Executive Summary

The Coronavirus Aid, Relief, and Economic Security (CARES) Act was signed into law March 28, 2020, and included a $14B allocation designated as the Higher Education Emergency Relief Fund (HEERF) which provided funds directly to institutions of higher education (IHE) to support the costs of shifting classes online, and for grants to students for food, housing, technology, and other purposes (DeVos, 2020). On April 9, 2020, the Department of Education (DOE) announced that $6.28B would be distributed immediately to IHE to provide direct emergency cash grants to college students whose lives and educations had been disrupted by COVID-19. In order to receive funds, each IHE had to sign a certification affirming that funds will be distributed in accordance with applicable law, however, the DOE’s interpretation of the applicable law was very unclear and still is even three months later (Department of Education, 2020). This project, managed by the DOE, was completed in such haste and with such unclear guidelines that it actually slowed down the process of providing emergency aid to students as quickly as possible as HEERF intended while causing much distress to financial aid offices. This assessment focuses on the Preparation and Implementation Phases of the project and will be assessed on its successes and shortfalls of applicable project management aspects and recommendations made for improved project management from the lens of the DOE.

Ideation Phase

The Ideation Phase of the CARES Act HEERF student portion was initiated by the Federal Government when the CARES Act was signed into law. The DOE was handed down the project Ideation through interpreting the spirit of the CARES Act and determining what course of action was best to execute the law. The DOE was able to successfully group ideas into project portfolios; HEERF was able to be divided into student portion of funds, institutional portion of funds, and special funds earmarked for Title III eligible institutions. The DOE chose to prioritize the allocation of student portion of funds in order to support college students during the economic crisis caused by the pandemic as quickly and as seamlessly as possible based on the dramatic change of educational environment as it transitions online due to the pandemic. Because the DOE had no stake in the actual business operations of IHE, they were able to prioritize the allocation of these funds based on nonfinancial criteria and stay true to the heart of the organization’s mission.

Though the DOE determined the optimal approach to execute the distribution of these student funds through IHE, it failed to ensure the continual support of the organization after conducting a more thorough evaluation on the Implementation feasibility of the project (Wu, 2020). This occurred due to an overemphasis on getting students the financial support they needed as quickly as possible and a failure to identify IHE as an additional stakeholder during this project. The DOE should have completed a Stakeholder Evaluation Matrix at the time of Ideation and it would have identified the impact on individual institutions, specifically their offices of financial aid. Additionally, in the DOE’s initial guidance to IHE on the distribution of these funds was intended to provide individual intuitions flexibility in awarding students using their professional judgement, instead a fuzzy front end was created and institutions spent significant time interpreting the DOE guidance which delayed the distribution of funds which was the ultimate goal. The DOE should have recognized the turbulent environment the pandemic created and provided clear and direct guidance to IHE. If the DOE would have identified offices of financial aid as a stakeholder in this project they potentially could have tapped into professional organizations representing these offices or advisory boards to assist with the development of business ideas. This project shortfall also could have been combated by conceiving an initial project schedule, developing an outline of a communication and information management plan. Finally, the DOE should have recognized that distribution of Title IV funds through the financial aid offices is a highly regulated environment and any flexibility or interpretation required by those offices stems anxiety and slows processes down.

Overall, there was a significant case for this project to be implemented as it was directed by Congress and mandated by law. However, the DOE could have spent more time defining and considering the scope of the project at this point to limit the issues the project faced at the start.

Initiation Phase

The Initiation Phase of this project should focus on determining the optimal approach to complete the distribution of student HEERF funds and ensure what support is required of DOE throughout the completion of the Implementation Phase. The DOE did an admirable job in developing a project schedule with a clear start and end date by providing IHE with a year to use all HEERF funds a calendar year within receipt of said funds. They also decided not to let IHE draw down any of the institutional portion of the HEERF funds until they had drawn down the student portion of the funds, which further highlighted the DOE’s position to expedite the disbursement of student funds. During this Phase, the DOE must solidify the project scope, establish a project team, and agree on a project methodology.

The DOE should focus on developing the project charter, further identifying stakeholders, identify key communication and information points that need to be communicated to said stakeholders, continue to evaluate the exceedingly turbulent environment, and develop a Project Governance Plan. The Project Charter was a key document that the DOE failed to produce. This contract should have been developed and communicated to key stakeholders for further insight and understanding of the project. The letter from Secretary DeVos to the IHE in a way serves as an informal Project Charter by providing a project name, description, roles of the IHE. However, the document was never updated and failed to outline any risks, assumptions, and support provided throughout the project, or a planned approach. Again, the DOE should have continued to engage and gain insight from key stakeholders for better understanding of what should be effectively planned in this next stage of the project life cycle. An additional shortfall that occurred throughout the project was the lack of a communication/information plan. During this Phase, any potential communication challenges and the available modes in which the DOE planned to communicate should have been identified.  Estimating the scope continues to be difficult due to the great variance with the pandemic has location to location and varying information from authority to authority. Finally, due to the usual strong regulatory environment used disburse of federal funds, the DOE essentially had a Project Government Plan in place that simply needs to be customized to fit this specific project’s needs and those adjustments must be communicated. As mentioned in the Ideation Phase, this project developed a fuzzy front end and that should have been mitigated during the Initiation Phase by identifying student and IHE issues and process gaps and modifying any future plans based on those identified issues. In this case, the project deliverables were understood to an extent by IHE who were experiencing a high level of project constraints in terms of resources while being impacted by various environmental factors stemmed from the unprecedented pandemic.

Preparation Phase

The Preparation Phase of the DOE’s project to disperse HEERF funds to students was the largest failure in the scope of project management. Scope management processes of defining and validating various requirements for the project, including a project scope statement, change control procedures, and a WBS were not communicated externally, so it is unknown if those documents exist. The DOE failed to prepare adequately for the Implementation of this project due to the pressure to distribute these funds as quickly as possible during this state of emergency, and this caused issues during the Implementation Phase, potentially compromising the total success of the project. The environment of the COVID pandemic created a very complex situation due to the interplay between politics, multiple levels of authority and large matrixes involvement with many stakeholders involved in the execution of the project, and the large potential for unanticipated changes and factors that could arise due to the variability of information on the virus. To combat these ingrained complexities, the DOE should have applied rigorous project management approaches with strong governance, executed a robust communication plan to increase stakeholder engagement, adopted an Agile approach to allow for flexibility during the ever-changing environment but still allow for diligent planning,

A key missing step the DOE failed to do was to develop a communication management plan and information management plan (Bauer-Wolf, 2020). This failure impacted the overall project integration management and communication management efforts for the rest of the project. During this project Phase, the DOE should have identified various mediums, formats, documents, and available technology to serve as a forum to communicate with stakeholders in an organized and overreaching manner (Wu, 2020). Timelines that ties with the stakeholder engagement plan and the project management plan should have been integrated into these two communication plans.

Additionally, the DOE failed to share an overall project management plan with IHE, who were key in the disbursement of the HEERF. This Project Management Plan should have included a schedule of activities in which IHE could have determined their upcoming workload and planned internally to accommodate it. In regards to stakeholder engagement, these issues also could have been mitigated through a stakeholder engagement plan. Many of the IHE felt in the dark and left to their own devices as to what was going to be required of them at the start of this project (Amour, 2020) (McLean, 2020). Overall, during this Phase the DOE should have attempted to provide as much clarity as possible and prepare project teams before organization commit to significant resources required for project Implementation (Wu, 2020).

Implementation Phase

During the Implementation Phase, the project manager should monitor and control the project work, especially schedule and scope in the project. The DOE did an adequate job during this Phase of the project in some aspects. The DOE required IHE to initiate the process of receiving all HREEF funds, including the institutional funds and Title III funds. They must complete a certification agreement affirming that funds will be distributed in accordance with the applicable law (Department of Education, 2020). The DOE then informed the individual IHE that they would receive access to the student portion of funds through the typical G5 system, which is typical of any Title IV or III federal funds. This process assisted in maintaining strong governance through the receipt and draw down of federal funds. Administration will be required to report to the Department of Education (DOE) in thirty (30) days from grant submission and every forty-five (45) days thereafter on how the grants were distributed to students, the amount of each grant awarded to each student, how the amount of each grant was calculated, and any instruction given to students about the grants. Each IHE agreed it shall promptly and to the greatest extent practicable distribute all the advanced funds in the form of emergency financial aid grants to students by one year from the date of this Certification and Agreement. Additionally, Administration must report that it continued to pay all of its employees and contractors during the period of any disruption or closures to the greatest extent practicable. All stakeholders were tied to this reporting system and made public.


During this Phase the DOE was also responsible for controlling the entire project and most importantly making adjustments throughout the entire process to ensure that the project remains on course (Wu, 2020). Though the DOE did its best to mitigate the issues caused by the shortfalls originated within the Preparation Phase by releasing subsequent FAQs answering the many questions posed by IHE, it was unsuccessful in addressing all questions and many of their answers raised even more questions. In addition to unsuccessful communications, the modality and timing of which the communications were released seemed random at best. The hesitation IHE had in determining fund allocation (Dam, 2020) caused strained relationships with both the DOE and the students. Additionally, there were significant political issues that caused even more disruption among the stakeholders—determining which students were eligible to receive funds. Students must be eligible to receive emergency financial aid grants, and only students who are eligible to participate in programs under Section 484 in Title IV of the Higher Education Act of 1965 (HEA), as amended, may receive emergency financial aid grants. However, due to the political motivation of the Trump Administration to end DACA funding, the DACA student population was removed from eligibility post facto, which led to various lawsuits (Bauer-Wolf, When will colleges get clarity around which students can get CARES aid?, 2020). These two instances of stakeholder mismanagement stemmed from a poor change management protocol and a poor or nonexistent communication plan.

Unfortunately, this project was a prime example of what happens when too much emphasis was placed on speed and agility which caused rushed decision making and unconsidered information (Wu, 2020). Then once the initial Implementation was botched to an extent, the DOE took too long to react, which negatively impacted the goal of the project, causing IHE to second-guess the DOE. To combat the poor work completed during the Preparation Phase, at this point, the DOE should have utilized a decision-making tool like the Analytical Hierarchy Process to help support the complex decision problems and keep the project on track. The DOE should have focused on monitoring the progress of the project, comparing the actual with the planned, and making adjustments to control the process and the outcome.

Closure Phase

To date, the distribution of HEERF to students could theoretically still be in progress, though it can be assumed that most institutions have distributed at least some of their earmarked funds to students at this point. Due to this being a currently active project, it is difficult to evaluate how the DOE preformed. However, the DOE should focus on evaluating if their mission had been achieved within project scope and if the satisfaction of both student and IHEs has been met. The DOE should complete a post project evaluation to ensure that if an additional distribution of HEERF comes through a future Federal program, the DOE can better plan and implement the project to ensure higher levels of satisfaction and financial support of students being provided even quicker.


In conclusion, The DOE’s efforts to distribute emergency aid to students during the early stages of the COVID pandemic were successfully completed though poorly executed. A Fuzzy Front End, all around failed Preparation Phase, poor change management, poor communication efforts, poor stakeholder management, and a very complex environment led to delays is distribution of funds in the most efficient manner possible and an exhaustion of resources among the IHE. The utilization of formal project management tools and a robust communication plan could have resolved many issues that impacted the stakeholder engagement and relations.


Ashton Vogelsang currently serves as Bloomfield College’s Business Operations Analyst for Finance and Administration and is working towards obtaining her MBA in Data Analytics at Montclair State University. Ashton strives to implement data-based decisions into business policies and practices at the College in hopes to assist in the success and retention of first-generation, minority college students. She has obtained her Masters of Arts degree in Psychological Studies at Seton Hall University and training in Multicultural Diversity at Bloomfield College. Ashton was key in Bloomfield College’s interpretation, acquisition, implementation, and disbursement of CARES Act funds during the COVID-19 pandemic. Ashton lives in Morris County, New Jersey with her husband and family.


Amour, M. (2020). Community Colleges Struggled With Emergency Aid Distribution. Inside Higher Ed. Retrieved from https://www.insidehighered.com/news/2020/06/02/federal-guidance-formula-made-disbursing-emergency-student-aid-difficult-community?utm_source=Inside+Higher+Ed&utm_campaign=4acb20e369-DNU_2019_COPY_02&utm_medium=email&utm_term=0_1fcbc04421-4acb20e369-234766

Bauer-Wolf, J. (2020). Ed Depart’s ‘evolving communications’ delayed aid to college students, watchdog finds. EducationDrive. Retrieved from https://www.educationdive.com/news/ed-depts-evolving-communications-delayed-aid-to-college-students-watchd/580717/?utm_source=Sailthru&utm_medium=email&utm_campaign=Issue:%202020-06-30%20Higher%20Ed%20Education%20Dive%20Newsletter%20%5Bissue:28203%5D&utm_

Bauer-Wolf, J. (2020). When will colleges get clarity around which students can get CARES aid? EducationDrive. Retrieved from https://www.educationdive.com/news/when-will-colleges-get-clarity-around-which-students-can-get-cares-aid/579504/?utm_source=Sailthru&utm_medium=email&utm_campaign=Issue:%202020-06-10%20Higher%20Ed%20Education%20Dive%20Newsletter%20%5Bissue:27809%5D&utm_t

Dam, J. (2020). University still identifying how to distribute CARES Act funds. The State Press. Retrieved from https://www.statepress.com/article/2020/05/sppolitics-asu-still-determining-approach-for-cares-acts-funds

Department of Education. (2020). Recipient’s Certification and Agreement for Funds under Section 18004(a)(3) of the Higher Education Emergency Relief Fund,Coronavirus Aid, Relief, and Economic Security (CARES) Act . Washington, D.C.

DeVos, B. (2020, April 9). CARES Act grant funding cover letter. Washington, D,C.: Department of Higher Education.

McLean, D. (2020). Months After Congress Sent Emergency Aid to College Students, Distribution Remains Spotty. The Chronicle of Higher Eduaction. Retrieved from https://www.chronicle.com/article/months-after-congress-sent-emergency-aid-to-college-students-distribution-remains-spotty#:~:text=In%20April%20the%20department%20issued,for%20Title%20IV%20financial%20aid.&text=The%20result%20has%20been%20delays,helping%2

Wu, T. (2020). Optimizing Project Management. Boca Raton, FL: Taylor & Francis Group.