A SMART Move?

For programs designed to put hundreds of millions of dollars in new federal financial support into the hands of students, the Academic Competitiveness Grant and National Science and Mathematics Access to Retain Talent (SMART) Grant Programs have been almost stunningly unappreciated by college administrators. That's because of their perception that the programs -- designed on the fly, in a matter of days, by a small group of Congressional aides in 2005 -- were designed in ways that limit the potential usefulness of the grants to students, and carried out by the Education Department in ways that make administering them a major headache.

And now, they say, it is getting even worse.

To qualify for the SMART Grant, which is designed to increase the number of students from low-income families in high-need scientific and technology fields, students must be enrolled in and working toward the requirements of one of the majors that are eligible under the program. In administering the program, college officials have generally interpreted that standard to require, in the Education Department’s own words, that a student be “enrolled in coursework … that may include the courses … in the … eligible major or other courses that make up the student’s … eligible program, or both.”

But policy guidance issued by the Education Department last week on the SMART program’s student enrollment requirements said that to be eligible to receive a grant in any given semester, a student must be enrolled in at least one course that is required for that major. In other words, the department said, “a student who is taking general education courses or electives that satisfy general degree requirements for the student’s National SMART Grant-eligible program, but who is not taking at least one course specific to and required for the … National SMART Grant-eligible major, is not eligible period for a National SMART Grant payment for that payment period.”

The department’s “Dear Colleague” letter unleashed a bevy of frustrated comments on listservs from financial aid officers, who characterized the announcement as yet more evidence that the department is making the SMART Grant program increasingly less accessible for students and increasingly more difficult for campus officials to administer.

Critics complained that department officials were altering the program’s standards outside the normal procedures for proposing changes in federal rules, since this was not an issue that had been raised in the negotiated rule making process that the department conducted last winter (department officials disputed that assertion -- more on that below).

Campus officials raised numerous concerns about the new guidance, saying that it would disqualify students (1) who had finished their major-specific coursework by their junior or senior year but still had general education requirements left to complete; (2) who were locked out of needed major-specific courses because of enrollment caps or other institutional policies outside their control.

The administrators also argued that the policy would be an administrative nightmare to carry out, as at many institutions, it may be difficult for financial aid officials to get accurate information about all the courses a student is enrolled in at the time that the SMART Grant would be disbursed, resulting in a situation where the institution would have to rescind a student’s grant after the fact if it later determines that the student had not been enrolled in a major-specific grant.

“There hasn’t been a call that the department has made that hasn’t been the opposite of what anybody at a school would want,” said Ted Malone, director of financial aid at the University of Alaska at Anchorage. “Sometimes it seems like the goal is to make this the hardest to work with that we possibly can.”

Department officials seemed in last week’s letter to recognize that the guidance would require colleges to alter the way they’ve been awarding the grants, saying that they would not impose the requirement for those grants awarded last year or already awarded for this fall.

But in a statement the department released from Diane Auer Jones, assistant secretary for postsecondary education, she disputed the assertion that the policy represented a change in the program’s rules.

“Our regulations have always and continue to require students to be enrolled in courses necessary to complete the degree program and to fulfill the requirements of the intended eligible major,” Jones said. “We have consistently told institutions that they must have a mechanism in place to document that all recipients were meeting both criteria. However, we learned that some of our earlier guidance was being interpreted in such a way that a student taking general education courses required for any major, and taking no courses required for a SMART eligible major, could have been a recipient of a SMART grant as long as he or she declared a SMART eligible major and maintained the required GPA.”

She added: “This Dear Colleague Letter simply reminds institutions that being enrolled in a program means that students should be taking courses that are required for that program.”

The department's suggestion that the new guidance simply clarified already existing laws and rules struck some experts on the SMART Grant Program as difficult to swallow. "The notion that the new rule changes nothing is self-contradictory," said Barmak Nassirian, associate executive director of the American Association of Collegiate Registrars and Admission Officers. "If it changes nothing, then why did they have to issue it.... [T]he new 'clarification' must concretely require something that was not required before, and its timing and retroactive application say volumes about the administration’s artless and indifferent approach to regulating higher education."