case investigation and contact 

tracing should be done in coordination with state, local, tribal, and territorial public health authorities and 

in accordance with local requirements and guidance. IHEs should continue to support case investigation 

and contact tracing detailed in CDC’s Guidance for Case Investigation and Contact Tracing in IHEs. Fully 

vaccinated people with no COVID-like symptoms do not need to quarantine or be restricted from work 

following an exposure to someone with suspected or confirmed COVID-19.

IHEs should arrange transportation and testing for individuals who need to isolate or quarantine. 

IHEs should also provide housing for symptomatic students to isolate and for their close contacts to 

quarantine. IHEs should have a plan to ensure that isolated/quarantined students can participate in 

remote learning, or if their symptoms prevent such participation, that they can access academic support 

services such as tutoring and advising to assist in the transition to remote learning. IHEs should also 

develop a plan to meet these students’ other basic needs and provide access to mental health support.

IHEs should also ensure that faculty and staff have flexible work arrangements (if able to work) and sick 

leave (if unable to work).

HEERF: With HEERF grant funding provided for institutional uses, IHEs can undertake the 

following activities related to testing, contact tracing, isolation, and quarantine (note that this 

list is not exhaustive):

 Hiring personnel to support contact  Providing academic support and 

tracing efforts in collaboration with mental health services for students in 

local public health authorities; isolation or quarantine;

 Procuring additional space both on  Providing food delivery for students

or off campus to house students and who are in isolation or quarantine; and

funding other costs associated with  Providing sick leave to employees 

meeting the basic needs of students who need to isolate or quarantine.

in isolation and quarantine;  IHEs may also seek FEMA 

reimbursement for some activities 

related to COVID diagnostic testing.
18 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

SUPPORTING HIGHER EDUCATION IN NAVIGATING 

ONLINE LEARNING IN A PANDEMIC

OVERVIEW OF CHALLENGES FACING INSTRUCTORS AND STUDENTS

To best understand the challenges IHEs have faced in navigating the shift to online learning, it is 

important to consider the state of digital learning before the COVID-19 pandemic. Nearly half of 

faculty had not taught online and many saw online teaching as less effective for student 

outcomes compared to in-person learning.19

While the conditions have since improved, several surveys 

conducted during the spring 2020 semester indicated 

widespread dissatisfaction among students with the remote 

learning experience they received.20 A survey conducted 

10 months into the COVID-19 pandemic identifies various 

potential contributors to this dissatisfaction. Half of 

respondents said they had to make purchases (e.g., computer, 

microphone, desks) to be able to learn online, with 70% of 

those respondents noting that these purchases came at a 

“significant cost.” Nearly 60% of learners noted “having access 

to stable, high-speed internet access” as a challenge and 79% 

of respondents noted concerns about mental health.21 An 

Inside Higher Ed survey yields insight into one of the factors 

that may contribute to challenges in delivering an online 

course effectively—course design.22 In order to ensure a consistent and e

ngaging online learning experience from both the educator’s and learner’s perspective, 

IHEs should consider bringing on instructional designers and technologists to collaborate 

with faculty on the design and delivery of courses.

For skills-based courses that require more hands on instruction such as welding or automotive 

classes, institutions have had to adapt to offer immersive labs online or utilize physical distancing 

to allow students to attend in person safely.23 For example, a public community college in Wyoming 

Nearly 60% of learners 

noted “having access 

to stable, high-speed 

internet access” as 

 a challenge.

19 Lederman, D., (2019, Oct. 30). Professors’ Slow, Steady Acceptance of Online Learning: A Survey. Retrieved from: https://www.insidehighered.com/news/survey/professors-slow-steady-acceptance-online-learning-survey. 

20 McKenzie, L., (2020, May 27). Ramping Up for Remote Instruction. Retrieved from: www.insidehighered.com/news/2020/05/27/new-resources-help-support-faculty-quality-online-instruction. 21 Burke, L., (2021, Jan 22). Survey Outlines Student Concerns 10 Months into Pandemic. Retrieved from: www.insidehighered.com/news/2021/01/22/

survey-outlines-student-concerns-10-months-pandemic. 

22 Lederman, D, (2019, Oct. 30). Professors’ Slow, Steady Acceptance of Online Learning: A Survey. Retrieved from: www.insidehighered.com/news/survey/professors-slow-steady-acceptance-online-learning-survey. 

23 ACTE, (2021, March). Retrieved from: https://www.acteonline.org/wp- content/uploads/2021/04/HighQualityCTE_COVID_ChallengesAndInnovations_March2021_Final.pdf.
19 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

continued offering its welding lab in person. The welding lab already comprised individual bays 

that facilitate physical distancing. One of these bays is now equipped with a heat-resistant camera 

that shows the weld and another camera above the bay that shows the student’s positioning. These 

cameras are linked to a large screen for the instructor to see, assess, and correct both the weld 

and the student’s physical movements. The college also accelerated its planned transition to a dual 

delivery model in some programs, offering two versions of the same course, one entirely online and 

one entirely in person. This allows for physical distancing in the in-person course and, if learners 

needs to quarantine or receive an accommodation to learn remotely due to a disability, they can 

switch seamlessly to the online version. Similarly, if a student is struggling in the online course, a 

switch to in-person learning can be made.

Despite challenges in getting remote learning up and running for students and faculty at some IHEs, 

the necessity of the shift helped many students and faculty adapt to digital learning platforms. 

Surveys24 conducted in May and August 2020 by Tyton Partners and Every Learner Everywhere 

reveal changing perceptions of digital learning among both tenure and non-tenure track faculty.25, 

26 When polled in May of 2020, 39% of instructors agreed with the statement, “online learning is an 

effective method for teaching,” and 31% disagreed. When the question was asked again in August 

2020, 49% agreed and only 21% disagreed, showing a shift in perceptions.27

Despite the gains in perceived effectiveness of online learning, student engagement still presents 

a challenge. Overwhelmingly, a lack of engagement and interactivity has been identified as a 

particularly complex challenge in online and digital learning in higher education. In fact, when 

polled on planning for fall 2020, 71% of faculty listed “increasing student engagement” as their top 

priority.28

71% of faculty listed “increasing student 

engagement” as their top priority.

In addition to uneven perceptions of online learning, faculty also faced challenges related to device 

access. An early 2020 Educause survey of faculty found that although a majority of faculty had 

access to a personal device, a large percentage of faculty did not have access to an IHE-provided 

laptop (45%) or desktop (40%).29 Without access to uniform technology, it is difficult to deliver 

effective, consistent online learning. Additionally, professional development and training can make 

a significant difference. Many IHEs offered professional development and training to staff related 

to digital learning when the COVID-19 pandemic began. IHEs should continue to offer this training 

post-COVID-19 pandemic to ensure faculty are continually up to speed on new developments and to 

strengthen their practice.

24 May 2020 survey n=4,798, August 2020 survey n=3,569). 

25 Fox, K., Bryant, G., Lin, N., Srinivasan, N.,(2020, July 8). Time for Class – COVID-19 Edition Part 1: A National Survey of Faculty during COVID-19. Tyton Partners and Every 

Learner Everywhere. 

26 Fox, K., Bryant, G., Srinivasan, N., Lin, N., Nguyen, A., (2020, Oct,6). Time for Class – COVID-19 Edition Part 2: Planning for a Fall Like No Other. Tyton Partners. 

27 Lederman, D., (2020, Oct. 6). Faculty Confidence in Online Learning Grows. Retrieved from: https://www.insidehighered.com/digital-learning/article/2020/10/06/

covid-era-experience-strengthens-faculty- belief-value-online. 

28 Fox, K., Bryant, G., Srinivasan, N., Lin, N., Nguyen, A., (2020, Oct. 6). Time for Class – COVID-19 Edition Part 2: Planning for a Fall Like No Other. Tyton Partners. 

29 Brooks, D. Christopher, and Susan Grajek., (2020, March 12).Faculty Readiness to Begin Fully Remote Teaching. Retrieved from: er.educause.edu/blogs/2020/3/faculty-readiness-to-begin-fully-remote-teaching#fn1.
20 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

EQUITY GAPS IN ONLINE LEARNING

Similar to K-12 learners, students enrolled in higher education continue to face challenges related to 

balancing “coursework with home and family responsibilities, managing student mental health and 

wellness, ensuring reliable internet access, and managing financial stress in light of COVID-19.” These 

challenges disproportionately impact learners from underserved communities and are compounded 

for those who do not have access to technology or do not have the digital literacy and foundational 

literacy skills to effectively engage remotely in education.30 In addition, students with disabilities 

may have additional needs that would facilitate their participation in online learning. In addition to 

the complexities facing underserved communities, there is also evidence that the shift to online 

learning has been accompanied by significant shifts in the educational plans of American Indian 

or Alaska Native, Black, and Latino (or Hispanic) students. According to a nationally representative 

2020 Strada and Gallup poll of more than 10,000 respondents, Black and Latino (or Hispanic) 

Americans reported higher rates of canceling or changing educational plans due to COVID-19.31

Tribal colleges and universities experienced an average decrease in student enrollment of 19% 

during the COVID-19 pandemic.32 A March 2021 profile on the California State University system 

illustrated this persistent gap. S. Terri Gomez, Associate Provost for Student Success, Equity and 

Innovation at Cal Poly Pomona notes, “We are seeing a disparate impact on students of color...a 

widening of equity gaps.”33 The shift to online learning also presented unique challenges for 

students with disabilities, who reported experiencing difficulties when accessing online learning 

platforms and communicating with their instructors.34

It is imperative that IHEs create and implement equitydriven strategies to respond to COVID-19 and mitigate 

the disparate impacts of the move to online learning. 

Below are several potential steps IHEs can take, 

along with information and resources that may be 

helpful as IHEs explore how to close access gaps 

for their students and support the effective use 

of technology in online teaching and learning. 

For many of the recommendations below, HEERF 

funds can be used to implement the solution. For 

more information on uses of HEERF funds please 

see the FAQs found at this link.

30 Lederman, D.,(2020, Oct. 6).Faculty Confidence in Online Learning Grows. Retrieved from: www.insidehighered.com/digital-learning/article/2020/10/06/covid-era-experience-strengthens-faculty-belief-value-online. 

31 Strada Education Network, (2020, June 10). People of Color Are More Likely Than White Americans to Have Changed or Canceled Their Education Plans in Response to the 

Pandemic. Retrieved from: https://www.globenewswire.com/news-release/2020/06/10/2046409/0/en/People-of-Color-Are- More-Likely-Than-White-Americans-to-Have 

Changed-or-Canceled-Their-Education-Plans-in-Response-to-the- Pandemic.html. 

32 Redden, E.,(2021, March 16). Trying Times for Tribal Colleges. Retrieved from: https://www.insidehighered.com/news/2021/03/16/tribal-colleges-report-pandemic-related-challenges-around- mental-health-persistence. 

33 Fain, P.,(2020, June 17). The pandemic has worsened equity gaps in higher education and work. 

34 Moody, J., (2020, Aug. 18). Navigating Online College as a Disabled Student. Retrieved from: https://www.usnews.com/education/best-colleges/articles/how-to-navigate-online-college-classes-as-a-student-with-disabilities. 
21 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

1. Invest in professional development opportunities focused on digital 

 learning. 

Though many IHEs are working to safely bring students back to in-person learning, the need 

for high-quality online options is here to stay. Given this reality, it is essential that IHEs invest in 

professional learning opportunities tailored to the digital context. To prepare for Fall 2021, these 

opportunities should target areas of known challenge, like student engagement, that have emerged 

as an urgent priority in COVID-19. In addition to such targeted topics, IHEs should also consider 

investing in longer-term professional learning endeavors that look to holistically improve the 

digital learning experience. IHEs should consider who within their community is best equipped 

to support this professional learning, drawing on expertise from instructional designers, learning 

engineers, researchers, institutional data analysts, technologists, and students. IHE leadership 

should actively encourage these constituencies to collaborate with faculty and instructors to design 

experiences that center student engagement and leverage evidence-based practices on how 

students learn in remote, technology-driven contexts.

IHEs should also 

consider investing 

in longer-term 

professional learning 

endeavors that look to 

holistically improve 

the digital learning 

experience.

Resources to support these efforts:

Online Learning Consortium provides a playbook for 

transitioning classes online.

 Instructional Design Emergency Response Network

provides a hub for tapping the expertise of 

instructional designers. 

 Every Learner Everywhere Network

 Expert Network provides free 1:1 coaching for 

digital learning in higher education. 

 Pillar Resources provides a suite of digital 

learning resources.
22 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

2. Explore different models of delivery. 

There are various models for delivering high-quality online instruction. To determine which model(s) 

to employ and at what time, IHEs should regularly solicit—and then act on—students’ feedback 

about their learning experience. For example, at the University of Wisconsin, faculty engaged in a 

conversation around student needs when exploring synchronous and asynchronous models. Some 

professors “shied away from synchronous meetings because of accessibility issues,” being mindful 

that students had much less agency over their day-to-day schedule than in a typical year. Other 

professors questioned whether to mandate attendance at a certain time given inconsistencies 

in internet access for their students. The university also heard from students who were eager for 

synchronous options as a way to meaningfully engage with their professors and fellow students. 

The breadth of perspectives at the University of Wisconsin illustrate the importance of considering 

both what students need pedagogically and what the capacities of the institution are when making 

decisions about different models of online learning.35

While asynchronous models can open doors for students who may not be able to attend classes 

during scheduled times, these models should be paired with appropriate supports as they may pose 

challenges for learners who struggle with time management and who benefit from the structure of 

regular synchronous meetings. When resources permit, a hybrid-flexible (hyflex) model (a student is 

given the option of in-person, virtual, or in-person and virtual simultaneously) may offer support for 

diverse learning needs. 

Given this spectrum/range of needs, some examples of questions IHEs should ask 

themselves include:

Is it important for this class to meet in person?

Is it imperative that this class meet in person all the time?

Will this class be delivered in a way that is easy to use and accessible for all students, 

including those with disabilities?

What resources will be needed to properly administer this class and support the 

diverse needs of the community?36

Resources to support these efforts:

 Hybrid-Flexible Course Design is a comprehensive guide for design and 

implementation of hyflex courses.

 Northern Arizona University’s Nauflex is an implementation example of a hybrid 

instructional model at public research university.

 Asynchronous to Synchronous offers a transition example from a public research 

university in Georgia.

35 Lederman, D., (2020, May 20). The Student View of This Spring’s Shift to Remote Learning. Retrieved from: www.insidehighered.com/digital-learning/article/2020/05/20/

student-view-springs-shift-remote-learning. 

36 Flaherty, C,(2020, April 29).Synchronous Instruction Is Hot Right Now, but Is It Sustainable?. Retrieved from: www.insidehighered.com/news/2020/04/29/synchronous-instruction-hot-right-now-it-sustainable.
23 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

3. Leverage technology to promote student engagement. 

Though the move to online instruction has increased feelings of social isolation among students, 

technology can also be leveraged as a tool to foster positive engagement and community building. 

For example, consider how instructors might use technology-based tools to foster an active 

learning environment where students have 

an opportunity to collaborate, engage in 

inquiry-based learning, and produce dynamic 

content.37 In a digital space, instructors 

can experiment with different participation 

techniques that may offer opportunities for 

more students to contribute their perspectives 

and participate in different ways. When 

synchronous, this might involve the use of 

small group breakout sessions, in-class polls, 

and the chat feature. When asynchronous, this 

could include the use of short video responses, 

online blogs, and social media. By expanding 

how educators think about and provide 

opportunities for engagement, technology can 

be leveraged to promote inclusion for students 

with learning differences.38

Technology-based tools 

can be used to foster 

an active learning 

environment where 

students have an 

opportunity to collaborate, 

engage in inquiry-based 

learning, and produce 

dynamic content.

It is also important to note 

that institutions offering 

distance education are 

required under federal law 

and regulations to ensure 

regular and substantive 

interaction between 

students and 

their instructor.39

Resources to support these efforts:

 Conceptual Framework shows how to facilitate 

student engagement through educational 

technology.

 Community of Inquiry Framework provides 

effective online discussion practices.

 Education’s Next Normal offers five teaching 

adaptations to improve student engagement in 

higher education.

37 U.S. Department of Education, Office of Educational Technology, Reimagining the Role of Technology in Higher Education: A Supplement to the National Education Technology Plan, Washington, D.C., 2017. Page 28. 

38 Glantz, Ed, et al., (2021, March 16). “Improved Student Engagement in Higher Education’s Next Normal.” Improved Student Engagement in Higher Education’s Next Normal, 

Educause Review, 16 Mar. 2021, Retrieved from: https://er.educause.edu/articles/2021/3/improved-student-engagement-in-higher-educations-next- normal#fn12. 

39 New regulations on distance education become effective on July 1, 2021. https://nc-sara.org/news-events/us-department-education-issues-final-rules-distance-eduction-and-innovation.
24 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

4. Invest in digital learning records to promote student mobility. 

COVID-19 has disrupted the plans of students across IHEs. Many have had to physically relocate 

while others have chosen to postpone or suspend their educational plans. In response to the 

COVID-19 pandemic and the rapidly changing demands of the workforce, many students are 

increasingly seeking and utilizing tools that were available prior to the pandemic, such as industry 

certifications, stackable micro credentials, and online degrees.40 To effectively leverage technology, 

advance social mobility, and close equity gaps, IHEs should begin building an ecosystem to support 

digitally verifiable learning records, also called digital credentials, as part of their comprehensive 

COVID response strategy. Digital learning records are a secure and detailed record of verifiable 

achievements that can easily transfer from one learning experience to another. They include 

data on discrete achievements and can provide deeper insight on the 

specific skills that are represented by a degree or certification. 

This ecosystem should be designed around students, with 

the goal of empowering them with ownership over their 

learning records, including how and with whom they are 

shared. Records should be published in a format that 

facilitates interoperability and the translation of a 

student’s skills, competencies, and knowledge across 

different educational and workforce institutions.

IHEs can also seek to aid students who wish to 

reenroll and/or transfer by conducting outreach to 

students, inviting them back to the institution and 

ensuring official transcripts are readily available 

without holds on students’ accounts. HEERF dollars 

may be used to discharge institutional debts that may 

be holding students back from reenrolling or transferring 

to another college. The Department encourages 

institutions to discharge such debts.

HEERF dollars may be used 

to discharge institutional 

debts that may be holding 

students back from 

reenrolling or transferring 

to another college. The 

Department encourages 

institutions to discharge 

such debts.

Resources to support these efforts:

 Building the Digital Credential Infrastructure for 

the Future

 How Digital Credentials Advance Student Mobility

 How Digital Credentials Will Reshape Higher Ed

 Credential Transparency Description Language

 Open Skills Network

 Case Study: Georgia Institute of Technology

 Case Study: Elon University in North Carolina

40 Fain, P., (2020, Aug. 27). Interest Spikes in Short-Term, Online Credentials. Will It Be Sustained? Retrieved from: www.insidehighered.com/news/2020/08/27/interest-spikesshort-term-online-credentials-will-it-be-sustained.
25 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

BROADBAND AND DEVICE ACCESS FOR HIGHER 

EDUCATION STUDENTS, FACULTY, AND STAFF

OVERVIEW OF CHALLENGES AND NEEDS

COVID-19 magnified the digital divide41 for college students as campuses closed and classes moved 

online. Before the pandemic, many students reported they could rely on access to high-speed 

broadband42 on campus in libraries, classrooms, and residence halls.43 Similarly, students who could 

not afford devices (e.g., computers, printers) and software often had free access in campus computer 

labs and libraries.44 When campuses closed, students returned home to communities across the 

country with varying degrees of access to high-speed broadband infrastructure, and many faced new 

financial challenges that impacted their ability to afford broadband access and devices.

Limited access to high-speed broadband infrastructure is a challenge faced by students and faculty 

across the United States in urban, rural, and tribal communities. The Federal Communications 

Commission (FCC) estimates that at least 21 million45 Americans do not have high-speed internet 

access, but other estimates range from 42 million46 to 157.3 million.47 Approximately 3 million to 4 

million postsecondary students are impacted by the digital divide—or 15% of all students attending 

2-year community colleges or 4-year private and public colleges.48

The digital divide is more pronounced in rural communities and in Black, Latino (or Hispanic), and 

American Indian or Alaska Native households.49 A January 2021 report from the Midwestern Higher

Education Compact (MHEC) found that, “approximately 16%—19% of college students reported 

technology barriers (inadequate computer hardware or internet connection) that inhibited 

participation in online learning. Higher rates of inadequate computer hardware or internet 

connection were observed among: students from lower income households (20%—30%) than 

41 The digital divide is defined as the “gap between individuals, households, businesses and geographic areas at different socio-economic levels with regard to both their 

opportunities to access information and communication technologies (ICTs) and to their use of the internet for a wide variety of activities.” OECD (2006). Understanding the 

digital divide. Paris, France: Organisation for Economic Co-Operation and Development. Retrieved from: https://stats.oecd.org/glossary/detail.asp?ID=4719. 

42 FCC. (2020). 2020 Broadband Deployment Report. Retrieved from: https://docs.fcc.gov/public/attachments/FCC- 20-50A1.pdf. The FCC defines broadband as a minimum of 

25 Mbps download and 3 Mbps upload. 

43 Gierdowski, D. C. (2019). ECAR Study of undergraduate students and information technology, 2019. Louisville, CO: ECAR. 

44 Regalado, M. & Smale, M. A. (2014). Commuter students using technology. New York, NY: City University of New York. 

45 Federal Communications Commission, (2019). 2019 Broadband Deployment Report. Retrieved from: https://www.fcc.gov/reports-research/reports/broadband-progress-reports/2019-broadband-deployment-report. 46 Busby, J., & Tanberk, J.,(2020). BroadbandNow Research. Retrieved from: https://broadbandnow.com/research/fcc-underestimates-unserved-by-50-percent. 

47 McKinley, S.,(2020). Microsoft Airband: An annual update on connecting rural America. Retrieved from:

https://blogs.microsoft.com/on-the-issues/2020/03/05/update-connecting-rural-america/. 

48 Ali, T., Chandra, S., Cherukumilli, S., Fazlullah, A., Galicia, E., Hill, H., McAlpine, N., McBride, L., Vaduganathan, N., Weiss, D., Wu, M. (2021). Looking back, looking forward: What 

it will take to permanently close the K–12 digital divide. San Francisco, CA: Common Sense Media. Retrieved from: https://www.commonsensemedia.org/sites/default/files/uploads/pdfs/final_what_it_will_take_to_permanently_close_the_k-12_digital_divide_vfeb3.pdf. 

49 Ujifusa, A., (2020, July 22).1 in 3 American Indian, Black, and Latino Children Fall Into Digital Divide, Study Says. https://www.edweek.org/education/1-in-3-american-indian-black-and-latino-children-fall-into-digital-divide- study-says/2020/07.
26 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

higher-income students (10%—12%) and Black (17%—29%) and Hispanic (23%—28%) students 

relative to White students (12%—17%). For students living in a rural area, 14%—25% reported having 

inadequate computer hardware or internet connection compared to 16% of students living in a 

suburban and 16%—20% of students living in an urban area.”50

Students with disabilities have also encountered difficulties in accessing critical technology (e.g., 

Wi-Fi, laptops) for remote education, internet access, and increased difficulty in coordinating 

courses across different time zones.51 Even prior to the COVID-19 pandemic, only one in four adults 

with disabilities reported having high-speed internet at home compared with more than two in five 

(42%) adults without disabilities.52

An estimated forty percent of college students faced 

unexpected out-of-pocket expenses associated 

with the sudden shift to remote learning. Required 

purchases included laptops or computers (44%), 

headphones/microphones (27%), and printers (24%). 

Almost a quarter of surveyed students said that these 

purchases “came at a very significant cost, with over 

40% saying the cost was somewhat significant.”53

Internet Service Providers (ISPs) often choose not 

to build and maintain expensive fiber networks to 

geographically remote locations with low population 

densities due to the limited return on investment. 

In urban communities, there is evidence of ISPs 

investing in building fiber infrastructure in wealthier 

neighborhoods while under-investing in the broadband 

infrastructure in low-income communities. As a result, 

broadband users from low-income households often receive more expensive but slower access.54

Access to consistent broadband can also be a challenge for unhoused and highly mobile students 

and families who lack a permanent address.55

The MHEC study also found that college students with inadequate technology reported 

struggling more with the transition to remote learning than students with robust internet 

access and reliable devices.

These students had more difficulty meeting deadlines, felt less successful as college students, 

and were more likely to opt for a “Pass/No-Pass” grade in Spring 2020.56

An estimated 40% 

of college students 

faced unexpected 

out-of-pocket 

expenses associated 

with the sudden 

shift to remote 

learning.

50 Jaggars, S. S., Motz, B. A., Rivera, M. D., Heckler, A., Quick, J.D., Hance, E. A., & Karwischa, C., (2021, Jan.). The Digital Divide Among College Students: Lessons Learned From 

the COVID-19 Emergency Transition. https://www.mhec.org/sites/default/files/resources/2021The_Digital_Divide_among_College_Students_1.pdf.

51 Madaus, J., Gelbar, N., Faggella-Luby, M., & Dukes, L., (2021). Experiences of students with disabilities during the COVID-19 interruption of in-person instruction. Journal of 

Postsecondary Education and Disability, 34(1), 5-18.

52 Anderson, M. & Perrin, A.,(2017, April 17). Disabled Americans are Less Likely to Use Technology. https://www.pewresearch.org/fact-tank/2017/04/07/disabled-americans-are-less-likely-to-use-technology/. 53 Fishman, R., & Hiler, T.,(2020, Sep. 2). New Polling from New America & Third Way on COVID-19’s Impact on

Current and Future College Students. Retrieved from: https://www.thirdway.org/memo/new-polling-from-new- america-third-way-on-covid-19s-impact-on-current-and-futurecollege-students.

54 Falcon, E.,(2021). The FCC and States Must Ban Digital Redlining. Electronic Frontier Foundation. Retrieved from: https://www.eff.org/deeplinks/2021/01/fcc-and-states-mustban-digital-redlining.

55 Shapiro, E., & Newman, B. (2019, Nov. 19). 114,000 Students in N.Y.C. Are Homeless. These Two Let Us into Their Lives. The New York Times. Retrieved from: www.nytimes.

com/interactive/2019/11/19/nyregion/student- homelessness-nyc.html. 

56 Jaggars, S. S., Motz, B. A., Rivera, M. D., Heckler, A., Quick, J.D., Hance, E. A., & Karwischa, C. (2021). The Digital Divide Among College Students: Lessons Learned From the 

COVID-19 Emergency Transition. Midwestern Higher Education Compact. Retrieved from: https://www.mhec.org/sites/default/files/resources/2021The_Digital_Divide_among_

College_Students_1.pdf.
27 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

INCREASING STUDENT ACCESS TO BROADBAND AND DEVICES

When the COVID-19 pandemic hit, many IHEs supplied students with the devices and internet 

access necessary for continuity of learning. As campuses reopen for in-person learning, IHEs will 

need to stay focused on the impact that digital access has on student success and the importance 

of continually investing in broadband supports for students long-term, particularly for students who 

are unable to be vaccinated due to a disability. For many of the recommendations below, HEERF 

funds can be used to implement the solution. For more information on uses of HEERF funds please 

see the ARP- HEERF FAQs. IHEs can implement solutions for keeping students connected and 

supported, including the following:

1. Conduct ongoing needs assessments. 

 

This can include the use of student surveys to determine the extent to which students and faculty 

have access to high-speed internet and devices and the quality of that access. Consider using a 

variety of communication methods including phone calls, text messages, or mailings in addition 

to email or learning management system surveys to reach students and faculty. For example, it is 

important to know whether a student only has home access through a cellular data plan, which 

may be subject to data caps that increase cost and slow down service once the cap is reached. 

The DigitalBridgeK-12 Home Access Needs Assessment Playbook, which was originally written for 

K-12 schools, has scripts, templates, and toolkits that can be adapted for use by colleges and other 

adult education settings. In addition, IHEs can consider mapping de-identified student and faculty 

address data to understand whether students and faculty live in areas with limited internet access. 

For example, North Dakota correlated de-identified K-12 student address data and service provider 

data, which led to the detection and connection of 1,762 student homes that were previously 

unconnected.

2. Expand Wi-Fi and broadband access to students and faculty. 

Many college campuses have extended campus Wi-Fi access beyond classrooms or residence halls to 

public and outdoor spaces, including campus parking lots. IHEs may consider mapping their public 

Wi-Fi access locations on a local or state public Wi-Fi map like this map from the Public Service 

Commission of Wisconsin or the New Mexico Broadband Map. If a Wi-Fi map of 

the community or state does not exist, IHEs could consider using faculty or 

student geographic information system expertise to create one.

Other colleges are looking at opportunities to expand their 

networks off campus to provide access for students, faculty, 

and their surrounding communities. IHEs can also loan mobile 

hotspots to students and employees but should be aware of 

mobile hotspot limitations in areas with limited cellular service. 

Examples of college hotspot lending programs can be found at 

this university in Kansas and this college in New York.

Another example is from Northern Michigan University (NMU) 

which launched a self-deployed wireless network using 2.5 GHz 
28 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

wireless spectrum to connect their 9,000 students and 1,100 faculty off-campus. The initial build-out 

was soon expanded to connect K-12 schools and offer low-cost, high-speed, uncapped internet access 

to twenty communities in the Upper Peninsula of Michigan. In addition, NMU provides access to online 

career and professional development courses through its network.57Additionally, a new pilot program

in Pittsburgh combines the efforts of eight universities, research groups, non-profit organizations, and 

school districts to turn the University of Pittsburgh’s Cathedral of Learning into a “super node” or hub 

that transmits free Wi-Fi to households around the city. Finally, IHEs could consider allowing students 

enrolled at other IHEs to use their open computer labs if those sites are nearer than their home IHEs, 

especially as students have dispersed across the country and away from campus during the COVID-19 

pandemic. For example, eduroam provides network access to researchers, teachers, and students 

visiting an IHE other than their own. Home IHEs authenticate users with the same credentials they use 

to access the network on their home campus.

3. Support students with disabilities by collaborating with internal and 

external partners to ensure accessibility of online learning platforms for 

all courses. 

This can include checking/reviewing for built-in accommodations within 

the digital learning platforms and ensuring that faculty understand 

how to utilize the built-in captioning or accessibility features (e.g., to 

make slides accessible to persons with disabilities). It is important 

to note that some functionality touted by developers as “built-in 

accommodations” may actually cause difficulty for some students 

with disabilities. For example, websites that have built-in screen 

reader functionality can interfere with a student’s personal screen 

reader software. In instances where automated captioning is used, 

it should be reviewed and edited for accuracy to be fully accessible 

to individuals who require captioning. This effort is particularly 

important for students who may have required a note-taker in an 

in-person classroom; in an online environment in which lectures 

are recorded with captioning—possibly even with transcripts being 

automatically produced—and the ability to rewatch these lectures, some 

students may no longer require notetaking services as an accommodation. 

Additional accommodations, like access to assistive technology, may be 

necessary to provide students with disabilities equal educational benefits to students 

without disabilities.

Further, as the Department noted in the section concerning Civil Rights Requirements, IHEs 

have obligations under Section 504 of the Rehabilitation Act and Title II of the Americans with 

Disabilities Act to ensure that individuals with disabilities have equal access to their services, 

programs, and activities unless doing so imposes a fundamental alteration or undue burden.

This obligation applies to online learning platforms an IHE uses as part of its programs, services, 

and activities.

57 Erickson, Fritz J., (2019, Jan. 28).“Providing Broadband to Rural America: How Educators with EBS Can Make the Difference.” Retrieved from: https://www.benton.org/blog/

providing-broadband-rural-america-how-educators- ebs-can-make-difference.
29 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

4. Offer scholarships or funding to defray the cost of internet service for 

students who may have trouble affording access. 

For example, a private, non-profit university with a large online presence has made $1 million 

in Online Access Scholarships available to ensure that students have broadband internet and 

device access during their course of study. Scholarships cover the cost of installing and accessing 

internet and provide recipients with a refurbished laptop, complete with a webcam. A public 

research university in North Carolina reallocated existing funding designated for regular classroom 

technology upgrades in order to offer up to 2,500 students a $200 supplement to help with 

internet costs during the fall 2020 semester. IHEs can also consider adapting the sponsored service 

model being used by many K-12 school districts and states to purchase home internet connections 

for students. Sponsored service is when a procurement lead (e.g., an IHE) acts as a single-payer and 

handles the payment of internet bills to ensure connectivity remains continuous for students.

5. Develop free technology lending programs for students. 

For example, a large public research institution in Michigan recently piloted a new approach to 

technology lending by proactively inviting admitted students from lower-income households to 

borrow laptops for their entire college careers. Students have the option to buy or return the laptop 

upon graduation. IHEs should utilize other technology lending where possible, such as for Assistive 

Technology programs.

6. Aggregate a school system’s buying power to leverage cost savings on 

hardware, software, or service procurements. 

For example, the Foundation for California Community Colleges operates the CollegeBuys program, 

which aggregates the system’s buying power. During the COVID-19 pandemic, the program has 

helped streamline emergency procurements, mitigated price fluctuations, and ensured continued 

access to the global technology supply chain.

7. Leverage federal broadband funding to connect students and campuses. 

The temporary $3.2 billion FCC Emergency Broadband Benefit (EBB) Program provides eligible 

households, including Pell Grant recipients who have received an award in the current award 

year, a discount of up to $50 per month towards broadband service and up to $75 per month for 

households on tribal lands. Eligible households can also receive a one-time discount of up to $100 

to purchase a laptop, desktop computer, or tablet from participating providers if they contribute 

$10-$50 toward the purchase price. IHEs can help students navigate the registration and verification 

process. The Department recently launched a major outreach campaign to inform millions of Pell 

Grant recipients of their eligibility for this benefit.
30 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

In addition, the $1 billion Tribal Broadband Connectivity Program from the National 

Telecommunications and Information Administration (NTIA) will provide grants to tribal 

governments, including TCCUs, to be used for broadband deployment on tribal lands, as well as 

for telehealth, distance learning, broadband affordability, and digital inclusion. Finally, the $285 

million Connecting Minority Communities Pilot Program from NTIA will provide grants to HBCUs, 

TCCUs, and MSIs for the purchase of broadband access and eligible equipment or to hire and 

train information technology personnel. Finally, the Treasury Department’s $350 billion State and 

Local Fiscal Recovery Fund will provide emergency funding for state, local, territorial, and Tribal 

governments to respond to the pandemic and its economic impacts, including making necessary 

investments in broadband infrastructure.

8. Join state-level broadband conversations to advocate for college students’ 

access needs. 

IHEs can visit the NTIA State Broadband Leaders Network (SBLN) website to learn whether their 

state has a state broadband office, coalition, or task force and a state broadband plan. IHEs can also 

enter into partnerships with other IHEs in their state to provide reciprocity to students for access to 

Wi-Fi or devices.

9. Expand the array of communication tools and methods. 

Before the pandemic, some IHEs used online learning management systems that allowed for faculty 

and students to communicate online (e.g., discussion boards) even when they met in person for 

class. However, some offices within IHEs that traditionally engaged in face-to-face interaction, like 

disability services offices, had to find new ways to transition to completely online communication, 

while at the same time evaluating and updating their internal/external office procedures to ensure 

students, faculty, and staff received the services they needed. In the coming months and years, IHEs 

should continue to make investments in multiple methods of communication to ensure students 

with disabilities can effectively use online platforms, broadband, and devices intended to increase 

their access to technology.
31 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

BASIC NEEDS SUPPORT FOR STUDENTS

OVERVIEW OF CHALLENGES AND NEEDS

It is still unclear how the increased mental, emotional, and physical demands of navigating 

education during a health crisis will impact student enrollment, retention, and completion long-term. 

However, the earliest data from the National Student Clearinghouse indicate that, with the exception 

of proprietary schools, undergraduate enrollment has declined across all sectors, particularly 

impacting community colleges and other IHEs that typically enroll underserved students.58

In a survey of over 38,000 college students in 2- and 4-year IHEs, over half reported experiencing 

housing, financial, or food insecurity during the COVID-19 pandemic.59 These results highlight 

the immense challenges many students are facing in meeting their basic needs during this time. 

Moreover, evidence has shown that the COVID-19 pandemic has disproportionately impacted 

underserved communities and communities of color,60 meaning that these students are at especially 

increased risk of facing basic needs challenges. As the COVID-19 pandemic has continued, many 

students, particularly students of color and students from low-income backgrounds, have juggled 

their class schedules with employment and/or the pursuit of resources to help support their families.

Additionally, some students with disabilities have had unique challenges accessing their classes, 

using support tools, and finding the resources they need to stay engaged and on track toward a 

degree, while possibly also facing greater risk for serious illness from COVID-19 than their peers. In 

order to be responsive to the current challenges students are facing, IHEs should implement broadbased supports and flexibilities that allow students to be responsive to their needs both at home 

and in the classroom.

EMERGENCY AND FINANCIAL AID

COVID-19 has had a disproportionate impact on communities of color and underserved communities 

that goes beyond health outcomes from the virus. The economic effects of the COVID-19 pandemic 

have hit Black, Latinx (or Hispanic), and women (particularly women of color) workers much more 

58 Sedmak, T., (2020, Nov. 12). Fall 2020 Undergraduate Enrollment Down 4.4%; Graduate Enrollment Up 2.9%. Retrieved from:

https://www.studentclearinghouse.org/blog/fall-2020-undergraduate-enrollment-down-4-4-graduate-enrollment- up-2-9/.

59 AAC&U News, (July, 2020). More than Half of College Students Facing Housing or Food Insecurity during the Pandemic. Retrieved from: https://www.aacu.org/aacu-news/

newsletter/more-half-college-students-facing-housing-or-food-insecurity-during-pandemic.

60 CDC, (2021, April 19). Health Equity Considerations and Racial and Ethnic Minority Groups. Retrieved from: https://www.cdc.gov/coronavirus/2019-ncov/community/

health-equity/race-ethnicity.html.
32 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

profoundly than White men. In April 2020, the American Indian or Alaska Native unemployment rate 

rose to 26.3%, three times greater than it was the previous month.61 For example, in December 2020, 

while women lost 140,000 jobs, men gained 16,000.62 Even still as the economy begins to rebuild, 

Black and Latinx (or Hispanic) workers 20 years and over are experiencing jobless rates of 9.7% and 

8.5%, respectively, while White workers have seen unemployment fall to 5.6% as of the first quarter 

in 2021.63 According to the U.S. Bureau of Labor Statistics, younger workers aged 20–24 are seeing 

unemployment rates in 2021 that are still higher than what they were one year ago.64

This unequal loss of employment across race, sex, age, and socioeconomic status has exacerbated 

food and housing insecurity for college students. Nearly one-third of 1,000 surveyed students said 

they had experienced food insecurity since the beginning of the COVID-19 pandemic.65 Moreover, 

over half of the students surveyed used off-campus food pantries during the COVID-19 pandemic.66

A recent survey of graduate and undergraduate students at 10 public universities in the United 

States and Canada found “students from lowincome and working-class backgrounds are 

more likely to experience financial hardships 

such as reduction of income from other family 

members, unexpected increases in living 

expenses and technology, loss or cancellation 

of jobs, and loss of wages from off- or oncampus employment.”67

In order to serve students well, IHEs are 

encouraged to use as much of their HEERF 

funds as possible to meet the financial needs of their students, prioritizing students with exceptional 

need—regardless of whether they completed the FAFSA—including students who receive Pell 

Grants or are undergraduates with extraordinary financial circumstances. With the additional 

funding provided through the ARP, approximately $76 billion collectively has been dedicated to 

HEERF; approximately $30 billion of these funds are to be directed to students in the form of 

emergency grants to help them meet their needs. States also received Governor’s Emergency 

Education Relief (GEER) Funds, which may be allocated to IHEs. These funds can cover the costs 

of providing connectivity for students, student services that promote a student’s emotional and 

physical well-being, and student financial aid.

IHEs should continue to work diligently to provide support for students that meet their basic needs 

whether on or off campus. This includes support for housing, financial aid, healthcare, child care, 

transportation, and food that allow a student to stay enrolled and continue their path toward a 

degree. IHEs should make certain all students have access to the support they need regardless of 

immigration status, race, national origin, sex, disability, or religion. The Department recommends IHEs:

Over half of the students 

surveyed used off-campus 

food pantries during the 

COVID-19 pandemic.

61 Feir, D., & Golding, C.,(2020, Aug, 5). Native employment during COVID-19: Hit hard in April but starting to rebound? Retrieved from: https://www.minneapolisfed.org/article/2020/native-employment-during-covid-19-hit- hard-in-april-but-starting-to-rebound.

62 Kurtz, A., (2021, Jan. 8). The US Economy Lost 140,000 Jobs in December. All of Them Were Held by Women. Retrieved from:

https://www.cnn.com/2021/01/08/economy/women-job-losses-pandemic/index.html. 

63 Labor Force Statistics from the Current Population Survey, (2021, April 2). Retrieved from: HYPERLINK “https://www.bls.gov/web/empsit/cpsee_e16.htm”https://www.bls.

gov/web/empsit/cpsee_e16.htm 

64 Labor Force Statistics from the Current Population Survey, (2021, April 2). Retrieved from: https://www.bls.gov/web/empsit/cpsee_e16.htm.

65 Chegg, Hunger and COVID-19: Food Insecurity Amongst US College Students in 2020. Retrieved from: https://www.chegg.org/covid-19-food-insecurity-2020.

66 Ibid.

67 Soria, K. M, & Horgos, B., (2020). Social Class Differences in Students’ Experiences during the COVID-19 Pandemic. UC Berkeley: Center for Studies in Higher Education. 

Retrieved from: https://escholarship.org/uc/item/3hw2m00g.
33 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

1. Make emergency aid available to all students. 

With the recent release of the Department’s final rule on student eligibility, HEERF grant funding 

can be used to make emergency financial aid grants to all students, including citizens, permanent 

residents, refugees, asylum seekers, Deferred Action for Childhood Arrival (DACA) recipients, 

other DREAMers, and similar undocumented students.68 IHEs should provide aid to students with 

exceptional need first.69 Students studying abroad who apply for emergency grant aid through their 

IHE are eligible and should receive the aid, as long as they meet the exceptional need prioritization 

criteria and funds are available.

2. Ensure emergency aid applications are streamlined. 

One in five IHEs surveyed required students to complete the Free Application for Federal Student 

Aid (FAFSA) for access to emergency aid (provided by both HEERF and non-HEERF funds).70

This can unfairly exclude many students who do not fill out the FAFSA, such as students who are 

ineligible for federal financial aid or students unable to resolve issues flagged through FAFSA 

verification. Whether completed or lacking, FAFSA may not be an accurate representation of a 

student’s current financial situation. IHEs may use the FAFSA but not require it and, to the extent 

practicable, should allow students to apply for emergency aid grants as needed (prioritizing 

exceptional need the IHE has established for distributing HEERF emergency financial aid grants) 

regardless of FAFSA completion or other state aid documentation. It is also imperative that IHEs 

continue to utilize the professional judgment process implemented by financial aid administrators to 

account for changes in a student’s financial circumstances.

3. Provide leniency. Provide leniency with bill due dates, waive late fees, and 

extend offer flexibilities for students facing financial difficulties. 

Additionally, as outlined in the most recent HEERF guidance,71 IHEs can discharge institutional 

debts that were accrued during the COVID-19 pandemic so students can re-enroll or obtain their 

transcripts to continue their education at a different IHE. Providing this level of leniency will help 

promote student re-engagement and help support retention efforts, including after the COVID-19 

pandemic. A public four-year university changed its normal billing procedures to delay the 

assessment of holds and late fees for non-payment and increased the threshold for balances that 

would result in a hold.

4. Provide a wide range of services. 

Consider expanding resources or making more visible what campus legal services and other 

departments can do for students, especially for COVID-19 pandemic-related services like estate 

assistance or consumer protections. A community college established a new office that coordinates 

68 See ARP HEERF III FAQs 8-12 for more information.

69 As described in ARP HEERF III FAQs, CRRSAA and ARP require IHEs to prioritize students with exceptional needs when distributing emergency financial aid from HEERF 

grant funding.

70 The Hope Center for College, Community, and Justice, #RealCollege During the Pandemic: Initial Institutional Responses To Address Basic Needs Insecurity. Retrieved from:

https://hope4college.com/realcollege-during-the-pandemic-institutional-responses/.

71 See FAQ #25 at this link: https://www2.ed.gov/about/offices/list/ope/arpfaq.pdf.
34 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

basic needs from multiple areas of discipline for their students. They offer a drive-through food 

pantry, referrals to low-cost housing, transportation vouchers, financial literacy, legal assistance, 

help finding work, child care, and academic support, in addition to emergency grants and assistance 

with applying for means-tested benefits.

5. Give flexibility to students in providing reasonable documentation of 

disability. 

IHEs may require reasonable documentation of disability, but given the increased difficulty in 

accessing healthcare providers for in-person assessment and testing, the Department encourages 

IHEs to demonstrate flexibility in the type of documentation required and how students may supply it.

FOOD AND HOUSING INSECURITY ON- AND OFF-CAMPUS

In a larger survey of 38,000 college students attending 54 different IHEs across 26 states, more 

than half reported experiencing food insecurity, housing insecurity, or homelessness during this 

time.72 Two separate surveys of more than 3,000 college students each showed that food and 

housing insecurity disproportionately impacts first-generation students and students of color, 

particularly Black students.73 This gap in housing and food access can exacerbate inequities 

and can result in widespread educational consequences. For many students, their college or 

university campuses may be the most visible and reachable place to obtain resources that help 

address their food and housing insecurities as 

well as other basic needs.

Faculty and staff at IHEs may also struggle with 

food or housing insecurity. IHEs should ensure onand off-campus resources available to students 

are also available to faculty and staff. Further, it 

is important to note that staff at many IHEs are 

employed by contractors, not the IHE itself. These 

recommendations apply to employees of the IHE 

and its contractors. HEERF funds can be used to 

support contractor and IHE employees.

To support students, faculty, and staff through 

this financially difficult time, the Department strongly encourages IHEs to:

The gap in housing 

and food access can 

exacerbate inequities 

and can result in 

widespread educational 

consequences.

1. Provide clear information. 

IHEs should make full use of additional Supplemental Nutrition Assistance Program (SNAP) 

authority to increase SNAP benefits provided under the ARP74 and ensure students are aware of this 

change. Additionally, IHEs should provide students with clear and concise information on federal 

72 AAC&U News, (July, 2020). More than Half of College Students Facing Housing or Food Insecurity during the Pandemic. Retrieved from: https://www.aacu.org/aacu-news/

newsletter/more-half-college-students-facing- housing-or-food-insecurity-during-pandemic.

73 AAC&U News, (Jan-Feb 2019). Facts & Figures – Food and Housing Insecurities Disproportionately Hurt Black, First-Generation, and Community College Students. Retrieved 

from: https://www.aacu.org/aacu-news/newsletter/facts-figures/jan-feb2017. 

74 USDA, (2021, March 22). USDA Increases SNAP Benefits Up To $100 Per Household with Funding from American Rescue Plan. Retrieved from:

https://www.usda.gov/media/press-releases/2021/03/22/usda-increases-snap-benefits-100-household-funding- american-rescue. 
35 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

support programs they may qualify for, such as SNAP, Temporary Assistance for Needy Families 

(TANF), Medicare, Housing Choice Vouchers, availability of Child Care Access Means Parents in 

School Program (CCAMPIS) if the campus participates, and the Special Supplemental Nutrition 

Program for Woman, Infants, and Children (WIC). For instance, a university in Vermont collaborated 

with its local SNAP program to communicate to students the eligibility criteria for these services. 

In the absence of direct food support programs, this is a critical way IHEs should connect students 

with programs that can help address their food needs.

2. Establish food pantries. 

In addition to providing students with information on federal, state, and local resources, IHEs may 

open food pantries to their students, faculty, and staff. If resources permit, these pantries should 

have access to refrigeration or a freezer to ensure that students who use this resource can receive 

fresh foods, not just non-perishable food items. Expanding food pantry availability to all on-campus 

workers can help ensure all individuals who contribute to a campus community have access to 

resources if they are experiencing food insecurity. In a survey of 550 instructional staff members 

from four community colleges and one university, 38% of instructional staff experienced basic needs 

insecurity in 2019.75 These pantries should be easily accessible to those in need.

38% of instructional 

staff experienced 

basic needs 

insecurity in 2019.

3. Go beyond food. 

If IHEs open food pantries on or off campus, they 

should work to include other staple items when 

possible (e.g., diapers, clothes, masks, feminine hygiene 

products, soap, and toilet paper). These items can 

be sourced through donations from philanthropic 

organizations, students, faculty, staff, or the surrounding 

community. These pantries should be as accessible as 

possible and follow the appropriate COVID safety measures outlined by the CDC, such as masking 

and social distancing. Additionally, IHEs should consider opening these pantries during early or late 

hours to accommodate those who have to work or provide child and/or elder care. IHEs can also go 

beyond the campus and partner with community centers, religious centers or institutions, or other 

organizations to provide a pantry to students and the surrounding community. Above all else, it is 

critical that these pantries and services be provided to individuals with no questions asked and no 

pre-requisite requirements.

For example, a non-profit university in Virginia established The Pantry. The Pantry has a primary 

location on campus that provides food, hygiene products, and limited fresh produce to students 

with no questions asked. The university also established a student-driven partnership with a local 

church to offer an off-campus food pantry for the community. A university in Vermont has a student 

food pantry, and various groups on campus create “grab and go bags” with items like granola bars, 

single-serve macaroni and cheese, soup, rice cups, apple sauce, pudding, and other snacks in a 

gallon-sized plastic bag.

75 The Hope Center for College, Community, and Justice, Basic Needs Insecurity in the Higher Education Instructional Workforce. Retrieved from: https://hope4college.com/

basic-needs-insecurity-in-the-higher-education- instructional-workforce/.
36 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

4. Make pantries and other resources accessible. 

Ensure any resource pantries and assistance programs are accessible to students with disabilities. 

Provide information about resources in alternative formats that can be accessed to ensure effective 

communication with those who are blind or who have visual impairments or who are deaf or hard of 

hearing. Additionally, be sure to translate as much information as possible into multiple languages to 

ensure access to those who have limited English proficiency. IHEs should also ensure food pantries 

have items that are safe for individuals with special dietary needs, such as food allergies. Lastly, for 

physical pantry sites, consider creating stigma-free, welcoming environments that allow students 

to access what they need discreetly, if preferred, and without risk of drawing unwanted attention to 

their circumstances or hardship.

5. Provide food for those in isolation or quarantine. 

It is imperative that IHEs ensure students and staff who are quarantining have access to food, 

medication, and other products they may need. Even if students or staff are quarantining off 

campus, IHEs should engage in outreach to ensure food and other basic needs are met, possibly 

with the aid of delivery services. This will help students and staff abide by COVID protocols and 

limit community spread.

SUPPORTING STUDENTS EXPERIENCING HOUSING INSECURITY

As noted above, food and housing insecurity are a large concern for students and families both 

pre- and post-COVID-19 pandemic. Before this crisis even began, one survey showed that as many 

as 46% of student respondents were housing insecure in 2019.76 These resource insecurities are 

even more severe for students of color and students from low-income backgrounds.77 In addition to 

assistance for food- insecurity, IHEs should also work to provide housing information and supports 

to those students experiencing homelessness or housing insecurity. To support students, IHEs can:

1. Refund room and board costs. 

For students who move home during the COVID-19 

pandemic or are sent home, IHEs should establish a 

refund program for pre-paid housing and dining costs 

so students can use those funds for other learning or 

living expenses at home. For example, a 4-year public 

IHE in Virginia issued housing and meal plan refunds 

for students who moved home or were sent home due 

to COVID. The IHE’s refunded dollars helped provide 

students with funding to provide for living expenses at 

home. IHEs can use HEERF institutional funds to defray 

costs associated with providing housing and dining 

refunds to students as a result of COVID-19.

Before this crisis 

even began, one 

survey showed that 

as many as 46% of 

student respondents 

were housing 

insecure in 2019.

76 Goldrick-Rab, S., (2020, March 16).Beyond the Food Pantry: Supporting #RealCollege Students During COVID-19. Retrieved from: https://hope4college.com/wp-content/uploads/2020/03/BTFP_SupportingStudentsDuringCOVID19_v2_Final.pdf. 

77 Anderson, G., (2020, Sep. 16). More Pandemic Consequences for Underrepresented Students. Retrieved from: https://www.insidehighered.com/news/2020/09/16/low-income-and-students-color-greatest-need-pandemic-relief.
37 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

 

2. Prioritize students with the greatest need. 

 

If IHEs are opening residence halls at limited or reduced 

capacity, they should prioritize students who are housinginsecure, students from lower-income households, students 

with disabilities, and/or international students who have 

limited housing options in the United States.

3. Partner with the community. 

If IHEs do not have on-campus housing, do not have the 

resources to provide direct housing assistance, or are primarily 

commuter schools, consider opening or partnering with community 

centers to provide housing options for students in need.

4. Provide transportation support. 

For IHEs partnering with hotels or other private companies for housing, or as an added benefit 

to students living on- or off-campus, ensure students have access to free transportation to get to 

classes and work. This can include vouchers for public transportation, a college shuttle service, or a 

ride share reimbursement program.78 Additionally, if providing transportation benefits or resources, 

make sure to include options that are accessible to students with disabilities.

5. Provide resources for those in unsafe environments. 

Some students may not have safe home environments and may have concerns about quarantining 

or living in a home where they are unsafe. IHEs should consider strategies to provide these students 

with an easy and confidential way to access resources such as mental health and counseling 

support and information on their options. For example, help is available 24/7/365 from the National 

Domestic Violence Hotline at thehotline.org or by calling 1-800-799-7233.

6. Provide clear information. 

If an IHE is unable to provide housing support on campus or find other housing alternatives for 

students, it is imperative the IHE provide students with resources that clearly outline any offcampus state, federal, or local supports. To the extent possible, IHEs should work with students 

to find options that meet their needs. For example, North Carolina provides resources for liaisons 

working with students experiencing homelessness.

78 KFDA, (2019, Aug. 15).Free transportation for Amarillo College students and faculty officially begins. Retrieved from: https://www.newschannel10.com/2019/08/15/city-transit-officially-allows-amarillo-college-students- faculty-use-public-transportation-free-charge/.
38 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

7. Expand access to supports. 

IHEs could consider expanding food and/or housing supports to on- campus workers and other 

support staff who are at increased risk of exposure as they work to keep campuses open. This 

should include staff in critical roles such as food service and maintenance who are more likely to be 

contract workers employed by management companies.

HEALTH CENTERS AND PARTNERING WITH THE COMMUNITY

COVID-19 has laid bare many of the fundamental issues facing students while trying to meet their 

basic daily needs. One critical component of meeting students’ basic needs, particularly during a 

health crisis, is ensuring students have access to health care and information. While some students 

remain on their parent’s health insurance plans throughout their time in college, many students do 

not have access to this benefit because they are independent or uninsured. As such, it is critical 

for colleges and universities to provide students with access to free and/or affordable health care 

options, including:

1. Access to free and affordable health services. 

If an IHE has an on-site health clinic, they should treat all COVID-19 cases free of charge along with 

any COVID-19 related health issues. In addition, IHEs should provide students with free healthcare 

services if needed—particularly sexually transmitted infection testing, flu shots, recommended 

vaccines, and general preventative health screenings. To the extent possible, IHEs should provide 

these services via a tele-health platform and in person for those who may not have access to reliable 

internet services. As referenced in the earlier “Safe Practices for In-Person Learning” section, as IHEs 

re-open, they should provide free and safe testing and care services for individuals experiencing 

symptoms of COVID-19. If students or faculty and staff must have a negative test to be on campus 

and/or if individuals on campus are experiencing COVID-19 symptoms, they should be provided with 

clear information on where they can access testing for free and how to mitigate exposure to others.

These types of services, that are the result of the national emergency, can be supported with HEERF 

institutional grant funding. Additionally, IHEs should give students information on any federal, state, 

or local resources that can help provide them insurance or assistance for health care costs and 

expenses, such as Medicaid or financial assistance available through federal and state health care 

marketplaces. ARP expanded financial assistance is available, and the U.S. Department of Health 

and Human Services (HHS) estimates that 9 out of 10 people who enroll are eligible for savings. 

Additionally, HHS has extended a Special Enrollment Period through August 15, 2021, for new 

enrollees in states that use the federally facilitated marketplace (healthcare.gov).79 For students not 

eligible for Medicaid or federal and state health care, IHEs can provide them with information about 

community health centers where they can access care.

79 Eligibility To Receive Emergency Financial Aid Grants to Students Under the Higher Education Emergency Relief Programs, (2021, May 14). Retrieved from: https://marketplace.cms.gov/outreach-and-education/need-2021-health-coverage.pdf.
39 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

2. Utilize Medicaid as a potential resource for students. 

This can be a crucial support for students in need of health care. It is imperative that IHEs provide 

tools to let students know that, if they are eligible for Medicaid, they can get coverage for 

screenings and treatment. If the on-campus health center does not accept Medicaid, IHEs can offer 

students information on a community provider that does. Additionally, if students require access 

to medications, IHEs should provide information for how students can access or acquire necessary 

prescriptions, especially for those students who are uninsured.

3. Well-being supports. 

IHEs should widely disseminate information, in the languages most commonly spoken by students, 

about wellness resources to aid in the mental and physical well- being of all students. This includes 

information on free mental health support, meditation guides or services, or anxiety and depression 

awareness toolkits, many of which are available upon request in alternate formats—such as Braille or 

large print—for persons with disabilities. For more information on how IHEs can specifically support 

students’ mental health needs, please see the mental health section of this guidebook.

ADDITIONAL RESOURCES:

Below are guides, resources, and tools put together by IHEs, organizations, and students to help 

IHEs think through programs to implement on campus.

 The Hope Center put together a guide for colleges and universities to support students 

during COVID-19. The guide has information on health care, food, emergency aid, housing, 

and instructional considerations. The Supporting Students Guide is available online.80

 The Hope Center, in partnership with SchoolHouse 

Connection and Juvenile Law Center, also published 

a guide that is specific to supporting students with 

experience in foster care andstudents experiencing 

homelessness.81

 The Hope Center also recommends that IHEs 

centralize information on basic needs support on a 

“basic needs webpage,” a link to which should be 

featured prominently on the school’s home page, 

on their Learning Management System, and on 

syllabi.

80 Goldrick-Rab, S., (2020, March 16). Beyond the Food Pantry: Supporting #RealCollege Students During COVID-19. Retrieved from: https://hope4college.com/wp-content/

uploads/2020/03/BTFP_SupportingStudentsDuringCOVID19_v2_Final.pdf.

81 Duffield, B.,Meyers, M.,Pokempner,J., & Sitjar, J., (2020, March 17). Beyond the Food Pantry: COVID-19 Response for Students Who are Homeless or With Experience in Foster 

Care. Retrieved from: https://hope4college.com/wp-content/uploads/2020/03/BTFP_COVID19_FosterCare_Homeless_Students_FINAL.pdf.
40 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

STUDENT CAREGIVERS

OVERVIEW OF CHALLENGES AND NEEDS

According to the 2015–2016 National Postsecondary Student Aid Study (NPSAS:16), more than one 

in five students across higher education are student parents (22%). A recent GAO report shows 

that this proportion of student parents has remained constant, but some estimates suggest that 

there could be nearly one in three student parents across higher education. Exacerbating the 

challenges faced by student parents is the reality that they are more likely to face high levels of 

economic insecurity. In NPSAS:16, 68% of all student parents had incomes below or near the federal 

poverty line. The rates are even higher for student parents of color: Black (79%), American Indian 

or Alaska Native (78%), and Latinx (or Hispanic) (73%) student parents are disproportionately from 

households with incomes below the federal 

poverty line.

Since long before the COVID-19 pandemic 

hit, student caregivers faced additional 

barriers to accessing and completing 

higher education. Researchers at The City 

University of New York and the University 

of Texas El Paso conducted a study that 

showed that student parents have less than 

half the amount of time (10 hours versus 

21 hours) as childless students to dedicate 

toward school work, sleeping, and leisure 

due to their additional responsibilities and 

higher likelihood of working while parenting and attending school.

Health implications were an added factor for student caregivers prior to the COVID-19 pandemic. In 

a fall 2019 survey administered by the Hope Center, 30% of parenting students reported they were 

experiencing moderately severe to severe levels of depression, and 27% were experiencing anxiety, 

with 13% experiencing severe anxiety.

Amid the COVID-19 pandemic, student caregivers have seen their ability to access and continue their 

education significantly impacted. As parents across the country have seen primary and secondary 

schools shift to online learning, student parents have taken on additional responsibilities to support 

their children’s continuing education, while often needing to transition their own learning environment. 

Amid the COVID-19 

pandemic, student 

caregivers have seen 

their ability to access and 

continue their education 

significantly impacted.
41 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

A survey conducted by the Lumina Foundation and Gallup between September 22 and October 5, 

2020, found that college students who provide care to children or adults (44%) were more likely than 

their non-caregiving peers (31%) to have considered stopping their education over the past 6 months.

Researchers reported that the relationship between caregiving and the consideration to pull out of 

courses existed “even after controlling for race, program level, age, gender, marital status, household 

income, and the amount of money taken out in loans.”

After communicating with numerous IHEs about the COVID-19 pandemic’s impact on student 

caregivers, the Department identified some of the most frequent and significant challenges IHEs 

have faced while attempting to support student caregivers. These categories are not exhaustive 

of all the issues faced by caregivers in higher education. In addition to the categories listed below, 

issues such as mental health, finances, and broader child care availability were raised repeatedly as 

issues faced by students, faculty, and staff.

STUDENT PARENTS HAVE STRUGGLED AMID THE LOSS OF CHILD CARE 

AVAILABILITY

Due to the closure of primary and secondary schools and networks of child care centers, which 

had to temporarily close or limit capacity, student parents often had to seek out alternative child 

care options.

One official at a community college that is a current grantee of the Department’s Child Care Access 

Means Parents in School (CCAMPIS) program noted, “Because of the pandemic, many students left 

school during spring 2020 or did not persist into summer or fall terms, particularly our Pell-eligible 

populations. Enrollment overall is down, and this has impacted our child care centers as there are 

fewer students attending class on campus.” As students stayed home, they kept their children home 

with them. As a result, centers in that state receiving grant funding were closed from April through 

December. Even when the center reopened in January, it was at reduced capacity and faced lower 

enrollment and revenue coupled with higher salary and cleaning costs.

To address this challenge, numerous IHEs partnered with National Association for the Education 

of Young Children (NAEYC)-accredited centers to make offsite child care options available for 

student parents. At one community college, the child care center opened its doors in September 

2020, despite the campus being open in person in a minimal capacity to provide a child care option 

for student parents and staff parents. The child care center also provided technology workshops, 

tutorials for curating a diverse home children’s library, and career advancement workshops to 

support student parents preparing for remote work.

DELIVERY OF VIRTUAL CHILD CARE SERVICES

When child care facilities were unable to remain open, many centers shifted to delivering virtual 

child care services. While helpful, virtual child care does not always meet the full scope of care 

student parents traditionally receive with in-person services.

 Numerous IHEs have expanded to providing virtual services by hosting Zoom meetings to 

supplement support services previously offered on campus. IHEs also reported sending 

out newsletters providing updates, resources, and activity ideas to their student parent 

communities. Others incorporated texting campaigns or using social media to provide 
42 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

additional supports—including Facebook groups and Pinterest boards—to give parents 

developmentally appropriate play-based activities to keep children busy and learning at home.

 An official at a public 4-year university explained, “When the center was closed, they 

provided regularly scheduled Zoom meetings for families; teachers continued to complete 

lesson plans and send activities home for families to do together; teachers created private 

YouTube channels to post videos of themselves reading or doing an activity that parents 

could access as available; and weekly newsletters were sent with photos and ideas from 

teachers and families that participated.”

 In circumstances where facilities remained closed, the technological gap affected both 

student parents and their children. IHEs reported that families did not always have the 

technological equipment to receive the needed support. Some schools reported providing 

devices and internet access so families could benefit from support services.

 The health and safety needs of staff need to be considered when child care facilities are 

open. IHEs reported the need to bring on additional staff to support children in child care 

centers. While student parents were unable to enter facilities, centers needed to provide 

additional support for pick up and drop off. To minimize risk of exposure, some centers 

reported needing to hire more part-time support staff to allow workers time to quarantine if 

needed. Further, some facilities reported limited PPE and concerns regarding risk to workers 

with pre-existing conditions.

RECOMMENDATIONS TO SUPPORT STUDENT CAREGIVERS

The Administration has made numerous investments to support students and families with 

children through both the American Rescue Plan (ARP) and the American Families Plan (AFP), 

including state and local funding for child care, tax credits and subsidies for parents, and significant 

investments across IHEs. As IHEs consider the recommendations below, they should keep in mind 

the availability of new resources to support student parents and child care providers.

1. Provide increased support to student parents through innovative child care 

supports and additional emergency grant aid to student parents. 

Several IHEs reported that student parents affected by job loss were less likely to have access 

to child care. Under these circumstances, IHEs worked to find resources to mitigate the cost of 

child care on campus for these students. For example, a public 4-year institution’s student parent 

programs re-allocated more than $60,000 of their existing university funding to address student 

parenting needs. According to one IHE: “Re-allocated funds were used to start an emergency 

grant program for student parents; to offer expanded child care options; and to offer more robust 

subsidies to families who were able to retain licensed care but required additional support to 

maintain that care. Throughout the academic year, the university allocated additional funding 

for child care subsidies in support of student parents. Additionally, other departments across 

the university received or allocated additional funding to expand their child care subsidy and 

emergency funding programs to support student parents from lower-income backgrounds. Funding 

was also expanded to support the university’s emergency supply closets to provide basic toiletries 

to students, including diapers and wipes for student parents.” As IHEs look to expand child care 

support, they should prioritize student parent needs at on-campus child care centers. 

Additionally, IHEs can use HEERF emergency grants for child care.
43 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

2. Extend services year-round and increase child care worker wages. 

Some IHEs reported extending child care support year-round. For example, one community college 

worked to provide additional access to those with additional need for child care services among 

its student population. The institution’s child development center extended services to be available 

during the fall, spring, and summer semesters for students. This has increased capacity for child 

attendance on an annual basis from 80 to 120 students. As child care workers remain in high 

demand, institutions should pay workers higher wages in order to recruit and retain child care staff. 

Research shows that higher wages for child care workers correlate with higher quality care for kids, 

allowing student parents to maintain peace of mind and the ability to focus on their education.82

3. Connect students with community resources. 

For example, one community college facilitated parents’ access to child care by identifying child 

care providers in the state directory that had availability. The college connected students to 

financial support for child care, including access to the Coronavirus Aid, Relief, and Economic 

Security (CARES) Act-HEERF I through microgrants, Child Care Access Means Parents in Schools 

(CCAMPIS), financial aid, and scholarships. In addition, the community college connected parents 

to self-care resources to cope with the COVID-19 pandemic. The institution also offered a safe oncampus child care setting to address some of the child care needs in the community.

4. Implement an emergency child-care program. 

One public 4-year university made its center for child care development an approved site for Child 

Care Crisis Assistance in Isolation Response Plan in order to provide temporary child care for 

emergency responders and other essential workers.

5. Extending access to the surrounding community. 

Broadening eligibility for services typically provided for campus 

students, faculty, and staff may be a way to build partnerships 

with the community while addressing pressing needs. Since 

residential campuses may have reduced occupancy as a 

result of remote learning, some on-campus services like child 

care may have excess capacity that could be useful to the 

surrounding community.

82 Kashen, Julie; Potter, Halley; Stettner, Andrew; (2016, June 13), Quality Jobs, Quality Child Care. Retrieved from: https://tcf.org/content/report/quality-jobs-quality-child-care/.
44 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

MENTAL HEALTH NEEDS OF STUDENTS AND STAFF

OVERVIEW OF CHALLENGES AND NEEDS

In August of last year, CDC released a report about the COVID-19 pandemic’s effect on mental 

health, showing over 40% of respondents reported at least one adverse mental or behavioral 

health condition, including symptoms of anxiety disorder or depressive disorder, symptoms of 

a trauma- and stressor- related disorder (TSRD) related to the COVID-19 pandemic, and having 

started or increased substance use to cope with stress or emotions. Further, this report showed 

that more than 1 in 10 respondents “seriously considered suicide in the 30 days before completing 

the survey,” but that rate was disproportionately higher for respondents of color and more than 1 in 

4 for respondents between the ages of 18–24. The Student Experience in the Research University 

Consortium separately found that students during the COVID-19 pandemic are being identified as 

having depression and anxiety at higher rates than in past years, but accessing mental health care 

during the COVID-19 pandemic has been more difficult than before for students, according to a 

survey by the ACHA and the Healthy Minds Network.

More than 1 in 4 survey respondents aged 18–24 

“seriously considered suicide in the 30 days before 

completing the survey.”

It is still unclear how the increasing mental and physical demands of navigating education during 

a health crisis and amid economic uncertainty will impact student retention and completion longterm. However, the earliest indications from IHEs show that students and staff are both struggling 

at higher rates across a number of categories related to mental health, economic security, and 

other factors that could impact long-term success. IHEs, college representatives, and mental health 

experts have reported to the Department that the COVID-19 pandemic and its contributing factors 

have led to increased levels of isolation, financial stress, academic stress, anxiety, depression, 

suicidal ideation, and alcohol and drug abuse across student and staff populations.

In addition to increased levels of distress, some schools are seeing declines in counseling center 

visits overall despite increased cases of crisis. One school official noted, “With only about half of our 

students coming to in-person classes, and with our work now remote, fewer students are getting 
45 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

connected to the Counseling Center, despite increased distress and crisis. We have seen 28% fewer 

students this year compared to last year at this time, while the number of hospitalizations for 

mental health crisis more than doubled! We are struggling to help students connect with us.”

Specific student populations, including students with disabilities, have also faced increasing mental 

health challenges. In a survey by the Association on Higher Education and Disability (AHEAD), 

faculty and staff reported that students with disabilities were struggling to access resources and 

services needed to thrive during the COVID-19 pandemic. Four-year IHEs reported that students 

with disabilities faced barriers to accessing and receiving counseling and mental health services. 

Staff members at 2-year IHEs reported that students with disabilities struggled with accessing 

technology equipment, technical support, and the learning management system.

Research indicates that students with disabilities have reported additional personal challenges 

during the COVID-19 pandemic, such as financial, food, and housing insecurity, as well as high levels 

of social isolation and increased mental health needs.83 In addition, some students with disabilities 

found that they acquired new responsibilities in caring for their parents and siblings amid the 

COVID-19 pandemic. In addition, recent surveys suggest that students with disabilities reported 

feeling less of a sense of belonging and support from their respective IHE.

The Department would like to reiterate that students with mental health disabilities are entitled 

to academic adjustments and reasonable modifications to policies, practices, and procedures 

where necessary to receive an equal opportunity to participate in an IHE’s service, program, or 

activity, unless doing so would impose an undue burden or cause a fundamental alteration to the 

institution’s services, programs, or activities.84 For example, a student with depression may need 

the opportunity to make up work missed for disability-related absences. Safely and equitably 

meeting the mental health and social support needs of students and staff during this time is critical 

for student success.

FLEXIBLE PRACTICES FOR MENTAL HEALTH CARE

As COVID-19 prevented many on-campus counseling centers and mental health providers from 

providing in- person services, many IHEs reported expanding virtual services to provide support 

to off-campus students during the COVID-19 pandemic.85 One IHE shifted entirely to remote work 

and tele-mental health in March 2020. After seeking training in tele-mental health, they pivoted to 

provide counseling for individuals, groups, and couples, clinical case management, crisis sessions, 

and psychiatry through videoconferencing and phone sessions.

IHEs also reported that in circumstances where students returned home to other states, counseling 

services were limited. To address this, one IHE reported, “We had to make sure they could provide 

counseling through telehealth to students in other states. For some IHEs, this was challenging, but 

some states were easier than others to grant permission to provide interstate counseling.”

Other IHEs reported partnering with off-campus facilities to provide their students, staff, and 

broader communities additional support. Another IHE increased partnerships and collaboration with 

campus and community groups to expand the reach of services. In one instance, an IHE reported 

collaborating with a community partner to provide live contact by phone (rather than a recording) 

for individuals affiliated with its campus, thereby bypassing the typical wait for a callback. The live 

83 Madaus, J., Gelbar, N., Faggella-Luby, M., & Dukes, L.,(2021). Experiences of students with disabilities during the COVID-19 interruption of in-person instruction. Journal of 

Postsecondary Education and Disability, 34(1), 5-18.
46 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

contact can schedule a session or immediately connect 

the caller with a therapist if the individual student or 

employee is in crisis.

IHEs and mental health professionals have acknowledged 

that isolation has had a detrimental effect on individuals 

and communities throughout the COVID-19 pandemic. In 

addition to providing virtual services and creating new 

partnerships to expand reach, IHEs have taken steps to 

provide group counseling and support services that create 

opportunities for individuals to engage with community 

members who may be similarly in need of connection. One 

IHE official explained, “We found an unlikely source for our 

in-person interventions: Our campus has two food banks, 

one for students only and a second one for the community 

at large. We found that by stationing ourselves at the food 

banks, we have been able to screen and refer an amazing 

number of people while also holding impromptu (at first) support group meetings. This evolved into 

regularly scheduled support group meetings on food bank days. People now come to the food banks 

seeking us out.” 

Safely and 

equitably meeting 

the mental health 

and social support 

needs of students 

and staff during 

this time is critical 

for student 

success.

PROVIDING FLEXIBLE GRADING

Students report that, as they have struggled to adapt to academic life in the wake of the COVID-19 

pandemic, traditional grading policies have created added stress. Some have raised concerns about 

the inequitable treatment of students in virtual settings, as well as the 

increased anxiety of virtual testing where stakes are elevated, 

particularly when faculty use online monitoring and remote 

test monitoring software.

An American Council on Education (ACE) report on 

mental health and COVID-19 acknowledges that as 

students increasingly struggle with burdens and seek 

compassionate and caring communication, faculty 

and staff should provide reasonable flexibility and 

accommodations to students. Some IHEs reported 

providing flexibility to students who were worried 

about the mental stress of coursework during the 

COVID-19 pandemic and in some cases even allowed 

students to take classes as pass/fail to limit anxiety, stress, 

and mental burden.

84 34 CFR 104.44. 

85 Responses from Garrett Lee Smith Campus Suicide Prevention grantees surveyed about COVID impact on mental health, responses received March 23, 2021.

86 All IHEs that are recipients of federal financial assistance from the Department have an obligation under federal civil rights law to take appropriate responsive action where 

the harassment of students based on actual or perceived race, color, or national origin has created a hostile environment in school. To learn more about these civil rights obligations, please see the March 1994 guidance document on racial incidents and harassment.

87 Balsamo, M., (2020, Nov. 16). Hate Crimes in US Reach Highest Level in More Than a Decade. Retrieved from: https://apnews.com/article/hate-crimes-rise-FBI-data-ebbcadca8458aba96575da905650120d.
47 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

SUPPORTING THE MENTAL HEALTH NEEDS OF STUDENTS AT HIGHER RISK 

OF ADVERSE MENTAL HEALTH CONDITIONS

IHEs have reported seeing an increased need for mental health support for underserved students, 

including students of color, students without documentation, and LGBTQ+ students, both on 

and off campus.

IHEs must be responsive to the needs of students experiencing race and national origin-based 

violence or harassment.86 Hate crimes across the United States are at the highest level they have 

been in a decade,87 which can have significant impacts on the ability or desire of students to attend 

in-person learning and/or can impact a student’s ability to perform in the classroom. Exposure to or 

being a direct victim of race-based violence or a hate crime can significantly impact the mental health 

and well-being of the targeted community.88 For example, over the past year, as the United States has 

seen an increase in hate crimes targeted at Black and Asian communities, rates of depression and 

anxiety increased among Black and Asian Americans surveyed by the Census Bureau.89

International students are also facing distinct hardships. In certain cases, international students 

who were unable to return home comprised the sole remaining student population on campus 

throughout significant portions of the COVID-19 pandemic. In other instances, international students 

who were able to return home may have needed to attend classes at nontraditional or nonworking 

hours and may have had unreliable internet connections, creating additional 

stressors. Failed attempts at reaching counseling and mental health services 

during off-hours can be especially difficult for students at higher risk of 

adverse mental health conditions.

One IHE reported, “Beginning last March and continuing through 

summer, our campus was completely remote, with only essential 

workers coming to campus. The majority of our students were sent 

home, with the exception of our international students, who were 

moved into a single residence hall. International students who may 

have cultural barriers to mental health intervention were isolated 

from peers and their families. International students have gotten 

lost in the COVID chaotic disruption, especially students who are still 

taking classes from an international location where time differences are 

challenging.”

Student caregivers also experienced increased stress and emotional 

challenges, particularly those who had lost child care. Prior to the COVID-19 

pandemic, research already pointed to the growing mental health concerns for student 

caregivers. A literature review by the Aspen Institute and the Jed Foundation outlines the mental 

health challenges faced by student parents. The COVID-19 pandemic has created new barriers for 

student parents, and IHEs have raised these concerns numerous times, while seeking out innovative 

strategies and practices to help student parents cope during this time. As was described by a 

4-year flagship university’s representatives, “Many of our student parents felt extremely isolated 

last March—June 2020 because all of the child care facilities were closed down. Some were closed 

88 Ghafoori, B., Caspi, Y., Salgado, C., Allwood, M., Kreither, J., Tejada, J.L., Hunt, T., Waelde, L.C., Slobodin, O., Failey, M., Gilberg, P., Larrondo, P., Ramos, N., von Haumeder, A., & 

Nadal, K. (2019). Global Perspectives on the Trauma of Hate-Based Violence: An International Society for Traumatic Stress Studies Briefing Paper .r_1.pdf.

89 Fowers, A., & Wan, W. (2020, June 12). Depression and Anxiety Spiked Among Black Americans after George Floyd’s Death. Retrieved from: https://www.washingtonpost.

com/health/2020/06/12/mental-health-george-floyd- census/; Kumar, N., (2021, April 27). Rise in Asian American Discrimination and Violence During COVID Is Causing Mental 

Health Crisis. Retrieved from: https://www.healthline.com/health/rise-in-asian-american-discrimination-is-causing-mental-health-crisis.
48 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

even longer. Student parents still needed to attend classes virtually and complete projects and 

assignments while caring for their children at home, so this created lots of stress as well. Isolation 

and stress were the biggest challenges that our student parents faced.”

To address this challenge, one IHE partnered with faculty in their psychology department and 

worked with doctoral students to provide staff with training and resources to help deal with stress 

and anxiety during the COVID-19 pandemic. Each month, the IHE noted providing staff and families 

with Zoom workshops presented by the mental health consultant around issues related to stress 

management, meditation, and mindfulness.

IHEs can consider ways to use emergency funds including HEERF grants, partnerships, and 

additional resources to provide mental health and counseling services to student and staff 

populations at higher risk of adverse mental health conditions during the COVID-19 pandemic and 

throughout the post- pandemic recovery, when students and staff will need additional support. 

When it is not possible to provide no-cost services, IHEs should consider ways to ease economic 

and mental strain on their communities. To further support the mental health needs of students, 

IHEs can:

1. Increase availability of mental health and counseling services. 

IHEs should consider increasing availability of mental health and counseling services by using a 

comprehensive approach to mental health, including by providing general support; promoting 

training for faculty, staff, campus security, facilities, and operations; integrating mental health 

support into other settings where students may access services; and highlighting the opportunities 

for additional support across campus and websites.

2. Partner with the community. 

IHEs should consider partnerships with off-campus facilities and community organizations to 

expand provision of mental health and social support, peer-based engagement options, and other 

wrap-around services in circumstances where they are unable to provide in-person services. Further, 

IHEs should communicate with their peer institutions to learn about successful practices to increase 

mental health support in their communities.

3. Expand virtual services. 

IHEs should consider expanding virtual counseling services and tele- health services so they can 

provide additional support to students and staff.

4. Work with states to understand licensing portability requirements. 

IHEs should work with states to understand existing tele-health compliance rules and flexibilities in 

order to provide services to students and staff who are in need of services but currently reside in 

another state. In instances where IHEs are unable to provide services to students and staff who are 

currently out of state, IHEs should consider gathering and promoting available resources for which 

students and staff may be eligible in their respective locations.
49 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

5. Provide more flexible grading. 

Given the ongoing COVID-19 pandemic, noted higher levels of stress, and the awareness of the 

impact on mental health, universities have encouraged faculty and staff to increase understanding 

and empathy for students, offering opportunities for students to have flexible deadlines when 

requested, and to even offer the use of alternative grading systems (e.g., pass/fail). The alternative 

grading system allows for courses to be taken without adding or detracting from their overall 

grade point average.

6. Provide resources to marginalized students and be responsive to 

reports of hate crimes. 

It is imperative to provide students with safe spaces to openly discuss their experiences with race 

and national origin on campus, particularly if an IHE is predominantly white. As noted above, hate 

crimes targeting Black and Asian communities have increased during the COVID-19 pandemic, and 

individuals of color are generally at increased risk of experiencing hate crimes.90 These challenges are 

playing out in tandem with long-standing hate crimes being perpetuated against other communities 

of color. As such, IHEs could provide student groups—particularly those focused on issues affecting 

students of color and other groups that have been marginalized—with the resources and space 

necessary to engage with one another throughout the year. Even if classes continue to be virtual, 

IHEs can establish safe, virtual spaces for these communities to connect. IHEs should also consider 

providing counselors with expertise or specialized experience in counseling individuals of color, 

including Black, Latinx (or Hispanic), American Indian or Alaska Native, and Asian American Pacific 

Islander students; LGBTQ+ students; students with disabilities; and other underserved groups.

IHEs must respond to reports of racial or national origin harassment that could create a racially 

hostile environment that denies or limits a student’s ability to participate in or benefit from 

educational programs and activities. If the school determines that discriminatory harassment has 

occurred, then it must take prompt, reasonably adequate steps to end the harassment, eliminate 

any hostile environment, and prevent the harassment from recurring.91 IHEs should provide safe, 

anonymous reporting methods to protect students who may fear retaliation. Further, IHEs should 

recognize the importance of lived experiences as they develop new institutional policies and 

supports. For example, IHEs should invite students affected by hate crimes or identity-based 

harassment or violence to participate in developing practices and solutions.

90 Balsamo, M., (2020, Nov. 16). Hate Crimes in US Reach Highest Level in More Than a Decade. Retrieved from: https://apnews.com/article/hate-crimes-rise-FBI-data-ebbcadca8458aba96575da905650120d.

91 U.S. Department of Education Office for Civil Rights, Racial Incidents and Harassment Against Students Investigative Guidance, available at www.ed.gov/about/offices/list/

ocr/docs/race394.html (March 1994).
50 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

COMMITMENTS TO THE COMMUNITY

Many IHEs with physical buildings and campuses play an integral part within the communities 

where they are located. In addition to students, faculty, and staff potentially comprising a 

significant portion of the local population, regular interaction between the campus and surrounding 

community can increase transmission rates, which, if improperly managed can become a source of 

tension. As such, the COVID-19 pandemic has, in some cases, stressed the relationships between 

IHEs and their surrounding communities. IHEs should provide critical assistance to the surrounding 

communities in ways that are accessible to individuals with disabilities and limited English 

proficiency. IHEs should also be sensitive and responsive to the novel concerns presented by their 

continued operations and community interactions. Specifically, they can:

1. Provide testing and vaccination.

As the COVID-19 pandemic unfolded, some IHEs rapidly stepped up to offer their assistance in 

meeting the significant challenges around testing capacity. IHEs with the means allocated physical 

space to establish mass testing sites, offered lab facility capacity to process COVID-19 tests, and 

in some cases provided personnel in the form of nursing students and students in other relevant 

fields of study to execute testing protocols. Similarly, as vaccines have become broadly available in 

the United States, many IHEs have served their communities as vaccination sites. Throughout these 

efforts, states should provide additional support to IHEs serving communities disproportionately 

affected by COVID- 19, including those that are underserved or located in rural areas. Such 

assistance could include, but is not limited to, procuring COVID-19 tests and PPE at governmental 

rates and/or facilitating the establishment of vaccination sites.

2. Be conscientious neighbors.

Even some IHEs with a primarily on-campus residential student population documented difficulties 

containing outbreaks on their campuses.92 IHEs with students living or spending time off-campus, 

and IHEs with a high percentage of commuter students, faced additional vectors of transmission, 

which often led to higher numbers of infections in their surrounding communities. As a basic 

step, the Department encourages IHEs to establish appropriate forums to listen to and address 

community concerns and to provide transparency around IHE actions and the results those actions 

have achieved.

92 Hannah Lu, Cortney Weintz, Joseph Pace, Dhiraj Indana, Kevin Linka & Ellen Kuhl (2021) Are college campuses superspreaders? A data-driven modeling study, Computer Methods in Biomechanics and Biomedical Engineering, DOI: 10.1080/10255842.2020.1869221. Retrieved from: https://www.tandfonline.com/doi/full/10.1080/10255842.2020.1869221.
51 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

Given the close relationship between on- campus transmission and community transmission rates, 

IHEs should establish safe operating procedures, such as a reduction in the size and number of large 

gatherings and an increased use of surveillance testing.93 In conjunction with these measures, IHEs 

could also consider conducting contact tracing for students living off-campus; public health officials 

should be notified of confirmed cases, and testing should be made available to individuals living on 

and near campuses.

3. Encourage students to take an active role in COVID safety. 

IHEs may also consider different ways of encouraging student behavior, including thoughtful 

enforcement of student codes of conduct that appropriately calibrates any potential sanctions. 

For example, during periods when increased off-campus student activity and large gatherings 

were anticipated— such as Halloween or St. Patrick’s Day—a large public university conducted joint 

visits to off-campus dwellings with campus police and student ambassadors to remind students 

of safe behaviors and to reduce gathering density without issuing sanctions. Numerous IHEs have 

employed “social norms” approaches to encourage positive behaviors by supporting the formation 

of student-led groups that encourage social-distancing, masking, and other recommended COVID19 mitigation practices.

 

93 Walke HT, Honein MA, Redfield RR. (2020, Sep. 29). Preventing and Responding to COVID-19 on College Campuses. Retrieved from: https://jamanetwork.com/journals/jama/

fullarticle/2771319.
52 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

AVAILABLE FEDERAL FUNDING AND FLEXIBILITIES

Since the date of the declaration of the national emergency on March 13, 2020, the federal 

government has allocated historic amounts of funding to IHEs and students while also providing 

unprecedented levels of flexibility in student financial assistance and higher education programs 

in order to support ongoing response and recovery efforts. Public benefits managed by a number 

of federal departments and agencies have contributed to helping meet the overwhelming needs 

of postsecondary students that have been exacerbated by the COVID-19 pandemic. These federal 

financial resources and flexibilities have been referenced throughout this volume and are provided 

together here for reference purposes.

HEERF: Beginning with the CARES Act, and supplemented by the Coronavirus Response and 

Relief Supplemental Appropriations Act (CRRSAA) and, most recently, the ARP, approximately 

$76 billion has been appropriated for allocations to more than 5,000 IHEs throughout the nation 

to help IHEs address COVID-19 and its disruptions to IHEs and their students.

HEERF I (CARES): In spring 2020, the Department allocated nearly $14 billion to IHEs 

under HEERF, including $12.6 billion to all eligible IHEs (section 18004(a)(1)). IHEs were 

required to use at least 50% of this funding ($6.3 billion) to provide financial aid grants 

to students and could use the remaining funding to address institutional needs arising 

from SARS-CoV-2 coronavirus. This initial round of awards to all IHEs was followed by an 

additional $1.05 billion to HBCUs, TCCUs, MSIs, and Strengthening Institutions Program 

(SIP) (section 18004(a)(2)), and an additional round of awards to public and private nonprofit institutions that had received less than $500,000 through the first two rounds of 

awards (section 18004(a)(3)). More information on CARES-HEERF I grants is provided in 

the CARES FAQs document. Importantly, unspent CARES funds can be spent according to 

the terms and conditions of the CRRSAA as of December 27, 2020, as described in these 

CRRSAA 314(a)(1) FAQs.

HEERF II (CRRSAA): In January 2021, the Department allocated over $20 billion to all 

public and private non-profit IHEs, approximately $6 billion of which must be used for 

financial aid grants to students. An additional $681 million was allocated to proprietary 

IHEs for financial aid grants to students. In February 2021, ED allocated nearly $1.7 billion 

in additional awards to HBCUs, TCCUs, MSIs, and SIP institutions. Finally, in March 2021, 

the Department published a notice inviting applications for additional awards to IHEs that 

continue to demonstrate unmet need after the first three rounds of awards. With the funds 
53 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

that are not set aside specifically for financial aid grants to students (including unspent 

CARES institutional funds), IHEs can:

 Defray expenses associated with coronavirus, (including lost revenue, reimbursement 

for expenses already incurred, technology costs associated with a transition to distance 

education, faculty and staff trainings, and payroll); and

 Carry out student support activities to address needs related to coronavirus.

The Department recently updated its guidance on allowable uses of funds to provide additional 

flexibility to IHEs in two areas where we have received substantial feedback from the higher 

education community—using HEERF grants to compensate for lost revenue, as well as questions on 

timing considerations for using HEERF grants to defray expenses associated with coronavirus. The 

FAQs, as well as other information on HEERF II, are available on the HEERF II website.

HEERF III (ARP): The Department is working to implement the additional $39.6 billion in 

“HEERF III” funding made available through ARP, signed by President Biden on March 11, 

2021. Of these funds, approximately $36 billion is provided to public and private non-profit 

IHEs. Of that amount, at least $18.4 billion must be used for additional financial aid grants 

to students. An additional $3 billion is provided for additional allocations to HBCUs, TCCUs, 

MSIs and other under-resourced IHEs. The bill also provides nearly $400 million in grants 

to proprietary IHEs for the sole purpose of making financial aid grants to their students; 

and nearly $200 million for additional grants to IHEs that demonstrate unmet need. The 

Department posted ARP–HEERF III allocations to public and private IHEs under (a)(1) and to 

proprietary IHEs under (a)(4) on May 11, 2021, and is currently making supplemental awards 

to IHEs with approved applications under HEERF I or II and accepting applications and 

making new awards for IHEs not previously funded. IHEs must use a portion of their HEERF 

III funds to:

 Implement evidence-based practices to monitor and suppress in accordance with public 

health guidelines; and

 Conduct outreach to financial aid applicants to notify them of the opportunity to 

receive a financial aid adjustment due to the recent unemployment of a parent or 

independent student, or other circumstance described in section 479A of the Higher 

Education Act of 1965, as amended (HEA).

On May 11, 2021, the Department released allocations and additional guidance on uses of funds and 

how to apply for HEERF III funding (see section D).

GEER: In addition, the Department also awarded $3 billion to Governors under the GEER Fund 

authorized by the CARES Act and an additional $4 billion in GEER II funds to states in January 2021 

under the CRRSAA. Governors award GEER funds, at their discretion, to school districts, IHEs, and 

other education-related entities in the state. Additional information on GEER can be found here.

CARES Act Flexibilities Applicable to Specific Higher Education Grant Programs: In addition 

to HEERF, the Department’s Office of Postsecondary Education makes thousands of grants each 

year to IHEs through various programs authorized under the HEA. Section 3518 of the CARES 

Act authorizes the Secretary to modify required or allowable activities for grants awarded under 

the institutional support programs for HBCUs, TCCUs, MSIs, and other under resourced IHEs, as 

well as under the Federal TRIO Programs and the Gaining Early Awareness and Readiness for 
54 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

Undergraduate (GEAR UP) Program, at the request of the grantees. 

IHEs that are current grantees in these programs may request that 

the Secretary grant such flexibilities as a result of the qualifying 

emergency through at least September 30, 2022. In June 2020, the 

Department released FAQs on flexibilities provided in non-HEERF 

grant programs administered by the Office of Postsecondary 

Education, including flexibilities provided pursuant to section 3518 

of the CARES Act. In addition, the Department has subsequently 

released letters on these flexibilities, one in July 2020, a followup letter to TRIO and GEAR UP grantees on December 2020, 

and a letter to grantees in the institutional service programs in 

December 2020.94 These letters provide examples of changes 

grantees could request, but they are not exhaustive. For 

example, an institution receiving funds under one of the Titles 

III and V programs could request that the Secretary waive the 

regulatory prohibition against using such funds to provide direct 

grants to students if doing so would assist the institution and its 

students during the qualifying emergency. Similarly, IHEs could 

request that the Secretary approve changes to their approved 

applications to shift funding into the provision of mental health 

services to students, faculty, and staff.

Flexibilities in the Student Financial Aid Programs:

On January 20, 2021, the Department extended the COVID-19 

emergency relief measures on Department-owned federal 

student loans through September 30, 2021.

 The Department used the authority provided under 

the CARES Act to set the interest rate on all ED-owned student loans to 0% during the 

qualifying emergency, from March 13, 2020, through at least September 30, 2021.

 The Department has suspended loan payments from March 13, 2020, through at least 

September 30, 2021, on all ED-owned student loans. Individuals can opt out if they wish to 

continue making payments.

 The Department has stopped collections on all defaulted ED-owned student loans from 

March 13, 2020, through at least September 2021.

In addition, on March 30, 2021, the Department announced the expansion of the COVID-19 

emergency relief measures to federal student loans made through the Federal Family Education 

Loan (FFEL) Program that are in default.

The Department has also provided a number of other key flexibilities to IHEs and students 

participating in the Federal Student Aid (FSA) programs. A few are highlighted below but IHEs are 

encouraged to review a comprehensive list on FSA’s website.

 Section 3508 of the CARES Act directs the Secretary to waive Return of Title IV 

requirements and cancel Direct Loan funds disbursed for students that withdraw as a result 

of COVID-19. Section 3506 of the CARES Act also provides that Pell lifetime eligibility 

94 The guidance to GEAR UP grantees on the match waiver flexibilities was updated on March 21, 2021, and is available at this link: https://www2.ed.gov/programs/gearup/

index.html.
55 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

will not be impacted for the students who withdraw as a result of COVID-19. IHEs are 

not required to return Title IV funds for students who withdraw, as a result of COVID-19 

circumstances, from a payment period or period of enrollment that coincides with the 

qualifying emergency. As of March 30, 2021, the Department has cancelled more than $440 

million in Direct Loan funds and restored the equivalent of more than 100,000 semesters of 

Pell Grant lifetime eligibility for students who withdrew due to COVID-19. More information 

on this provision is available in this Electronic Announcement.

 Section 3509 of the CARES Act allows IHEs to exclude from a student’s Satisfactory 

Academic Progress (SAP) calculation any credits that were attempted but not completed 

if the institution determines that the failure to complete the credits was the result of 

COVID-19.

 In recognition of the fact that campus work-study opportunities are limited as a result of 

COVID- 19, section 3503 of the CARES Act allows IHEs to transfer any unspent funds from 

its Federal Work-Study (FWS) allocation to its Federal Supplemental Education Opportunity 

Grants (FSEOG) allocation. IHEs may use FSEOG funding to make emergency financial aid 

grants to students for unmet financial need and to address unexpected expenses resulting 

from the qualified emergency.

Finally, in January 2021, the Department sent a letter reminding financial aid administrators that 

section 479A of the HEA gives an institution’s financial aid administrator the authority to exercise 

professional judgment to adjust student aid eligibility, on a case-by-case basis, to reflect a student’s 

special circumstance. For example, this authority allows the financial aid administrator to use 

documented unemployment or reduction in work to adjust the factors that determine a student’s 

expected family contribution. The Department continues to encourage the use of this authority 

during the COVID-19 pandemic and reiterates that the Department will not consider incidence of 

the use of professional judgment as a factor in selecting institutions for program reviews. As noted 

above, one of two new required uses of funds for IHEs receiving grants under the ARP (HEERF III) 

is to conduct outreach to financial aid applicants to notify them of the opportunity to receive a 

financial aid adjustment due to the recent unemployment of a parent or independent student, or 

other circumstance described in section 479A of the HEA.

SNAP: The Consolidated Appropriations Act, 2021 temporarily expanded SNAP eligibility to include 

any postsecondary students who meet the SNAP eligibility criteria and, in the current academic 

year: 1) are eligible to participate in federal or state work-study programs, as determined by the IHE 

or 2) have an expected family contribution (EFC) of zero. This temporary expansion will be in effect 

until 30 days after the qualifying emergency ends. FSA issued an electronic announcement on this 

issue on February 25, 2021, that provides more detail on this temporary expansion in eligibility, 

including information on the role of IHEs in eligibility verification. The Department also recently 

announced that it has designated the U.S. Department of Agriculture (USDA) as an entity that 

can use FAFSA data. FSA will begin emailing students with a zero EFC so that they can print that 

email and present it as documentation for SNAP eligibility at their state and local SNAP agencies. 

The Department also encourages IHEs to actively conduct outreach to students to ensure that 

they are aware of this temporary expansion in eligibility for SNAP benefits and to assist them with 

documentation of FWS eligibility.

FCC Emergency Broadband Benefit: The Consolidated Appropriations Act, 2021 omnibus 

provided $3.2 billion for the FCC to establish an Emergency Broadband Benefit program to make 

broadband service more affordable by providing monthly discounts to eligible households and to 
56 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

provide a one-time reimbursement benefit of $100 on purchases of laptops, tables, and computers 

purchased through qualified providers. Under this program, eligible households can receive 

$50 monthly discounts on broadband service and up to $75 if the household is on tribal lands. 

Households can meet eligibility criteria in a number of ways, including by having one member 

of the household who is a Pell Grant recipient. The FCC Emergency Broadband Benefit Program 

launched on May 12, 2021. The Department of Education has designated the FCC as an entity that 

can use FAFSA data and encourages IHEs to help the FCC get the word out to their students on this 

important benefit that can provide financial relief to students and their families as they continue to 

navigate the remote learning environment. More information, including the online 

application, is available at https://getemergencybroadband.org/.

Connecting Minority Communities (CMC) Pilot Program: The 

Consolidated Appropriations Act, 2021 provided $285 million for 

the Department of Commerce’s National Telecommunications 

Information Administration (NTIA) to implement the CMC Pilot 

Program to provide grants to HBCUs, TCCUs, and MSIs to 

purchase broadband internet access service or any eligible 

equipment, or to hire and train information technology 

personnel.

FEMA Reimbursement: FEMA’s Public Assistance (PA) 

program provides supplemental disaster assistance to state, 

local, tribal, and territorial governments and certain Private 

Non-Profit (PNP) organizations. PA eligibility is based on 

determining the eligibility of the Applicant, Facility, Work, and 

Costs in accordance with program authorities and policies. PNP 

eligibility is based both on determining Applicant eligibility and 

Facility eligibility based on the service provided. 

Claimed work and associated costs must be the legal responsibility of the 

Applicant, required as a result of the declared event, and within an area 

authorized for PA.

On January 21, 2021, the President issued the “Memorandum to Extend Federal Support to 

Governors’ Use of the National Guard to Respond to COVID-19 and to Increase Reimbursement 

and Other Assistance Provided to States,” authorizing FEMA to provide funding to PA Applicants 

for the measures to support safe opening and operation of eligible facilities. FEMA issued the 

“Coronavirus (COVID-19) Pandemic: Safe Opening and Operation Work Eligible for Public Assistance 

(Interim)” in April 2021, expanding eligibility for the COVID-19 disaster declarations to applicants 

outlined in the memorandum, including public and private non-profit IHEs. For eligible work from 

January 21, 2021, through September 30, 2021, FEMA is funding the entire cost of the emergency 

protective measures made eligible by this policy, including COVID diagnostic testing as defined by 

the U.S. Food and Drug Administration, temperature screening, cleaning, eligible social distancing 

measures, and PPE. Under the PA program, eligible IHEs may apply to become a Subrecipient and 

receive reimbursement for eligible work through their state, local, territorial, or tribal government 

that is a direct FEMA PA Recipient. Eligible IHEs applying to become Subrecipients should follow 

appropriate guidance from the CDC and local Public Health officials when determining what is 

necessary for the safe opening and operation of their facilities. More information regarding PNP 

Applicant eligibility under the PA program can be found at COVID-19 PNP FACT SHEET (fema.gov).
57 U.S. DEPARTMENT OF EDUCATION ED COVID-19 HANDBOOK

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