Community Service Crackdown

The U.S. Education Department is toughening its enforcement of a federal law that requires colleges to award at least 7 percent of their federal work study funds to students engaged in community service.

The department has long required postsecondary institutions to reach a minimum threshold on the proportion of work study funds for community service, and while college officials overwhelmingly support the concept, administrators at some institutions -- particularly in rural areas, where opportunities to participate in community service may be few -- have struggled to meet it. The law also requires that each institution sponsor at least one project in which work study students tutor children in reading or work on family literacy. (The education secretary is empowered to exempt an institution from the requirement when "enforcing the requirements ... would cause a hardship for students at the institution," according to federal rules.)

As the percentage requirement has increased over the years, from the pre-2000 figure of 5 percent of an institution's total federal work study funds to the current 7 percent, colleges have taken various steps to try to ensure that they meet the standard, and the Education Department has regularly reminded them of their obligation. But the cost of failure has been negligible, as there was no penalty for noncompliance.

That is now changing. The department announced in a "Dear Colleague" letter in May that beginning in the 2007-8 award year that started this month, "[a]n institution that participates in the [work study program] that fails to meet one or both of the ... community service requirements ... will be required to return [federal work study] funds in an amount that represents the difference between the amount that the institution should have spent for community service and the amount that it actually spent." The department also warned institutions that failure to comply with the requirements could result in the financial aid death penalty: a "limitation, suspension and termination proceeding," which could lead to a college's inability to award any federal aid to its students.

The department's Federal Student Aid office followed that general warning with a letter in June to nearly 300 colleges that had fallen below the 7 percent threshold in the 2005-6 fiscal year. Inside Higher Ed requested a list of the institutions and information about their compliance with the community service requirements under a Freedom of Information Act request, and the list appears below. It included a broad mix of types of colleges (two-year, four-year, public, private, for-profit) that varied widely in the extent and apparent scope of their shortfalls.

Upper Iowa University awarded 6.92 percent of its $332,158 federal work study dollars to students engaged in community service, just narrowly missing the 7 percent ceiling, for instance, while Norwich University, in Vermont, is shown as directing not a single dollar of its $544,840 in federal work study funds to community service. Same for Southern University and A&M College,

Rhodes College awarded just $2,915 (or 1.6 percent) of its $180,233 in federal work study funds to students engaged in community service, according to the Education Department's data. Forrest M. Stuart, director of financial aid at Rhodes, said in an interview that the independent institution in Memphis had met the community service requirement just once since he arrived there in 2000, a fact that he "hated." Seventy percent of students at Rhodes perform some kind of community service, Stuart said, so the problem isn't that its students don't want to contribute to society.

But fewer than half of the students at Rhodes qualify for federal need-based financial aid, and Stuart said that "most of the people who are doing community service work don't qualify for federal aid," and many "high need" students "don't have transportation to go off campus" to the heart of downtown Memphis, where most of the community service jobs are.

Rhodes' failure to meet the requirement has aggravated and frustrated Stuart and other officials there, but the stakes went way up this spring, when college administrators were alerted after a required federal financial aid audit that they would be required to repay the portion of the 7 percent requirement that Rhodes did not spend. "It took me by surprise; I did not know they could do that," Stuart said. The college later received the Federal Student Aid office's letter, he said, which made it clear that "they are putting teeth into that" requirement for the first time.

Rhodes began adapting its policies immediately, paying higher hourly wages to work study students who do community service while participating in the college's innovative Student Associate Program, which is aimed at giving students management-style responsibilities instead of more menial campus jobs. For instance, the college is giving work study funds where appropriate to students who are coordinating reading tutors in local schools, and paying them significantly more than minimum wage. Rhodes has also significantly increased the number of social service organizations with which it collaborates, and those changes, among others, helped the college fulfill the community service requirement in 2006-7, with between 8 and 9 percent of its federal work study funds going to community service participants, Stuart said.

Palm Beach Community College also fell short of the community service requirement in 2005-6, according to the Education Department's data, allocating $15,596, or 3.93 percent, of its $396,882 in federal work study funds for community service participants. The two-year institution has been "in and out of compliance" over the years, says its financial aid director, David Bodwell, mainly because under county law, its officials must sign new contractual agreements each year with the school districts social service groups that employ its students, and "executing them in a timely fashion proves to be difficult" because employees turn over, rules change, etc.

Palm Beach made several changes in the 2006-7 fiscal year, including employing many of its work study students over the summer and contracting with one agency that can accommodate many more students than the college needs to fulfill the requirement. "With those two efforts, we're going to exceed the minimum requirement by threefold" this year, Bodwell said.

While some college officials might rue it when the Education Department comes knocking on their door (or, in this case, their mailbox, to mix a metaphor), Kristin Tichenor, vice president for enrollment management at Worcester Polytechnic Institute, said she actually welcomes the department's heightened scrutiny of colleges' compliance with the work study rules. "From a philosophical standpoint, what we're most excited about -- as excited as you can get about a government enforcement operation, I suppose -- is that it elevates the importance of community outreach for our students" and "gives us the ammunition we need to make this a priority for colleagues on campus," Tichenor said.

Although many students Worcester Polytechnic participate in community service, she said -- students logged 95,000 community service hours as part of the campus "project experience" that is a graduation requirement -- just 3.24 percent of its federal work study funds went to students working in the community. That's mostly because students who would qualify for work study funds are often doing low-level campus jobs for their federal money and performing community service on their own time, and the institution did a "woeful" job of tracking the community work its students did, Tichenor said.

Worcester Polytechnic is crafting a new system that will prod campus managers to direct work study students to community-related work that can qualify under the federal program's guidelines. Not only will the new arrangement result in the institution easily surpassing the federal requirement, said Tichenor, but it will allow the institution to keep much better track of its students' civic activities on a campus where "if you threw a stick, you’d hit somebody who was doing community service."

"We wouldn't have done it without the push" from the Education Department, Tichenor added. "For my purposes, this has turned out to be a blessing."

The following is a list of institutions that received letters this summer from the Education Department because they failed to comply with the community service requirement -- presumably some of whom may not see the inquiries as quite the blessing Tichenor does:

Recipients of Letter on Work Study Community Service Requirement and Their Level of Compliance With It