The Department of Education (DOE) announced in January the release of six issue papers in support of the Biden-Harris Administration’s efforts to “help ensure students are well served by the institutions of higher education they attend and that Federal Student Aid programs work in their best interest.” The DOE issue paper on Cash Management includes new rules that could impact inclusive/equitable access course materials programs (IA/EA) and cash value meal plans. The latest version of these proposed rules (March 4, 2024) are detailed in V3 of the cash management issue paper.
NACAS opposes the proposed rules as there are a myriad of unintended consequences that will negatively impact student success. The proposed cash management rules should reflect the value of these programs, while also ensuring compliance with Administration goals.
- IA/EA programs provide course materials at prices well below Federal Financial Aid estimates and reduce the overall cost of attendance.
- IA/EA programs make traditionally high-cost course materials more accessible to low-income populations on day 1 of the semester, which is known to increase student academic success, persistence, and graduation.
- Cash value meal plans provide flexibility and choice to meet the varied nutritional needs of students. Proper nutrition is critical to cognitive function and development.
- Cash value meal plans provide a lower cost dining option that can be purchased with financial aid which reduces the potential for some students to suffer the negative impacts from food insecurity.
To reduce the negative impact on student success, NACAS proposes that alternative rule changes be considered:
- IA/EA course materials program administrators should be required to:
- Certify that the program will reduce the published cost of attendance.
- Communicate the ability to opt out of the IA/EA program in the course registration system, the campus bookstore website, and via multiple, direct email messages to all registered students.
- Provide an opt-out period that extends at least 7 calendar days after the start of the semester.
- Cash value meal plan administrators should be required to:
- Certify that cash value meal plan programs provide a lower cost alternative to traditional meal swipe plans.
- Provide roll-over of funds until the end of the academic year.
- Promote the full utilization of cash value meal plan funds to meet student nutritional needs and to exhaust meal plan fund balances before the end of the academic year.
NACAS will track the development of these rules through the negotiation process and work to provide public comment for the next negotiating session scheduled for March 4-7. NACAS has also agreed to sign a higher education association letter to the Department of Education regarding course materials in the cash management regulations.
NACAS will continue to represent and educate our membership regarding governmental rules and guidelines that may impact your operations.
If you have questions or comments, reach out to NACAS CEO Rich Steele at rich.steele@nacas.org.
Resource Links:
- Biden-Harris Administration Takes Next Steps on Rulemaking to Strengthen Institutional Quality and Program Integrity
- Negotiated Rulemaking for Higher Education 2023-24
- Session 2: Issue Paper - Cash Management V2 (February 5, 2024)
- Session 3: Issue Paper - Cash Management V3 (March 4, 2024)
Rich Steele
NACAS : 01/09/24
