FR 2021-00889

In a recent notice by the Department of Education, the agency has requested an emergency review from the Office of Management and Budget (OMB) for a new information collection tied to the Coronavirus Response and Relief Supplemental Appropriations Act, 2021 (CRRSAA). This collection aims to allocate funds to proprietary schools, which in turn should provide financial aid to students affected by the pandemic. The public has been invited to comment on this collection until March 16, 2021.

Summary of the Document

The core initiative of this request is to address the pressing financial needs of students who have been significantly impacted by COVID-19. These financial aid grants are intended to cover critical expenses such as tuition, housing, healthcare, and other related costs. The Department of Education is actively soliciting public feedback to ensure that the proposed collection is both necessary and effective.

Significant Issues and Concerns

While the document outlines a well-intentioned plan to support students, several issues warrant attention.

1. Lack of Detail on Burden Estimates: The notice estimates an annual burden of 8,787 hours for respondents. However, it does not specify how this figure was calculated. This absence of detail might lead to skepticism or misunderstanding among stakeholders who may question the validity of the estimate.

2. Transparency in Fund Allocation: The document does not clarify the criteria or methodology for selecting proprietary schools that will receive funding. This lack of transparency could drive concerns regarding fairness and potential favoritism, as stakeholders may not understand why certain schools are chosen over others.

3. Use of Technology: While the document mentions the use of technology to minimize the burden on respondents, it fails to mention which technologies or methods will be employed. This could cause confusion and uncertainty about how the process will be modernized or made efficient.

4. Complex Legal References: The inclusion of specific legal references, such as the Paperwork Reduction Act and the related codes, without any context or explanation can be challenging for individuals without legal expertise to interpret. This may prevent the general public from fully understanding the regulatory framework backing the request.

5. Vague Urgency: Though the document outlines the negative consequences of not approving the emergency collection, it does so in persuasive but vague terms. Providing more detailed data about immediate student needs or specific situations that demand urgency could strengthen the case for expedited action.

Broad Public Impact

This initiative has the potential to deliver crucial support to students struggling with the unforeseen financial challenges posed by the pandemic. By easing the financial burden on students, the policy could allow them to continue their education without interruption, thereby reducing dropout rates and ensuring academic continuity.

Impact on Specific Stakeholders

• Students: Students stand to gain significantly through this program, as they would receive financial assistance for essential needs. This could alleviate stress and uncertainties experienced during the pandemic, contributing to better academic and mental health outcomes.

• Proprietary Schools: These institutions would be directly responsible for disbursing the funds, which presents an opportunity to solidify their relationship with students by offering timely and needed support. However, they also bear the responsibility to operate equitably and transparently under public scrutiny.

• Taxpayers: The broader taxpayer base may be concerned about how effectively their contributions are utilized. Transparent processes and clear communication from the Department of Education can mitigate concerns by ensuring funds achieve their intended effect without wastage or misallocation.

In summary, while the collection initiative is designed with positive intentions of supporting pandemic-impacted students, there are several areas where additional clarification and transparency could enhance its efficacy and public trust. These improvements can help assuage concerns and maximize the program’s impact on the intended stakeholders.